The defence of accident under the second limb of s 23 of the Criminal Code 1899 (Qld) does not arise for the jury's consideration where a deliberate blow to the head propels the victim down stairs causing head injury, as such a consequence is obviously reasonably foreseeable to an ordinary person. For grievous bodily harm arising from a single spontaneous blow by a security officer of good character in circumstances at the lower end of seriousness, a two-year sentence without suspension is manifestly excessive; a suspended sentence is appropriate.
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