 In Hill v Baxter, Kilmuir, LC, explained the need of eliminating automatism, defined as "the existence in any person of behaviour of which he is unaware and over which he has no conscious control,"

Therefore, a somnambulist or a person under the influence of hypnosis or any other automatic phenomena who steals a property, commits a monetary fraud or participates in any other criminal act will be excluded from actus reus as he has performed the illicit act in a state of unconsciousness.Spiritualism is a belief that the spirits of the dead communicate with the living world.It is essential not to confuse it with 'spirituality'.