R v Steer [1988] 1 AC 111
Criminal Damage Act 1971 – intent to endanger life
Facts
Steer went to his business partner’s property rang the doorbell and after no answer, fired a rifle at the bedroom and sitting room windows and the door, following a disagreement between the two of them. No injury was caused. Following this, Steer was charged with damaging property with intent and being reckless to injury of life under the Criminal Damage Act 1971, section 1. Initially, Steer claimed that there was no case to answer which was initially rejected before he pleaded guilty and appealed against the conviction to the Court of Appeal which upheld his appeal. The Crown appealed this.
Issues
It was important to consider whether Steer’s actions had endangered the life of the individuals in the house by the damage that shooting the windows and doors of the property had caused. This had to be weighed against the inherent dangers of the method of causing the damage (i.e. the shooting of a gun in this instance).
Decision/Outcome
The Crown’s appeal was dismissed and Steer’s conviction was quashed. The recklessness or intention specified by the Criminal Damage Act 1971 section 1 (2) was intended to cover danger to life caused by property damage, not the dangers that could be caused by the method the damage was inflicted (i.e. the rifle). The prosecution were required to prove that the danger to life was caused by the danger to the property which in this case, it was not. It was also noted that a person who has in his possession, a firearm commits a distinct offence under the Firearms Act 1968 section 16.
Updated 20 March 2026
This case summary remains accurate. R v Steer [1988] 1 AC 111 is a House of Lords authority and the legal principle it established — that under section 1(2) of the Criminal Damage Act 1971 the danger to life must arise from the property damage itself, not from the means used to cause that damage — remains good law. No statutory amendments to the relevant provisions of the Criminal Damage Act 1971 have altered this position. The reference to section 16 of the Firearms Act 1968 is also correct, though readers should note that the Firearms Act 1968 has been amended on various occasions since 1988 (including by the Firearms (Amendment) Acts 1988 and 1997 and the Violent Crime Reduction Act 2006); those amendments do not affect the accuracy of the point made in the summary. The principle in Steer has been consistently applied and affirmed in subsequent case law, including R v Webster [1995] 2 All ER 168 and R v Warwick [1995] 2 All ER 168, which extended and refined the principle. Students reading this summary should be aware of those later cases as they develop the law in this area.
