Intervention of Third Parties This has been considered in a number of cases and is illustrated by the case of R v Pagett (1983) 76 Cr App R 279. R v Pagett FACTS: Using his pregnant girlfriend as a shield, Pagett shot at the police, who were attempting to arrest him for various serious offences. The police returned fire and killed the girl. The judge, directing the jurors on causation, stated that they had to be sure that the appellant had fired first at the officers and that that act caused the officers to fire back, with the result that the girl was killed. The jury also had to be satisfied that, in doing so, the police acted reasonably, either by way of self-defence or in the performance of their duties as police officers. The judge said that if they were not sure of those facts then they should acquit because the chain of causation, linking the Pagett's unlawful acts to the girl's death, would be broken. The jury convicted Pagett, who appealed against his conviction. HELD: The Court of Appeal rejected the appeal and held that there may only be a break in the chain of causation if the actions of the third party were 'free, deliberate and informed. This was not held to be the case here.' Goff LJ was of the opinion that the police officers' actions were neither free nor deliberate. Instead, he considered it to be a reasonable act performed for the purpose of self- preservation in response to the appellant's act.