R v Goodfellow

 A guy set his house on fire with the aim that the others should leave the house (so that they could be placed in a new council house). The fire spread too rapidly and though he saved some, he was unable to save his wife, girlfriend and son, who died. The judge directed the jury on the “unlawful and dangerous act” definition as well as the R. v. Lawrence (1981) 73 Cr.App.R. 1 that he created a “serious and obvious risk” to somebody and took the risk regardless. He appealed but the CA held that he could be held guilty for either type of manslaughter