Where, as a result of violence and threats of violence, a 15-year-old victim had run away but had collapsed and died of an undiagnosed heart complaint, the judge was right to refuse a submission of no case to answer in relation to a count of affray where there was evidence of a fear of attack. However, a count of unlawful act manslaughter should have been withdrawn from the jury, as the only physical harm to the victim did not cause her death.
[2006] EWCA Crim 17