In R. v. Ethier (Ont CA, 2023) the Court of Appeal considered 'accident' as a criminal defence:
 A defence to a criminal charge that what occurred was an “accident” may mean one of two different things: (a) the act in question was involuntary (negating the actus reus of the offence); or, (b) the accused lacked the requisite mens rea: R. v. Barton, 2019 SCC 33,  2 S.C.R. 579, at para. 186.
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