Causing the victim to apprehend violence

There is no need for physical contact between defendant and victim. The acts or words must cause the victim to fear that immediate force is going to be used against them.

In Logdon (1976) the defendant pointed a replica gun at the victim as a joke, the victim was terrified, it was held victim had apprehended immediate physical violence and the defendant had been reckless as to whether this would occur.

Emphasis is on what the victim thought was about to happen (Smith v Chief Superintendent of Woking Police Station (1983)).

Words alone or even silence can constitute assault. In Ireland (1997) the defendant terrorised the victim, who suffered psychiatric injury, with silent phone calls.

Written words may be enough. In Constanza (1997) the defendant stalked the victim, sending her over 800 letters in a period of 4 months and it was held the content of the letters were assaults as the victim read them as threats. Words can also make clear an assault is not imminent (Tuberville v Savage (1669)).

Immediate violence

Courts take a fairly liberal approach to meaning of immediate , in order to give justice to the victim.

It was noted .. when one is in a state of terror, one is very often unable to analyse precisely what one is frightened of as likely to happen next.. (Smith v Chief Superintendent of Woking Police Station (1983)).

In Ireland (1997) immediacy was found in the phone calls made by the defendant as the victim may fear the purpose of the call was to establish whether she was at home.

Unlawful violence

Threatened violence must be unlawful. A policeman may threaten to handcuff or restrain if someone resists arrest and this is not an unlawful action.