Abstract
R. v Steane (1947) is regularly cited in modern textbooks on criminal law on the distinction between motive and intention in respect to mens rea. In that case the conviction of the defendant for having broadcast enemy propaganda from Berlin during the Second World War was quashed by the Court of Appeal on the basis of the trial judge's misdirection. Steane himself claimed that he had been forced to broadcast for the Nazis as a result of threats to himself and to his family. The present article looks at new evidence, including that from MI5 sources, which, it is submitted, now casts serious doubt on Steane's credibility and which suggests that the question of his loyalty as a British subject was at least ambiguous during the war.
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