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R v. Sheppard [1980] UKHL J1127-1,

“Wilful neglect”

"The presence of the adverb “wilfully” … makes it clear that an offence under Section 1 requires mens-rea, a state of mind on the part of the offender directed to the particular act or failure to act that constitutes
the actus reus and warrants the description “wilful”… neglect refers to failure to act…”

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