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“In Lidar, a group of men had a fight in the car park of a pub.  When two of them got in a car and started to drive off, a third leant in the window of the car and the fight continued.  They drove off with him half in the window and at some point he fell off and suffered injuries from which he died.  The jury were directed in terms of recklessness and the driver was convicted of manslaughter.  The CA upheld the conviction, possibly relying on Lord Mackay’s reference in Adomako to it being “perfectly appropriate” to use the word reckless.  A driver owes a duty to other road users, and his recklessness in driving with someone hanging on to the car would be covered by the term gross negligence.  A finding of gross negligence manslaughter would have therefore been possible, so it is the rules from Adomako that are important to know. The requirements for gross negligence manslaughter”
Sally Russell, Involuntary Manslaughter

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