In the case "Attorney General's Reference No. 3 of 1994" Lord Mustill noted that the legal position of the unborn, and other pertinent rules related to transferred malice, were very strongly embedded in the structure of the law and had been considered relatively recently by the courts. The Law Lords concurred that a fetus, although protected by the law in a number of ways, is legally not a separate person from its mother in English law. They described this as outdated and misconceived but legally established as a principle, adding that the fetus might be or not be a person for legal purposes, but could not in modern times be described as a part of its mother. The concept of transferred malice and general malice were also not without difficulties; these are the legal principles that say when a person engages in an unlawful act, they are responsible for its consequences, including (a) harm to others unintended to be harmed, and (b) types of harm they did not intend. For example, the concept of transferred malice was applied where an assault caused a child to die not because it injured the child, but because it caused the child’s premature birth. It was also applied where manslaughter through a midwife’s gross negligence caused a child to die before its complete birth.