JCC (A Minor) v Eisenhower

A wound requires a break in the continuity of the whole skin, so internal bleeding is not a wound.

Citation
[1984] QB 331
Court
Divisional Court
Year
1984
Subject
Criminal Law
Topic
Non-fatal offences against the person

Facts

JCC, a youth, fired an air gun at a group of people, and a pellet hit the victim near his eye. The pellet caused a bruise and the rupture of a blood vessel in the eye, causing internal bleeding, but did not break the outer skin. JCC was convicted of unlawfully and maliciously wounding under section 20 of the Offences Against the Person Act 1861.

Legal principle

The Divisional Court quashed the conviction. Robert Goff LJ said that a wound, for the purposes of the 1861 Act, requires a break in the continuity of the whole skin, including both the outer and inner layers. Internal bleeding caused by the rupture of a blood vessel, without a break in the skin, is not a wound. A cut on the inside of the lip or cheek, where there is a break in the mucous membrane, may however be a wound.

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