R v White [1910]
1. Facts:
• The defendant (the son) attempted to poison his mother by putting poison in her drink.
• Mother died from a heart attack before the poison could take effect.
• Medical evidence showed the heart attack was unrelated to the poisoning attempt.
2. Outcome:
• White was not found guilty of murder due to lack of factual causation.
• The "but for" test could not be satisfied as the mother would have died from the heart attack regardless of the poison.
• White was found guilty of attempted murder.
3. Impact and Analysis:
• Causation in Fact: R v White is a crucial case for understanding the requirement of causation in criminal law, specifically the application of the "but for" test.
• Criminal Liability: Demonstrates how legal liability is assigned based on the factual circumstances, ensuring that defendants are charged according to the actual impact of their actions.