R v Steane [1947] KB 997

Court: Court of Appeal

Facts: During World War II, the defendant (D) was a British national who was coerced by the Nazis into making propaganda broadcasts. He feared for the safety of his family and believed that non-compliance would lead to their harm. D was charged with assisting the enemy under the Treachery Act 1940.

Held: The Court of Appeal quashed D’s conviction. The court ruled that while D had made the broadcasts, his actions were not accompanied by the necessary mens rea to assist the enemy, as his intention was influenced by duress rather than a desire to aid the enemy.

💡Levelup: This case is significant for the role it played in recognizing duress as a potential defense to negate mens rea, particularly when the defendant’s actions are taken under extreme pressure or threats of violence.