The case illustrates the application of the M v The Queen unreasonable verdict test where causation of death is contested, confirming that where the Crown's primary causation theory (knee-blows causing spleen rupture) is supported by credible eyewitness evidence, alternative hypotheses (a 'poleaxe fall' or earlier fall) need not raise a reasonable doubt if the jury was entitled to reject them. Even if a post-assault fall ruptured the spleen, the jury may find the fall was substantially caused by the assault itself.
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