R v Woollin [1999] 1 AC 82

Court: House of Lords

Facts: The defendant (D) lost his temper and threw his 3-month-old son against a hard surface, causing the child's death. D was charged with murder, but he claimed that he had no intention to kill or cause serious harm to the child. The question before the court was whether D’s actions amounted to indirect intention for murder.

Held: The House of Lords quashed D’s murder conviction and substituted it with manslaughter. The court held that the jury could infer intention if they were satisfied that the result of death or serious harm was a "virtual certainty" from D’s actions and that D foresaw this as a virtual certainty. The jury is allowed to infer intent, but it is not mandatory to do so.

💡Levelup: This case is significant as it refined the "virtual certainty" test introduced in Nedrick and set the modern standard for determining indirect intention in murder cases. The court's direction clarified how foresight of consequences interacts with the legal concept of intent.