R v Roberts
A victim's escape from an attack does not break the chain of causation unless it is so daft as to be unforeseeable.
Facts
Mr Roberts was giving a young woman a lift in his car late at night. He made sexual advances to her and tried to pull off her coat. She jumped out of the car while it was moving at about 20 to 40 miles per hour, and was injured. He was convicted of assault occasioning actual bodily harm.
Legal principle
The Court of Appeal upheld the conviction. Stephenson LJ said that the test was whether the victim's reaction was the natural result of what the defendant said and did, in the sense that it was something that could reasonably have been foreseen as the consequence of what he was saying or doing. Only if the victim did something so daft or unexpected that no reasonable man could be expected to foresee it would the chain of causation be broken. Her reaction was foreseeable.
Related cases on causation
- Baker v Willoughby [1970] AC 467
- Barker v Corus UK Ltd [2006] UKHL 20, [2006] 2 AC 572
- Barnett v Chelsea and Kensington Hospital Management Committee [1969] 1 QB 428
- Bonnington Castings Ltd v Wardlaw [1956] AC 613
- Chester v Afshar [2004] UKHL 41, [2005] 1 AC 134
- Fairchild v Glenhaven Funeral Services Ltd [2002] UKHL 22, [2003] 1 AC 32
- Gregg v Scott [2005] UKHL 2, [2005] 2 AC 176
- Hotson v East Berkshire Area Health Authority [1987] AC 750
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