This case established that psychiatric injury can constitute "bodily harm" under sections 20 and 47 of the Offences Against the Person Act 1861. It also confirmed that assault can be committed through words or silence, including repeated silent telephone calls, where the victim apprehends immediate and unlawful violence. The ruling modernised criminal law to recognise psychiatric harm and harassment as actionable offences. 

• Ireland: The appellant made numerous silent telephone calls to three women over several months, sometimes accompanied by heavy breathing. Psychiatric evidence showed the victims suffered anxiety and depressive illness. Ireland pleaded guilty to assault occasioning actual bodily harm (s47 OAPA 1861).

• Burstow: The appellant harassed a woman over eight months following the end of a social relationship. His acts included silent calls, menacing notes, offensive cards, appearing at her home and workplace, and taking photographs of her and her family. Psychiatric evidence showed she suffered severe depressive illness. Burstow pleaded guilty to unlawfully and maliciously inflicting grievous bodily harm (s20 OAPA 1861).

1. Whether psychiatric injury can amount to "bodily harm" under sections 20 and 47 OAPA 1861.

2. Whether repeated silent telephone calls causing psychiatric harm can constitute an assault under section 47.

3. Whether grievous bodily harm under s20 can be "inflicted" without direct or indirect physical violence.

Appeals dismissed. The House of Lords held:

1. Recognisable psychiatric illnesses qualify as "bodily harm" for the purposes of sections 20 and 47.

2. Assault can be committed by words or silence where the victim apprehends immediate and unlawful violence; silent telephone calls can satisfy this element depending on circumstances.

3. Section 20 "inflict" does not require direct or indirect physical violence; psychiatric injury caused by deliberate harassment satisfies the actus reus.

1. The law must be interpreted in light of contemporary scientific knowledge; psychiatric injury is encompassed by "bodily harm."

2. Assault includes acts causing the victim to apprehend immediate unlawful violence, including by telephone or silence.

3. "Inflict" in s20 is satisfied by causing harm, not necessarily through direct physical contact.

4. The rulings harmonise the statutory ladder of offences under the 1861 Act, recognising that modern forms of harassment and psychological harm are actionable.