#ar #causation #crime #law
The Defendant's Act Must be the 'Substantial' Cause of the Prohibited Harm
In R v Cato [1976] 1 WLR 110, it was held that substantial does not mean 'really serious'. It means an act (or omission) that is not a 'de minimus, trifling one'. Latterly, the courts have confirmed that D's act need not be a substantial cause, see R v Malcherek and Steel [1981] 1 WLR 690.
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