In R v Dalby it was recognised that the possession or supply of drugs did not cause death. The appellant had supplied Stefan O'Such, with Diconal tablets. Both had injected themselves. O'Such subsequently met a friend who helped him to administer intravenous injections of an unspecified substance to himself. O'Such then went home where he fell asleep. An attempt to wake him the next day was unsuccessful. Dalby was prosecuted for manslaughter and convicted on the basis that his supply of the Diconal tablets was an unlawful and dangerous act which caused the death of O'Such. His conviction for manslaughter was quashed. The supply of drugs was not the cause of death. It was the deceased's act of injecting himself which was the direct cause of
