LAW

Published on
KembaraXtra-Case Law- Attempts: Geddes (1996) CA
Case Summary
  • Defendant (D): Found in a school lavatory block with a rucksack, despite having no connection to the school.
  • Rucksack Contents: Large kitchen knife, rope, masking tape.
  • Additional Evidence: D's cider can found in a lavatory cubicle.
  • Charge: Attempted false imprisonment.
  • Outcome: Convicted by lower court.
Court of Appeal (CA) Ruling
  • Held: Conviction quashed. D's actions were merely preparatory, not amounting to an attempt.
Key Legal Principles
  • Distinguishing Preparation vs. Attempt: The line is not clear or easy to recognize; no "rule of thumb" test.
  • Case-by-Case Judgment: Each case requires an individual exercise of judgment based on the facts.
Statutory Test (Paraphrased by Lord Bingham LCJ)
  • "To ask whether the available evidence, if accepted, could show that a defendant had done an act which showed that he had actually tried to commit the offence in question, or whether he had only got ready or put himself in a position or equipped himself to do so."
Application to Geddes
  • D's Intention: Little doubt regarding D's intention to commit false imprisonment.
  • Preparatory Acts: D clearly made preparations and equipped himself (knife, rope, tape).
  • Lack of Direct Action: D had not confronted or communicated with any pupil.
  • Conclusion: His actions were "more than merely preparatory." He had not yet "actually tried to commit the offence."

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