R v MS [2021] EWCA Crim 288

Court: Court of Appeal (Criminal Division)

Facts: D, wanting to move abroad with her child, forged consent documents and prepared for the move despite a court ruling against it.

Held: Conviction upheld. Geographical proximity did not have the same relevance for attempted child abduction as it might have for other crimes and here the evidence was clearly of the taking of steps which were more than merely preparatory to the commission of the offence. The court found that the actions were sufficiently close to the intended abduction to constitute an attempt.

Key Judicial Statement: Lord Justice Holroyde stated, "The proximity of D's actions to the completed crime, including preparations and false documents, suffices for an attempt."