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R v Winning (1973), 12 CCC (2d) 449


Convicted of obtaining false credit from Eatons. Eatons did not rely on info they obtained.

AR of s.362(1)(b)
**Obtain Credit (forbidden consequence)
**False Pretences (forbidden act) or Fraud
***Fraud – dishonest act and deprivation


Did the misrepresentations cause Eatons to extend credit to her?


Even where Crown proves that the accused in fact caused the prohibited consequence, the accused may argue that his conduct contributed in such a minor way to the occurrence of the consequence that it should no count as a cause

But for the acts of the accused, the forbidden consequence would not have been brought about, then causation is satisfied

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