Ratio Decidendi
Possession of a controlled drug requires proof that the defendant had a substance in their possession and knew it was a controlled drug, or was wilfully blind to that fact.
Facts
The defendant was found with traces of cannabis on a penknife. He argued he did not know the substance was cannabis.
Judgment Summary
The Court of Appeal held that possession requires knowledge that the substance is a controlled drug. Mere possession of a container is not sufficient without knowledge of its contents being a controlled drug.
Key Quotes
"A person has possession if he knows that the thing he possesses is a controlled drug."
— Lord Widgery CJ
Subsequent Treatment
Applied
Applied in subsequent drug possession cases.