Criminal law – Infanticide. For infanticide to be left as an alternative verdict to murder, s 1(1) of the Infanticide Act 1938 did not require the effects of giving birth to be the sole cause of a mother's disturbance of balance of mind. It was sufficient if a failure to recover from the effects of birth was an operative or substantial cause of the disturbance of balance of mind, even if there were other underlying mental problems which were part of the overall picture. Accordingly, the Court of Appeal, Criminal Division, allowed the defendant mother's appeal against conviction for the murder of her baby, as the trial judge had erred by refusing to leave infanticide as an alternative to murder.