In English law, proving corporate manslaughter and securing a conviction of an individual where the corporation involved is a small concern are easier where it is easier to identify a "controlling mind" (in "R v OLL Ltd", 1994, about the Lyme Bay canoeing tragedy, managing director Peter Kite was convicted), but efforts to convict people in larger corporate entities tends to fail as the management structure is more diffuse making this identification more difficult. Instead, the prosecution stands more chance of pursuing a case successfully if it prosecutes simply on the grounds of a safety breach under the Health and Safety at Work Act 1974.