A man and wife had a fight in which he knocked her unconscious. In trying to remove her body he dropped her, causing her skull to fracture and hence she died. The judge directed that if the man dropped his wife by accident while attempting to move her body to cover up his previous attack or to take her home against her wishes, then he was guilty of manslaughter. The mens rea was contained in the initial assault and the actus reus was in dropping her. Simply because they did not perfectly coincide does not release the defendant from his liability, therefore the appeal was dismissed.