R v Pitts – Case Summary

R v Pitts

Assizes Court

Citations: (1842) Carrington and Marshman 284; 174 ER 509.


The defendant attempted to rob the victim, threatening him with a stick. To escape the violence, the victim moved towards a riverbank. At that point, he either threw himself into the water to escape, or slipped and fell in. The victim drowned.

The defendant was charged with murder. They argued in their defence that either the death was an accident or their actions did not cause death – the victim’s actions broke the chain of causation.

  1. Could the victim’s actions break the chain of causation?

The judge directed the jury that if the victim had decided to jump into the water, it was not a voluntary decision because the victim had been under duress from the defendant. The jury acquitted the defendant (indicating that they thought the victim had slipped and the defendant had not intended to cause death or grievous harm).

This Case is Authority For…

If the defendant’s actions cause a victim to reasonably apprehend violence, any reasonable steps they take to avoid the violence do not break the chain of causation.