Ratio Decidendi
Throughout the web of the English criminal law one golden thread is always to be seen — that it is the duty of the prosecution to prove the prisoner's guilt. The burden of proof lies on the prosecution from start to finish, subject only to the defence of insanity and any statutory exceptions.
ข้อเท็จจริง
Woolmington was charged with the murder of his wife. He claimed the gun went off accidentally while he was threatening to commit suicide to persuade her to return to him. The trial judge directed the jury that once the prosecution proved the killing, the burden shifted to the defendant to prove it was an accident.
สรุปคำพิพากษา
Viscount Sankey LC held the trial judge's direction was wrong. The prosecution bears the burden of proving every element of the offence beyond reasonable doubt throughout the trial. The only exceptions are the defence of insanity (M'Naghten Rules) and express statutory reversals. The conviction was quashed.
คำกล่าวสำคัญ
"Throughout the web of the English Criminal Law one golden thread is always to be seen, that it is the duty of the prosecution to prove the prisoner's guilt subject to what I have already said as to the defence of insanity and subject also to any statutory exception."
— Viscount Sankey LC
การอ้างอิงภายหลัง
The foundational authority on the presumption of innocence and burden of proof in English criminal law. Applied and affirmed in countless subsequent cases.