T v DPP – Case Summary

T v Director of Public Prosecutions

High Court

Citations: [2003] EWHC 266.


The victim was approached by a group of boys, who began attacking him. The victim attempted to escape, but fell. The defendant, one of the boys, kicked the victim so hard he lost consciousness for a brief amount of time. A police officer then intervened to stop the attack.

The defendant was convicted of assault occasioning actual bodily harm. He appealed his conviction. He argued that he had not caused actual bodily harm to the victim.

  1. Did a brief loss of consciousness amount to actual bodily harm?

The High Court held that a brief loss of consciousness could amount to actual bodily harm.

This Case is Authority For…

Actual bodily harm is an everyday phrase. Juries normally should not need specific direction on its meaning. It will general cover all injuries which are not so trivial as to be wholly insignificant.


Actual bodily harm includes brief losses of consciousness.