Westminster City Council v Croyalgrange Ltd [1986] 1 WLR 674

House of Lords

Facts: The defendant company (D) operated a property without obtaining the required licences from the council, despite having strong reasons to suspect that these licences were necessary. The company argued that they had not obtained the licences because they were unaware of the legal requirements.

Held: The House of Lords held that wilful blindness—where a person deliberately shuts their eyes to something they suspect is true—amounts to knowledge for the purposes of mens rea. In this case, D’s deliberate failure to inquire about the licensing requirements was treated as equivalent to actual knowledge of the illegality.

💡Levelup: This case is a leading authority on the doctrine of wilful blindness in criminal law. It establishes that deliberately avoiding knowledge of a fact is equivalent to actual knowledge, thus satisfying the mens rea requirement for certain offences.