attempts MR

• must generally be established that defendant had intent to commit the complete offence
• indirect intention will suffice but recklessness will not
• easom: conditional intent was not sufficient for intent
• attorney generals reference (no 1 and 2 of 1979): decision in easom criticised, court of appeal changed the law to say conditional intent will satisfy an attempt
• r v millard and vernon: it is not possible to be guilty of an attempt recklessly
• for attempted murder, it must be proved that defendant had intention to kill. intention to cause gbh will not suffice
• presenting circumstances may make it impossible for a defendant to commit an offence
• s1(2) criminal justice act 1981: ‘a person may be guilty of attempting to commit an offence… even though the facts are such that the commission of the offence is impossible’
• r v shivpuri: conviction upheld irrelevant of the fact that it was factually impossible to commit the offence