This can be further evidenced by the case of R v Burstow, where the accused made nuisance telephone calls, but never actually attacked the victim. The House of Lords upheld the conviction for inflicting grievous bodily harm (psychological injury). The House of Lords held that 'inflict' did not require an assault to be committed first. Essentially therefore infliction now bears the same meaning as 'cause' and the normal rules of causation should apply.