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10 cards from this deck
D acts due to dangerous situation, not direct threat from person
Essentially the same defence (Lord Woolf)
R v Martin (1989) - established modern test
Unavoidability, reasonable necessity, proportionality
Objective reasonableness + Graham test
Death or serious injury only
NO - unavailable for murder or attempted murder
Necessity refused - sailors killed cabin boy
Source: dangerous circumstances vs direct threat from person
Lawful alternatives available (internal reporting)
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