“Psychiatric injury can be actual bodily harm if more than emotions.”
Chan-Fook suspected the victim of stealing his fiancée's engagement ring. He dragged the victim upstairs, locked him in a room, and questioned him aggressively. The victim jumped from a window to escape, injuring himself. Evidence suggested psychiatric harm.
Whether psychiatric injury can constitute 'actual bodily harm' under s.47 Offences Against the Person Act 1861, and what threshold must be met.
The Court of Appeal held that psychiatric injury can constitute actual bodily harm, but it must be more than mere emotions such as fear, distress or panic.
This case was the first to clearly establish that psychiatric injury could constitute actual bodily harm, paving the way for later developments in Ireland/Burstow. It's crucial for understanding the modern scope of assault and battery offences.
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OSCOLA Citation
R v Chan-Fook [1994] 1 WLR 689 (CA)
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