WILLIAMS v. THE REPUBLIC

The Ghana Court of Appeal, per Mensa Boison J.A., heard the appeal of nursing officer Mariama Williams from her Sekondi High Court jury conviction for murdering her husband, Special Branch superintendent J.B. Lari. The couple’s marriage had deteriorated amid allegations that Lari had sexual relations with Williams’s daughter, Narki. After Lari rushed from Kumasi to Sekondi on 3 March 1979 and a pastor’s unsuccessful intervention, a violent nocturnal quarrel culminated in Lari suffering severe burns when his bedroom ignited; he died at Police Hospital, Accra. Williams variously denied setting the fire or admitted pouring what she thought was kerosene, and raised insanity and automatism. The Court of Appeal rejected complaints about insanity and automatism directions, but found the trial judge misdirected the jury by failing to require intent to cause death for murder, wrongly shifting the burden concerning petrol, and mishandling provocation by withdrawing key questions and omitting the community-standard test. The court set aside the murder conviction, substituted manslaughter, and imposed twelve years’ imprisonment.