With regards to sugar levels in the body, it can be divided into two categories. They are as follows:-
1) Hypoglycemia (a lack of glucose in the body). Hypoglycemia is caused by external factors i.e. the defendant not doing something he should be doing or doing something that he shouldn’t be doing. In such instances, depending on the facts, the defense can raise the defense of automatism
2) Hyperglycemia (excess sugar in the body). Hyperglycemia is a condition that occurs naturally and it is caused by internal factors. In such instances, the defense can raise the defense of insanity
In R v Quick (1973) the defendant a male nurse who was a diabetic had taken insulin without consuming any food, and in addition to that had consumed alcohol which aggravated the situation (whisky and rum). He assaulted a patient who was a paraplegic and inflicted injuries that included a broken nose and a black eye.
The defendant was charged under s.47 of the Offences Against Person Act (1861) and the trial judge directed the jury on insanity (automatism that arises naturally). He was convicted and he appealed.
The appeal was allowed and the conviction was quashed. The defendant was suffering from automatism that arose from a failure to consume food after taking insulin or taking excessive insulin and his condition was further aggravated or exacerbated by the fact that he’d been drinking.
It was automatism that arose from external factors i.e. a failure to do something that is required or doing something that the defendant shouldn’t be doing given his condition and the type of automatism that the defendant suffered from fell under the category of intoxication.
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