R v Moffatt [2000] NSWCCA 174

Facts: The defendant (D) and victim (V) had been drinking large quantity of alcohol. They had an argument and D hit V with a hammer and strangled him. The autopsy was unable to isolate a cause of death, suggesting it could have been from either advanced cardiac disease, acute alcohol toxicity or D’s actions.

Held: It was incorrect to search for a principal cause of death in this circumstance. If a contribution by D was present, it is irrelevant that there was more than one possible cause of death. The proper question is whether D accelerated the death of V in that his actions were a substantial contribution to death of V.