R v Roberts [1971]

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

• Yes

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