SUMMARY OF R v M’Naghten

M’NAGHTEN RULE:

R v M’Naghten

In January 1843, at the parish of Saint Martin, Middlesex, Daniel M’Naghten took a pistol and shot Edward Drummond, who he believed to the British Prime Minister Robert Pell, wounding him fatally. Drummond died five days later and M’Naghten was charged with his murder. He pleaded not guilty by reason of insanity. At trial, evidence was given of the shooting of Drummond and witnesses were called on the behalf of the defendant, M’Naghten, to attest to the fact he was not in a sound state of mind at the time of committing the act. Some of the witnesses who gave this evidence, had previously examined M’Naghten, whilst others had not seen him prior to the trial and, and they formed their opinion on hearing the evidence given by other witnesses.

The medical evidence brought forward stated that persons of otherwise sound mind, might be affected by morbid delusions and that M’Naghten was so affected. A person labouring under such delusion, might usually possess a moral perception of right and wrong, but in relation to acts connected to their delusion may be carried beyond power of their own control leaving them with no such perception. Accordingly M’Naghten was not capable of exercising control over his acts whilst under his delusion. Due to the nature of M’Naghten’s condition these delusions went on gradually until they reached a climax, ending with Drummond being shot. Evidence brought before the Court about the condition from which M’Naghten suffered stated that a man may go on for years quietly whilst under the delusion’s influence, but had the potential break out into extravagant and violent paroxysms. In relation to the charge against M’Naghten, Lord Chief Justice Tindal stated that “the question to be determined is, whether at the time the act in question was committed, the prisoner had or had not the use of his understanding, so as to know that he was doing a wrong or wicked act. If the jurors should be of opinion that the prisoner was not sensible, at the time he committed it, that he was violating the laws both of God and man, then he would be entitled to a verdict in his favour: but if, on the contrary, they were of opinion that when he committed the act he was in a sound state of mind, then their verdict must be against him.”M’Naghten was found not guilty. Following this a panel of Judges attended the House of Lords and had a series of hypothetical questions on the topic of insanity put before them.

Held

In response to these questions the Judges formulated the M’Naghten Rules (1843) 4 St.Tr.(N.S.) 847. These provide the legal definition of insanity. They provide that a defendant wishing to rely on the defence of insanity must show that: They laboured under a defect of reason; Caused by a disease of the mind; so that either; He did not know the nature and quality of his acts, or that he did not know what he was doing was wrong.

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