... been determined it should be quite straight forward as this issue can be left for the jury with little or no direction. Factual causation is often decided using the 'but-for' test, if the result would not have occurred in the way that it did but for D's conduct, then D has in fact caused that result. This test cannot be applied in isolation otherwise too many defendants would ensue as the correlations between acts, omissions and resultant causes would be far too remote. There is a need for common sense to be applied, for juries and law students alike. It should be appreciated that there can be more than one cause of a consequence and in these circumstances we need to "look further"3 for proper direction. If D's act therefore can be adduced to be factual causation, he will be held to have caused that prohibited consequence only if the ...

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