ABSTRACT
The illegal act required for constructive manslaughter must be a criminal act (R v Franklin (1883)), but there is no need for the act to be ‘aimed’ at the victim. For example, in R v Goodfellow (1986) the defendant, wishing to be rehoused, set fire to his council house. The fire spread faster than he expected, killing his wife, child, and another person. The Court of Appeal upheld the conviction for manslaughter, even though the defendant’s acts were not directed at the victims but rather against property.
