R v Grant [2014] EWCA Crim 1433

Court: Court of Appeal

Facts: D, while in pursuit of B, fired multiple gunshots intending to cause grievous bodily harm (GBH) to B. However, in the process, two innocent bystanders, S and T, were struck by the bullets. Neither S nor T were the intended targets of D's attack.

Held: The Court of Appeal upheld D’s convictions for the attempted murder of B and grievous bodily harm to S and T. The doctrine of transferred malice applied because D's intent to cause GBH to B transferred to the unintended victims, S and T.

💡Levelup: This case is a key illustration of the doctrine of transferred malice, demonstrating that a defendant’s intent to harm one person can be transferred to unintended victims who suffer the harm instead.

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R v Mitchell [1983] QB 741

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R v Hudson [1996] EWCA Crim 2937