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6. The first part of the Graham test is a) was the defendant compelled to act as he did because he reasonably believed that he had a good cause to fear serious injury or death

  • b) if so would a sober person of reasonable firmness, sharing the characteristics of the defendant have acted in the same way
  • Pommell - a failure to go to the police straight away prevented him from having any defence
  • Conway, where a passenger in D's car had been shot at a few weeks earlier, when D saw two men run towards the car he drove away recklessly
  • Duress of Circumstances could be a defence to all crimes except murder, attempted murder and some treason