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戈夫勋爵在他发表的一篇关于谋杀罪的法律的典雅而动人的演说中,他仍然期望扩大谋杀罪的精神要素的范围。戈夫认为,以故意杀人作为谋杀罪的定义过于狭窄,但反对把构成现行法律一部分的这一定义加以引伸。这种引伸是要把导致死亡的故意致人重伤包括在谋杀罪中。显然,这条引伸规则需要稍加限制;因而刑法修改委员会已经建议,这一精神要素应当限于罪犯明知这种伤害有造成死亡的危险的情况。戈夫勋爵仍然加以反对,其理由不是说
In his elegant and moving speech on the law of murder, Lord Goethe still expects to expand the sphere of the spiritual element of murder. Goff believes the definition of intentional murder as a murder is too narrow, but opposes extending the definition that forms part of the law in force. This extension is intended to include the willful and serious injury that led to death in the crime of murder. Obviously, the extension rule needs a bit more restriction; therefore, the Criminal Law Amendment Board has suggested that this spiritual element should be limited to situations in which criminals knowingly have the risk of causing such death. Lord Gove still disagreed, not for the reason