## Facts

- The defendant, Bollom, was convicted of causing grievous bodily harm (GBH) to his partner’s 17-month-old child.
- The child sustained multiple bruises and marks on the body.
- Individually, each injury may not have been classified as severe for an adult.
- The Court of Appeal determined that the combined effect of the injuries, in light of the child’s age and fragility, satisfied the threshold for GBH.
- The initial conviction was overturned due to the trial judge’s inadequate directions to the jury regarding the relevance of the victim’s age in assessing the seriousness of harm.

## Issues

1. Whether injuries that are not individually severe can amount to GBH when regarded in combination.
2. Whether the victim’s age and health must be considered when determining if the injuries constitute GBH.
3. Whether the jury requires explicit instruction on considering the victim's specific vulnerability in GBH assessments.

## Decision

- The Court of Appeal held that GBH must be assessed in relation to the particular victim, including their age and health.
- Injuries that may be minor for a healthy adult could amount to GBH for a vulnerable person, such as a young child or elderly individual.
- The assessment of harm must be based on the cumulative impact of all injuries, not just on each injury individually.
- The failure of the trial judge to instruct the jury on the importance of the victim’s age required the initial conviction to be set aside.

## Legal Principles

- Grievous bodily harm is to be evaluated by considering the victim's circumstances, including age and health.
- Combined effects of injuries are relevant in determining whether harm is sufficiently serious to qualify as GBH.
- Legal protection is extended to vulnerable groups by recognising their increased susceptibility to harm.
- Accurate jury instructions are essential regarding the relevance of victim characteristics in GBH determinations.

## Conclusion

The decision in R v Bollom established that assessment of GBH must be individualized, factoring in the age and health of the victim and recognising that vulnerable individuals may suffer greater harm from injuries that might otherwise seem minor, thus shaping prosecutorial, defence, and judicial approach to such cases.


R v Bollom [2003] EWCA Crim 2846