R v White – 1910

February 26, 2024
Micheal James

Jurisdiction / Tag(s):

Introduction to R v White – 1910

In 1910, the English Court of Appeal delivered a landmark judgement in R v White, shaping the legal landscape around attempted murder and the concept of causation. The case centered around Marvin White, accused of attempting to murder his mother through poisoning, despite her ultimate death being attributed to a heart attack.

Facts of the Case

Marvin White harbored animosity towards his mother and sought to poison her. He acquired cyanide, a deadly substance, and slipped it into her lemonade. Fortunately, his mother only consumed a small portion of the drink before experiencing sudden chest pains and ultimately dying from a heart attack. The medical examiner confirmed that the cyanide did not contribute to her death, raising the crucial question: could White be convicted of attempted murder despite the poison’s lack of actual effect?

Arguments of the Parties

  • Crown Prosecution: Despite the lack of direct causation, the prosecution argued that White’s actions constituted an attempt to murder. They emphasized his clear intention to poison his mother with a potentially lethal substance. The cyanide, regardless of the specific cause of death, evidenced his premeditation and attempt to bring about his mother’s demise.
  • White’s Defense: White’s defense countered that since the poison did not cause his mother’s death, his actions could not be considered an attempt, as the essential element of causation was absent. They argued that even if he intended to kill her, the attempt remained incomplete as the intended outcome (death by poison) never materialized.

Court’s Holding and Reasoning

The Court of Appeal upheld White’s conviction for attempted murder, establishing the “but for” test as a fundamental element in such cases. Lord Justice Darling, delivering the judgement, declared that the prosecution must prove that “but for” the defendant’s act, the result (in this case, the attempted poisoning) would not have occurred. While White’s mother ultimately died from a different cause, his intentional act of placing the poison in her drink, combined with its dangerous nature, constituted a substantial step towards achieving the desired outcome – her death. Therefore, despite the lack of direct causation, his attempt was deemed punishable.

Analysis and Impact

R v White significantly impacted the understanding of causation in attempted murder cases. The “but for” test clarified that intention and a substantial step towards the desired outcome, even if not fully realized, could suffice for an attempt conviction. This case solidified the focus on mens rea (guilty mind) and proximate cause in establishing attempts, setting a precedent for future legal proceedings. However, some scholars debate the potential harshness of applying the “but for” test strictly, potentially criminalizing incomplete acts with uncertain outcomes.


R v White stands as a significant case in legal history, refining the concept of causation and its application in attempted murder charges. The “but for” test continues to hold relevance in legal proceedings, balancing the defendant’s intent with the need for a substantial step towards a harmful outcome. The case serves as a reminder of the intricate relationship between intent, action, and consequence in the complexities of criminal law.

Why Choose Us:

Crafting a law dissertation tailored to your specific needs is made effortless with our Custom Law Dissertation Writing Services. We specialize in creating personalized solutions that align with your academic requirements. Our services encompass thorough research, detailed analysis, and the creation of well-crafted dissertations. Recognizing the distinct demands of legal studies, we ensure each document reflects precision and excellence. Trust our commitment to provide custom-tailored assistance, guiding you through the intricacies of law dissertation writing. Our aim is to make your academic journey in law both seamless and distinguished, offering a service marked by proficiency and clarity.

Cite This Work

Select a referencing style to export a reference for this article:

All Answers ltd, 'R v White – 1910' (Mylawtutor.net, September 2012 ) <https://www.mylawtutor.net/cases/r-v-white-1910> accessed 25 April 2024
My, Law, Tutor. (September 2012 ). R v White – 1910. Retrieved from https://www.mylawtutor.net/cases/r-v-white-1910
"R v White – 1910." MyLawTutor.net. 9 2012. All Answers Ltd. 04 2024 <https://www.mylawtutor.net/cases/r-v-white-1910>.
"R v White – 1910." MyLawTutor. MyLawTutor.net, September 2012. Web. 25 April 2024. <https://www.mylawtutor.net/cases/r-v-white-1910>.
MyLawTutor. September 2012. R v White – 1910. [online]. Available from: https://www.mylawtutor.net/cases/r-v-white-1910 [Accessed 25 April 2024].
MyLawTutor. R v White – 1910 [Internet]. September 2012. [Accessed 25 April 2024]; Available from: https://www.mylawtutor.net/cases/r-v-white-1910.
<ref>{{cite web|last=Tutor |first=MyLaw |url=https://www.mylawtutor.net/cases/r-v-white-1910 |title=R v White – 1910 |publisher=MyLawTutor.net |date=September 2012 |accessdate=25 April 2024 |location=UK, USA}}</ref>

Related Cases

Dick Bentley v Harold Smith

. Last modified: April 24, 2024

Introduction to Dick Bentley v Harold Smith The world of contracts can be a complex one, especially when it comes to the interpretation of statements made during negotiations. Dick Bentley Productions Ltd v Harold Smith (Motors) Ltd [1965] stands as a significant case in English contract law, offering valuable insights into the distinction between a […]

Performance Cars v Abraham

. Last modified: April 15, 2024

Introduction to Performance Cars v Abraham Performance Cars Ltd v Abraham (1962) stands as a landmark case in English tort law, specifically regarding the concept of causation in negligence claims. This case study delves into the factual background, the legal issue at stake, the court’s decision and reasoning, and the lasting impact of the case […]

R v Hennessy – 1989

. Last modified: April 15, 2024

Introduction to R v Hennessy – 1989 The criminal justice system grapples with complex issues when a defendant’s actions seem involuntary due to a medical condition. R v Hennessy (1989) stands as a significant case in English law, delving into the boundaries of the defense of automatism in the context of diabetic hypoglycemia. This case […]

go to top