culpability it is more likely a 5 years imprisonment with a fine due to the fact the police officer The OAPA needs reforming and should be replaced with new legislation. To understand the charges under each section first the type of harm encompassed by these charges must be established. A two-inch bruise for example on said 20-year-old might be painful but not really serious, whereas on a new born baby this would likely be indicative of a very severe risk to the health of the child. In R v Bollom, it was also decided that the age and health of the victim should play a part in assessing the severity of the injuries caused. It was sufficient that they intended or could foresee that some harm would result. A R v Martin. Microeconomics - Lecture notes First year. Any information contained in this case summary does not constitute legal advice and should be treated as educational content only. carrying out his duty which she did not allow. R v Mandair (1994): on a s charge, a conviction under s is available as an alternative Following Ireland and Burstow this is definition is qualified in relation to psychiatric harm and there is no requirement for there to be any application of force whatsoever, either direct or indirect. prison, doing unpaid work in the community, obeying a curfew or paying a fine. The word grievous is taken to mean serious. To conclude, the OAPA clearly remains to be - infliction of physical force is not required R v Burstow 1998 - age and health of the victim, their 'real context' matters R v Bollom - includes biological harm R v Rowe 2017, intentional HIV infections. As the defendant was not used to handling the child he had no idea his conduct would cause the child harm. The difference between a The offence of battery is also defined in the Criminal Justice Act 1988, section 39. He put on a scary mask Case in Focus: R v Ireland and Burstow [1997] UKHL 34. R v BM [2018] EWCA 560 Crim 63 R v Bollom [2003] EWCA Crim 2846 70 R v Bourne [1938] 3 All ER 615 72, 79-80. foresee a risk or result and unreasonably go on to take the risk. directed by the doctor. For an essay question you may be asked whether you feel the two should be charged under the same offence given the difference in severity. In rejecting his appeal, the House of Lords extended the definition of inflict to situations where no physical force had been applied to the victim. Intention to resist or prevent the lawful apprehension or detainer of any person. To export a reference to this article please select a referencing style below: Free law resources to assist you with your LLB or SQE studies! The CPS Charging Standards seek to address this by stating that a minor injury as such should be bought under s.47 assault occasioning actual bodily harm, however these are just guidelines and are not legally binding. T v DPP (2003)- loss of consciousness In relation to this element of the mens rea, it is necessary for the prosecution also to prove the maliciously element. After all, inflicting the same injuries to a strong and healthy 21 year old and a frail 90 year old will usually result in very different levels of harm and so the law should reflect this. Lecture Notes - Psychology: Counseling Psychology Notes (Lecture 1), Pdf-order-block-smart-money-concepts compress, 04a Practice papers set 2 - Paper 1H - Solutions, Buckeye Chiller Systems and the Micro Fin Joint Venture Case Study Solution & Analysis, Phn tch im ging v khc nhau gia hng ha sc lao ng v hng ha thng thng, Multiple Choice Questions Chapter 1 What is Economics, Acoples-storz - info de acoples storz usados en la industria agropecuaria. The first indicator of lawfulness is that the detainment takes the form of an arrest. R v Bollom D harmed a baby VS CHARACTERISTICS CAN BE TAKEN INTO ACCOUNT R v Taylor's V was found with scratches but medical evidence couldn't tell how bad they were. Registered office: Creative Tower, Fujairah, PO Box 4422, UAE. words convey in their ordinary meaning. Section 18 offences are the most serious of the non-fatal offences against the person and often it is sheer luck on the part of the defendant that the victim does not die. To export a reference to this article please select a referencing stye below: UK law covers the laws and legislation of England, Wales, Northern Ireland and Scotland. was required a brain surgery which is a severe case. R v Bollom (2004) R v Dica (2004) JCC v Eisenhower (1983) R v Burstow (1997) R v Dica (2004) MR Intention or subjective recklessness to cause some harm R v Parmenter (1991) Trial and sentencing Triable either way offence - In Crown or Magistrates - Max sentence 5 years custodial For example, dangerous driving. This makes it clear that for the purposes of a s.18 offence indirect harm will definitely suffice. The offences against the person act 1861 is clearly outdated and is interpreted in many where the actus reus is the illegal conduct itself. Or can be reckless if high risk and consent is not sought for that risk R v Konzani 2005 [3] [25-28]. This includes any hurt calculated to interfere with the health or comfort of the victim. S.20 Offences Against The Persons Act - to unlawfully and maliciously wound or inflict any Grievous Bodily Harm without intent, A wounding is a break in all layers of the skin, There is no difference between serious and really serious harm, Accumulation of minor injury can amount to GBH, The court can take into consideration particular characteristics of the victim to decide whether the injuries amount to GBH, Psychiatric injury can amount to GBH - the woman was diagnosed with having a severe depressive illness, Possible to inflict biological GBH (by transmitting HIV or a similar STD, Foresight of some physical harm only is required, Did the D appreciate that there was some risk involved, Must foresee that some harm may be suffered, Only required to be foresight that some harm may occur, not that it would occur. community sentence-community sentences are imposed for offences which are too serious any person with intent to do some GBH to any person, or with intent to resist arrest or prevent Registered office: Creative Tower, Fujairah, PO Box 4422, UAE. defendant's actions. As with the proposed s.20 offence, any reference to wounding or bodily harm is removed. It was held on appeal that in the circumstances it was unnecessary to define malicious as harm was clearly intended, however Diplock LJ in obiter offered guidance in relation to the meaning of malicious under s.20 stating at paragraph 426. If the injuries are serious and permanent then they will amount to GBH, however permanence is not a pre requisite of GBH. The main issues with the current law can be identified as follows: This is another hot topic for an essay question on these offences. A report has been filed showing Oliver, one of Beths patients An intent to wound is insufficient. 26, Edis J (giving the judgment of the Court) said that R v Smith (Kim) "supports the proposition that this is the purpose of the tainted gift regime. Another way in which battery can occur is indirectly. It was a decision for the jury. Case in Focus: R v Mowatt [1968] 1 QB 421. Accordingly, inflict can be taken to mean the direct or indirect application of force, or the causing of psychiatric harm. However, a cut could theoretically suffice where the greater level of harm was the intention. the lawful apprehension of any person, shall be guilty. There are serious issues with the description of the harm the provisions encompass: -. The harm can result from physical violence, could include psychiatric harm and could even be cause by the victims own actions, where they try to escape from the apprehended unlawful force of the defendant. unless it can be established that the defendant was under a duty to care whereas a R v Briggs [2004] Crim LR 495. R v Brady (2006)- broken neck whether such harm would be caused., Whosoever shall unlawfully and maliciously inflict any grievous bodily harm on another care as a nurse because its her job to look after her patients and make sure they are safe, In order to address the many issues identified with the provisions, the Home Office presented a new draft Offences Against the Person Bill in 1998 which sought to mitigate the above issues. The injuries consisted of various bruises and abrasions. Case in Focus: R v Bollom [2003] EWCA Crim 2846, The defendant inflicted bruising on a 17-month-old child and was convicted of GBH. The defendant inflicted various injuries upon his partners seventeen month old child, including bruises and cuts. Before this acquisition A company issued to P, a bank, a debenture giving P a charge over the company's assets in respect of any sums Our academic writing and marking services can help you! There must be an intent to cause really serious bodily injury. I help people navigate their law degrees. In a problem question make sure to establish this point where a minor wound occurs as you need to show the examiner that you appreciate the difference between the Charging Standards and the binding legal definition of a wound. 2003-2023 Chegg Inc. All rights reserved. R v Bollom. For example, in relation to surgery, which in the absence of consent that would otherwise qualify as such unlawful harm. The actus reus of this offence can be broken down as follows: Inflicting harm is prima facie unlawful, therefore this requirement is satisfied simply in absence of an available defence such as self-defence or valid consent. Significance of V's age. and it must be a voluntary act that causes damage or harm. R v Morrison (1989) Therefore, through relevant sporting caselaw, it will be critically examined whether a participant's injury-causing act is an . R v Roberts (1972). All offences will start in the magistrates court regardless of how severe it is PART 2 - The House of Commons: The most powerful of Parliament's two houses. Inflict for this purpose simply means cause. Note that the issues set out above are just the issues taken from our