R v. Hayward (1908) 21 Cox CC 692

Material Facts:

The defendant chased his wife while shouting threats at her. During this, she fell and died. It was established that he did not physically touch her. However, and unknown to both the defendant and his wife, she was suffering from a thyroid condition, which made her more likely to die from the combination of physical exertion and panic. Her running was the physical exertion, and the threats caused her to panic. The defendant was charged with manslaughter.

Issue:

1. Whether or not the defendant, oblivious of his wife’s medical condition, caused her death and was accordingly guilty of manslaughter
2. Whether a victim’s unknown medical condition breaks the chain of causation

Holding:

1. The defendant caused his wife’s death.
2. A victim’s unknown medical condition does not break the chain of causation.

Ratio Decidendi:

There is a rule that a person must take his victim as he finds him. The victim’s medical condition did not affect the question of who caused her death and does not break the chain of causation.

The defendant’s acts were accordingly held to be the factual and legal cause of his wife’s death.