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R v Constanza [1997] Crim LR 576.

The defendant mounted a campaign of hate against an ex-work colleague over a period of 20 months. He sent over 800 threatening letters, would follow her home, wrote offensive word on her front door, drove past her house, stole items from her washing line. As a result she suffered clinical depression. He was charged with ABH under s.47 OAPA 1861. The defendant contended that words alone could not amount to an assault and that the letters could not amount to an assault as there was no immediacy.


The defendant's conviction was upheld.

The jury were entitled in the circumstances to find that immediacy was present and words can amount to an assault. Meade & Belt overruled.
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