R v Quick [1973]

1. Facts:

• D, a diabetic, entered a hypoglycaemic episode (low blood sugar) due to insulin injection.

• Suffered a fit induced by diabetes and attacked V.

2. Outcome:

• Conviction was quashed.

• The court held that the hypoglycaemia was caused by the external administration of insulin, not by the diabetes itself.

3. Impact and Analysis:

• External Cause: Established that hypoglycaemia due to insulin is considered an external factor, allowing automatism as a defence.

• Subjective Test: Emphasised the subjective nature of assessing the cause of the condition.

• Insanity Defence: Lawton LJ noted that insanity defences are typically used by those in "desperate need of some kind of defence," highlighting the strict criteria and challenges associated with it.