## Facts

- Robert Stefan Majewski voluntarily consumed substantial quantities of alcohol and drugs, including amphetamines and barbiturates.
- While intoxicated in a public house, he assaulted the landlord and several customers.
- After arrest, he assaulted the officer transporting him and a police inspector at the station.
- He was charged with four counts of assault occasioning actual bodily harm and three counts of assaulting a constable in the execution of duty.
- At trial, he argued his extreme self-induced intoxication left him unaware of his actions (analogized to automatism) and therefore without mens rea.
- The trial judge instructed that voluntary intoxication was not a defense to the charged offenses, and Majewski was convicted.
- Majewski appealed on the ground that intoxication should negate the mental element of the assaults.

## Issues

1. Whether voluntary intoxication, even when extreme, can negate mens rea for offenses categorized as crimes of “basic intent,” including assault occasioning actual bodily harm and assault on a constable.
2. Whether a defendant’s self-induced intoxication can be treated as the requisite culpability for basic-intent offenses.

## Decision

- The House of Lords dismissed the appeal and affirmed the convictions.
- Voluntary intoxication is not a defense to crimes of basic intent.
- For basic-intent crimes, the defendant’s culpability is satisfied by the recklessness inherent in voluntarily becoming intoxicated.
- Evidence of intoxication may be relevant only where the charged offense requires specific intent and intoxication prevents formation of that specific intent.

## Legal Principles

- Offenses of “basic intent” are satisfied by general intent or recklessness; they do not require proof of an ulterior purpose beyond the actus reus.
- Voluntary (self-induced) intoxication does not excuse or negate mens rea for basic-intent offenses; the law imputes recklessness from the defendant’s choice to consume intoxicants.
- The specific-intent/basic-intent distinction governs the relevance of intoxication evidence: intoxication may prevent proof of specific intent, potentially reducing liability to a lesser basic-intent offense.
- Extreme intoxication approaching automatism does not exempt a defendant from liability for basic-intent crimes when the intoxication is self-induced.

## Conclusion

The House of Lords held that self-induced intoxication cannot be used to avoid liability for basic-intent crimes such as common assault-related offenses; the decision to become intoxicated is treated as reckless and supplies the culpability needed for conviction, while intoxication evidence remains potentially relevant only to negate a required specific intent.


Director of Pub. Prosecutions v. Majewski, [1976] 2 All E.R. 142 (H.L.)