LEGAL PRINCIPLE: CRIMINAL LAW — Defence of Insanity — Self-Induced Intoxication — No Defence
PRINCIPLE STATEMENT
No accused can take shelter under the defence of intoxication if it is self-induced. Self-induced intoxication is no defence to a charge. The accused is presumed to intend the natural consequences of his act.
RATIO DECIDENDI (SOURCE)
Per Belgore, JSC, in Okeke v. State (2003) NLC-2592000(SC) at p. 10; Paras C–E.
"No accused is allowed to take shelter under defence of intoxication if that intoxication is self-induced. The appellant could not excuse his conduct on his getting off his head or faculty because he voluntarily took cocaine or any other stupefying substance. In the case of crime committed, e.g. murder, during the period of self-induced intoxication, it is no defence to a charge that the accused did not intend to do the act alleged in the offence. He is presumed to intend the natural consequence of his act."
EXPLANATION / SCOPE
Self-induced intoxication is not a defence to a criminal charge. The principle applies to criminal law. The accused is responsible for his voluntary acts. The rule prevents abuse of intoxication defence. The presumption of intent applies. The principle is well-established.