All non-fatal offences require causation to be proved. There are 2 tests that the defendant has to pass to prove that they can be blamed for the actus reus of the crime. Factual Causation: the P has to prove that the D caused the criminal act (but for test) - case of Pagett (1983) Legal Causation: the P has to prove it is fair to blame the D for the criminal act caused by his conduct, is the D more than a minimal cause/ the legal cause - case of Cato (1976)