(Latin for "guilty mind"), R v. Cunningham (1957) 2 AER 412 was the pivotal case in establishing both that the test for "maliciously" was subjective rather than objective, and that malice was inevitably linked to recklessness. In that case, a man released gas from the mains into adjoining houses while attempting to steal money from the pay-meter:

In any statutory definition of a crime, malice must be taken ... as requiring either:
# an actual intention to do the particular kind of harm that in fact was done; or
# recklessness as to whether such harm should occur or not (i.e. the accused has foreseen that the particular kind of harm might be done and yet has gone on to take the risk of it).