R v Larsonneur (1933) 24 Cr App Rep 74

Key point

  • This case shows the harshness of a ‘state of affairs’ offence, where there is no requirement of voluntary action by the defendant


  • Larsonneur was deported from the UK and went to Ireland
  • She was deported from Ireland and forced to return to UK
  • She was then arrested and charged with breaching the Aliens Order 1920 for “being an alien to whom leave to land in the United Kingdom has been refused was found in the United Kingdom,”

Held (Court of Criminal Appeals)

  • Larsonneur was guilty despite being brought to the UK by force

Lord Hewart CJ

  • How Larsonneur got into the UK “makes no difference at all”


  • Here “found” has been interpreted to cover a situation which has been brought about without any voluntary conduct on the part of the defendant
  • Voluntariness refers to the presence of free will in the act
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