The defendant could be convicted of gross negligence manslaughter in the absence of evidence as to state of mind. In the absence of evidence establishing the guilt of an identified human individual for the same crime, a non-human defendant could not be convicted of the crime of manslaughter by gross negligence. The identification principle remained the only basis in common law for corporate liability for gross negligence manslaughter.

CA (Crim Div) (Rose LJ, Potts J, Curtis J)

15/02/2000