R v Parker [1977] 1 WLR 600

Key point

  • Deliberate closing of one’s mind to an obvious risk amounts to recklessness


  • D smashed down a telephone handset onto the dialing box of a public telephone, damaging it
  • D was charged under s1(1) Criminal Damage Act
  • D said that he did not occur to him that he might damage the phone as he smashed it in a fit of anger

Held (Court of Appeal)

  • D was guilty as he had the requisite mens rea of recklessness

Geoffrey Lane LJ

  • D was, ‘in effect, deliberately closing his mind to the obvious – the obvious being that damage in these circumstances was inevitable’
  • ‘In the view of this court, that type of action, that type of deliberate closing of the mind, is the equivalent of knowledge and a man certainly cannot escape the consequences of his action in this particular set of circumstances by saying, “I never directed my mind to the obvious consequences because I was in a self-induced state of temper.”’: p. 604B