... held that the defendant's conviction should be quashed because his intention was not to assist the enemy but to save his family; an intention ulterior to the actus reus so there was no intent constituting the mens rea. Glanville Williams has argued that duress would have been a more appropriate defence than of lack of intent, because the defendant's actions were surely deliberate. In murder cases the intent necessary for the mens rea is greater than others. In the case of Moloney, the House of Lords held that a jury should only be directed to consider whether death or really serious injury was a natural consequence of the defendant's actions, which he foresaw. In Woollin, the Lords held that if the defendant foresaw the killing as a virtually certain consequence of his actions there is sufficient intent, but if he thought only that the killing was a potential consequence the jury ...

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