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Section 1(1) of the Criminal Attempts Act 1981 states: "If with intent to commit an offence to which this section applies, a person does an act which is more than merely preparatory to the commission of the offence, he is guilty of attempting to commit the offence." What does this section mean and how has it been interpreted by the courts? The majority of Statute law in the UK is formed on the basis of the Common Law position of the issue in hand; the Criminal Attempts Act 1981 is no different. Before the enactment of the Criminal Attempts Act 1981 there was a plethora of different tests used by the judges. The Common Law position settled upon the "proximity test", in which the defendant's actions had to be proximate to the completed offence, in the sense of it being "immediately and not merely remotely, connected"1 with the completed offence. In DPP v...

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