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R v Mowatt [1968]

Facts

  • The defendant repeatedly hit a police officer in the face
  • He was convicted under section 20 OAPA (inflicting grievous bodily harm)

Issue

  • What was the meaning of ‘malicious’ under section 20?

Decision

  • Foreseeing some harm

Reasoning

  • The gravity of harm need not be foreseen for a section 20 conviction
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