ABSTRACT
For many years, it was uncertain whether words alone could constitute an assault (R v Meade and Belt (1823); R v Wilson (1955)). However, it seems settled that words can
negate an assault (Tuberville v Savage (1669)). Moreover, in R v Burstow; R v Ireland (1997), the House of Lords held that an assault could be committed by words alone, thus ending this long standing uncertainty. The emphasis is now on the effect of the defendant’s actions on the victim, rather than the means adopted by the defendant.
