Yes, I would agree with Tdol, in the case of law reports where they are reporting, after a court decision, on information that could set a precedent as part of "case law". As such, the decision on whether or not a crime had been committed would have already been determined.
There have been cases, in the UK, where, apparently, one of a number of masked burglars who broke into someone's property, was mortally wounded. The burglary would definitely be treated as a crime, but the householder could, and has, in the past, I believe, been charged with murder. I seem to remember a case, some time ago, involving, I believe, a farmer with a shotgun.
I believe that there are attempts under way to clarify this aspect of the law (e.g. wounding a thief in the back when they are trying to escape may be considered differently - (i.e. not considered a case of self defence).
Regards
R21