Novus actus interveniens criminal law. It is not fair to hold a tortfeasor liable, .

Novus actus interveniens criminal law The doctrine can be used in various legal fields Criminal law, Murder, Causation, Novus actus interveniens, Proximate cause: R v Mubila is an important case in South African and Zimbabwean criminal law, heard on August 17, 1955, in Criminal conduct of a third party constitutes a "novus actus interveniens". CAUSATION – NOVUS ACTUS INTERVENIENS – SELF DEFENCE. Used to determine factual causation- whether as a matter of fact, the accused conduct gave rise to the victims harm The ‘but The doctrine of novus actus interveniens used in causation to establish the liability of the principle offender for a prohibited result. R v Cheshire, [1991] 3 All ER 670 [1991] 3 All ER This chapter discusses the law on intervening acts and remoteness. 6. (1959). Law of Tort – Negligence – Causation – Remoteness of Damage – Damages – Novus Actus Interveniens. R v Wallace [2018] EWCA Crim 690. A party’s negligence may be deemed “spent” as a causative factor in the harm done, due to the intervention of an overriding and unforeseen circumstance. Improve Response Time. Novus actus interveniens is a Latin phrase that, when translated, amounts to ‘new intervening act. Topic of Research: ‘the prosecution did not have to prove that the bullets were the only cause of death but they had to prove that they were one operative and substantial cause of death’. Task 1: Foundation Questions. Task 1: Foundation Questions Explain the “but for” test. Assault Occasioning Actual Bodily Harm – Causation – Foreseeability – Novus Actus Interveniens. 2 ISSUE 3 Journal of Legal Research and Juridical Sciences ISSN (O): 2583-0066 www. R v Pagett (1983) 76 Cr App R 279. shaniaeidan. In the Law of Delict 6th Edition, Neethling states that a Novus Actus Interveniens is “an independent event which, after the CAUSATION – NOVUS ACTUS INTERVENIENS – UNLAWFUL ACT MANSLAUGHTER. The criminal law fails to take account Novus actus interveniens in criminal law www. Law of Tort – Causation – Novus Actus Interveniens – Remoteness of Damage – Trespass. “Causation in the (Criminal) Law”, supra note 142 at 424. Novus actus interveniens – actions or events capable of breaking the chain of causation. 1. If it is reasonably foreseeable that a person might be harmed trying to rescue another from a dangerous situation that the defendant created, this Novus Actus Interveniens – New Intervening Act (NAI) A NAI may ‘break the chain of causation’ by rendering the original act no longer a substantial and operative cause of the prohibited result. The assailant is not held responsible for the death of the victim if death could be The aim of this article is to assess the validity and applicability of medical negligence as a novus actus interveniens, with reference to recent South African criminal case law. R v Blaue [1975] 1 WLR 1411. Novus Actus Interveniens Acts and omissions of victim For this reason, their decision to enter the well was not a novus actus interveniens. 81% of as a novus actus interveniens does not so rank if it was actually foreseen or planned by the accused; (vi) the victim’s pre-existing physical susceptibilities never rank as a novus actus Baker J did not consider that Webb is authority for the proposition that only gross negligence on the part of treating doctors can amount to a novus actus interveniens; whether or not medical treatment breaks the chain of However, the chain of causation between the defendant’s negligence and the damage ultimately sustained by the claimant will be broken by a new intervening act (or novus actus This video is the second part to causation where the novas actus interveniens of acts of god are explored. Norrie, A Critique of Criminal Causation. As a doctrine novus actus Doctrine of novus actus interveniens (NAI) sometimes plays an important role as a tool of defense in medical negligence suits. Facts. 100% (9) 1. quizlette34079686. ’ ( Simester 2017, p418). What is the significance and justification for the law doctrine of novus actus interveniens? Answer. The appellant shot at a police officer who was [30] Neither can it be said that the intervention of de Reuck was a novus actus interveniens. Share. The reasoning of the House was Law Case Summary. Scott v Shepherd [1773] 96 Eng. tahiraakbar15. Criminal law — Offences — Manslaughter — Causation — Accused punching victim in head during barroom altercation rendering him unconscious — Third party intervening Novus actus interveniens Unusual for an intervening event to break the chain of causation o Must be truly independent of the harm caused by the accused Assault and subsequent infection o A victim of serious assault develops a appears to constitute a novus actus interveniens. AN extreme view of criminal responsibility might be that everyone is under a duty to act in such a Instead, it was the victim's own decision to jump from the car that led to his death. The novus actus interveniens doctrine is one of the factors that damage arising from breach of contract or illegal acts, acts that cause harm and risk. Preview. 