that English law allowed for alternative remedies in some cases, specifically those based on "unlawful act" and "gross negligence" manslaughter and other offenses which do not require intent to harm the victim (manslaughter in English law is capable of a sentence up to and including life imprisonment): "Lord Hope has, however, ... [directed]... attention to the foreseeability on the part of the accused that his act would create a risk ... All that it [sic] is needed, once causation is established, is an act creating a risk to anyone; and such a risk is obviously established in the case of any violent assault ... The unlawful and dangerous act of B changed the maternal environment of the foetus in such a way that when born the child died when she would otherwise have lived. The requirements of causation and death were thus satisfied, and the four attributes of 'unlawful act' manslaughter were complete." In the same ruling, Lord Hope drew attention to the parallel case of Regina v. Mitchell ([1983] Q.B. 741) where a blow aimed at one person caused another to suffer harm leading to later death, and summarized the legal position of the 1994 case: "The intention which must be discovered is an intention to do an act which is unlawful and dangerous ... irrespective of who was the ultimate victim of it. The fact that the child whom the mother was carrying at the time was born alive and then died as a result of the stabbing is all that was needed for the offence of manslaughter when actus reus for that crime was completed by the child's death. The question, once all the other elements are satisfied, is simply one of causation. The defendant must accept all the consequences of his act, so long as the jury are satisfied that he did what he did intentionally, that what he did was unlawful and that, applying the correct test, it was also dangerous. The death of the child was unintentional, but the nature and quality of the act which caused it was such that it was criminal and therefore punishable. In my opinion that is sufficient for the offence of manslaughter. There is no need to look to the doctrine of transferred malice ... ." In other cases where the fetus has not achieved independent existence, an act causing harm to an unborn child may be treated