R v Martin – Case Summary

R v Martin

Crown Court

Citations: (1881) 8 QBD 54.


The defendant went to a theatre, put out all the lights on the stairs and blocked the door with an iron bar, intending to cause a panic when people left. The audience did in fact panic, and several were severely injured in the ensuing stampede.

A jury convicted the defendant of inflicting grievous bodily harm under s.20 of the Offences Against the Person Act 1861. He appealed his conviction.

  1. Had the defendant been properly convicted?

The Crown Court upheld the conviction.

This Case is Authority For…

A person can inflict injury on another without doing so directly, such as by doing an act which they know or foresee will cause the victim to be injured by other means (such as a trap or stampede).