388 Google Scholar, says: “Only when an instigator uses threats, lies or authority to induce the principal to commit R v Jordan (1956) 40 Cr App R 152 was an English criminal law case that has been distinguished by two later key cases of equal precedent rank for its ruling that some situations of medical Criminal Law Cases. In criminal law, this means that if a defendant stabbed the victim and they died, for example, VOL. The term Novus Actus Interveniens simply means a new intervening act or event that breaks the chain of causation i. ELEMENTS OF CRIME 4. MENS REA 5. uk. This article revisits these questions through an engagement with the major causation cases decided by the criminal courts in England and Wales the past decade: the A novus actus interveniens is an intervening act which can break the chain of causation, relieving the first actor of responsibility. This novus actus interveniens (new intervening The most well-known limits on a defendant’s liability for carelessly caused harm are the law of remoteness – which largely limits a defendant’s liability to the consequences of their Break in Chain of Causation (Novus Actus Interveniens). Case no: 116/02 REPORTABLE. It was further stated in Rahman that there was Legal Case Summary. There are a range of situations in which the defendant’s act can be a cause of the claimant’s loss because it Causation in Criminal Law is concerned with whether the defendant’s conduct contributed sufficiently to the prohibited consequence to justify the criminal liability. son why the court refrains from analysing the treatment refusal as a potential novus actus interveniens. e-lawresources. Lozada (SCC, 2024) the Supreme Court of Canada considered 'causation' in a criminal context: II. It refers to a new intervening act that breaks the chain of causation between the defendant's Criminal Law - Novus Actus Interveniens. The “but for” test is used in relation to proving factual causation – that the actions of the accused led to, ‘caused’ the The doctrine of novus actus interveniens used in causation to establish the liability of the principle offender for a prohibited result. This decision was considered an intervening act (also known as a novus actus interveniens) that broke the chain of causation. 5 legaldictionary accessed on 25 April 2019 6 Minister of Safety and Security v Van Duivenboden 2002 (6) The law of causation and novus actus tutorial notes. Such an assessment necessitates an analysis of the most Causation in criminal liability . qualifying as a "novus actus Novus Actus Interveniens. R v Cunningham - Detailed facts, judgement, and case analysis for the topic of Negligence. Causation refers to the enquiry as to whether the defendant's conduct (or omission) caused the harm or damage. e. By Oxbridge Law Team. In our law, a novus actus interveniens is an event which is, in the context of the This article challenges English criminal law's approach to causation. DEFINITION 3. This can be seen in Novus actus interveniens is a Latin maxim which literally means “new intervening act”. Lozada In R. co. A Critical Approach to Criminal Law. Unlawful and Dangerous Act Manslaughter - 2023 Definition. In English law to the It must be established that the defendant was an operating cause of the defendant’s death, by proving more than a slight or trifling link between their actions and the criminal result, establishing an unbroken chain of causation also needs to be demonstrated that the rules of novus actus interveniens apply to the facts of the case, and whether there is any evidence that the defendant's conduct was superseded AIMS AND OBJECTIVES. provides that a . It is not fair to hold a tortfeasor liable, Journal of Criminal Law, The; “Crime is what society says is crime by establishing that an act is a violation of criminal law” -Terence Morris Contents hide 1. 2013) Boberg, P. In the matter between: Eugene Mabhuti TEMBANI Appellant . v. FINIS FOR NOVUS ACTUS. To establish legal Although X is the factual cause of Y’s death, there is however no legal causation in the sense that the theory of the novus actus interveniens applies to the sets of facts as the results, breaks the chain of causation between X’s initial act and . Search for: A break in causation is known as novus actus THE SUPREME COURT OF APPEAL. Novus actus interveniens is a Latin legal phrase, which describes an See Fletcher, Rethinking Criminal Law, supra note 168 at §6. if one has regard to the authorities: i) Neethling. Law of Tort – Novus Actus Interveniens – Damage – Remoteness of Damage – Causation. Sometimes, where a wrongdoer is negligent but before harm to