06/03/2026
R v Wallace (2018)
Court: Court of Appeal (Criminal Division), England and Wales
Case Facts
Berlinah Wallace was in a relationship with Mark van Dongen.
After their relationship ended, Wallace became angry and jealous.
She bought a bottle of sulphuric acid online.
One night in 2015, while Mark was sleeping in her flat, she woke him up and threw sulphuric acid on his face and body.
Mark suffered extremely severe burns, blindness, paralysis, and amputation of a leg.
Because of the unbearable pain and permanent injuries, he later travelled to Belgium and chose euthanasia (assisted death) in 2017.
National Case Law Archive +1
Main Legal Issue
Whether Wallace could be liable for murder, even though the victim later chose euthanasia, which might break the chain of causation.
Judgment (Court of Appeal)
The Court of Appeal held that the jury could still find Wallace responsible for the victim’s death.
The court stated:
The acid attack caused catastrophic injuries and unbearable suffering.
The victim’s decision to seek euthanasia did not necessarily break the chain of causation.
The defendant’s actions could still be considered a significant cause of death.
National Case Law Archive
Legal Principle
In criminal law, if the defendant’s act is a substantial and operating cause of death, liability may still exist even if later events occur, unless those events completely break the chain of causation.
Significance
The case is important for the doctrine of causation in criminal law.
It discusses the concept of novus actus interveniens (a new intervening act).
It shows that euthanasia may not automatically break the chain of causation when the victim’s suffering was caused by the defendant.
