... in the case of R v Watson, where the D burgled an 87 year-old man who died of a heart attack. The act was dangerous because of the frailty of the old man. It was obvious to a reasonable person that the V could suffer some physical harm e.g. a heart attack. Act simply means that the initial crime must be an action not an omission. E.g. in R v Love, the D did not do anything for the child so it does not classify as an Act. Finally, it resulting in death; where there must be a causal link between the initial crime and the death. E.g. in R v Church, she died because she was unconscious when thrown in the river. In this question clearly Don has been died due to the unlawful and dangerous act of Brian elbowing him in the face twice. The MR of Constructive Manslaughter is ...

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