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R v Hennessy – 1989

R v Hennessy [1989] 1 WLR 297

Diabetes and defences – automatism or insanity in hyperglycaemic cases


The appellant, who was diabetic, was arrested for driving a stolen car. He had a diabetic episode at the police station and it was revealed that he had not taken his insulin for several days, partly due to emotional stress caused by his wife leaving him. Evidence showed that hyperglycaemia, which the appellant was suffering from, can cause drowsiness and impair a person’s ability to understand their surroundings, as well as their physical and mental abilities. Additionally, emotional states such as anxiety and depression can worsen the effects. He was charged with theft and driving while disqualified. He did not remember taking the car and argued that he was not in control of his actions due to automatism.

The trial judge ruled that automatism did not apply in this case and that the appellant should have plead insanity instead. The appellant was convicted. On appeal, the issue was whether automatism or insanity was the correct defense for the appellant’s condition during the episode of hyperglycaemia.

Held: The court ruled that the trial judge was correct in determining that insanity was the correct defense, since hyperglycaemia is a result of the underlying condition of diabetes and can be considered a disease of the mind. Additionally, automatism refers to situations where the actions are involuntary. The case R v Quick [1973] QB 910 was cited as an example of how the two defenses were distinct.Regenerate response

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