R v Golds [2016] UKSC 61

Key point

  • Under s2(1)(b) Homicide Act, substantial means significant or important, not just more than trivial


  • The issue arose as to the meaning of substantial under the s2(1)(b) Homicide Act

Lord Hughes

  • ‘Substantial’ did not mean ‘having some substance’ or ‘anything more than merely trivial’ but rather required something ‘important or weighty’: [27]
  • Ordinarily the judge should not have to define the term substantial in his direction to the jury, it should be taken by its ordinary meaning by the jury, but if the issue arises as to whether being more the merely trivial suffices, the judge should clarify that it does not: [43]
Homicide Cases
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