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The defence is set out in Bratty v AttorneyGeneral for Northern Ireland (1963)which states
that: "an act done by the muscles without any control by the mind, such as a spasm...or an act
done by a person who is not conscious of what he is doing such as an…

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This occurred in Hardie (1984) where D took Valium due to his girlfriend asking
him to leave. He set fire to the wardrobe. The CoA quashed the conviction as the D
believed that drugs would calm him down due to it being the normal effect of
Valium. Therefore the defendant…


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