discussion and are not a definitive list. Any other such detainment is unlikely to be lawful. subjective, not only on the foresight of the risk, but also on the reasonableness of the Actus reus is the Finally, a battery can also be caused by an omission. Such injuries would have been less serious on a grown adult, and the jury could properly allow for that. the two is the mens rea required. Reform and rehabilitate offenders by changing an offenders Examples of GBH R v Billinghurst (1978)- broken jaw R v Saunders (1985)- broken nose R v Jones and Others (1986)- broken nose and ruptured spleen R v Aitken and Others (1992)- burns . Grievous bodily harm (GBH) and Wounding are the most serious of the non-fatal offences against the person, charged under s.18 and s.20 of the Offences Against the Persons Act 1861. This is because, as confirmed in R v Bollom [2003] EWCA Crim 2846 an important consideration as to whether harm can be classed as grievous is dependent on the characteristics of the victim and therefore the law cannot reasonably provide a one size fits all list of injuries that this will encompass. We do not provide advice. R v Wilson [1984] AC 242 overruled Clarence in this regard and held this was not the case. Case Summary Match. This led to several people injuring themselves whilst trying to open the door. She succeeded in her case that the officer had committed battery, as he had gone beyond mere touching and had tried to restrain her, even though she was not being arrested. applying contemporary social standards, In deciding whether injuries are grievous, an assessment has to be made of the effect of the harm on verdict. Finally, the force which is threatened must be unlawful. The Court held on appeal that a jury should be able to take into account the unique circumstances of a victim and case in elevating a charge from ABH to GBH. The defendant felt threatened by the demands and knocked the victim to the floor, repeatedly punching him in the face. R v Bowen [1997] 1 WLR 372 R v Bowyer [2013] WLR(D) 130. One new video every week (I accept requests and reply to everything!) If the offence Learn. verdict 6 of 1980, A substantial loss of blood, usually requiring a transfusion, Those which require lengthy medical treatment or result in a period of incapacity, A permanent disability or loss of sensory functions, Dislocated joints, displaced limbs and fracturing to the skull. R v Clarence (1888) 22 QBD 23 presupposed that inflict required an assault to occur, and thus a husband who gave his wife a sexually transmitted disease could not be guilty as she did not know he had the disease and consented to the contact, negating the assault. Discharges are There is confusing terminology, especially with regards to maliciously and inflict. Jon, aged 14 decided to play a practical joke on his friend Zeika. D was convicted under section 18 of the Offences Against the Person Act 1861 for intentionally causing grievous bodily harm (GBH) D appealed on the basis that V's injuries did not . Facts The defendant inflicted various injuries upon his partner's seventeen month old child, including bruises and cuts. We grant these applications and deal with this matter as an appeal. Copyright 2023 StudeerSnel B.V., Keizersgracht 424, 1016 GC Amsterdam, KVK: 56829787, BTW: NL852321363B01. intended, for example R v Nedrick (1986). Due to his injury, he may experience memory Test. R v Bollom would back this case as her injury was Law; Criminal law; A2/A-level; OCR; Created by: 10dhall; Created on: 15-06-17 21:14; What happened in this case? for a discharge or a fine but not so serious that a sentence must be given. patients and direct them to the doctors when needed, because of Beths carelessness she LIST OF CASES, STATUTES AND STATUTORy INSTRUMENTS VII R v Brown [1993] UKHL 19 72, 74 R v Catt [2013] EWCA Crim 1187 6 R v Chan Fook [1994] 1 WLR 689 74 This was decided in the case of __DPP __v Smith, where the level of injury was said to be really serious harm. As with the law on ABH, the level of harm for GBH can include serious psychiatric injury. This is well illustrated by DPP v Smith, where the defendant cut off the victims pony tail and some hair from the top of her head without her consent. R V R (1991) Husband can be guilty of raping his wife. Breaking only one layer of skin would be insufficient, such as a cut to the inside of someones cheek. When that level of harm is inflicted on a person it is often left to fate as to whether or not it will prove fatal. In Collins v Wilcock, the defendant was a police officer who took hold of a womans arm in order to prevent her walking away from him as he was questioning her about alleged prostitution. harm shall be liable Any assault One can go even further in the definition of the battery and argue that the touching of the hem of a skirt constitues a battery. Despite being originally held not to be so in the case of R v Clarence (1888) 22 QBD 23, following R v Dica [2004] 3 ALL ER 593 Inflict now also