R v Shepherd (1862)

Facts:

  • D was mother of 18-year-old who died during childbirth.
  • D failed to seek assistance from their midwife and lacked any means to pay for the services.
  • D was charged with manslaughter.

Held:
  • As the victim was over the age of 18, D was not under any legal duty to assist her by calling the midwife.
  • No actus reus and D was acquitted.

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