R v Geddes [1996] 2 Cr App R 377

Court: Court of Appeal (Criminal Division)

Facts: D was found in a school toilet cubicle with items suggesting he intended to commit a crime but had not yet acted. D was convicted of attempted false imprisonment.

Held: Conviction quashed. The court found that being in a position to commit the crime was insufficient for an attempt. No jury could properly have concluded that D’s acts had gone beyond the stage of mere preparation.

Key Judicial Statement: Lord Justice Stuart-Smith stated, "Merely being present with intent is not enough for an attempt; the defendant’s actions must move beyond mere preparation."