[1][2] The case defendant landlady of a farmhouse (which was let to students and which she visited infrequently) was charged under a 1965 Act "of having been concerned in the management of premises used for smoking cannabis".
[3][4] Even though she had neither knowledge of nor privity with the offence, it took place on her property and at first instance she was convicted, being deemed "liable without fault".
This conviction was later quashed by the House of Lords on the grounds that knowledge of the use of the premises was essential to the offence.
[1] Effectively the absence of express words imposing the requirement of proving mens rea is not conclusive that the offence is one of strict liability.
[2] Lord Reid declared: ... there has for centuries been a presumption that Parliament did not intend to make criminals of persons who were in no way blameworthy in what they did.