The House of Lords attempted to clarify the doctrine of indirect intent in Woollin’ by stating that if a consequence is a substantially certain effect of an act and the actor foresaw it as such, the result may be determined to be intended by a jury even though it was not the actor’s intention to produce it.

This article will look at the precedent that led to Woollin and discuss whether the House was correct in allowing a legal question (the meaning of intention) to be decided as a fact by a jury.



The appellant hurled his three-month-old kid upon a hard surface. The infant perished as a result of a shattered skull. If the jury was satisfied that the defendant “must have realized and appreciated when he threw that child that there was a substantial risk that he would cause serious injury to it, then it would be open to you to find that he intended to cause serious injury to it,” the trial judge instructed the jury.

The defendant argued that the court had broadened the definition of murder by referring to “significant danger,” and that the judge should have referred to “virtual certainty” in accordance with Nedrick guidance. The Court of Case dismissed the appeal, ruling that there was no legal requirement to use the term “virtual certainty.”


Murder was charged against the defendant.

The jury was instructed by the trial judge that they might convict the accused of murder based on an indirect intent to cause the kid’s death if he recognized or realized that his conduct put the youngster in serious danger. The jury decided that exposing a victim to a significant danger of harm was enough to create the necessary intent for murder.



A manslaughter conviction was substituted for a murder conviction. As a result of the significant misdirection, the Mens rea of murder was extended, and the murder conviction was deemed unsafe. With a small change, the House of Lords mostly agreed with the Nedrick principles.

The correct path to take is:

“Where the charge is murder, and in the rare cases where the simple direction is insufficient, the jury should be instructed that they are not entitled to find the necessary intent unless they are confident that death or serious bodily harm was a virtual certainty (barring some unforeseen intervention) as a result of the defendant’s actions, and that the defendant appreciated it.”



The Woollin direction can be read in two ways.

  • The first is that if the prosecution proves that the defendant predicted that causing death or grievous bodily damage to the victim was virtually certain, this alone establishes the required purpose to inflict death or grievous bodily harm to form the mens rea of murder.
  • The second is that proof that the defendant foresaw that causing death or serious bodily damage to the victim was virtually certain is just evidence from which the jury can infer that the defendant intended to cause death or grievous bodily harm to the victim. It does not constitute indirect murder intent on its own.



The Court of Appeal concluded in R v Matthews and Alleyne¬†that the Woollin test was an evidential rather than substantive rule of law: judges should instruct jurors that what they would see as certain knowledge on the defendant’s part of the virtually certain consequence of death can be interpreted as evidence of intent, but Woollin does not substantively define a secondary type of intention.




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