R v Roberts [1972] 56 Cr App R 95

Facts

  • The defendant offered the victim a ride to a party but instead drove to a deserted area and made unwanted sexual advances.
  • The victim rejected the advances, but the defendant persisted.
  • In an attempt to escape, the victim opened the car door and jumped out while the vehicle was moving, sustaining injuries.
  • The case centered on whether the defendant was legally responsible for the injuries resulting from the victim's actions in response to his conduct.

Issues

  1. Whether the defendant could be held criminally liable for assault occasioning actual bodily harm when harm was caused by the victim's own act in response to the defendant's conduct.
  2. What standard of foreseeability should apply in determining causation: subjective (what the defendant actually foresaw) or objective (what a reasonable person would have foreseen).
  3. Whether the victim's actions were so unforeseeable or extraordinary that they broke the chain of causation.

Decision

  • The Court of Appeal held the defendant liable for assault occasioning actual bodily harm.
  • The court adopted an objective test for foreseeability: the victim’s actions are considered a “natural result” of the defendant’s conduct if they were reasonably foreseeable.
  • The chain of causation would only be broken if the victim's response was so “daft and unexpected” that no reasonable person could have foreseen it.
  • In this case, the victim's act of jumping from the moving car was not extraordinary and was a direct and foreseeable consequence of the defendant's actions.

Legal Principles

  • The test for causation in assault cases is objective foreseeability: whether a reasonable person would have foreseen the victim’s response as a possible result of the defendant’s conduct.
  • Liability is not dependent on the defendant’s actual intent or foresight, but on what was reasonably foreseeable.
  • Defendants remain responsible for foreseeable consequences of their actions, even when those consequences involve a victim’s intervening, reasonable response.
  • The chain of causation is not broken unless the victim’s response is so unforeseeable as to be considered extraordinary or “daft.”
  • Comparison with other cases (such as R v Blaue and R v Williams and Davies) illustrates liability persists unless the victim’s actions fall outside the scope of reasonable responses.

Conclusion

R v Roberts [1972] 56 Cr App R 95 established that a defendant may be held liable for injuries resulting from a victim’s foreseeable reaction to unlawful conduct. The Court of Appeal’s endorsement of an objective foreseeability test ensures that defendants are accountable for the natural consequences of their actions, unless the victim’s response is so unusual as to break the chain of causation. This case remains a leading authority on causation in criminal law.

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