R v Parker [1977] 1 WLR 600

Court: Court of Appeal

Facts: D, in a fit of rage after losing his temper, slammed down a public telephone receiver, breaking it. He claimed that he had not foreseen or appreciated the risk of causing damage due to his anger. D was charged with criminal damage.

Held: The Court of Appeal upheld D’s conviction, ruling that D had "deliberately closed his mind" to the risk of causing damage by acting out of anger. The court held that recklessness could be found even if the defendant was too angry to consciously appreciate the risk, as long as the risk was obvious and D had disregarded it.

💡Levelup: This case broadened the scope of recklessness by introducing the concept of "closing one's mind" to obvious risks, expanding the subjective test for recklessness to include situations where the defendant willfully ignores the risks.