Director of Public Prosecutions v Crawford (Approved) [2024] IESC 44 (14 October 2024)

Section 18 of the Non-Fatal Offences against the Person Act 1997 applies to all offences, both fatal and non-fatal, and abolishes the common law rules of self-defence in such cases. The statutory language is clear and unambiguous, and the Oireachtas intended to create a unified statutory defence of self-defence, regardless of the offence's fatality.

Citation: [2024] IESC 44
Parties: Prosecutor/respondent: The People (Director of Public Prosecutions); Defendant/appellant: Mark Crawford
Jurisdiction: Ireland
Judgment Date: 14 October 2024
Procedural Posture: Criminal Appeal / Supreme Court Judgment
Outcome: appeal dismissed
Legal Topics: Self Defence, Statutory Interpretation, Abolition of Common Law Defences, Homicide, Non Fatal Offences Against the Person Act 1997

Criminal Law Self Defence Statutory Interpretation Abolition of Common Law Defences Homicide Non Fatal Offences Against the Person Act 1997

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Parties

The People (Director of Public Prosecutions)

Prosecutor/respondent

Mark Crawford

Defendant/appellant

Procedural Posture

Criminal Appeal / Supreme Court Judgment

Legal Issues

1 Does section 18 of the Non-Fatal Offences against the Person Act 1997 replace the common law rules of self-defence in homicide cases?
2 Does section 18 apply to both fatal and non-fatal offences?

Ratio Decidendi

Court Disposition

appeal dismissed