Ratio Decidendi
The defendant's act need not be the sole or even the main cause of death; it is sufficient that it contributed significantly to the result. Only if the original wound has healed and the medical treatment is so independent of the defendant's acts and so potent in causing death that the contribution of the defendant's acts is insignificant will the chain of causation be broken.
Facts
Cheshire shot a man in the leg and stomach during an argument. The victim was treated in hospital and developed breathing difficulties. A tracheotomy was performed but complications were negligently missed by medical staff, and the victim died two months later from the tracheotomy complications, not from the gunshot wounds.
Judgment Summary
The Court of Appeal upheld the murder conviction. Even though negligent medical treatment was the immediate cause of death, the defendant's act of shooting need not be the sole or even the main cause. The chain of causation was not broken because the gunshot wounds had initiated the chain of events leading to death.
Key Quotes
"It is not the function of the jury to evaluate competing causes of death and to decide which is dominant provided they are satisfied that the accused's acts can fairly be said to have made a significant contribution to the victim's death."
— Beldam LJ
Subsequent Treatment
Leading authority on medical intervention and causation in homicide. Applied where medical negligence follows the defendant's initial unlawful act.