Williams, R. v

Blameworthy conduct is not required for the offence under s.3ZB; it is sufficient that the appellant's driving was a cause of death that was more than negligible.

Parties: Respondent: Regina; Appellant: Jason John Williams
Jurisdiction: England and Wales
Judgment Date: 02 November 2010
Procedural Posture: Criminal Appeal / Judgment on Appeal
Outcome: appeal against conviction dismissed; appeal against sentence allowed
Legal Topics: Causing Death by Driving, Statutory Interpretation, Strict Liability, Causation

Criminal Law Causing Death by Driving Statutory Interpretation Strict Liability Causation

Case Brief

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Parties

Regina

Respondent

Jason John Williams

Appellant

Procedural Posture

Criminal Appeal / Judgment on Appeal

Legal Issues

1 Whether fault or blameworthy conduct is required for the offence of causing death by driving when unlicensed, disqualified or uninsured under s.3ZB of the Road Traffic Act 1988
2 Whether causation requires the appellant's driving to be a substantial or major cause of death

Ratio Decidendi

Blameworthy conduct is not required for the offence under s.3ZB; it is sufficient that the appellant's driving was a cause of death that was more than negligible.

Court Disposition

appeal against conviction dismissed; appeal against sentence allowed

Orders

sentence substituted to 24 weeks' imprisonment
custodial sentence affirmed as appropriate