LAW

Published on
KembaraXtra-Case Law-Moloney (1985)
I. Case Summary:
  • Facts: Defendant (D) and Victim (V) were engaged in a late-night drinking contest involving loading and firing a shotgun. Following V's taunting, D shot V without aiming.
  • Issue: Was D guilty of murder?
  • Holding: D was not guilty of murder.
II. Key Principle (Lord Bridge):
  • Foresight of consequences relates to evidence of intention, not the substantive law of intention itself (especially in crimes of specific intent, like murder).
III. Jury Direction on Foresight of Consequences:
In the rare instances where foresight needs to be considered, the judge should direct the jury to consider these two questions:
  1. Natural Consequence: Was death or really serious injury (in a murder case) a natural consequence of the defendant's voluntary act?
  2. Foresight of Natural Consequence: Did the defendant foresee that consequence as being a natural consequence of their act?
IV. Inference of Intention:
  • If the jury answers "yes" to both questions above, it is a proper inference (but not a mandatory one) for them to draw that the defendant intended that consequence.
V. Implications for Understanding Intention:
  • This case emphasizes that foresight of consequences is evidence that can lead to an inference of intention.
  • The jury must still determine whether the defendant actually intended the consequence, based on all the evidence. Foresight is not a substitute for intention.




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