R v Matthews and Alleyne [2003]
Court: Court of Appeal
Facts: The defendants (Ds) were involved in the drowning death of a victim after they threw him into a river. They argued that, despite knowing the victim could not swim, they did not intend for him to die. The key legal issue arose from the judge's instructions to the jury regarding the intent necessary for a murder conviction, specifically whether the defendants had the requisite intention given their foresight of the victim’s likely death.
Issue:
Whether the judge misdirected the jury by stating that they must find the defendants guilty of murder if they believed the victim was “virtually certain” to die or suffer serious harm, rather than whether the defendants intended to kill or cause serious harm.
Held: The Court of Appeal dismissed the appeal, acknowledging a misdirection by the judge but ultimately concluding that the conviction was safe. The court clarified that the test established in Woollin and Nedrick serves as a rule of evidence, allowing juries to infer intent based on foresight of death or serious harm but does not require them to find intent in every case where such foresight exists.
Key Judicial Statements: Rix LJ noted that the judge had mistakenly treated the test from Nedrick and Woollin as a substantive rule of law rather than a rule of evidence. He emphasized that the approved direction in those cases allows the jury to infer intention for murder based on an appreciation that death was “virtually certain,” but does not impose a requirement to find intention in all cases where this level of foresight is present.
💡 Leveluplaw: the distinction between evidentiary rules and the substantive elements of a crime. It highlights that the Woollin test should be understood as a guideline for juries to draw permissible inferences regarding intent based on foresight of consequences, rather than a mandatory requirement that obligates them to find intent whenever such foresight is established. This clarification is essential for ensuring that juries properly assess the mental state required for murder convictions without conflating evidentiary considerations with substantive legal standards.