R v Ireland [1998] AC 147

House of Lords

Facts: The defendant (D) made a series of silent phone calls to three different women, causing them psychological harm, including anxiety and depression. D was charged with assault occasioning actual bodily harm (ABH) under s47 of the Offences Against the Person Act 1861. The issue was whether silent phone calls could amount to an assault and whether psychiatric harm could be considered "bodily harm."

Held: The House of Lords ruled that silent phone calls could indeed constitute an assault if they caused the victim to apprehend immediate and unlawful violence. The court further held that psychiatric injury could qualify as "actual bodily harm" under s47.

💡Levelup: This case significantly expanded the scope of assault, establishing that silence and psychological harm can amount to an assault if they cause fear of immediate harm. It marked a major development in recognizing the impact of harassment and psychological abuse.