Ratio Decidendi
Where the victim freely and voluntarily self-injects a drug supplied by the defendant, the defendant is not guilty of manslaughter. The victim's autonomous act breaks the chain of causation.
Facts
Kennedy prepared heroin and gave a syringe to the deceased, who injected himself and died.
Judgment Summary
The conviction was quashed. The deceased freely and voluntarily injected himself, breaking the chain of causation. Kennedy did not 'administer' the drug.
Key Quotes
"The deceased's free and voluntary act of self-injection broke the chain of causation."
— Lord Bingham
Subsequent Treatment
Good law
Definitive authority on causation in drug supply cases.