Jury directions on dangerous driving causing death must convey that the offence requires a serious breach of proper driving conduct meriting criminal punishment and creating a considerable risk of serious injury or death, as set out in R v De Montero. Directions that state there need not be 'a high risk of death or serious injury' and that criminal punishment need not be warranted are inadequate. In racing cases where a non-colliding driver is charged with causing death, the Crown should preferably rely on aiding and abetting rather than acting in concert. The question whether a non-colliding driver's driving can independently be a 'substantial and operative cause' of death in the absence of complicity was left open.
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