held that a defendant who manufactured ten petrol bombs to defend his shop during the Toxteth Riots could set up the defence of showing that he possessed an explosive substance "for a lawful purpose" if he could show he acted to protect himself or his family or property by means he believed reasonably necessary to meet the attack.
See self-defence (Australia) for a comparative view on whether the use of excessive force causing death should give rise to a mitigatory defence and "Reform" below.
One recent case on using force against a burglar is Anthony Martin v R (2001) EWCA 2245,[2] which resulted in the householder being convicted.
Further, where the threat to the land or its possession is not immediate, and other measures could be taken that would make force unnecessary (e.g., calling the police or seeking remedies through the courts) the defence will normally be lost.
Although this case is on the specific interpretation of the statutory defence under §5 Criminal Damage Act 1971, the fact that the defendant was not "out of time" after nine months of inaction is interesting.