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R v Royle [2013]


  • The defendant, Royle, intended to rob the 79-year-old victim
  • Royle caused injuries to the victim during the robbery, which the victim later died from


  • Did Royle murder the victim?


  • Yes


  • The R v Woollin [1999] virtual certainty jury direction is required where a defendant’s purpose is not to cause really serious harm
  • The judge’s jury direction of finding ‘certainty’ as opposed to a ‘virtual certainty’ did not affect the security of the conviction, where a minimum 25 year sentence was recommended
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