Regina v Burke (Michael) [2012] EWCA Crim 770; [2012] WLR (D) 119
“Where a defendant had been charged with an offence of voyeurism but had been found to be under a disability so that he was unfit to plead or to stand trial, the ingredients of ‘the act…charged against him as the offence’, for the purposes of section 4A(2) of the Criminal Procedure (Insanity) Act 1964, included a requirement to prove that his act had been for the purpose of sexual gratification.”
WLR Daily, 20th April 2012
Source: www.iclr.co.uk