The recklessness sufficient for this offence as laid down by the House
of Lords in Caldwell has been modified and clarified by the Court of
Appeal to take account of observations in Reid on reckless driving, bu
t only partially. The unsatisfactory distinctions produced by the hybr
id nature of the offence in Criminal Damage Act 1971, s. 1 (2) have be
en highlighted by recent decisions; and the question of how far reckle
ssness suffices for an attempt at the offence has been clarified but,
it is submitted, in a less than completely satisfactory way.