R v Martin [1881]

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.
Back to blog
UOL Case Bank

UOL Case Bank

Upon joining, you become a valuable UOL student and gain instant access to over 2,100 case summaries. UOL Case Bank is constantly expanding. Speed up your revision with us now.

Subscribe Now

Where are our students from?

Yale University
Council of Europe
Baker Mckenzie 
University of Chicago
Columbia University
New York University
University of Michigan 
University College London (UCL)
London School of Economics (LSE)
King’s College London (KCL)
University of London
University of Manchester
University of Zurich
University of York
Brandeis University
University of Exeter
University of Sheffield
Boston University
University of Washington
University of Leeds
University of Law
Royal Holloway, University of London 
Birkbeck, University of London
SOAS, University of London
University of Kent
University of Hull
Queen’s University Belfast
Toronto Metropolitan University
Hong Kong University of Science and Technology
University of Buckingham

  • Criminal Practice

    Diagrams and Charts

    Our carefully designed diagrams and charts will guide you through complex legal issues.

  • Criminal Law

    Clear and Succinct Definitions

    Key concepts are concisely defined to help you understand legal topics quickly.

  • Property Law

    Statutory Provisions

    Statutory provisions are provided side by side with legal concepts to help you swiftly locate the relevant legislation.

  • Public Law

    Case Summaries

    We have summarised important cases for you so that you don't need to read long and boring cases.

  • Evidence

    Rules and Exceptions

    Rules and exceptions are clearly listed so that you know when a rule applies and when it doesn't.

  • Company Law


    Legal terms and key concepts are explained at the beginning of each chapter to help you learn efficiently.

  • Case Law

    Case law is provided side by side with legal concepts so that you know how legal principles and precedents were established.

  • Law Exam Guide

    Law Essay Guide

    You will learn essential law exam skills and essay writing techniques that are not taught in class.

  • Law Exam Guide

    Problem Question Guide

    We will show you how to answer problem questions step by step to achieve first-class results.

  • Conflict of Laws

    Structured Explanations

    Complex legal concepts are broken down into concise and digestible bullet point explanations.

  • Legal System and Method

    Legal Research

    You will learn legal research techniques with our study guide and become a proficient legal researcher.

  • Jurisprudence and Legal Theory


    All essential concepts, principles, and case law are included so that you can answer exam questions quickly.