R v Blaue is a landmark case in English criminal law concerning causation in relation to homicide. It established the "thin skull" rule, also known as the "eggshell skull" rule, firmly in the context of criminal responsibility. This rule dictates that a defendant must take their victim as they find them, meaning that they are responsible for the full extent of the victim's injuries, even if those injuries are exacerbated by a pre-existing condition or the victim's own actions resulting from the initial injury.
Facts of the Case:
The defendant, Blaue, stabbed the victim. The victim required a blood transfusion to save her life. However, she was a Jehovah's Witness and refused the transfusion on religious grounds. As a result, she died from the stab wound.
Legal Issue:
The central question was whether the victim's refusal of a blood transfusion broke the chain of causation between the defendant's act (the stabbing) and the victim's death. The defendant argued that the victim's unreasonable refusal constituted a novus actus interveniens (a new intervening act) that relieved him of responsibility for her death.
Judgment:
The Court of Appeal rejected the defendant's argument. They held that the defendant was responsible for the victim's death because the stabbing was an operative and significant cause of the death. The court stated that it was not for the defendant to dictate what medical treatment a victim should receive, and the victim's religious beliefs, while perhaps unusual, were a valid and rational basis for refusing the transfusion. The court affirmed the principle that a defendant must take their victim as they find them, "with all their strengths and weaknesses, their health and their susceptibilities, their religious beliefs, and their lack of them."
Significance:
- Reinforcement of the Thin Skull Rule: R v Blaue is a key authority for the thin skull rule. It clarifies that the rule extends beyond pre-existing physical conditions to include the victim's religious beliefs and other personal characteristics.
- Causation in Criminal Law: The case underscores the importance of establishing a clear chain of causation between the defendant's actions and the victim's injury or death.
- Limits of Novus Actus Interveniens: R v Blaue illustrates that not every intervening act will break the chain of causation. The intervening act must be unreasonable or "daft" in the circumstances to relieve the defendant of responsibility. A voluntary and informed decision, even if it contributes to the victim's death, will generally not be considered a novus actus interveniens if it stems directly from the defendant's original act.