R v Hennigan (James) – Case Summary

R v Hennigan (James)

Court of Appeal

Citations: [1971] 3 All ER 133; (1971) 55 Cr App R 262.


The appellant was convicted of causing death by dangerous driving when he crashed into the side of a car at high speed with his vehicle. Two people died as a result. Appealing his conviction, he argued that his actions were not the main cause of death because the driver of the other vehicle had failed to stop at a ‘give way’ sign.

  1. Was the appellant the cause of the victims’ deaths?

The Court of Appeal upheld the conviction. There was no need for the appellant to be a substantial or major cause. It was enough that he was a cause of the victims’ deaths – even if there had been others.

This Case is Authority For…

Where the actus reus of a criminal offence requires the defendant to ’cause’ something, he does not not need to be the main or only cause. It is enough that his contribution is more than de minimis.