R v Whoolley (Unreported) Divisional Court of Queen's Bench Division

The defendant lorry driver, was travelling on the M62 in a queue of slow moving traffic. He suffered a sneezing fit, losing control of his vehicle he knocked into the car in front. This car in turn knocked into the car in front causing a domino effect involving 7 cars. The Magistrates allowed the defence of automatism. The appeal court held that the Magistrates were right to do so and that an attack of sneezing could amount to an involuntary action for the purposes of the defence of non-insane automatism.

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