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In R v Mowatt [1968] 1 QB 421; [1967] 3 All ER 47, it was

held that the word 'maliciously' imports an awareness


that the act may have the consequence of causing
physical harm to some person.
A breaking implies an injury whereby the skin is broken
either externally, or internally, eg a 'skin' within the
mouth: see Moriarty v Brooks (1834) 6 C & P 684.
'Grievous bodily harm' simply means bodily harm that is
really serious: Director of Public Prosecutions v Smith
[1961] AC 290 at 334;
Provocation and reaction to anothers aggression, though
not defenses either to wounding or to wounding with
intent, may have an impact upon sentence: HKSAR v
Yuen Wai Kui (unrep., CACC 280/2004, [2005] HKEC 630).
HKSAR v Jiang Guohua (unrep., CACC No 302 of 2004)
Court accetped provocation, though not a defence to
wounding might provide some mitigation to sentence.
Grievous bodily harm should be given its ordinary and
natural meaning of really serious bodily harm, and it is
undesirable to attempt any further definition of it: DPP v
Smith [1961] AC 290, HL; R v Cunningham [1982] AC 566,
HL
Diplock LJ in R v Mowatt [1968] 1 QB 421 at 426, to the
effect that where the evidence shows that the physical
act which caused the injury was a direct assault that any
ordinary person would be bound to realise was likely to
cause some physical harm, and the defence is that the
defendant did not do the alleged act or that it was done

in self-defence, it is unnecessary to deal specifically with


the meaning of the word maliciously.

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