A direction on causation in terms of harm 'following directly upon' or 'following from' the accused's act is adequate where it conveys to the jury the need for a causal connection sufficient to attract criminal responsibility, determined by common sense in a criminal context. Where the Crown does not rely on the subjective element of the accident defence (intention or foresight), a direction focusing on the objective element alone is not a misdirection. Under the first paragraph of s 248 of the Criminal Code (WA), the accused's state of mind is not entirely irrelevant to the objective assessment of whether force was reasonably necessary.
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