Ratio Decidendi
Where a victim takes evasive action to escape the defendant's unlawful conduct, the defendant is liable for the resulting injuries provided the victim's reaction was within the range of reasonably foreseeable responses.
Facts
Roberts made unwanted sexual advances to a woman in his car. She jumped from the moving car and was injured.
Judgment Summary
The conviction for ABH was upheld. The victim's act of jumping was a reasonably foreseeable reaction. Only a 'daft' or 'wholly unexpected' response would break the chain of causation.
Key Quotes
"The test is whether the victim's act was the natural result of what the assailant said and did, in the sense that it was something that could reasonably have been foreseen."
— Stephenson LJ
Subsequent Treatment
Key authority on victim response and causation. Applied in R v Williams and Davis [1992].