Where a victim of an unlawful and dangerous act flees and is killed by a motor vehicle, the unlawful act may be a substantial cause of death if the victim had a well-founded apprehension of further violence and the flight was a natural or reasonable response, even where the victim was heavily intoxicated. A direction that the jury should consider the deceased's intoxication as it appeared to the accused does not impermissibly introduce reasonable foreseeability into the causation inquiry. Different verdicts for co-accused on manslaughter and assault are not necessarily inconsistent where the evidence supports a distinction based on the continued threatening presence of some accused after the assault ended.
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