KembaraXtra-Case Law-Treacy v DPP (1971) HL

I. Case Summary
Issue: Jurisdiction for the crime of blackmail when the act occurred in England, but the result (receipt of the demand) occurred abroad (Germany).

II. Facts
Defendant (D): In England, posted a letter to Victim (V).
Letter Content: Contained an unwarranted demand.
Victim (V): Received the letter in Germany.
D's Argument: Cannot be tried for blackmail in England because the demand was "made" in Germany (where V received it).

III. Held (House of Lords Ruling)
Offence of Blackmail: Was committed.
Result Crime: Blackmail is a result crime (requires D's actions to cause prohibited consequences).
Sufficient Jurisdiction: Jurisdiction exists in England if either the acts are done or the consequences take effect in England.

Application to this Case:
D's Acts: D performed the act (posting the blackmail letter) in England.
Consequences: The consequence (V receiving the demand) took effect in Germany.
Therefore: English courts did have jurisdiction because the act was committed in England.
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IV. Key Principles
Jurisdiction for Result Crimes: Jurisdiction exists where the act occurs or the result of the crime occurs.
Blackmail as a Result Crime: Emphasizes the importance of the impact of the action (e.g. the letter being received) in defining the crime.