In a prosecution for manslaughter by unlawful and dangerous act where death results from an explosion caused by the creation of explosive conditions (such as evaporating flammable solvents in an unventilated space), the Crown is not required to prove the actual source of ignition. The dangerousness of the act is assessed prospectively by reference to all possible sources of ignition, and causation does not require identification of the specific ignition source. The question of whether any intervening act broke the chain of causation is for the jury, not the trial judge on a no-case submission.
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