R v Richards [2002] EWCA Crim 3175 Court of Appeal


The appellant pleaded guilty to supplying heroin and constructive manslaughter and sentenced to life imprisonment. At the time the law relating to constructive manslaughter was as set out by the Court of Appeal in R v Kennedy 1999. That it was an unlawful act to self-inject the drug and that assisting that act constituted a sufficient unlawful act for the offence of manslaughter. This position of the law was successfully challenged in R v Dias 2002. The Criminal Cases Review Commission referred the case to the Court of Appeal.

Held:

The appeal was allowed and the conviction quashed. The guilty plea was based on an erroneous basis of the law which was subsequently corrected.

Back to lecture outline on constructive manslaughter in criminal law