R v White [1910] 2 KB 124

The defendant put some poison in his mother's milk with the intention of killing her. The mother took a few sips and went to sleep and never woke up. Medical reports revealed that she died from a heart attack and not the poison. The defendant was not liable for her murder as his act of poisoning the milk was not the cause of death. He was liable for attempt.

This case established the 'but for' test. Ie would the result have occurred but for the actions of the defendant? If the answer is yes the defendant is not liable.

Back to lecture outline on causation in criminal liability