On March 10, 1965, Robert Patrick Ryan and his accomplice, Mr White, committed an armed robbery of a service station in Carramar, New South Wales.

Under the doctrine of common purpose, White was also liable for Taylor's death, but was offered and accepted a plea of guilty of manslaughter.

Generally, the law will not hold people accountable for involuntary actions such as spasms, sneezes or twitches.

New South Wales follows a modified version of the felony murder rule, wherein the prosecution does not need to prove malice to convict for murder if the death is caused "in an attempt to commit, or during or immediately after the commission, by the accused, or some accomplice with him, of a crime punishable by death or penal servitude for life.

"[1] Since Ryan's actions and Taylor's death occurred during and as the result of an armed robbery, which at the time was punishable with life imprisonment, the felony murder rule applied.