R v Richardson [1999] Q.B. 444, [1999] Crim. L.R. 62

Key Point

  • Fraud as to matters that are not sufficiently integral to one’s identity, such as one’s qualifications, do not vitiate consent to acts resulting in actual bodily harm

Facts

  • D, a dentist, had been disqualified but continued to treat patients without informing them of her suspension
  • D was convicted with assault occasioning actual bodily harm although her patients had consented to the treatment

Held (Court of Appeal)

  • Appeal allowed – conviction quashed
  • D’s fraud did not vitiate consent

Otton LJ

  • Fraud can only vitiate consent to actual bodily harm in circumstances where V was deceived either as to the nature of the act performed or the identity of the performer
  • The identity of the person did not extend to knowledge of D’s qualifications or attributes
  • Lesser forms of fraud may suffice for civil claims such, D’s conduct was reprehensible and gives rise to a civil claim

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