Facts
- Roberts gave a lift to the victim, whom he had never met
- After refusing his sexual advanced, Roberts drove off at speed
- In order to escape, the victim jumped from Roberts’ moving car and sustained actual bodily harm
Issue
- Did Roberts cause the actual bodily harm?
Decision
Reasoning
- The victim’s action were neither daft, nor so unexpected that no reasonable man would have acted in the same way
- Escaping does not break the chain of causation unless it is ‘daft’ in the eyes of the jury
- The requisite mens rea for causing actual bodily harm under section 47 of the Offences Against the Person Act 1861 is merely an intent or recklessness as to some harm