## Facts

- The defendants, including Thabo Meli, devised a plan to kill a victim by first intoxicating him and then assaulting him with intent to cause his death.
- Believing the victim was dead after the initial assault, the defendants rolled his apparently lifeless body down a hill to stage an accident.
- Medical evidence revealed the victim died not from the initial injuries but from exposure after being left unconscious on the hillside.
- The defendants appealed their convictions, arguing that their intent to kill (mens rea) only existed during the initial assault, not at the time when the act causing death occurred.

## Issues

1. Whether criminal liability for murder requires the mens rea and actus reus to coincide at the exact moment the fatal act occurs.
2. Whether a series of actions forming one transaction allows the presence of mens rea at any point in those actions to satisfy the coincidence doctrine for criminal liability.

## Decision

- The Privy Council upheld the murder convictions, rejecting the defence based on a lack of mens rea at the moment of the fatal act.
- The court held that the defendants' actions constituted a single transaction, not separable events, and should be viewed holistically.
- It was determined that the coincidence rule was satisfied because the series of acts was part of a pre-planned scheme and the mens rea existed during that continuing transaction.

## Legal Principles

- The coincidence of actus reus and mens rea can be satisfied where a sequence of pre-planned actions forms a single transaction, even if the mens rea does not exist at every stage.
- Liability is not avoided by temporal argument or by dissecting a continuous transaction when an overarching criminal plan is evident.
- The case distinguishes the single transaction principle from transferred malice, emphasizing that Thabo Meli addresses temporal coincidence rather than misdirection of intent.

## Conclusion

The decision in R v Thabo Meli [1954] 1 WLR 228 clarified that if a sequence of acts forms a single transaction towards a criminal objective, the requirement for coincidence of actus reus and mens rea is met as long as the mental state is present at some point during the overall transaction. This principle prevents avoidance of liability by dividing interconnected acts and remains influential in criminal law.
