<Li> Manslaughter - provocation </Li> <Li> Manslaughter - suicide pact </Li> <P> In R v Creamer, the court said obiter that attempted manslaughter is not an offence known to law . </P> <P> Provocation in English law was abolished on 4 October 2010 by section 56 (1) of the Coroners and Justice Act 2009, but replaced by the similar partial defence of "loss of control". </P>

Why was the conviction for manslaughter in the case of watson 1989 overturned