The reasonable person test for criminal negligence manslaughter does not require a direction on the ethnic or cultural background of the accused where the evidence does not establish that cultural factors would justify a different standard of care. Where a parent is also an alternative health practitioner who treats their child, the Crown may advance liability on the alternative basis of the standard of a reasonable practitioner of that discipline. Evidence that parents took a child to various medical consultations does not preclude a finding of criminal negligence where they failed to follow through with recommended conventional treatment and the child's condition deteriorated to the point of death.
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