Regina v. Faulkner, 13 Cox CC 550 (1877), was a case tried before the Court for Crown Cases Reserved holding that the mens rea for committing one criminal act does not necessarily transfer to all possible consequences of that act.
Decision
The defendant was employed on a ship transporting rum, sugar, and cotton. The defendant was not allowed into the cargo area, but he entered the area, poked a hole in a barrel of rum, and drank some of it. To be able to see while plugging the hole, the defendant lit a match. The rum caught fire, injured the defendant, and destroyed the ship. The trial court found the defendant guilty of larceny for the rum and arson for the ship. The Court for Crown Cases Reserved reversed based on jury instructions that allowed the jury to find the defendant guilty of the arson even if they found that he only had intent to commit the larceny. The court held that the intent to commit the larceny did not necessarily mean that the defendant had the intent to commit the arson, so the jury instructions were improper.