R v Thabo Meli [1954]

1. Facts:

• The defendants believed they had killed the victim (V) and, to cover up the crime, rolled V's body down a cliff.

• V actually survived the fall but later died from exposure (hypothermia).

2. Outcome:

• The defendants were convicted of murder.

• The court ruled that the acts were part of a continuous series, and the intention to kill V was sufficient to support the murder conviction, despite the death occurring later due to exposure.

3. Impact and Analysis:

• Series of Acts: The case demonstrated that it is often impossible to separate out the various stages of a criminal act when they form part of a continuous series. The intention to kill, even if occurring at different times, can still be sufficient for a murder conviction.

• Intention and Causation: The decision affirmed that intention to kill can be established even if the actual death resulted from a subsequent and unforeseen cause.

• Modern Implications: Under current rules, particularly the Miller rule, such cases might be examined in the context of whether the defendants created a dangerous situation, potentially shifting the focus from temporal intention to the overall creation of risk.