R v Pearman [1985] 1 WLR 1260

Court: Court of Appeal (Criminal Division)

Facts: D drove erratically and swerved towards police officers during a traffic stop, knocking one officer into a car.

Issue : Is recklessness sufficient to establish an attempt to commit an offence?

Held: Conviction quashed. The court found that recklessness was insufficient; actual intent was required for an attempt to cause grievous bodily harm.

Key Judicial Statement: Lord Justice Dillon noted, "Recklessness does not suffice for an attempt; intention, either direct or oblique, is necessary."

💡Leveluplaw : For an attempt, the prosecution must prove that the defendant intended (either in the purposive or oblique sense) to commit the primary offence.