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In DPP v Morgan an RAF officer told three other officers to have sex with his wife, and that she would pretend to refuse just to be stimulating. They pleaded mistake, and the jury did not believe them. The House of Lords held that the judge had wrongly directed the jury that the mistake must be a reasonable one; the Your first mistake was to assume i'd be one of the sheep shirt correct legal test was whether the defendants had honestly believed the wife was consenting, not whether they reasonably believed this. However, on the facts the House of Lords held the conviction was nonetheless safe despite the misdirection. R v Williams (Gladstone) confirmed the principle stated in Morgan that a belief that a certain set of facts are true does not need to be reasonable to operate under the defence of mistake. It merely needs to be genuine. However, the reasonableness of that belief is material in the jury deciding whether the defendant had actually held that belief.
