Anderton v Ryan [1985] AC 560 (HL)

Facts

  • Mrs. Ryan purchased a video recorder believing it was stolen property.
  • She later disclosed this to the police.
  • There was no evidence that the video recorder was, in fact, stolen.
  • The prosecution argued that her belief and actions constituted an attempt to handle stolen goods under the Criminal Attempts Act 1981.

Issues

  1. Whether a defendant can be guilty of attempting to commit a crime based solely on a mistaken belief that their act was criminal, when commission of the full offence was factually impossible.
  2. Whether an act, combined with the defendant's belief, can satisfy the requirements for an attempt under the Criminal Attempts Act 1981 if the offence could not actually be completed.

Decision

  • The House of Lords quashed Mrs. Ryan’s conviction.
  • The court held that a genuine belief in the existence of facts making an act illegal does not suffice for attempt liability if the actus reus of the offence is impossible.
  • It was determined that since the goods were not stolen, there could be no attempt to handle stolen goods, regardless of Mrs. Ryan’s belief.
  • The court stressed that an attempt requires acts that go beyond mere preparation and are objectively capable of leading to the commission of a real offence.

Legal Principles

  • The Criminal Attempts Act 1981 requires an objective element in the actus reus of attempt; an act must be one that could amount to commission of the full offence if circumstances were as believed by the defendant.
  • Mistaken belief alone, without the objective possibility of the offence, cannot establish criminal attempt.
  • The decision seeks to prevent prosecution where no substantive harm or real offence has occurred due to factual impossibility.
  • The principles from Anderton v Ryan were later overruled by R v Shipley [1986] AC 490, which held that liability for attempt can arise even when the completed crime is factually impossible, provided the defendant's actions and intentions meet statutory requirements.

Conclusion

Anderton v Ryan initially narrowed the liability for attempts, requiring the offence to be possible in fact, thus protecting defendants acting under mistaken beliefs. This position was later reversed in R v Shipley to allow for attempt liability even where commission of the substantive offence was impossible.

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