R v Quick & Anor [1973] EWCA Crim 1 (18 April 1973)
The malfunctioning of Quick's mind was caused by an external factor (insulin), not by a disease of the mind, so the defence of automatism should have been left to the jury. The judge's ruling was wrong, making the convictions unsafe.
- Citation
- [1973] EWCA Crim 1
- Parties
- Appellant: Quick; Appellant: Paddison; Respondent: The Crown
- Jurisdiction
- England and Wales
- Judgment Date
- 18 April 1973
- Procedural Posture
- Criminal Appeal / Appeal Against Conviction
- Outcome
- Convictions quashed
- Legal Topics
- Automatism, Insanity Defence, Disease of the Mind, Aiding and Abetting, Hypoglycaemia, M'naughten Rules
Case Brief
Summary, issues, holding and outcome
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Parties
Quick
Appellant
Paddison
Appellant
The Crown
Respondent
Procedural Posture
Criminal Appeal / Appeal Against Conviction
Legal Issues
- 1 Whether hypoglycaemia-induced automatism constitutes 'disease of the mind' under the M'Naughten Rules
- 2 Whether automatism or insanity is the appropriate defence for acts committed under hypoglycaemia
- 3 Whether a person can be convicted of aiding and abetting when the principal is acquitted on grounds of automatism
Ratio Decidendi
The malfunctioning of Quick's mind was caused by an external factor (insulin), not by a disease of the mind, so the defence of automatism should have been left to the jury. The judge's ruling was wrong, making the convictions unsafe.
Court Disposition
Convictions quashed
Orders
- Conviction of Quick quashed as unsatisfactory; defence of automatism should have been left to the jury.
- Conviction of Paddison quashed as unsatisfactory due to the acquittal of Quick.
Full Case Text
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