R v Church [1966]

1. Facts:

• The defendant (D) assaulted the victim (V), knocking her unconscious.

• Believing she was dead, D discarded her body into a river.

• It was later revealed that V actually died from drowning.

2. Outcome:

• D was convicted of constructive manslaughter.

• The court held that the unlawful act of assaulting V, which led to her death through an act of omission (disposing of the body), constituted the basis for constructive manslaughter.

3. Impact and Analysis:

• Constructive Manslaughter: The case clarified that constructive manslaughter can arise from an unlawful act that causes death, even if the specific outcome (drowning) was not intended.

• Unlawful Act: The original assault constituted the unlawful act, and the subsequent action of disposing of the body was seen as part of the criminal act leading to death.

• Legal Precedent: The decision reinforced that a defendant can be held liable for manslaughter if their unlawful act is a substantial cause of the victim's death, even if the exact manner of death was not anticipated.