It is well-recognised that a defendant can be responsible for deliberately inflicting harm on the claimant. In Wilkinson v Downton (1897) 66 LJQB 493 the defendant told the claimant, as a joke, that her husband had been badly injured in an accident. The claimant suffered nervous shock, for which the defendant was held liable. Thus liability can also arise where a defendant deliberately acts or makes a statement which is calculated to cause physical harm to the claimant and which does in fact achieve that result.