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In our opinion, grievous bodily harm may be inflicted ... either where the accused has directly and violently "inflicted" it by assaulting the victim, or where the accused has "inflicted" it by doing something, intentionally, which, although it is not itself a direct application of force to the body of the victim, does directly result in force being applied violently to the body of the victim, so that he suffers grievous bodily harm. Before 1983 In R v Clarence,[16] it appeared that at a time when the prisoner knew, but his wife did not know, that he was suffering from gonorrhoea, he had "connection" with her; that the result was that the disease was communicated to her, and that had she been aware of the prisoner's condition she would not have submitted to the intercourse. Clarence's conviction under section 20 was quashed by the Court for Crown Cases Reserved by a majority of 9 to 4. Wills,[17] A. L. Smith,[18] and Stephen[19] JJ specifically said that they thought the disease had not been inflicted within the meaning of the word "inflict" in section 20. Mathew J[20] said that he agreed with Stephen. Stephen[21] said that he had been informed that Grantham J agreed with him. Huddleston B[22] said that he thoroughly agreed with Stephen. Lord Coleridge CJ[23] said that he agreed with all or almost all of what Wills and Stephen said. Hawkins J[24] specifically said that he thought it had been inflicted within the meaning of the word "inflict" in sectio
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