D was convicted of dangerous driving when he was trying to escape attackers, in reasonable fear for the safety of himself and his passenger. Judge did not put a direction of necessity. CA said the judge ought to have directed that there was a possible defence of “duress of circumstances”. Lord Woolf defines duress of circumstances in this case as: “where the defendant was compelled by circumstances to do as he did to avoid death or serious bodily harm to himself or some other person.” Lord Woolf also said, importantly, “"Whether 'duress of circumstances' is called 'duress' or 'necessity' does not matter. What is important is that, whatever it is called, it is subject to the same limitations as the 'do this or else' species of duress." i.e. objectively “reasonable” belief in danger.