The words 'significant' and 'substantial' in the causation test for manslaughter by criminal negligence are interchangeable and there is no material difference in how a jury would understand them. A direction that these words mean 'not trivial' in reverse does not amount to a misdirection when viewed in the context of earlier clear directions on causation. Use of the conjunctive 'significant and substantial' rather than the disjunctive 'significant or substantial' favours the accused by imposing a more stringent test.
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