Whether property is damaged is a question of fact and degree. In Samuels v Stubbs [1972] 4 SASR 200, the court considered that it was difficult to lay down a general rule as to what constitutes damage. It held that it must be guided by the circumstances of each case, the nature of the article, and the mode by which it was affected. The court stated:

'[T]he word … is sufficiently wide in its meaning to embrace injury, mischief or harm done to property, and that in order to constitute damage it is unnecessary to establish such definite or actual damage as renders the property useless or prevents it from serving its normal function …'