R v Blaue
A defendant must take his victim as he finds him, including the victim's religious beliefs: the thin skull rule.
Facts
Mr Blaue stabbed an 18 year old woman four times, piercing her lung. She was taken to hospital and told that she needed a blood transfusion to save her life, but she refused because she was a Jehovah's Witness. She died the next day. Mr Blaue argued that her refusal of the transfusion broke the chain of causation.
Legal principle
The Court of Appeal upheld his conviction for manslaughter. Lawton LJ said that it has long been the policy of the law that those who use violence on other people must take their victims as they find them, and that this means the whole man, not just the physical man. The victim's religious beliefs, which led her to refuse a transfusion, did not break the chain of causation, and the physical cause of death was the bleeding from the stab wound.
Related cases on causation
- Baker v Willoughby [1970] AC 467
- Barker v Corus UK Ltd [2006] UKHL 20, [2006] 2 AC 572
- Barnett v Chelsea and Kensington Hospital Management Committee [1969] 1 QB 428
- Bonnington Castings Ltd v Wardlaw [1956] AC 613
- Chester v Afshar [2004] UKHL 41, [2005] 1 AC 134
- Fairchild v Glenhaven Funeral Services Ltd [2002] UKHL 22, [2003] 1 AC 32
- Gregg v Scott [2005] UKHL 2, [2005] 2 AC 176
- Hotson v East Berkshire Area Health Authority [1987] AC 750
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