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[Automatism - reckless driving - total loss of control required – driving without awareness not sufficient] D drove his lorry for six hours and hit a stationary vehicle on the hard shoulder, killing two people. He claimed automatism because he was 'driving without awareness'.

Held: automatism occurs when there is a total loss of voluntary control. Impaired or reduced control is not sufficient. D had some control of the lorry, he was able to steer and was partially aware of what was going on the road ahead of him.

Not Guilty. (but should have)

Because he was acquitted the issue of whether his condition amounted to automatism came before the Court of Appeal in the form of a reference(AG'S REFERENCE NO.2 of 1992). Experts described the defendants condition as driving without awareness. " the drivers capacity to avoid a collision ceased to exist because repetitive stimuli experienced on straight flat featureless motorways could induce a trance like state". 'The Court of Appeal however, ruled that this did not amount to automatism.