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R v Corbett [1996]


The appellant had been out drinking with a friend, Eric Bishop, a man of low intelligence and suffering mental illness. They were both heavily intoxicated. Bishop accidentally urinated on the appellant's foot. The appellant chased Bishop down the middle of a road and on catching him punched him and head butted him. Another friend pulled the appellant off Bishop and held him back. Bishop ran off, tripped and landed in the gutter of the road. He sat up but had his head protruding into the road. He was then hit by a passing car which killed him. The jury convicted him of constructive manslaughter. He appealed contending the chain of causation had been broken.

Held:

Appeal dismissed. The chain of causation was not broken. The actions of Bishop were within the foreseeable range of events particularly given the intoxicated state he was in at the time.