The kind of negligence which brings criminal consequences in its train has frequently been the subject of consideration in the courts1, and, in particular, numerous cases have dealt with negligent medical treatment causing or accelerating2 death3. The test to be applied in cases of manslaughter generally, and of so-called 'medical manslaughter' in particular, is one of gross negligence. The breach of duty must go beyond a mere matter of compensation between subjects and show such disregard for the life and safety of others as to amount to a crime against the state and conduct deserving punishment4. To establish gross
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