## Facts

- Geddes was discovered in the boys' toilets of a school, carrying a knife, rope, and masking tape.
- He had no lawful reason to be on the premises.
- The prosecution argued these items and his presence demonstrated evidence of an attempted false imprisonment.
- It was contended that Geddes had moved beyond mere preparation, placing himself in a situation to execute the offence promptly.

## Issues

1. Whether Geddes's actions constituted merely preparatory steps or acts sufficiently proximate to form the actus reus of attempted false imprisonment.
2. Where the legal line lies between preparation and direct acts for the purposes of attempt liability.

## Decision

- The Court of Appeal overturned Geddes’s conviction for attempted false imprisonment.
- The court determined that although Geddes intended to commit the offence, his actions remained at the stage of preparation.
- It was found that Geddes had not taken steps directly and immediately connected to the commission of the offence charged.
- Possession of implements and presence at the scene did not meet the required threshold for attempt.

## Legal Principles

- The actus reus of attempt requires acts that go beyond mere preparation and constitute a direct movement towards the commission of the offence.
- The “last act” test is not absolute; the focus is on whether the defendant’s conduct demonstrates a clear advance towards carrying out the crime, not simply intent or preparatory behavior.
- Planning with intent alone is insufficient—direct and proximate action linked to the offence is essential for attempt liability.
- _R v Geddes_ serves as a principal authority on distinguishing preparatory acts from acts amounting to an attempt, as reaffirmed in later cases.

## Conclusion

The decision in R v Geddes established that intent and preparatory steps do not amount to an attempt; a clear move from preparation to direct action is required before criminal attempt liability will arise under English law.


R v Geddes [1996] 160 JP 697