R v White

Facts

White put potassium cyanide into a drink he called nectar, intending to kill his mother. She was found dead beside a glass that was still partly full. The medical evidence was that she died of heart failure, not of the poison.

Issue

Is a person guilty of murder if the death he wanted happened, but his act did not cause it?

Held

No. He was acquitted of murder and convicted of attempt. The intended result occurred, but he did not cause it.

Principle

A result crime requires causation. Wanting the result, and seeing the result, is not enough.

Why it matters

It is the standard illustration of factual causation, and of the difference between murder and attempt.

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