“Distinguished insane automatism from non-insane automatism in criminal defences.”
Quick, a diabetic nurse, took insulin but failed to eat properly and consumed alcohol. While supervising patients at a mental hospital, he became hypoglycaemic and assaulted a patient. He claimed automatism, arguing he was not conscious of his actions due to his medical condition.
Whether automatism caused by self-induced hypoglycaemia constitutes insane automatism (requiring special verdict) or non-insane automatism (leading to acquittal)?
The Court of Appeal held this was non-insane automatism. Hypoglycaemia caused by external factors (insulin and alcohol) rather than the disease itself did not constitute insanity within the M'Naghten Rules.
This case is crucial for understanding the distinction between insane and non-insane automatism, with important implications for defendants' outcomes. It clarifies how medical conditions and their treatment interact with criminal defences in modern law.
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OSCOLA Citation
R v Quick [1973] QB 910
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