“House of Lords clarifies intent requirements for assault causing bodily harm”
Savage threw beer over a woman in a pub, and the glass broke causing a cut to the victim's hand. Parmenter injured his baby son while playing roughly with him. Both defendants argued they lacked the necessary intent for the charges brought.
Whether the prosecution must prove that defendants intended or foresaw the actual bodily harm (s.47) or grievous bodily harm (s.20), or whether it suffices to prove intent or recklessness as to the underlying assault or battery.
For section 47 offences, the prosecution need only prove intent or recklessness as to the assault or battery that caused the actual bodily harm. For section 20 offences, the prosecution must prove intent or recklessness as to some harm, though not necessarily grievous bodily harm.
This decision established the definitive interpretation of mental elements in non-fatal offences and remains the leading authority on the intent requirements for sections 47 and 20 of the 1861 Act.
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OSCOLA Citation
R v Savage; R v Parmenter [1992] 1 AC 699 (HL)
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