This case stands for:
Bastarache preferred to define automatism as a state of impaired consciousness, rather than unconsciousness, in which an individual is capable of action but has no voluntary control over that action. He also held that the accused had to prove any defence of automatism on a balance of probabilities.
A lack of voluntariness is not the same as a lack of mens rea. There can be a voluntary act without there being mens rea.
Involuntariness is a more fundamental defect than lack of mens rea. There is not even an actus reus. You cannot be said to “have shot” someone if doing the act was beyond your control (such as when a stronger person forces your hand).
The law holds people to account for acts that they think they can control. This is the basic definition of “voluntary” that circumvents any controversies between proponents of determinism vs. free will.
R. v. Lucki  17 W.W.R. 446 (Sask. Pol. Ct.)
In icy conditions, a motorist ended up on the wrong side of the road and collided with an oncoming car.
Is the motorist liable for the accident?
No. Not guilty.
A person who by an involuntary act for which he is not to blame gets onto the wrong side of the road is not guilty under the section in question.
What conceivable purpose can legitimately be served by imposing a sentence on someone who can't control his actions?
R. v. Wolfe  20 C.C.C. (2d) 382 (Ont. C.A.)
Wolfe had good reason to not want the complainant in his bar. The complainant came to the bar and refused to leave. As Wolfe was calling the cops, the complainant punched him and Wolfe turned in a reflex action and struck the complainant in the head with the telephone receiver. Wolfe was charged with assault causing bodily harm.
Is Wolfe liable for the injuries that the complainant suffered?
No. Appeal allowed; trial decision overturned.
As a finding of fact, the trial judge characterized the receiver incident as a reflex action on Wolfe’s part so the necessary ingredient of intent is lacking in order to uphold this charge.
R. v. Ryan  40 A.L.J.R. 488 (Aus. H.C.)