Regina v. Cunningham (1957) is an English Court of Appeal ruling that clarified that indirect, not reasonably foreseeable consequences to a totally distinct, reprehensible, even "wicked" activity would not be considered "malicious" where that is set out as the mens rea for a particular offence.

[2] The level of mens rea, by statute, specifically needed to accompany "administration", which it was common ground that negligent release would amount to, of noxious gases.

The precedent value of the case has been applied to broadly analogous situations and rules where an enhanced mens rea is required for a particular class of offence to be proven.

The trial judge explained the word "maliciously" to mean general wickedness, and because of that as to stealing the money from the gas meter the mens rea for the crime was present.

Other cases give greater insight as to relevance of oblique, sufficiently proven, intentions and examples of motives which would be considered malicious for particular crimes having that specified mens rea.