R v Martin [1881]
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R v Martin [1881] 8 QBD 54 revolves around the concept that battery can occur without direct application of force on the victim. The defendant, Martin, engaged in actions that resulted in a panic in a crowded theatre, leading to injuries to some members of the audience.
Martin placed an iron bar in front of an escape route in a crowded theatre and extinguished the lights, causing a panic among the audience. As a result of the ensuing chaos, individuals were injured. Martin was convicted of inflicting grievous bodily harm under Section 20 of the Offences Against the Person Act 1861.
Martin appealed against his conviction, arguing that there was no direct application of force on the victims. The Court for Crown Cases Reserved dismissed the appeal. Lord Coleridge CJ, delivering the judgment, emphasised that the defendant must be deemed to have intended the natural consequences of his actions. While Martin may not have harboured personal malice against specific individuals, his unlawful and malicious act, calculated to cause injury, justified the conviction for inflicting grievous bodily harm.
The case established the principle that an individual can be convicted of battery even if there is no direct application of force on the victim. The focus is on the intentional commission of an unlawful act that leads to foreseeable harm.
The Court for Crown Cases Reserved, which decided this case, was later replaced by the Court of Criminal Appeal and subsequently the Court of Appeal. R v Martin remains significant in illustrating the broad interpretation of battery in instances where deliberate actions create a risk of harm, resulting in injury to others.
Martin placed an iron bar in front of an escape route in a crowded theatre and extinguished the lights, causing a panic among the audience. As a result of the ensuing chaos, individuals were injured. Martin was convicted of inflicting grievous bodily harm under Section 20 of the Offences Against the Person Act 1861.
Martin appealed against his conviction, arguing that there was no direct application of force on the victims. The Court for Crown Cases Reserved dismissed the appeal. Lord Coleridge CJ, delivering the judgment, emphasised that the defendant must be deemed to have intended the natural consequences of his actions. While Martin may not have harboured personal malice against specific individuals, his unlawful and malicious act, calculated to cause injury, justified the conviction for inflicting grievous bodily harm.
The case established the principle that an individual can be convicted of battery even if there is no direct application of force on the victim. The focus is on the intentional commission of an unlawful act that leads to foreseeable harm.
The Court for Crown Cases Reserved, which decided this case, was later replaced by the Court of Criminal Appeal and subsequently the Court of Appeal. R v Martin remains significant in illustrating the broad interpretation of battery in instances where deliberate actions create a risk of harm, resulting in injury to others.
