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R v Adomako 1994 | Criminal Law

R v Adomako 1994

R v Adomako [1994] UKHL 6 is a landmark case in English criminal law that established the legal test for gross negligence manslaughter.


The case involved an anaesthetist named Dr Adomako who was responsible for monitoring the patient's vital signs during an eye surgery. However, during the procedure, the patient's breathing tube became disconnected, and Dr Adomako failed to notice the problem, leading to the patient's death.


Dr Adomako was charged with gross negligence manslaughter and was convicted at trial. He appealed his conviction, and the case eventually made its way to the House of Lords which held that for a person to be convicted of gross negligence manslaughter, the prosecution must establish the following elements:


  1. The defendant owed a duty of care to the victim.
  2. The defendant breached that duty of care by an act or omission that was grossly negligent.
  3. The breach of duty caused (or significantly contributed to) the victim's death.
  4. The breach falls under the ordinary principles of gross negligence and therefore amounts to a crime.


In this case, the House of Lords found that he had breached his duty of care to the patient and that his breach was so serious that it amounted to a criminal act. Therefore, his conviction for gross negligence manslaughter was upheld. The case has since been cited as a leading authority on the law of gross negligence manslaughter in the UK.


You can learn more about this topic and other case law with our Criminal Law notes.


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