Disclaimer: This work was produced by one of our expert legal writers, as a learning aid to help law students with their studies.

Any opinions, findings, conclusions, or recommendations expressed in this material are those of the authors and do not reflect the views of LawTeacher.net. Any information contained in this case summary does not constitute legal advice and should be treated as educational content only.

R v Hayward

284 words (1 pages) Case Summary

3rd Jul 2019 Case Summary Reference this In-house law team

Jurisdiction / Tag(s): UK Law

R v Hayward (1908) 21 Cox CC 692

Unlawful Act Manslaughter – Causation – Egg Shell Skull Rule – Pre-Existing Medical Condition.


A husband and wife had an argument that led to the husband chasing his wife out into the street.  The wife collapsed during this altercation and died.  Whist the husband did not physically touch her, he did shout threats at her.  The wife was found to have been suffering from an abnormality of the thyroid gland that neither was aware of that meant that fright or shock could cause death if combined with physical exertion.  The husband was charged with manslaughter.


Did the wife’s medical condition mean that the husband’s action caused the wife’s death or did the the wife’s condition break the chain of causation.


The husband was found guilty of manslaughter.  No actual proof of violence was necessary as long as the defendant’s unlawful act, which was the threat of violence, caused her fright leading to her death.  The criminal law acknowledges that an assailant must take their victim as they find them.  The victim’s state of health did not affect the question of whether or not the defendant’s unlawful act accelerated the victim’s death.   It was irrelevant to the issue of causation whether or not the fright was one which would have caused the effect it did on a reasonable person as it did on one of exceptional timidity.  Provided the defendant had the requiste mens rea the victim’s pre-existing medical condition did not break the chain of causation.  This is sometimes known as the ‘egg-shell skull’ rule.

Cite This Work

To export a reference to this article please select a referencing stye below:

Reference Copied to Clipboard.
Reference Copied to Clipboard.
Reference Copied to Clipboard.
Reference Copied to Clipboard.
Reference Copied to Clipboard.
Reference Copied to Clipboard.
Reference Copied to Clipboard.

Related Services

View all

Related Content

Jurisdictions / Tags

Content relating to: "UK Law"

UK law covers the laws and legislation of England, Wales, Northern Ireland and Scotland. Essays, case summaries, problem questions and dissertations here are relevant to law students from the United Kingdom and Great Britain, as well as students wishing to learn more about the UK legal system from overseas.

Related Articles