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R v Mitchell [1983] QB 741 Court of Appeal

The appellant tried to jump the queue at a Post Office. An elderly man took issue with the appellant's behaviour and challenged him. The appellant hit the old man and pushed him. The man fell back onto others in the queue including an elderly lady who fell and broke her leg. She later died. The appellant was convicted of manslaughter and appealed contending that the unlawful act was not directed at the woman.

Held:

The appeal was dismissed and the conviction was upheld. There was no requirement that the unlawful act be directed at the victim.
 
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