R v Miller [1983]

Facts:

  • D spent an evening drinking before returning to a property where he was squatting. Falling asleep with a cigarette in his hand, he started a fire. He took no steps to extinguish the fire and was charged with arson after the whole house caught fire.

Held:
  • D was under a duty to take action to resolve it once he became aware of the fire and was accordingly convicted of arson.

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