R v Dr Bodkins Adams – Case Summary

R v Dr Bodkins Adams

Crown Court

Citations: [1957] Crim LR 365.


The defendant was a doctor caring for terminally ill and elderly patients. He administered life-shortening doses of pain-relief medication to them, and the patients died. The defendant was charged with murder.

  1. Had the defendant committed murder?

The jury found the defendant not guilty of murder.

This Case is Authority For…

When directing the jury, Devlin J reaffirmed the principle that shortening a person’s life can constitute murder. However, he also stated that ‘a doctor is entitled to do all that is proper and necessary to relieve pain and suffering even if such measures may incidentally shorten life.’


The principle that led the jury to acquit in this case became known as the doctrine of double-effect. It is an exception to the rule that oblique intent suffices for homicide offences. The doctrine makes it lawful for a medical professional to shorten a person’s life with pain-relief medication, for the purposes of alleviating pain.