R v Matthews and Alleyne [2003]

1. Facts:

• Matthews and Alleyne, two boys, threw another teenager off a bridge into a river.

• The teenager, who could not swim, drowned as a result.

• The defendants claimed they did not intend to kill or seriously injure the teenager.

2. Outcome:

• The defendants were charged with murder.

• The jury was instructed that if it was "virtually certain" that their actions would result in death, they could infer intention, following the Woollin test.

• The Court of Appeal affirmed the application of the Woollin test, emphasising that intention could be inferred from the foreseeability of death as a virtually certain consequence of their actions.

3. Impact and Analysis:

• Affirmation of Woollin Test: The case confirmed and applied the Woollin test, which allows a jury to infer intent if the result of the defendant's actions was a virtual certainty and the defendant was aware of that certainty.

• Rix LJ’s Comment: Rix LJ noted that the law had not yet reached a precise definition of intent to murder, indicating ongoing legal development in understanding and defining criminal intent.

• Application to Murder Convictions: The judgment reinforced that the approach to finding intention was specifically tailored to murder cases and left open the question of whether this reasoning would extend to other types of criminal convictions.

• Legal Clarity: The case emphasised the need for clarity in applying the test for intention in murder cases and continued the dialogue on how to appropriately define and interpret intent within criminal law.