Criminal Law: Offences Against the Person I (Non-fatal, non-sexual offences against the person)

Criminal Law: Offences Against the Person I

Learning Outcomes and Recommended Reading

  • Goals for Lecture: By the end of this lecture, students should be able to:

    • Identify the meaning of "non-fatal, non-sexual offences against the person".

    • Understand the relationship between these offences and other categories of crimes.

    • Explain the requirements of specific offences:

    • Assault (including aggravations)

    • Reckless injury

    • Reckless endangerment

    • Threats

    • Extortion

    • Outline the operation of specific defences related to assault.

  • Recommended Reading:

    • T H Jones and I Taggart, Criminal Law (7th edn, 2018), Chapter 9 (pages 193-211, 217-227, and 265-268).

Non-fatal, Non-sexual Offences Against the Person

  • Definition of Offences Against the Person:

    • An offence causing harm or risk of harm to an individual.

    • Not limited to physical harm; includes:

    • Assault

    • Reckless injury

    • Threats

    • Extortion

  • Characteristics:

    • Non-fatal: Excludes homicide offences (murder, culpable homicide).

    • Non-sexual: Excludes sexual offences (rape, sexual assault, non-consensual distribution of intimate images, voyeurism, sexual exposure).

Recap of Offences

  • Basic Principles:

    • All offences must establish actus reus and mens rea for criminal liability.

    • Actus reus: The conduct element; voluntary action by the accused.

    • Causation Requirement: For result crimes, proof of causation is necessary (the conduct must have caused a particular result).

    • Mens rea: The mental element; the required mental state (intention, recklessness, negligence, or no fault).

    • Variability of mens rea: Changes according to the offence type.

Assault

  • Definition of Assault:

    • Primary non-fatal, non-sexual offence against the person.

    • Defined as a broad offence but can differ based on aggravations.

    • Classified as a conduct crime.

Actus Reus of Assault
  • Understanding:

    • Defined as an attack on a person, which may be:

    • Direct: Physical assault.

    • Indirect: Involving third parties or objects.

    • Threatening conduct: Causes fear without physical contact.

    • No requirement to produce injury.

    • Key cases illustrating this concept include:

    • Direct Attacks:

      • Aitken v Wood, 1921 JC 84

      • Dewar v HM Advocate, [2021] HCJAC 28

    • Indirect Attacks:

      • Kay v Allan, 1978 S.C.C.R. Supp. 188

      • Quinn v Lees, 1994 SCCR 159

    • Fear-Inducing Attacks:

      • Atkinson v HM Advocate, 1987 SCCR 534

      • Gilmour v McGlennan, 1993 S.C.C.R. 837

Mens Rea of Assault
  • Intent: Assault is a crime of intention, requiring "evil intent".

    • Cannot be committed unintentionally or recklessly.

    • Doctrine of Transferred Intent:

    • Confirmed in Roberts v Hamilton, 1989 SLT 399.

    • Key quotes define mens rea:

    • Hume: Intent to hurt or wound.

    • HMA v Phipps, 1905: Evil intention or intent to bodily injury.

    • Lord Advocate’s Reference (No 2 of 1992): Motive is irrelevant to mens rea.

Aggravated Assaults
  • Nature of Aggravation:

    • Refers to the labelling of the offence impacting sentencing.

    • Principle of fair labelling: Offence names must capture the offence's conduct.

    • Factors affecting seriousness include:

    • Conduct of the accused

    • Result of the accused’s conduct

    • Intention of the accused

Common Law Examples of Aggravated Assaults
  • Intention-based Aggravation: E.g., intent to ravish (James Gibb, 1836).

  • Perpetration Mode: E.g., use of a weapon (Campbell v HMA, 1986).

  • Result-based Aggravation: E.g., assault causing severe injury (Kirkwood v HMA, 1939).

  • Causation: Must be proven when an aggravation requires a specific result.

Statutory Aggravations
  • Safety-related crimes that include prejudicial motives, such as:

    • Racism (Crime and Disorder Act 1998)

    • Religious prejudice (Criminal Justice (Scotland) Act 2003)

    • Disability-related offences (Offences (Aggravation by Prejudice) Act 2009)

    • Sexual orientation and gender identity (Offences (Aggravation by Prejudice) Act 2009)

    • Domestic abuse-related assaults (Abusive Behaviour and Sexual Harm (Scotland) Act 2016)

    • Serious organised crime connections (Criminal Justice and Licensing (Scotland) Act 2010)

Defences to Assault

  • Relevance of Defences:

    • Even when actus reus and mens rea are established, defences may apply, barring criminal liability.

