R v Burstow [1998] AC 147

House of Lords

Facts: D engaged in a prolonged campaign of harassment against V, which included making silent phone calls, sending menacing letters, and following her. As a result, V suffered from severe psychological harm, including depression. D was charged under s20 of the Offences Against the Person Act 1861 for inflicting grievous bodily harm (GBH).

Held: The House of Lords upheld D's conviction, ruling that psychiatric injury could amount to GBH under s20. The court also clarified that the word "inflict" in s20 simply means "cause," and that it does not require a direct application of force.

💡Levelup: This case broadened the interpretation of "inflict" in the context of GBH to include indirect violence and affirmed that psychiatric injury can be treated as grievous bodily harm under s20.