Manslaughter conviction quashed as re-entry to burning building found to break chain of causation

The Court of Appeal overturned a conviction for manslaughter that had been imposed by the Circuit Criminal Court after a fatal fire in an apartment building. Although the accused was found guilty by a jury of causing the fire (arson) and burglary, the central issue on appeal concerned whether the chain of causation between the accused’s actions and the deceased’s death remained intact, given that the deceased had safely escaped the burning building before voluntarily re-entering it and succumbing to smoke inhalation. The Court held that, as the deceased acted independently after reaching safety and not as a direct or foreseeable consequence of the accused’s actions, the act of returning broke the chain of causation and the accused’s arson could not be considered a significant contributing factor to the death. The court concluded that the trial judge erred in allowing the manslaughter count to go to the jury, quashed the manslaughter conviction, and allowed the appeal.