R v Roberts (1972) 56 Cr App R 95 (CA). FACTS: The victim was a passenger in Roberts' car. She was terrified by Roberts' unwanted sexual advances and jumped out of the moving car, suffering injuries in the process. HELD: Roberts was convicted of assault occasioning actual bodily harm. The Court of Appeal considered that the accused had caused her injuries and said that the victim's reaction would only break the causation if it were an act that was 'so daft' that no reasonable person could have foreseen it. In the Court of Appeal judgment, Stephenson LJ stated that, to determine whether the passenger's actions broke the chain of causation, the jury should be directed to ask the following question:

'Was it the natural result of what the alleged assailant said and did, in the sense that it was something that could reasonably have been foreseen as the consequence of what he was saying or doing? As it was put in one of the old cases, it had got to be shown to be his act, and if of course the victim does something so "daft" … or so unexpected … that no reasonable man could be expected to foresee it, then it is only in a very remote and unreal sense a consequence of his assault, it is really occasioned by a voluntary act on the part of the victim which could not reasonably be foreseen and which breaks the chain of causation between the assault and the harm or injury.'