Provided a jury were agreed that a defendant was guilty of manslaughter, in the sense that they were sure that the defendant perpetrated an unlawful act which caused the death of the deceased, it was unnecessary for there to be any unanimity by the jury as to the route by which that verdict was reached. The principles in R v Brown (1984) 79 Cr App R 115 had no application in manslaughter cases.
CA (Crim Div) (Rose LJ, Ognall J, Burton J)
08/02/1999