The previous chapter explained the different types of mens rea. This chapter considers those offences where mens rea is not required in respect of at least one aspect of the actus reus. Such offences are known as strict liability offences. The ‘modern’ type of strict liability offence was first created in the mid-nineteenth century. The first known case on strict liability is thought to be Woodrow (1846) 15 M & W 404. In that case the defendant was convicted of having in his possession adulterated tobacco, even though he did not know that it was adulterated. The judge, Parke B, ruled that he was guilty even if a ‘nice chemical analysis’ was needed to discover that the tobacco was adulterated. The concept of strict liability appears to contradict the basis of criminal law. Normally criminal law is thought to be based on the culpability of the accused. In strict liability offences there may be no blameworthiness on the part of the defendant. The defendant, as in Woodrow, is guilty simply because he has done a prohibited act. A more modern example demonstrating this is Pharmaceutical Society of Great Britain v Storkwain Ltd  2 All ER 635.