Jack Trevor (Steane) was an actor living in Germany leading into World War II with his wife and children.

Goddard also referred to duress as a possible defence but ruled that it was unnecessary to consider it because of the particular conditions pertaining while he was under the control of an enemy power.

In support a legal academic has published that applying too rigid a definition of intent/intention would remove "moral elbow-room" from the jury.

[1] Much opprobrium is expressed that R v Steane on its face extends the traditional definition of criminal liability by adding a criterion of true or moral purpose to offences for which a specific intent must be shown (not just actus reus and mens rea).

[2] In R v Howe, Bannister & Burke (R v Clarkson) conjoined appeals[3] the highest domestic court held that co-murderers were liable even if they acted under a threat to their own lives, the idea of purpose being considered irrelevant, arguably obiter as the certified questions for the consecutive appeals were limited to duress — leave for such a question was denied from the senior courts as to any "oblique purpose" in the more common context of a set of facts of a violent offence.