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Assaults- actusreus

breakingboth layers of the skin or "grievousbodily harm'. DPP v Smith [196U "grievousmeans no more and no lessthan 'really serious"', R v Saunders [1985] the word "seriously"could safely be omitted, R v Janiua (1998); R v Choudhury (1998) the trialjudge should decidewhether or not to include "really" R v Brown & Stratton lL99Bf whether the injury amountsto grievousor merely actual bodily harm is to be judged objectively accordingto the standards of ordinary usage and experience. Grievous Bodily Harm with intent Sections 18

SectionlS: "Whosoevershall unlawfully and maliciously by any means whatsoever wound or cause any grievous bodily harm to any person with intent to do some grievous bodily harm to any person or with intent to resist or prevent the lawful apprehensionor detainer of any person,shall be guilty of an offenee,and being csnvicted theresf shall be liable to imprisonmentfor life" Thereare four offencesunder this section: (a) Woundor (b) causeany grievousbodilyharm to any person with intent to do somegrievousbodily harm to any person and , or with intent to resist or prevent the lawfulapprehension or detainerof any p e rs o n . . . CPS Code Section 18 The greater rnens rea requirement in section 18 means that it should be reserved for the more serious cases,as where there is: a repeated or planned attack; deliberate selection of a weapon or adaptation of an article to cause injury, such as breakinga glassbefore an attack; making prior threats; or using an offensive weapon against, or kicking,the victim's head. Note also that the ulterior intent in section 18 may consist of an intent to resist or prevent the lawful apprehensionor detainer of any person,and in these easesthere must obviously be evidence of such an intent.