R v Wilson [1984] AC 242
Whether force can be indirectly, as well as directly, applied to satisfy the meaning of ‘inflict’ for a s. 20 charge of grievous bodily harm, and whether an initial assault must first be established.
Facts
The defendant nearly hit a pedestrian, the victim, with their vehicle and an altercation between the two subsequently ensued. The argument became heated and the defendant subsequently punched the victim.
Issues
Could a charge of GBH be brought under s. 20 of the Offences Against the Person Act where an initial assault has not been established. Moreover, was it correct that a jury, when considering the verdict for a person primarily charged with GBH under s. 20, could instead return a guilty verdict for the lesser charge of actual bodily harm under s. 47.
Decision/Outcome
The Court found that both ABH and GBH charges could successfully be brought under such circumstances, as both charges implied a claim of assault causing actual bodily harm. Here, Lord Roskill, delivering the leading judgment, cited with approval the earlier case of R v Salisbury [1976] VR 452, noting:
‘grievous bodily harm may be inflicted, contrary to [section 20], either where the accused has directly and violently ‘inflicted’ it by assaulting the victim, or where the accused has ‘inflicted’ it by doing something, intentionally, which, though it is not itself a direct application of force to the body of the victim, it does directly result in force being directly applied violently to the body of the victim so that he suffers grievous bodily harm’ ([251]).
Words: 261
Updated 20 March 2026
This article accurately summarises the House of Lords’ decision in R v Wilson [1984] AC 242. The case remains good law and is still regularly cited in discussions of the Offences Against the Person Act 1861, ss. 20 and 47.
Readers should note one important subsequent development: the interpretation of ‘inflict’ under s. 20 was further considered by the House of Lords in R v Ireland; R v Burstow [1998] AC 147, which confirmed that ‘inflict’ does not require a technical assault or the direct application of force, and that psychiatric injury can constitute grievous bodily harm. This later decision builds upon and extends the reasoning in Wilson rather than undermining it, but students should read both cases together for a complete picture of the current law on s. 20. The Offences Against the Person Act 1861 itself remains unreformed in this area.
