... gun at the friend who was taking it as a joke, both men thought the gun would not fire but the defendant pulled the trigger and killed his friend, he was convicted of manslaughter and appealed, the appeal was allowed on the grounds that the defendant had not committed any unlawful act which causes death or assault. Unlawful Act Manslaughter has several factors comprising of the Act must be both unlawful and dangerous for a person to be liable, the test for this was created in the case of Church (1966) where the defendant made the victim unconscious and upon failing to revive her he threw her into a nearby river where she drowned. The Defendant was convicted of Manslaughter and appealed on the grounds of misdirection, The Court of Appeal set down the test for dangerousness which was, "The unlawful act must be such as all sober and reasonable people ...

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