R v Blaue [1976] 61 Cr App R 271 is an English criminal law

English criminal law

English criminal law refers to the body of law in the jurisdiction of England and Wales which deals with crimes and their consequences. Criminal acts are considered offences against the whole of a community...

 case in which the Court of Appeal decided that the refusal of a Jehovah's Witness to accept a blood transfusion after being stabbed did not constitute a novus actus interveniens for the purposes of legal causation

Causation (law)

Causation is the "causal relationship between conduct and result". That is to say that causation provides a means of connecting conduct with a resulting effect, typically an injury. In criminal law, it is defined as the actus reus from which the specific injury or other effect arose and is...

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Facts

The defendant entered the home of an 18 year old woman and asked for sex. When she declined his advances, he stabbed her four times; the wound penetrated her lung which necessitated both a blood transfusion and surgery in order to save her life. After refusing treatment because of her religious beliefs (as a Jehovah's Witness) she died. Medical evidence showed that she would not have died if she had received treatment. In his final speech to the jury, counsel for the Crown accepted that the girl’s refusal to have a blood transfusion was a cause of her death. The prosecution did not challenge the defence evidence that the defendant was suffering from diminished responsibility. The defence argued that the victim’s refusal to accept medical treatment broke the chain of causation between the stabbing and her death.

Judgment

Lawton LJ ruled that, as a matter of public policy

Public policy

Public policy as government action is generally the principled guide to action taken by the administrative or executive branches of the state with regard to a class of issues in a manner consistent with law and institutional customs. In general, the foundation is the pertinent national and...

, those "who use violence on others must take their victims as they find them.", invoking the thin-skull rule.