This term includes all things that have contributed to the result insofar as to be essential to it. The conduct must be a material factor in the chain of events. The three tests for factual causation under criminal law are: 1) But for test: Sine qua non. 2) Substantial: If two or more factors operate to achieve the result, and if all of them by themselves are material factors, then all are liable as substantial factors. 3) Contributory: If two or more factors are combined in a dependent or independent action to achieve a certain result, none of which alone would have caused the final result, then liability will result for each if they are material factors. The tests for factual causation when an omission or forbearance to act is found is: The test for factual causation is the same for both an act or an omission to act, if a duty to act is found. Courts use the contributory, substantial and but for tests.