Legal Case Summary
R v Williams and Davies [1992] 1 WLR 380
Unlawful Act Manslaughter – Causation – Eggshell Skull Rule
Facts
The defendants picked up a hitchhiker who was on his way to Glastonbury festival. The defendants then attempted to rob the victim who became agitated and afraid and in this mental state jumped out of the moving vehicle which was travelling at 30 mph. The victim hit his head and died of his injuries. The defendants were charged with manslaughter. What had happened in the car to cause the victim to jump out was not certain.
Issues
Whether the act of the defendant in jumping out of the car broke the chain of causation. The victim had jumped out of the car and this was an act of his which may have been argued to have broken the chain of causation between the defendant’s unlawful act of robbing the victim and his death. What role the question of foreseeability of the victim’s actions played in the defendant’s guilt.
Decision / Outcome
The defendants were found not guilty after a direction to this effect was given to the jury. Modifying the test set down in R v Roberts (1971) 56 Cr App R 95 which held that the chain of causation would only be broken if the victim committed an act so unforeseeable that no reasonable man could be expected to foresee the act, it was held that the jury should consider whether the victim’s act was within the range of reasonable responses available to the victim in the circumstances. This required consideration of his psychological state and any particular characteristics of the victim and an acknowledgement that the stress of the situation or event may lead to the victim acting without thought. In this case however there was not enough evidence that the defendant’s acts had led to the victim’s reaction being within the range of reasonable responses available to him.
Updated 20 March 2026
This case summary accurately reflects the decision in R v Williams and Davies [1992] 1 WLR 380 and its treatment of causation in unlawful act manslaughter. The core legal principles described — including the modification of the Roberts test and the ‘range of reasonable responses’ approach to intervening acts by a victim — remain good law and continue to be cited in English criminal law. There are no subsequent statutory changes or appellate decisions that have overruled or substantially altered the legal position as stated. Students should note that causation principles in manslaughter have been further discussed in later cases such as R v Dear [1996] and R v Kennedy (No 2) [2007] UKHL 38, the latter particularly relevant to drug-supply scenarios, but neither affects the principles directly stated in this summary. The article remains broadly accurate and suitable for study purposes.
