[2] Expanding on Lord John Holt's definition of intent in Cole v Turner, Lord Robert Goff's ruling in Collins v Wilcock narrowed the law.

[3] "An assault is committed when a person intentionally or recklessly harms someone indirectly.

A battery is committed when a person intentionally and recklessly harms someone directly."

It notes that the only distinction between common assault and causing actual bodily harm (under section 47 of the Offences Against the Person Act 1861) is the degree of injury.

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