lord hope definition: an unlawful act has to be intentionally preformed, the defendant had the mens rea for the act, the unlawful act was dangerous and resulted in death
to establish manslaughter the d needs to have commited both: an unlawful act and a dangerous act
battery- r v mitchell
robbery- r v dawson
can not be proven through omisson it must be a positive act
test for dnagerousnes established in r v church
the ordinary perosn would see a risk of some harm
no requirement for it to be aimed at a victim- r v mitchell