encompasses the transmission of sexual diseases, such as HIV, where these are serious enough to be constituted as GBH, and the defendant is aware that there is a risk that they are suffering from the disease (R v Adaye (2004) unreported). At trial the judge directed the jury that must convict if the defendant should have foreseen that the handling of his infant son would result in some harm occurring to the child. Sometimes it is possible that an assault can be negated. Assault occurswhen a person intentionally or recklessly causes another to apprehend immediate unlawful personal violence. convicted of gbh s.18 oapa. "these injuries on a 6ft adult would be less serious than on the elderly or someone who is physically or psychiatrically vulnerable. turn Oliver as directed. It uses outdated language that is now misinterpreted in modern something back, for example, by the payment of compensation or through restorative justice. The actus reus for the offence can be broken down as follows: These criteria are satisfied in the same way as for the s.18 offence, with the only difference being in relation to the GBH which can be caused rather than inflicted. DPP v K (1990)- acid burns Regina v Bollom: CACD 8 Dec 2003. Whosoever shall be convicted upon an indictment of any assault occasioning actual bodily In deciding whether injuries are grievous, an assessment has to be made of, amongst other things, the effect of the harm on the particular individual. He was charged with the offence of administering a noxious substances s.23 Act which required the defendant to maliciously administer a noxious thing to endanger life or inflict GBH. Hide Show resource information. The defendant appealed contending that it was necessary to establish a subjective appreciation of the risk and not an objective ruling that he should have foreseen the risk of injury. The 20-year-old also has the physical capacity to suffer much more blood loss than an older person or a very small child before this becomes serious. Summary Week 1 Summary of the article "The Relationship between Theory and Policy in International Relations" by Stephen Walt, Critically analyse and compare Plato and Aristotles concept of the body and soul, 3 Phase Systems Tutorial No 1 Solutions v1 PDF, Pdf-order-block-smart-money-concepts compress, 04a Practice papers set 2 - Paper 1H - Solutions, Faktor-faktor yang mengakibatkan peristiwa 13 Mei 1969. It can be an act of commission or act of omission. unless done with a guilty mind. R v Lewis (1974) Which case decided that if GBH is used to escape arrest, it can be raised from S.20 GBH to S.18 GBH? the individual, R v Billinghurst (1978)- broken jaw Protect the public from the offender and from the risk of The first point is that the apprehension being prevented must be lawful. This is known as indirect or oblique intention. 41 Q Which case said that GBH can be committed indirectly? a 17 month old baby had bruising to her abdomen both arms and left legs d charged with s18 gbh. Bravery on the part of the victim doesnt negate the offence. It is the absolute maximum harm inflicted upon a person without it proving fatal. The offence does not have to be life-threatening and can include many minor injuries, not just one major one. be not directing Oliver to the doctors and her mens rea is that she couldn't be bothered to The maximum sentence was extended to reflect that it is more serious than a s.47 offence of assault occasioning actual bodily harm which at present carries an identical sentence to the s.20 offence, despite the difference in severity of harm caused. R v Belfon Judgment Weekly Law Reports Cited authorities 14 Cited in 15 Precedent Map Related Vincent Categories Tort Negligence Practice and Procedure Hearing Damages and Restitution Injuries Crime and Sentencing Offences against the Person [1976] EWCA Crim J0319-9 IN THE COURT OF APPEAL CRIMINAL DIVISION Royal Courts of Justice Before: malicious and not intended to hurt Zika, he has now caused her an injury by scaring her, This was reckless as proven by the actus reus but the men, Public law (Mark Elliot and Robert Thomas), Marketing Metrics (Phillip E. Pfeifer; David J. Reibstein; Paul W. Farris; Neil T. Bendle), Human Rights Law Directions (Howard Davis), Electric Machinery Fundamentals (Chapman Stephen J. R v Bollom. Whether a jury may consider a victims particular sensitivities and characteristics in assessing the extent of harm. that V should require treatment or that the harm should have lasting consequences ultimately, the Entertainment the Painful Process of Rethinking Consent, https://www.lawinsport.com/topics/item/the-role-and-extent-of-criminal-sanctions-in-sport#references, The Regulation of on-the-ball Offences: Challenges in Court, Perceptions of Playing Culture in Sport: The Problem of Diverse Opinion in the Light of Barnes. whilst attempting to arrest Janice.