R v Roberts (Kenneth Joseph)
Court of Appeal
Citations:  EWCA Crim 4; (1972) 56 Cr App R 95.
The complainant was a passenger in the defendant’s car. The defendant began threatening her. In a state of fear, she jumped out of the moving vehicle and injured herself. The defendant was charged with assault occasioning actual bodily harm and convicted. On appeal, he argued that he was not guilty as he had not foreseen that the complainant would jump from the car. It could not be said, therefore, that he caused the woman’s injuries.
- Was it relevant that the defendant had not foreseen that the complainant would jump from the car?
The Court of Appeal upheld the conviction. It was not relevant that the defendant did not foresee the victim’s behaviour. The prosecution only needed to prove that the victim’s behaviour was a reasonably foreseeable result of the defendant’s actions.
This Case is Authority For…
The actions of the victim will not break the chain of causation if they were a reasonably foreseeable result of the defendant’s actions.
Stephenson LJ commented that a victim’s act is unlikely to break causation unless they are so ‘daft’ or so ‘unexpected’ that no reasonable person would foresee it.