In a circumstantial manslaughter case, the prosecution is not required to prove the cause of death or exclude natural causes; it must prove beyond reasonable doubt that the accused unlawfully killed the deceased. The absence of a determinable cause of death does not preclude a jury from inferring guilt from the totality of circumstantial evidence. A trial judge is not required to direct on the defence of accident where there is no evidentiary foundation for it, and is not required to identify every inference consistent with innocence provided the jury is properly directed on the standard for drawing adverse inferences.
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