R v CLD

The appellant, R, appealed against a directed verdict of acquittal given by the trial judge in a manslaughter case involving the death of CLD. The death occurred as a result of the explosion of a drug manufacturing operation. The Crown's case was based on the appellant's act of manufacturing pseudoephedrine by the evaporation of a potentially explosive solvent in a small, unventilated space with multiple potential ignition sources. The trial judge directed a verdict of acquittal because the Crown had not proven the actual source of ignition, which was necessary to characterise the relevant act as dangerous.

The legal issues for the court to decide were whether the Crown had to prove the actual source of ignition in order to characterise the relevant act as dangerous, and whether the Crown needed to negate all possible sources of ignition that were consistent with innocence because they broke the chain of causation. The court considered whether the trial judge erred in not leaving the question of causation to the jury.

The court held that the Crown did not need to prove the actual source of ignition to establish causation, as it was sufficient to show that the appellant's act carried with it an appreciable risk of serious injury. The court held that the Crown needed to negate only those possible sources of ignition that were inconsistent with the Crown case, not all possible sources of ignition. The court held that the trial judge did not err in directing a verdict of acquittal because the Crown had not proven the essential elements of the offence beyond reasonable doubt. The appeal was dismissed.