Kembaraxtra-Case Law- Case Brief: Anderton v Ryan (1985) HL

Case Details

• Case Name: Anderton v Ryan
• Year: 1985
• Court: House of Lords

Facts of the Case

• Defendant (D): Charged with attempting to handle stolen property (a video recorder).
• D's Belief: D believed the video recorder was stolen at the time of purchase.
• Actual Status of Property: No evidence could be found that the video recorder was, in fact, stolen. It was presumed not stolen.

Legal Issue

• Interpretation of Section 1 of the Criminal Attempts Act 1981 regarding attempts where the substantive crime is objectively impossible but subjectively believed possible by the defendant.

Holding

• The House of Lords quashed D's conviction.

Reasoning

• Statute in Question: Criminal Attempts Act 1981, Section 1 (overruled common law of attempt).
• Court's Interpretation: If Section 1 created an offense for attempting an objectively impossible crime merely because D subjectively thought it possible, the results would be "asinine."
• Parliamentary Intent: Parliament could not have intended such an outcome.
• Sections 1(2) and 1(3) Interpretation: These subsections must be interpreted to prevent conviction of a defendant who mistakenly believes the substantive offense is possible when it is objectively impossible.

Key Takeaway

• Objective Impossibility: A person cannot be convicted of an attempt if the substantive crime is objectively impossible to commit, even if the defendant subjectively believes it is possible. The Act does not criminalize acts based solely on subjective belief if the actual circumstances preclude the commission of the crime.