R v Harbottle

R v Harbottle, [1993] 3 SCR 306 is a Canadian criminal law case decided by the Supreme Court of Canada on the standard of causation required in order for an accused to be convicted of first degree murder under section 231(5) (where the murder is subsequent to a predicate offence) of the Criminal Code. The Court held that the standard for this provision must be strict requiring a "substantial and integral cause". On the facts, the Court found that Harbottle's conduct in holding the victim's legs while she was strangled to death was sufficient to be a substantial and integral cause. This standard does not apply to all first degree murder, where the standard articulated in R v Nette applies.