R v Roberts [1972] 56 Cr. App. R. 95, [1972] Crim LR 27

Key point

  • A defendant is liable for reasonably foreseeable consequences of his actions


  • A young woman accepted a lift from D to a party
  • D drove to a deserted location and made sexual advances but was rejected
  • Later, when D was driving he continue to make sexual advances
  • Woman jumped out of car and sustained injury

Held (Court of Appeal)

  • D was guilty of assault occasioning actual bodily harm for causing the woman’s injury

Stephenson LJ

  • ‘The test is: Was it the natural result of what the alleged assailant said and did, in the sense that it was something that could reasonably have been foreseen as the consequence of what he was saying or doing?’
  • There is a break of chain of causation only if victim’s actions were so daft and unexpected that no reasonable man could have expected
  • In this case D is guilty as the woman jumped out as a direct consequence of D’s actions


  • The issue had been whether the test of causation should be based on subjective foreseeability, as proposed by counsel for D, or objective foreseeability as had been held by the trial judge
  • The Court of Appeal clarified that the test is objective
Scroll to top