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KembaraXtra-Case Law-Study Guide: Pratt (1984) CC
​Indecent Assault & Mens Rea

Case: Pratt (1984) CC
Facts:
  • Defendant (D) charged with indecent assault on two 13-year-old boys.
  • Boys were fishing at night.
  • D, wearing a stocking mask, threatened the boys, pretending to have a gun.
  • D forced the boys to almost completely undress, exposing their private parts.
  • Each boy was forced to shine a torch on the other while undressing.
  • D did not physically touch the boys and maintained a distance.
  • D claimed his motive was to search the boys for stolen cannabis.
Issue:
  • Does the act constitute indecent assault if there is no indecent intention, even if the act itself is objectively indecent?
Held:
  • To prove indecent assault, the prosecution must prove:
    • A common law assault.
    • Objective indecency as a question of fact.
    • Mens rea (guilty mind) in respect of the indecency.
  • Crucially: If there is no indecent intention, there cannot be an indecent assault.
Key Principle:
  • Indecent assault requires both an objectively indecent act and a corresponding indecent intention (mens rea). The actus reus (guilty act) alone is not sufficient for a conviction. The prosecution needs to prove the mens rea.
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