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The defence is set out in Bratty v Attorney-General 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…

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Sullivan (1984) and Burgess (1991) the D's would have been able to plead non-insane automatism
rather than insanity. This shows much improvement within the law.


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