As manslaughter is not defined by legislation in Australia, common law decisions provide the basis for determining whether an act resulting in death amounts to manslaughter by unlawful and dangerous act. To be found guilty of manslaughter by an unlawful and dangerous act, the accused must be shown to have committed an unlawful act which is contrary to the criminal law, and that a reasonable person in the position of the accused would have known that by their act, they were exposing the victim to an ‘appreciable risk of serious injury’.