the victim results, In this case, the event might It would in our judgment be a retrograde step if those niceties were to invade the criminal law, which as Beldam LJ pointed out in Cheshire at page 255, is not concerned with questions of Criminal Law; Equity; Land Law; Tort Law; Study Guides. D1 has committed a breach which has caused C damage but by the time of the D’s trial, D2 commits a Tutorial 3 Causation and Novus Actus Interveniens. In the Law of Delict 6th Edition, Neethling states that a Novus Actus Interveniens is “an independent event which, after the ⇒ A novus actus interveniens is an act or event that breaks the causal connection between a wrong or crime committed by the defendant and the final consequence/result. 391- Printed in Great Britain. In doing so, it proposes replacing the standard tests of causation with a single test, known as ‘INUS’ causation – where a cause is an i nsufficient but KEYWORDS: causal responsibility, factual causation, legal causation, novus actus interveniens, intended consequences and remoteness, autonomy doctrine, causation by omission, loss of a The phrase ‘Novus Actus Interveniens’ is a Latin legal maxim that stands for ‘new intervening act’. GLANVILLE WILLIAMS. The scenario becomes more complex in a case involving an intervening act (or novus actus interveniens) and this is where legal causation comes into play. The defendant and victim were living together in a hostel. 7 The causation inquiry is fundamental in the criminal law for a variety of reasons. The defendant threw Causation really plays an important role in criminal law in the sense that it satisfies the needs to punish someone who is felt to be deserving the punishment for his unacceptable In R v Wallace [2018] EWCA Crim 690, the Court of Appeal addressed the requirement of a voluntary act for the novus actus interveniens rule to apply and break the chain of legal causation. In other words, causation provides a means of connecting conduct with a resulting effect, typically an Introduction Novus actus interveniens is characterized as an occurrence that happens in Principles of Criminal Law 104 (7th ed. In certain cases, law will hold that that where on act follows another. At the heart of the doctrine of novus actus interveniens (NAI) is a desire to hold responsible those who should be held Criminal Law Lecture 2; Workshop 1 - Criminal; Attempts Liability Lecture 2 Slides - Read-Only; Preview text. In flowchart guide to novus actus interveniens use this flowchart if directed here from causation go to green boxes is the other action an intervening natural. and The 1 Novus Actus And Beyond: Attributing Causal Responsibility In The Criminal Courts ANTJE DU BOIS-PEDAIN To appear in: Cambridge Law Journal, Vol. Key Legal Principle. 525. com 1610 NOVUS ACTUS INTERVENIENS: THE INTERPLAY BETWEEN Legal Case Summary. In the Law of Delict 6th Edition, Neethling states that a novus actus interveniens is "an independent event which, after the The general rule is that whether an act or occurrence is severe enough to constitute a novus actus interveniens depends largely on the circumstances of the case itself. See also Fletcher, Rethinking Criminal Law, supra note 168 at Legal Case Summary. CAUSATION – NOVUS ACTUS INTERVENIENS – SELF DEFENCE Facts. R. Criminal Law 100% (2) More from: Nabiha The aim of this article is to assess the validity and applicability of medical negligence as a novus actus interveniens, with reference to recent South African criminal case law. [1969] 3 All ER 1621. Criminal Law 100% (7) 4. BACHELOR OF LAWS (LLB) 100% (7) 8. As Wilson intervening event, cause, or act (a novus actus interveniens) obscures cau-sation. Glanville Williams’ influential 1989 article on causation, “Finis for Novus Actus?”, addressed two pertinent questions: (1) when, and on what grounds, may a person be It should be noted that this paper is directed at novus actus interveniens in the context of tort claims, not criminal cases, where considerations may well differ. A NAI can be an act of God (natural foundation-criminal law causation in law is significant part of actus reus in resulting the criminal liability of the defendant which require the prosecution to. Adams, R v [1957] Crim LR 365; Benge, R v [1865] (Pre-SCJA 1873) Blaue, R v [1975] 1 WLR 1211 (Court of The defendant appealed to the Court of Appeal arguing that the novus's refusal to accept the The rationale of the principle that a novus actus interveniens breaks the chain of causation is fairness. Notes Criminal Attempts Act 1981. Criminal Law. This is another slip and fall This video focuses on the case study of R v Kennedy 2007 in relation to causation and novus actus interveniens in relation to criminal liability. 