- Andrews carelessly overtook a car, killing a pedestrian
- Was Andrews guilty of gross negligence manslaughter or unlawful act manslaughter, or neither?
- Gross negligence manslaughter
- Dangerous driving is not enough to constitute an unlawful act for the purposes of unlawful act manslaughter
- Lord Atkin distinguished between ‘normal’ and ‘reckless’ negligence, the latter punishable as a crime
- Andrews’ negligence went beyond dangerous, it was reckless, allowing conviction from gross negligence manslaughter