LAW

Published on
Kembaraxtra-Case Law-Lamb (1967)-Unlawful Act Manslaughter & Criminal Negligence
Facts:
  • Defendant (D) jokingly pointed a revolver at his friend (V) and pulled the trigger.
  • D believed the gun wouldn't fire as he thought no bullet was in line with the barrel.
  • The revolver fired, killing V.
Holding:
  • D was found not guilty of unlawful act manslaughter.
Reasoning:
  1. Unlawful Act Must Be Criminal:
    • The court clarified that merely being unlawful from a civil liability perspective is insufficient for establishing unlawful act manslaughter.
    • Sachs LJ: "...it is long settled that it is not in point to consider whether an act is unlawful merely from the angle of civil liabilities."
  2. Technical Assault Not Established:
    • To qualify as an unlawful act, the act must, at minimum, constitute a technical assault.
    • The court found that the evidence did not sufficiently establish a technical assault.
  3. Criminal Negligence Consideration:
    • The court suggested the Defendant could be properly convicted of criminal negligence manslaughter.
    • Criminal negligence arises if the Defendant's belief that there was no danger in pulling the trigger was formed in a criminally negligent manner.



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