R v Martin (1881) 8 QBD 54

Key point

  • This case shows that there does not need be direct application of force on the victim to constitute battery


  • D placed an iron bar in front of an escape route and put out the lights in a crowded theatre
  • This caused a panic and the audience charged out, some of them becoming injured in the process
  • D was convicted of inflicting grievous bodily harm under section 20 of the Offences Against the Person Act 1861, but appealed against his conviction

Held (Court for Crown Cases Reserved)

  • Appeal dismissed; D was rightly convicted of inflicting grievous bodily harm

Lord Coleridge CJ

  • “The prisoner must be taken to have intended the natural consequences of that which he did. He acted ‘unlawfully and maliciously’, not that he had any personal malice against the particular individuals injured, but in the sense of doing an unlawful act calculated to injure . .”


  • The Court for Crown Cases Reserved was superseded by the Court of Criminal Appeal, which was in turn substituted by the Court of Appeal