“Impossibility could provide defence to attempts - later overruled”
Mrs Ryan bought a video recorder cheaply, believing it to be stolen. She later admitted this to police during an unrelated inquiry. The video recorder was not actually stolen, making completion of the offence of handling stolen goods impossible.
Whether a defendant could be convicted of attempting to handle stolen goods when the goods in question were not actually stolen, making the completed offence impossible.
The House of Lords allowed the appeal and quashed the conviction. The Lords held that where completion was impossible, there could be no conviction for attempt.
Although overruled by Shivpuri just two years later, this case remains important for understanding the development of attempt law and the problems with distinguishing between different types of impossibility. It demonstrates how the law evolved on this complex area and is often studied alongside Shivpuri.
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OSCOLA Citation
Anderton v Ryan [1985] AC 560 (HL)
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