LEGAL PRINCIPLE: CRIMINAL LAW – Intention – Presumption – Natural and Probable Consequences of Acts
PRINCIPLE STATEMENT
The law presumes that a man intends the natural and probable consequences of his acts. And the test to be applied in these circumstances is the objective test namely, the test of what a reasonable man would contemplate as the probable result of his acts. The appellant in this case emerged from his hideout and dealt the deceased a blow on the head with a stick. The deceased fell down and died on the spot. The sole question here is whether the unlawful and voluntary act of the appellant was of such a kind that grievous bodily harm was the natural and probable result. On the state of the evidence, it must be observed that the appellant must at least have appreciated that the blow with a stick on the head of the deceased, which resulted in instant death, would at least occasion serious harm to him. That would undoubtedly lead to a conviction on a charge of murder.
RATIO DECIDENDI (SOURCE)
Per Katsina-Alu, JSC, in Garba & Ors v. State (2000) NLC-1571999(SC) at p. 8; Paras A–C.
"The law presumes that a man intends the natural and probable consequences of his acts. And the test to be applied in these circumstances is the objective test namely, the test of what a reasonable man would contemplate as the probable result of his acts. The appellant in this case emerged from his hideout and dealt the deceased a blow on the head with a stick. The deceased fell down and died on the spot. The sole question here is whether the unlawful and voluntary act of the appellant was of such a kind that grievous bodily harm was the natural and probable result. On the state of the evidence, it must be observed that the appellant must at least have appreciated that the blow with a stick on the head of the deceased, which resulted in instant death, would at least occasion serious harm to him. That would undoubtedly lead to a conviction on a charge of murder."
EXPLANATION / SCOPE
The law presumes a person intends the natural and probable consequences of their acts, applying an objective test—what a reasonable person would contemplate as the probable result. Where an unlawful act—such as striking the head with force—results in death, the presumption operates. The accused must have appreciated that such an act would cause serious harm. This presumption assists in proving intent where direct evidence is absent. The objective standard ensures that persons are held accountable for consequences a reasonable person would foresee from their voluntary actions.