Retreat Doctrine to Self-Defense in Criminal Law

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Introduction
Whether the accused has a duty to retreat before using force in self-defense is an arguable topic in the criminal law. In some jurisdictions, such a duty exists and the burden of proof is on the defense to show his or her conduct was reasonable or necessary. However, in other jurisdictions, the courts are more reluctant to have or even deny having such a requirement. This essay will first examine the retreat doctrine in Hong Kong and then compare it with other jurisdictions which are the U.S. and Scotland. Finally, it will be argued that Scotland system is better from the policy standpoint because the right to life is a fundamental right possessed by all human beings and should be given priority to wherever there is a reasonable possibility.

English law and Hong Kong law
In R v Julien , the Court of Appeal held that the self-defense would fail only if the defendant failed to take a reasonable opportunity to escape from the situation of danger. As for whether the defendant should first demonstrate an unwillingness to fight, Widgery LJ asserted, ‘what is necessary is that he should demonstrate by his actions that he does not want to fight.’ However, the ruling in Julien case has been modified ever since. In R v McInnes, it was held that failure to retreat is merely one element for the court to consider in terms of the reasonableness of the defendant’s conduct. Then in the leading case, R v Bird, the English Court of Appeal has implicitly disapproved the rule in Julien case, holding that it was unnecessary to show an unwillingness to fight. The court observed: ‘If [D] is proved to have been attacking, retaliating or revenging himself, then he was not truly acting in self-defence. Evidence that the defend...

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...1958] 100 CLR 448, 463.
[2007] EWHC 3169 (Admin).
[1992] 1 HKCLR 255. ibid 258,259.
The Model Penal Code 1981.
Fiona Leverick, Killing in Self-Defence, (1st edn, OUP 2006) 75. ibid 72.
1999 SLT 1333. ibid 1336. ibid 1337. ibid. A.J. Ashworth, ‘Self-defence and the right to life’ (1975) 34 CLJ 290.
P. Luevonda Ross, ‘The Transmogrification of Self-Defense By National Rifle Association-Inspired Statutes: From The Doctrine of Retreat to The Right to Stand Your Ground’ (2007) 35 S.U.L. Rev.1, 46.
John Lott, More Guns, Less Crime” (3rd edn, University of Chicago Press 2010).
Chandler B. McClellan and Erdal Tekin, ‘Stand Your Ground Laws, Homicides, and Injuries’ (2012) NBER Working Paper 18187.
Ian Ayres and John J. Donohue III, ‘Shooting Down the “More Guns, Less Crime” Hypothesis’ (2003) Stanford Law Review 1193.
Leverick (n13) 82-84.

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