R v Owino

D committed actual bodily harm against his wife, V, and he was convicted after the judge gave the standard direction on self-defence (albeit late). D appealed on the basis that D’s force was only unlawful if he intended to use more force than HE BELIEVED was necessary. CA said that while the court had to take the circumstances as D believed them to be (subjective) the actual force permitted had to be “reasonable” by objective standards.