... remember nothing about a journey, he was able to exercise some voluntary control over his movements, he had not been acting in an entirely involuntary manner. This approach was recently followed by the Court of Appeal who insisted that automatism is only available where there is a total loss of voluntary control as suggested in Attorney-General's Reference (No 2 of 1992) where D had been put into a trance-like state by the repetitive vision of the long flat road which reduced, but did not eliminate, awareness of what he was doing. This follows the quote above, as there is no suggestion of a knowledge of the defendant's acts. In Bratty, Lord Denning made it clear that an act is not involuntary simply because the offender simply could not resist the impulse or did not intend the consequences. The courts have employed very different approaches to the defence of automatism, which ...

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