<P> Wounding does not imply the use of a weapon; a kick may be wounding . </P> <P> Grievous bodily harm means "really serious bodily harm": DPP v Smith (1961) AC 290, HL; R v Cunningham (1982) AC 566, HL; R v Brown (A) (1994) 1 AC 212, HL; R v Brown and Stratton (1998) Crim LR 485, CA . It encompasses a range of injuries: R v Woodland (2007) 48 MVR 360 . </P> <P> However, R v Saunders (1985) Crim LR 230, (1985) LS Gaz R 1005, allows "serious injury" as a sufficient direction to the jury . It is for the judge to decide whether the word "really" needs to be used in their direction to the jury: R v Janjua and Choudhury (1999) 1 Cr App R 91, The Times, 8 May 1998, CA (in this case, as a knife with a blade at least 51⁄2 inches long had been used, it was not possible that something less than really serious harm was intended). </P> <P> Where, shortly before the conclusion of a performance at a theatre, the defendant put out the lights on a staircase which a large number of persons had to descend in order to leave the theatre, and he also obstructed the exit by placing an iron bar across a doorway which they had in leaving to pass, and upon the lights being thus extinguished, a large proportion of the audience were seized by panic and rushed in fright down the staircase forcing those in front against the iron bar, he "inflicted" injuries which resulted by reason of the pressure and struggling of the crowd thus created on the staircase . </P>

Section 18 offences against the person act 1861 sentencing