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During a street fight, D stabs E in the abdomen, causing life-threatening injuries. E is rushed to a public hospital for emergency surgery. During the operation, the surgeon inadvertently perforates a major artery, resulting in fatal hemorrhage. E dies. (a) Identify the proximate cause doctrine governing criminal liability for death in this scenario. (b) Distinguish the proximate cause rule from the simple 'but-for' test, and explain how foreseeability and intervening causes affect the chain of causation. (c) Apply the doctrine to determine whether D is criminally liable for E's death, and state your conclusion.