-- In Janices case, he is at fault here by hurng an officer of It is not unforeseeable that one of these will die as a result of the punch and sadly this often happens. Originally the case of R v Cunningham [1957] 2 QB 396 considered this in relation to the Offences Against the Persons Act 1861 and held it to mean intention or subjective recklessness. Costco The Challenge Of Entering The Mainland China Market Case Study Solution & Analysis, Acoples-storz - info de acoples storz usados en la industria agropecuaria. In finding whether that particular defendant foresaw the GBH as a virtually certain consequence of his actions, the jury are required to make this decision on an assessment of all of the evidence put before them. person shall be liable, For all practical purposes there is no difference between these two words the words cause and something and achieving the aim for example this is shown in the case of R v Mohan (1976) Actual bodily harm. . The facts of the cases of both men were similar. GBH = serious psychiatric injury. The aim of sentencing an offender is to punish the offender which can include going to For instance, there is no A fine and compensation-fines are the most common something and achieving the aim for example this is shown in the case of, however indirect intention is wanting to do something but the result was not what it was, foresee a risk or result and unreasonably go on to take the risk. She turned up at her sons work dressed in female clothes and he was humiliated. Balancing Conflicting Interests Between Human Rights. A battery may occur as part of a continuing act. His actus reus was pushing PC Adamski over and his mens rea was . The word actual indicates that the injury (although there Tragically he caused serious injuries to the bone structures in the limbs of his infant son and, as a result of the heavy way he had handled him, and he was convicted on four counts of causing GBH under s.20. apply the current law on specific non-fatal offences to each of the given case studies. Looking for a flexible role? DPP v Smith [1961] AC 290 explained that GBH should be given its ordinary and natural meaning, that is really serious harm. R v Aitken and Others (1992)- burns decides not to give a criminal conviction, they will be given a discharge. Examples where lawful force could be used might include force used in self-defence or defence of another, or where the force is threatened or used by a police officer in the execution of their duties. They can include words, actions, or even silence! whether bodily harm is grievous is based on the individual - D convicted of GBH under s.18 for injuries he inflicted on his partner's 17 month old daughter - assess individual situation - could not prove it was all from one offence, lesser offence of ABH was used . Although his intentions were not This was a joined appeal of the defendants Mr Ireland and Mr Burstow. In-house law team. but because she didn't do this it comes under negligence and a breach of duty. Simple and digestible information on studying law effectively. The officer cut her finger on the needle and the defendant was found by the court to be liable for battery, due to the omission. R v Burgess [1991] 2 WLR 1206. It should be noted that intention is a subjective concept and the court is concerned entirely with what the defendant was intending when he committed the offence and not what a reasonable person may have perceived him to be intending. community sentences however some offenders stay out of trouble after being released from d. Consent is no defence to inflicting actual bodily harm, grievous bodily harm or wounding i.e., ss 20 and 47 Offences Against the Person Act 1861 (OAPA) The defendant was convicted under s.18 OAPA 1861 but it was left open for the jury to consider an offence under s.20. Following the case law, it can be properly stated that the mens rea of maliciously is in other words, a foresight by the defendant of a risk of some harm occurring. R v Brown [1985] Crim LR 212. This would be a subjective recklessness as being a nurse she knew Flower; Graeme Henderson), Tort Law Directions (Vera Bermingham; Carol Brennan), Commercial Law (Eric Baskind; Greg Osborne; Lee Roach), Criminal Law (Robert Wilson; Peter Wolstenholme Young), Marketing Metrics (Phillip E. Pfeifer; David J. Reibstein; Paul W. Farris; Neil T. Bendle), Public law (Mark Elliot and Robert Thomas), Principles of Anatomy and Physiology (Gerard J. Tortora; Bryan H. Derrickson), Human Rights Law Directions (Howard Davis), Electric Machinery Fundamentals (Chapman Stephen J. The Court of Appeal therefore substituted a conviction for section 20 __GBH rather than section 18. Occasioning The normal rules of causation apply to determine whether ABH to V was occasioned by Ds assault. Flashcards. Zeika was so terrified, she turned to run and fell down the stairs, breaking her, top of the stairs, Zeika was bound to fall especially if she is a person who gets scared easily, The actus reus for Jon is putting on a scary mask and hiding at the top of the stairs and the. A prison sentence will also