To be criminally liable for any crime in the UK, a jury must prove beyond reasonable doubt that the accused committed Actus Reus and Mens Rea. The Actus Reus is the physical element of the crime; it’s Latin for “guilty act.” The defendant's act must be voluntary for criminal liability to be proven. Mens Rea is Latin for guilty mind; it is the more difficult of the two to prove. To be convicted of a crime, Mens Rea requires that the accused planned his actions before committing them. There are two types of Mens Rea; direct intention and oblique intention. Direct intent “is the common definition of intent and applies when the accused actually desires the outcome that occurs and strives to achieve it” (Elliot and Quinn, 2010: 59). Oblique intent occurs when “the accused did not desire a particular outcome but, in acting, he or she realized that it might happen” (Elliot and Quinn, 2010: 60). I will illustrate, using relevant case law, the difference between direct and oblique intent. Oblique intention requires foreseeing consequences, finding oblique intention is difficult; as a result, a number of cases have helped clarify the law of intent. In the case of R v Maloney (1985), the defendant and the victim (the defendant's stepfather) were drunk when they decided to have a competition to see who can load and fire a gun faster. The defendant shot the victim without aiming, while the victim taunted him into firing his gun. Lord Bridge held that “foresight of consequences as a factor bearing on the question of intent in murder... belongs, not to substantive law but to the law of evidence” (Molan, 2001 : 95), the oblique intention is here retained... ... middle of document ......ing Limited.• Elliot, C & Quinn, F (2010a), Criminal law. Great Britain. Pearson Education Limited.• Herring, J (2010b), Textual and Material Cases. Great Britain. Oxford University Press.• Parliament of the United Kingdom (1997-1998), Regina v Woolin Judgments, http://www.publications.parliament.uk/pa/ld199798/ldjudgmt/jd980722/wool.htm. Accessed 11/06/2010.• Law Reform Commission (2001), Consultation Paper on Homicide: The Mental Element of Murder. http://www.lawreform.ie/_fileupload/consultation%20papers/cpMentalElementinMurder.pdf. Accessed 06/11/10. • Criminal law and procedure cases (undated). Regina vs. Maloney. http://www.vanuatu.usp.ac.fj/courses/la205_criminal_law_and_procedure_1/cases/R_v_Moloney.html. Accessed 06/11/10.• Sixthformlaw (No date). Affairs - Murder - Mens Rea. http://sixthformlaw.info/02_cases/mod3a/cases_32_murder_mens.htm. Accessed at 6/11/10