## Facts

- William Bradshaw and Herbert Dockerty played on opposing teams in an association football match governed by game rules.
- About fifteen minutes into the match, Dockerty ran toward goal at speed while controlling the ball.
- Bradshaw approached at an angle to challenge Dockerty; witnesses disagreed whether the ball had already been played past Bradshaw when contact occurred.
- Some testimony described the contact as an unfair charge involving Bradshaw jumping and striking Dockerty in the abdomen with a protruding knee.
- Dockerty suffered severe internal injuries, collapsed, and died the next day.
- An umpire reportedly viewed the incident as not unfair, suggesting it was seen by some as within ordinary match play.
- The prosecution charged Bradshaw with manslaughter based on an allegedly unlawful act (assault) during the match causing death.

## Issues

1. When does violent conduct occurring during a lawful sporting contest become sufficiently unlawful to support manslaughter liability?
2. In assessing criminality in sport, what mental state is required beyond mere dangerousness, clumsiness, or error in judgment?
3. How should a jury distinguish conduct consented to as an ordinary incident of a contact sport from non-consensual unlawful violence?

## Decision

- The jury acquitted Bradshaw of manslaughter.
- The trial judge instructed that sport context matters because players consent to ordinary physical contact and risk inherent in the game.
- The jury was directed to decide whether Bradshaw’s act was a legitimate play for the ball or an excessively violent act showing intent to cause serious injury or reckless disregard for safety.

## Legal Principles

- Participants in contact sports are treated as consenting to physical contact and risks that are ordinarily incident to playing under the sport’s understood rules and practices.
- Criminal liability for on-field conduct requires more than carelessness or misjudgment; it turns on conduct intended to cause serious bodily harm or done with reckless disregard as to whether such harm will be caused.
- For manslaughter, causing death during play is not enough; the prosecution must prove the act crossed the boundary from lawful sporting contact into unlawful violence with the requisite culpability.
- Whether conduct exceeds accepted play and reaches a criminal level is a fact question for the jury, assessed in light of the game context and the nature of the act.

## Conclusion

The case treated organized football as a context in which players consent to substantial physical contact, holding that a fatal on-field collision supports manslaughter only if the act was intentionally seriously harmful or recklessly dangerous beyond what is accepted in the sport; on the evidence presented, the jury found that threshold unmet and returned a not-guilty verdict.


Regina v. Bradshaw, 14 Cox Crim. Cas. 83 (Leicester Spring Assizes 1878)