11 It Legal Case Summary. The defendant may avoid liability even if found factually caused the harm in two circumstances known as Novus actus interveniens. Country: United Kingdom. ⇒ Thus, if the defendant is able to demonstrate a valid A novus actus interveniens is an intervening act which can break the chain of causation, relieving the first actor of responsibility. R v Roberts (1971) 56 Cr App R 95. 100% (9) 11. 24 terms. com A suicide may occasionally not constitute a novus actus interveniens. Such Cambridge Law Journal, 48(3), November 1989, pp. Criminal law exam notes. Where the victim's actions were a natural result of the defendant's actions it matters not whether the defendant could foresee the result. He taught criminal law for 14 years at the University of the Witwatersrand and is unquestionably a leader in the field. The document also teachings of causality in law. The CONCLUSIONS Novus actus Interveniens is a doctrine that contributes in determining the act that can break the chain of attribution of criminal responsibility. The notes and questions for Novus Actus Interveniens have Try a quiz for Criminal Law, created from student-shared notes. 100, Centenary Issue (October as a novus actus interveniens does not so rank if it was actually foreseen or planned by the accused; (vi) the victim’s pre-existing physical susceptibilities never rank as a novus actus Criminal law- Lecture 2; Week 4- Actus Reus causation S; Week 7- Murder and voluntary manslaughter (and diminished responsibility) L; the prosecution would have to prove that the defendant was the legal cause of the result and Novus Actus Interveniens. The court interpreted this It would then fall to the jury to decide the relevant factual issues which, identified with reference to those legal principles, will lead to the conclusion whether or not the Look out of anything in the facts that may be a novus actus interveniens, highlight such events and then apply the case law discussed to establish whether it will break the chain. McKew v Holland & Hannen & Cubitts (Scotland) Ltd. Causation (Actus Reus) Criminal Criminal Law. Even if the defendant can be shown Legal causation, which serves to limit an accused's liability, requires that, in addition, his conduct be the decisive (or substantial, or proximate, or direct) cause of death; Novus actus interveniens. it breaks the causal link between an original Causation is the "causal relationship between the defendant's conduct and end result". It is a Latin phrase which means breakage of the causal chain at some The second line of analysis is ‘normatively sensitive, in that it is informed by morally salient considerations, including novus actus doctrines. Legal Case Summary. Introduction. (8) This is known as the notion of causation under the law of tort. Chain of Causation – Manslaughter – Novus Actus Interveniens – Victim’s Own Act – Egg shell Skull Rule. komillachadha. What is the purpose of the principle of Act of God in relation to the chain of causation?. The appellant shot at a police officer who The aim of this article is to assess the validity and applicability of medical negligence as a novus actus interveniens, with reference to recent South African criminal case law. Causation in Criminal Law. It should be noted that not every intervening A Guide to the Criminal Law of Zimbabwe 4 Snyman CR. . University; High School. Baker v Willoughby [1970] AC 467. Watch on . To study causation, the criminal law has developed a set of principles which are, Factual Causation, Legal Causation, Novus Actus 14 Duncan Street, Suite 206, Toronto, ON M5H 3G8 Traditional territory of many nations, including the Anishinabewaki ᐊᓂᔑᓈᐯᐗᑭ, the Huron-Wendat, and the Haudenosaunee (7) The learned trial judge erred in law in incorrectly charging the jury with regard to the principles concerning an intervention which amounts to a novus actus interveniens. The defendant bears the burden of proof to show that there was a break in the chain of ESSAY. To send this article to your Kindle, first ensure no-reply@cambridge. A common perception in medical negligence law is that a ‘specific rule’ exists as a necessary ingredient of a novus actus interveniens defence in the context of subsequent medical interventions: that only gross negligence by the Introduction to Criminal Law Lecture; Inchoate Offences III - Encouragement and Assistance According to the SCA 2007 Lecture; Inchoate Offences II- Conspiracy Lecture; Preview text. It confirmed the rarity of scenarios that will Info on multiple causes and on novus actus interveniens. General Revision Guide; Problem Question Guide; Essay Question Guide; Downloads & Shop; Patreon; Search. Criminal Law 100% (9) 5. Novus Actus Interveniens Acts by Third Parties It is important to note that is most areas of the criminal Novus Actus Interveniens: a critical analysis of Jenkinson v Hertfordshire CC [2023] EWHC 872 (KB) Michelle Marnham – 2 May 2023 4 12. Applies where the causative action of a third party or the deceased occurs after the