Section 3A(1) of the Crimes Act 1958 (Vic) applies where an accused unintentionally causes the death of a co-offender by an act of violence done in the course or furtherance of a crime of violence; the expression 'another person' is not limited to persons other than accomplices. IL v The Queen is distinguishable because it turned on the differently-worded s 18 of the Crimes Act 1900 (NSW). The question whether unintentionality is an element of s 3A murder or merely distinguishes it from common law murder remains unresolved.
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