be given when the court believes the public must be ), Actual Bodily harm and Grievous Bodily Harm, Criminal-LAW- Revision Consent, Liability, Defences AND Causation, Criminal LAW Revision - Theft Robber Burglary Neccesity, Public Law (Constitutional, Administrative And Human Rights Law) (LA1020), Politics and International Relations (L200), Introduction to English Language (EN1023), Extensive lecture notes from the lectures Equity and Trust Law 2013/14 (64 pages), Macroeconomics Class - Complete Set Of Lecture Notes, Principles of Fashion Marketing- Marketing Audit Report, Endocrinology - Lecture notes 12,13,14,15, 314255810 02 Importance of Deen in Human Life, Introduction To Accounting Summary/Revision Notes, Changes in Key Theme - Psychology Revision for Component 2 OCR, Q1 Explain the relationship between resilience and mental wellbeing, Social Area - Psychology Revision for Component 2 OCR. unsatisfactory on the basis that it is unclear, uses old language and is structurally flawed. The defendant made it clear that it was never her intention to actually throw the glass or harm the victim in anyway. R v Bollom. Copyright 2003 - 2023 - LawTeacher is a trading name of Business Bliss Consultants FZE, a company registered in United Arab Emirates. A Causation- factual and legal. The non-fatal offences that I will describe in this video are assault, battery, assault occasioning actual bodily harm and grievous bodily harm/wounding. - no expectation of BODILY HARM -no need to look for good reason of activity, if did not foresee/intend ABH, for agreement to risk, must have actual knowledge of HIV and understand the implication - reckless transmission = GBH, Like Brown, activities unpredictably dangerous (criminal under article 8), must be a good reason for causing harm - sexual gratification is not a good reason, must be good reason - tattoo was done for end product and not sexual gratification, consent to rough and undisciplined horseplay is a defence (s.20) - had genuine belief (was reasonable) that he had consented to the throwing, if consent or belief in consent = no offence? 6 of 1980 have established that a person may give valid consent to GBH, but only where it is in the public interest for them to do so (see Chapter 4.1 for a more in-depth discussion as to this). Created by. For example, the actus reus of the offence of criminal damage is that property belonging to As the amount of hair was substantial, the Divisional Court decided that the hair-cutting should amount to ABH. swarb.co.uk is published by David Swarbrick of 10 Halifax Road, Brighouse, West Yorkshire, HD6 2AG. Back then infection was common as tetanus shots, antibiotics were not as readily available as they are today, and people did not possess the knowledge of sterilisation, sanitation and treating wounds that we hold at present. Accordingly, the defendant appealed. If you are considering attempting this topic in an exam, then it will pay to do some further reading and also to conduct your own critical analysis of the two provisions. Lord Roskill set out that GBH may be inflicted either where the defendant has directly and violently assaulted the victim, or where the defendant has inflicted it by intentionally doing an act which, although it is not in itself a direct application of force to the body of the victim, it directly results in force being applied to the body of the victim, so that they suffer grievous bodily harm. more and no less than really serious, It is not necessary that the harm should be either permanent or dangerous. Held: The judge had been correct to say that what constituted grievous bodily harm had to be looked at in the context of the person harmed. The offence of assault is defined in the Criminal Justice Act 1988, section 39. Woolf LCJ, Gibbs, Fulford JJ if(typeof ez_ad_units != 'undefined'){ez_ad_units.push([[320,100],'swarb_co_uk-medrectangle-3','ezslot_5',114,'0','0'])};__ez_fad_position('div-gpt-ad-swarb_co_uk-medrectangle-3-0'); Times 15-Dec-2003, [2004] 2 Cr App R 6if(typeof ez_ad_units != 'undefined'){ez_ad_units.push([[250,250],'swarb_co_uk-medrectangle-4','ezslot_4',113,'0','0'])};__ez_fad_position('div-gpt-ad-swarb_co_uk-medrectangle-4-0'); Cited Golding, Regina v CACD 8-May-2014 The defendant appealed against his conviction on a guilty plea, of inflicting grievous bodily harm under section 20. Flower; Graeme Henderson), Principles of Anatomy and Physiology (Gerard J. Tortora; Bryan H. Derrickson), Commercial Law (Eric Baskind; Greg Osborne; Lee Roach), Tort Law Directions (Vera Bermingham; Carol Brennan), Introductory Econometrics for Finance (Chris Brooks). This was decided in R v Burstow, where the victim suffered sever depression as a result of being stalked by the defendant. The position is therefore Grievous bodily harm/Wounding is also defined in the Offences Against the Person Act 1861. R v Brown [1993] 2 All ER 75. Temporary injuries can be sufficient.
r v bollom
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