R v Inglis
A mother who killed her severely injured son out of love was guilty of murder, because the law does not recognise mercy killing as a defence.
Facts
Frances Inglis's son, Thomas, suffered catastrophic brain injuries after falling from an ambulance. He was in a permanent vegetative state. Believing that he was suffering and that it would be merciful to end his life, she injected him with heroin. He survived, and she was charged with attempted murder and released on bail on condition that she did not visit him. A year later, she gained access to his hospital room and killed him with another injection of heroin. She was convicted of murder and sentenced to life imprisonment, with a minimum term of nine years.
Legal principle
The Court of Appeal upheld the conviction and reduced the minimum term to five years. Lord Judge CJ said that the law of murder does not distinguish between murder committed for malevolent reasons and murder motivated by love, and that mercy killing is murder. Thomas was a living person entitled to the protection of the law, and only the courts could decide whether his life should be ended, for example by withdrawing treatment under Airedale NHS Trust v Bland. The mother's motive of love was a mitigating factor in sentencing, but not a defence.
Related cases on murder and voluntary manslaughter
- Attorney General for Jersey v Holley [2005] UKPC 23, [2005] 2 AC 580
- R v Ahluwalia [1992] 4 All ER 889
- R v Asmelash [2013] EWCA Crim 157, [2014] QB 103
- R v Byrne [1960] 2 QB 396
- R v Challen [2019] EWCA Crim 916
- R v Clinton [2012] EWCA Crim 2, [2013] QB 1
- R v Dawes; R v Hatter; R v Bowyer [2013] EWCA Crim 322, [2014] 1 WLR 947
- R v Dietschmann [2003] UKHL 10, [2003] 1 AC 1209
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