R v Hayward – Case Summary

R v Hayward

Crown Court

Citations: (1908) 21 Cox CC 692.


The defendant chased his wife out into the street while shouting threats. Unbeknownst to both of them, the wife had an unknown medical condition. Due to the condition, the wife collapsed from exhaustion and fright. This killed her.

The defendant was charged with unlawful act manslaughter. The prosecution argued that he caused the victim’s death with his assault. The defendant responded that his actions did not cause his wife’s death, because her hidden medical condition broke the chain of causation.

  1. Does a victim’s unknown medical condition break the chain of causation?

The judge directed the jury that the defendant had to take the victim as she found her, unknown condition and all. The jury found the defendant guilty of manslaughter.

This Case is Authority For…

if the victim has an unknown, pre-existing medical condition which, combined with the defendant’s actions, leads to harm (or greater than normal harm), the condition does not break the chain of causation. This is known as the egg-shell skull rule.


This case demonstrates that there is no need for proof of actual violence to establish manslaughter. The threat of violence here was sufficient.