The meaning of 'really serious injury' for the purposes of the mens rea of murder is not defined by law and is for the jury to determine by applying their ordinary experience. An inference of intent to cause really serious injury may be drawn from the nature of the act done, especially where a weapon is used and the immediate consequence is obvious. The relationship between the M v The Queen formulation (appellate court's own doubt) and later articulations of the unreasonable verdict test in Libke, SKA, Fennell and Pell was expressly left open.
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