R v Goodfellow
Unlawful act manslaughter does not require an act directed at the victim.
Facts
Mr Goodfellow wanted to be rehoused by the council and decided to set fire to his council house, so that it would look as if it had been firebombed. The fire spread more quickly than he expected, and his wife, his girlfriend and a child died. He was convicted of manslaughter.
Legal principle
The Court of Appeal upheld the conviction. Lord Lane CJ said that the unlawful act, setting fire to the house, did not need to be directed at the victims, provided that it was unlawful, dangerous, and a substantial cause of their deaths. The act of arson was clearly dangerous, because all sober and reasonable people would recognise that it carried a risk of harm to the people in the house.
Related cases on involuntary manslaughter
- DPP v Newbury and Jones [1977] AC 500
- R v Adomako [1995] 1 AC 171
- R v Bateman (1925) 19 Cr App R 8
- R v Bawa-Garba [2016] EWCA Crim 1841
- R v Cato [1976] 1 WLR 110
- R v Cotswold Geotechnical Holdings Ltd [2011] EWCA Crim 1337
- R v Dawson (1985) 81 Cr App R 150
- R v Kuddus [2019] EWCA Crim 837
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