In Roberts v Ramsbottom [1980] 1 All ER 7, the defendant, an elderly man, suffered a stroke whilst driving his car. As a result there was an accident and the claimant sustained an injury. The court held that the defendant was negligent; he had to be judged according to the standard of the reasonable competent driver. Emphasis was placed on whether he should have stopped the car as soon as he realised that his driving was being affected. Neill J held that the defendant could only escape liability if the incapacity amounted to automatism (a defence in criminal law that requires a total loss of consciousness or control).