Williams, R. v [1983] EWCA Crim 4 (28 November 1983)

Williams, R. v [1983] EWCA Crim 4 (28 November 1983)

A genuine mistake of fact, even if unreasonable, can provide a defence to assault if the defendant honestly believed in the circumstances as he perceived them; the trial judge's direction requiring the belief to be reasonable was a material misdirection, necessitating the quashing of the conviction.

Citation
[1983] EWCA Crim 4
Parties
Appellant: Gladstone Williams; Respondent: Crown
Jurisdiction
England and Wales
Judgment Date
28 November 1983
Procedural Posture
Criminal Appeal / Appeal Against Conviction
Outcome
appeal allowed; conviction quashed
Legal Topics
Assault, Mistake of Fact, Self Defence, Prevention of Crime, Burden of Proof
Criminal Law Assault Mistake of Fact Self Defence Prevention of Crime Burden of Proof

Case Brief

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Parties

Gladstone Williams

Appellant

Crown

Respondent

Procedural Posture

Criminal Appeal / Appeal Against Conviction

Legal Issues

  1. 1 Whether a defendant's honest but unreasonable mistake of fact can provide a defence to assault
  2. 2 Whether the trial judge misdirected the jury regarding the burden of proof and the relevance of the reasonableness of the defendant's belief

Ratio Decidendi

A genuine mistake of fact, even if unreasonable, can provide a defence to assault if the defendant honestly believed in the circumstances as he perceived them; the trial judge's direction requiring the belief to be reasonable was a material misdirection, necessitating the quashing of the conviction.

Court Disposition

appeal allowed; conviction quashed

Orders

  • All consequential financial provisions to disappear
  • Order for costs to cover this Court and the Court below