The Supreme Court has quashed Celyn Eadon’s murder conviction, finding that the trial judge’s directions on intoxication could have misled the jury about the law and did not adequately explain how intoxication related to the intent required for murder.
The judgment, delivered by Justice William McKechnie on 20 December 2019, says the key question when intoxication is raised in a case involving a specific-intent offence is whether the accused actually formed that intent. It is not enough to ask only whether the accused had the capacity to form it.
Eadon was convicted in 2014 of murdering his mother, Noreen Kelly, in March 2011. The killing itself was not disputed at trial. The jury rejected his defence of diminished responsibility; his appeal concerned intoxication and whether he had formed the intent to kill or cause serious injury required for murder.
The trial judge initially said voluntary intoxication did not provide a defence or mitigation. After defence counsel objected that intoxication had not been addressed separately, the judge said it was “part of the mix” in considering whether a person was capable of forming the necessary intent. The Supreme Court held that this remained a capacity-based direction and did not tell jurors to consider whether Eadon actually formed the intent.
The Court also found a more fundamental problem: the judge’s repeated statement that intoxication was not a defence could reasonably have left jurors thinking it could not reduce murder to manslaughter. In law, the judgment explains, intoxication may negate the specific intent required for murder, though it does not provide a defence to manslaughter.
The DPP argued that the jury could understand the law from the trial lawyers’ closing speeches, which discussed intoxication’s relevance to intent. The Supreme Court rejected that argument. It said jurors are directed to take the law from the judge, so counsel’s speeches cannot supplement or cure a deficient legal direction. The Court found that the judge’s charge, considered on its own, was inadequate.
The Supreme Court allowed the appeal and quashed the murder conviction, concluding that the trial was unsatisfactory, unsafe and not in accordance with law. It did not order a retrial at that stage. After hearing the parties, the Court recorded that the manslaughter plea offered before trial stood as a valid judicial admission. The indictment was adjourned to the next Central Criminal Court list, pending the DPP’s decision whether to accept that plea or seek a retrial on the murder charge.