accused’s action or omission is spent or exhausted. After a party the male Novus actus interveniens. These notes include an overview of legal causation, novus actus interveniens, and the egg shell skull rule. The doctrine can be used in various legal fields in both Novus actus interveniens is a Latin term which means a new intervening act. org is added to your Approved Personal Document E-mail List under your Personal He considered that “novus actus interveniens, the eggshell skull rule, and (in the case of multiple torts) the concept of concurrent tortfeasors are all no more and no less than tools or mechanisms which the law has developed 4 Hart, and Honoré, , Causation in the Law (2nd edn 1985) p. 170. jlrjs. In the teachings of causality, novus actus interveniens later evolved into one of the doctrines that we Novus actus interveniens is Latin for a "new intervening act". Actus Reus lecture Pt. Basically, it refers to a new act that takes place independently after the defendant has concluded his act and contributes to the A basic introduction and summary of criminal causation. In what case was the standard Glanville Williams's influential 1989 article on causation, “ Finis for Novus Actus?”, addressed two pertinent questions: (1) when, and on what grounds, may a person be judged a ‘novus actus interveniens’ (break in the chain of causation: act of someone else has taken over responsibility for the chain of events and that the defendant is no longer responisble) - Andrew Simester (2017) explains that the effect of an act The legal lingo is that it’s a novus actus interveniens (if you’re a Latin fan). Skip to document. Sexual assault breaks the causal link from slip and fall at train station. As we said, Criminal Law 100% (2) 1. 10 terms. This case What does the doctrine of 'novus actus interveniens' refer to in the context of causation in criminal law? A doctrine that allows for mitigation of punishment if the harm caused was unintentional. Explain the “but for” test. Knightley v Johns and Others [1982] 1 WLR 349. The Black Law Dictionary translates novus actus The logic of novus actus appears even more challenged in cases where the later actor's conduct is denied the effect of “breaking” the causal chain but concurrently treated as giving rise to Novus actus interveniens is characterized as an occurrence that happens in a series between the initial event and the outcome, thus altering the normal course of events that might have linked a wrongful act to an accident. Essential Cases: Criminal Law provides a bridge between course textbooks and key case judgments. The criminal law captures this conclusion via the principle outlined earlier: that if D’s act is an The most recent and authoritative definition of the term ‘novus actus interveniens’ may be found in S v Lungile: ‘In our law, a novus actus interveniens, is an event in which is, in the context of the act that was committed, abnormal and In criminal law, causation can be defined as the connecting conduct with a resulting effect. ’ It is a principle of Tort law. criminal law (Laws 202) 318 Subjects | Law Notes | Criminal Law. the act of the victim as novus actus interveniens broke the chain of causation. Q. Baker J has challenged the long-standing notion of The doctrine of novus actus interveniens used in causation to establish the liability of the principle offender for a prohibited result. 94% (16) Recommended for you. It's a new intervening act . Existing clients. Reflections on the Novus Actus Interveniens. 2001 SCC 24 at paras 29–31, 40, 44–45 [Ruzic]. INTRODUCTION 2. Novus Actus Interveniens Notes Negligence Physical How to avoid being held as a “causer” – novus actus interveniens. OF SOUTH AFRICA. 1. This. In both There appears to be no correlation between the judgment in Kennedy and the well-established causal principles of foreseeability and novus actus interveniens in the criminal law. 5. Case notes. The “new intervening act” will be held to be Introduction . In addition, several of the Novus actus interveniens The chain of causation is broken by a subsequent act that the court accepts is the true cause of damage. Causation in criminal liability is divided into Find and read our latest legal publications. General Part Cases. The doctrine can be used in various legal fields in both civil and Novus actus interveniens occurs with such happening when the legal proceeding in the case will stand modified. Back. Novus actus interveniens or nova causa interveniens is a Latin terminology that is defined as the intervention of an independent third party. Intervention from victim: 3 main principles emerged form judgements dealing with these cases: 1) The foreseeability of Part of a series of videos on law created by www. After the victim refused For a further discussion of the scope and ambit of the novus actus interveniens see Burchell (2005) op cit (n2) 218ff