#crime #law #oapa
In R v Wilson  1 All ER 744 Lord Goddard stated that the words 'get out the knives' would, on their own, be sufficient to constitute an assault. This opinion was merely obiter. The issue does appear to have been resolved in the decision on R v Ireland; Burstow  AC 147. Technically, on this issue, the comments made by their Lordships were obiter since the defendants in these two cases had repeatedly made silent telephone calls to their victims. No words had been spoken. Lord Hope of Craighead believed that silence conveyed a message to the victim and as such was capable of forming the basis of an assault.
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