In felony murder cases under s 302(1)(b) of the Criminal Code 1899 (Qld), where the deceased had a pre-existing condition that could independently cause death, the prosecution must prove beyond reasonable doubt that the dangerous act was a substantial or significant cause of death. The possibility of an independent cause of death need not be excluded with scientific certainty; it is sufficient if the possibility is so unlikely that it can safely be ignored for practical purposes. The majority and dissent disagreed on whether the evidence in this case met that standard, highlighting the difficulty of applying the 'substantial or significant cause' test where expert evidence cannot exclude an alternative mechanism of death.
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