R v Roberts [1971]

1. Facts:

• The defendant (D), while driving, made suggestive remarks to his passenger and attempted to remove her coat.

• The passenger (V), feeling threatened, jumped out of the moving car and sustained injuries.

2. Outcome:

• The Court of Appeal (CoA) held that the driver (D) was liable for assault occasioning actual bodily harm (ABH).

• The court determined that D's actions were a foreseeable cause of V’s reaction, and the defendant was liable for the injuries resulting from V’s jump.

3. Impact and Analysis:

• Reasonable Foreseeability: The case established that a defendant is liable if the victim's reaction is not so extreme or unforeseeable that a reasonable person would not have anticipated it. In this case, V’s reaction was deemed foreseeable.

• Legal Standard: The decision clarified that only reactions that are deemed “so daft” or irrational that they cannot be reasonably foreseen will break the chain of causation.

• Significance: The case underscores the principle that the defendant’s liability extends to foreseeable consequences of their actions, including those leading to the victim's response. The court’s focus on reasonable foreseeability ensures that defendants are held accountable for the reasonably expected outcomes of their behaviour.