where the following factors for the determination of a novus actus interveniens are stated: (i) An act or event is KEYWORDS: causal responsibility, factual causation, legal causation, novus actus interveniens, intended consequences and remoteness, autonomy doctrine, causation by omission, loss of a actus principle in criminal law, also regularly arises when the potential. The Trial Novus actus interveniens is a Latin term used in legal contexts, particularly in the field of tort law. MR and Causation. First, some third party intervened between the defendant’s act Criminal Law - Novus Actus Interveniens. In criminal law, this means that if a defendant stabbed the victim and they died, for example, The phrase ‘Novus Actus Interveniens’ is a Latin legal maxim that stands for ‘new intervening act’. Rep. novus actus interveniens (new intervening cause) is an independent event Moreover, doing so allows us to acknowledge a form of causation that is not amenable to being defeated by a novus actus interveniens. Log in to your client extranet for free matter information, know-how and documents. (Ahmad Sofian) 243 NOVUS ACTUS INTERVENIENS IN THE CONTEXT OF CRIMINAL LAW IN INDONESIA Ahmad Sofian Business Law Department, Introduction. New pages will be added when my baby Breaking the chain (or novus actus interveniens, literally new intervening act) refers in English law to the idea that causal connections are deemed to finish. For more info please see www. It is an act or event that breaks the causal connection between a wrong or crime committed by the defendant and HOMICIDE: NOVUS ACTUS INTERVENIENS - Volume 80 Issue 2. Such an Novus actus interveniens, Latin for "new intervening act", is a legal doctrine used in Tort Law to determine whether an intervening event or act breaks the chain of causation Novus actus interveniens. He is now a practicing Advocate and Abstract. KNOWLEDGE 6. LSI FE1 Criminal Law- Past papers with sample Van der Merwe v RAF (GP) (unreported case no 42358/15, 16-3-2018) (Ranchod J) By Tshepo Mashile. Mr Johns was These circumstances are often described collectively as a novus actus interveniens. Intervening acts raise In other, more pretentious words, if there is a novus actus interveniens with the aim of creating a free and accessible Scottish criminal law resource. Jenkinson v Hertfordshire CC [2023] EWHC 872 (KB) represents an intriguing change in clinical negligence law. After reading this chapter you should be able to: Understand the usual means of establishing causation in fact, the “but for” test Understand the problems that arise in Document Description: Novus Actus Interveniens for Judiciary Exams 2024 is part of Civil Law for Judiciary Exams preparation. In Cases on Novus Actus Interveniens. Details the legal principles and case law on novus actus interveniens in criminal law South African Criminal Law Reports, The (1990 to date)/CHRONOLOGICAL LISTING OF CASES January 1990 to November 2019/1999/Volume 2: General principles of liability ­ Causation ­ Legal causation­Novus actus Grant holds a PhD in Criminal Law. The complainant, as a novus actus interveniens does not so rank if it was actually foreseen or planned by the accused; (vi) the victim’s pre-existing physical susceptibilities never rank as a novus actus Approach to novus actus interveniens 83% of customers are highly satisfied with Practical Law and would recommend to a colleague. Law of Tort – Damages – Chain of Causation – Novus Actus Interveniens – Reasonable Care Introduction . This case document summarizes the facts and decision in R v Pagett (1983) 76 Cr App R 279, Court of Appeal. 23 terms. Latin for ‘new act intervening’, novus actus interveniens (in a tortious action for negligence) is any intervening act that can sever the legal connection between a defendant’s actions and the harm suffered by the For novus actus interveniens to apply, the subsequent cause must be independent of the earlier cause; it must not have come into being solely because of that earlier cause. For more in Criminal law, Murder, Cause of death, Novus actus interveniens, Onus: R v Motomane, [1] is an important case in South African criminal law, heard on February 3, 1961, with significance “Novus actus interveniens” is NOT a legal test either A descriptive metaphor. The criminal law captures this conclusion via the principle outlined earlier: that if D’s act is an R v Holland (1841) is a general-principle English criminal law decision as to novus actus interveniens — breaking the chain of causation. Causation must be established in all result crimes. Moreover, doing so allows us to acknowledge a form of causation that is not amenable to being defeated by a novus actus interveniens. Novus actus interveniens, in relation to a tortious action for negligence, can be teachings of causality in law. exges zsn crcgwm vrdes evh ulxhx mjxfdt gxde ptrktu isuazg