Director of Public Prosecutions V. Beard. (1920) AC 479
Arthur Beard, while heavily intoxicated, engaged in a violent act that tragically resulted in the death of a young girl. The specific nature of the act and the evidence presented varied across accounts.
Beard's defense argued that his drunken state rendered him incapable of forming the necessary specific intent (mens rea) for murder, crucial for conviction.
The issues of the case are:
- Does intoxication negate mens rea? The central question hinged on whether Beard's drunkenness prevented him from intending the consequences of his actions, specifically the young girl's death.
- o Presuming intent vs. burden of proof: If intoxication is presumed to affect intent, does the burden fall on the prosecution to prove intent despite drunkenness, or should the defendant prove their incapability due to intoxication?
- Degree of intoxication: Determining the level of intoxication necessary to negate mens rea proved crucial. Mere drunkenness vs. complete mental incapacity due to intoxication needed differentiation.
The House of Lords established three key principles (the "Beard rules"):
- Presumption of intent: Generally, if an act has natural consequences (like death from violence), the actor is presumed to intend those consequences.
- Shifting burden of proof: Intoxication itself isn't a defense. However, if presented, the burden shifts to the defendant to prove they were too intoxicated to form the specific intent required for the crime.
- Degree of intoxication: Only intoxication rendering the accused demonstrably incapable of forming the specific intent is relevant. Mere drunkenness is insufficient.
Based on these principles, the Lords found Beard guilty of manslaughter rather than murder, acknowledging the potential impact of his drunkenness on specific intent for the higher charge.