  • General Defences:

    • Self-defence

    • Mental disorder

    • Automatism

  • Specific Defences to Assault:

    • Consent: Considered within the context of sports; exceptions noted from Lord Advocate’s Reference (No.2 of 1992) and Smart v HMA, 1975.

    • Medical Examination: Related case Hussain v Houston, 1995.

    • Lawful Force: Referenced in cases like Codona v Cardle, 1989 and Wightman v Lees, 2000.

    • Self-defence and Provocation: Discussed in more detail in subsequent modules.

  • Abolishment of Certain Defences:

    • Reasonable chastisement of children abolished by Children (Equal Protection from Assault) (Scotland) Act 2019.

Non-intentional Offences

Recklessly Causing Injury
  • Definition: Unintentional but reckless action causing injury.

  • Leading Case: HMA v Harris, 1993 SLT 963.

    • Established two common law offences: recklessly causing injury and causing danger to others.

  • Significance: Performance of reckless conduct that leads to injury is a crime; this differs from mere recklessness that does not result in harm.

Reckless Endangerment
  • Understanding Reckless Endangerment:

    • Confirmed in HMA v Harris, entailing conduct that endangers without showing injury.

    • Historic Authority: Refers to conduct dangerous to individuals or the public.

  • Case Examples:

    • Throwing/dropping objects from heights (W v HMA, 1982 SLT 420).

    • Reckless conduct such as burning (MacPhail v Clark, 1982).

    • Organizing unsafe events (Normand v Robinson, 1994).

Mens Rea Requirement
  • Disregard for Consequences: Required to establish mens rea.

  • Refer to cosmic examples such as Cameron v Maguire, 1999.

Examples of Reckless Endangerment
  • Needles/Sharps Cases: E.g., Kimmins v Normand, Donaldson v Normand.

  • Supply of Drugs Cases: E.g., Khaliq v HM Advocate, Ulhaq v HM Advocate.

  • Contemporary Example: HM Advocate v Lindsay, 2020, involving reckless behaviour during a pandemic.

Threats and Extortion

Threats
  • Nature of Threats:

    • Require no physical attack, but can still be criminal.

    • Historical case: James Miller defined threats' basis.

  • Types of Threats:

    • Verbal or written, with specific classifications like death threats.

    • Criminally actionable without intent to follow through.

  • Statutory Considerations:

    • Statutory provisions for causing fear and alarm under s.38 of the Criminal Justice and Licensing (Scotland) Act 2010.

Extortion
  • Definition of Extortion:

    • Characterized by a demand backed by a threat.

    • Historic context: James Miller defined extortion.

  • Paradoxical Nature:

    • Both demand and threat can be legal, but their combination constitutes a crime.

Characteristics of Threats and Demands in Extortion Under Scots Law
  • Types of Threat:

    • Inflicting physical injury (Fielding v HM Advocate, 1959).

    • Disclosing personal information (Hopes and Lavery v HM Advocate, 1960).

    • Car clamping as a unique case (Black v Carmichael, 1992).

  • Demands:

    • Typically financial but not limited to monetary demands (Rae v Donnelly, 1982).

    • Lawful demands in lawful procedures are not extortionate (Carmichael v Black, Silverstein v HM Advocate).

Other Non-fatal, Non-sexual Offences Against the Person

  • Additional Offences Covered:

    • Not exhaustive; further offences include:

    • Assaulting or impeding police officers (Police and Fire Reform (Scotland) Act 2012).

    • Assaulting emergency service workers (Emergency Workers (Scotland) Act 2005).

    • Assaulting retail workers (Protection of Workers (Retail and Age-restricted Goods and Services) (Scotland) Act 2021).

    • Stalking and domestic abuse offences, which will be examined in later modules.

    • Robbery, deemed theft by force, will be discussed in conjunction with theft.

Summary and Closing Remarks

  • Next Week (Week 6): Seminars on prior content and upcoming lectures on homicide offences.

  • Assignment Due: February 24 for BA students; inquiries can be made via email to Robbie.Reid@stir.ac.uk.