R v Parker – Case Summary

R v Parker

Court of Appeal

Citations: [1993] Crim LR 856.


The defendant lodged in a council house. The victims were a couple who lived next door. One night, the defendant used a cigarette to set fire to a sofa in the council house. He intended to help his landlady persuade the council to rehouse her.

The fire caused smoke to fill the victims’ property through a vent in the party wall. The defendant had given no thought as to whether his actions put the victims in danger and so took no precautions against it. However, the victims were not home at the time, and so were not in any danger.

The defendant was charged with arson intending or being reckless to the endangerment of life under s.1(2) of the Criminal Damage Act 1971. He argued that he was not guilty because his actions did not in fact put anyone in danger.

  1. Does the s.1(2) offence require someone to actually be put in danger?

The Court of Appeal upheld the defendant’s conviction. There was no need to prove that life was endangered to establish the offence.

This Case is Authority For…

The offence under s.1(2) of the Criminal Damage Act 1971 does not require anyone’s life to actually be endangered. It is enough that the defendant’s actions create a risk that someone might be endangered.