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Why R v Vickers is important

In R v Vickers, the Court confirmed that an intention to cause grievous bodily harm is sufficient as the mens rea for murder.


Vickers broke into a premises in order to steal money. During the break-in, Vickers came across the victim who resided in the flat above the shop. The defendant attacked the victim, who subsequently died from her injuries.

Conviction at Issue

Vickers was convicted of murder on the basis that he intended to cause grievous bodily harm. He appealed this conviction, arguing that an intent to cause grievous bodily harm was not sufficient to satisfy the mens rea of murder.

Issue facing the Court

Whether an intent to cause grievous bodily harm is sufficient to form the mens rea for murder.


The Court of Criminal Appeal rejected the defendant’s appeal and upheld his conviction for murder.

The court stated that an intent to cause grievous bodily harm was sufficient as the mens rea for murder. This is because the infliction of the grievous bodily harm was the direct cause of death.

Lord Goddard CJ:

“[For] the prisoner inflicted grievous bodily harn by a voluntary act and intended to harm the victim and the victim has died as a result of that grievous bodily harm. If a person does an act on another which amounts to the infliction of grievous bodily harm, he cannot say: ‘I did not intend to go further than so-and-so.’ … If he intends to inflict grievous bodily harm and the injured person dies, that has always been held in English law, and was so held at the time when this act was passed, sufficient to supply the malice aforethought.”

The Court of Appeal approved this direction to the jury by the judge for future use:

“Malice will be implied, if the victim was killed by a voluntary act of the accused . . . – done with the intention either to kill or to do some grievous bodily harm. The grievous bodily harm need not be permanent, but it must be serious, and it is serious or grievous if it is such as seriously and grievously to interfere with the health and comfort of the victim…”

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