LEGAL PRINCIPLE: CRIMINAL LAW – Murder – Medical Evidence – Proof of Cause of Death – Requirement to Exclude Intervening Cause
PRINCIPLE STATEMENT
Where the court relies on the medical evidence to prove the cause of death of the deceased, such medical evidence must go to show clearly that the injury inflicted on the deceased caused the death without any intervening cause or causes culminating in the death of the deceased. Where there is the slightest possibility of any such intervening factor creating the possibility that the cause of death could be through causes other than the actual injury inflicted, there is some doubt on the proper cause of death and such doubt must go to the benefit of the accused person.
RATIO DECIDENDI (SOURCE)
Per Kalgo, JSC, in Oforlete v. State (2000) NLC-1771999(SC) at pp. 4–5; Paras D–A.
"Where the court relies on the medical evidence to prove the cause of death of the deceased, such medical evidence must go to show clearly that the injury inflicted on the deceased caused the death without any intervening cause or causes culminating in the death of the deceased. Where there is the slightest possibility of any such intervening factor creating the possibility that the cause of death could be through causes other than the actual injury inflicted, there is some doubt on the proper cause of death and such doubt must go to the benefit of the accused person."
EXPLANATION / SCOPE
Medical evidence proving cause of death must exclude intervening causes. If the slightest possibility exists that death resulted from factors other than the accused’s act, reasonable doubt arises. That doubt must benefit the accused. The prosecution must establish a direct causal link between the inflicted injury and death without interruption. This ensures that convictions are not based on speculative causation. The principle reflects the criminal standard of proof beyond reasonable doubt. Where multiple potential causes exist, the prosecution must eliminate alternative explanations. Medical certainty is required.