[2012] EWCA Crim 641

In order to rely on conduct comprising interference with a motor vehicle within the Road Traffic Act 1988 s.22A(1)(b) as evidence of unlawful act manslaughter, the section was not to be read as requiring the interference to have taken place prior to the driving, or to have altered the external and physical state of the vehicle. A passenger who applied the handbrake while the vehicle was moving deliberately interfered with a mechanical part of the car in a manner that was obviously dangerous to any reasonable person, and the offence would be made out.

CA (Crim Div) (Toulson LJ, Kenneth Parker J, Judge Barker QC)

29/02/2012