In R. v. Groves (Ont CA, 2023) the Court of Appeal considers the defence of 'accident':
 The defence of “accident” is used in two senses in the law: an unintended act or an unintended consequence. The first has to do with the actus reus element of a crime: an unintentional act, in contradistinction to an intentional act. The second relates to the mens rea of a crime, where an accused says that they did not intend the consequence of their conduct: R. v. Aristor, 2022 ONCA 719, at para. 20; R. v. Mathisen, 2008 ONCA 747, 239 C.C.C. (3d) 63, at para. 70; R. v. Parris, 2013 ONCA 515, 300 C.C.C. (3d) 41, at para. 106. Accident as an unintended act is a complete defence, while accident as an unintended consequence is not.
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