판결 이유
The reasonable act of a third party acting in self-defence or in the execution of duty does not break the chain of causation. The defendant who creates the dangerous situation remains the legal cause of the victim's death.
사실관계
Pagett held his pregnant girlfriend as a shield while firing at armed police officers. The police returned fire, killing the girl. Pagett was charged with her manslaughter.
판결 요약
The Court of Appeal upheld the conviction. The police officers' instinctive return of fire was a reasonable and foreseeable response to Pagett's actions. It did not break the chain of causation. Pagett's act of using her as a shield was both the factual and legal cause of her death.
주요 인용문
"The reasonable act of a third party, such as a police officer acting in self-defence, does not break the causal chain between the defendant's act and the victim's death."
— Robert Goff LJ
후속 처리
Standard authority on third-party acts and the chain of causation in criminal law.