To be criminally responsible for any crime in the UK, a jury must prove beyond a reasonable doubt that the defendant committed Actus Reus and Mens Rea. The Actus Reus is the physical element of the crime; is Latin for “guilty act.” In order for criminal liability to be proven, the defendant's act must be voluntary. Mens Rea is the Latin word for guilty mind; of the two it is the more difficult to prove. To be found guilty of a crime, Mens Rea requires the accused to have planned his actions before carrying them out. There are two types of Mens Rea; direct intention and oblique intention. Direct intention “corresponds to the everyday definition of intention and applies where the accused actually wants the outcome to occur and sets out to achieve it” (Elliot & Quinn, 2010: 59). Oblique intention is when “the accused did not desire a particular outcome but, in taking action, realized that it might occur” (Elliot & Quinn, 2010: 60). I will illustrate, using relevant case law, the difference between direct intention and oblique intention. Oblique intent requires foresight of consequences, finding oblique intent is difficult; consequently, there have been numerous cases that have helped to clarify the law of intention. In the case of R v Maloney (1985), the defendant and the victim (defendant's stepfather), were drunk when they decided to have a contest over who can load and fire a gun the fastest. The defendant shot the victim without aiming while the victim provoked him into shooting. Lord Bridge held that "the prediction of consequences as an element relevant to the question of intention in murder... belongs not to the substantive law but to the law of evidence" (Molan, 2001: 95), here it is held that oblique intent ... ... half of the paper ......ing Limited.• Elliot, C & Quinn, F (2010a), Criminal Law. Great Britain. Pearson Education Limited.• Herring, J (2010b), Case Texts and Materials. Great Britain. Oxford University Press.• Parliament of the United Kingdom (1997-1998), Regina v Woolin, http://www.publications.parliament.uk/pa/ld199798/ldjudgmt/jd980722/wool.htm. Accessed 06/11/10.• Law Reform Committee (2001), Consultation paper on murder: the mental element in murder. http://www.lawreform.ie/_fileupload/consultation%20papers/cpMentalElementinMurder.pdf. Accessed on 6/11/10.• Cases of criminal law and procedure (No date). Regina vs. Maloney. http://www.vanuatu.usp.ac.fj/courses/la205_criminal_law_and_procedure_1/cases/R_v_Moloney.html. Accessed on 6/11/10.• Sestaformalegge (undated). Cases - Murder - Mens Rea. http://sixthformlaw.info/02_cases/mod3a/cases_32_murder_mens.htm. Access to 6/11/10