'Mental harm' in s 21A of the Crimes Act 1958 (Vic) is not confined to medically diagnosed mental conditions but takes its ordinary English meaning. Posting multiple identical letters to different addressees on one occasion is capable of constituting a 'course of conduct' for stalking, as each act of posting to a different addressee may be treated as a separate piece of conduct. Where assault and obstruct police charges arise from the same incident, the jury must be clearly directed that evidence relied upon for the assault charges must not also be used to prove the obstruct charges, or convictions on the latter risk being quashed as involving double punishment.
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