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R v Roberts [1971]


  • 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


  • Did Roberts cause the actual bodily harm?


  • Yes


  • 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
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