R v Adams (1957)

R v Adams [1957] Crim LR 365 is an English case that allows a doctor to hasten death (as a secondary intention) using analgesic medications such as heroin and morphine.

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Case Facts

The defendant, John Bodkin Adams, was a doctor who was charged with murder by "easing the passing" of elderly patients by giving drugs calculated to hasten their deaths (one had left a bequest - including a Rolls-Royce - to him in her will).

Judgement

It was said that a doctor has no special defence, but "he is entitled to do all that is proper and necessary to relieve pain even if the measures he takes may incidentally shorten life" (i.e. as a secondary intention). On these grounds, the defendant was acquitted. This case was the first to formulate a "double effect" in respect of the "mens rea" of murder. Liability for murder can be avoided if medicine which is beneficial to the patient is given, despite the knowledge that death will occur as a side effect.

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