The phrase 'I will fuck you up', while too imprecise in isolation to constitute a threat to inflict serious injury under s 21 of the Crimes Act 1958 (Vic), can satisfy the actus reus when viewed in the context of surrounding conduct including stalking and aggravated burglary. The Hogarth principles regarding confrontational aggravated burglary apply to intimate-partner contexts, and general deterrence is paramount in such cases. Stalking by covert surveillance devices where the offender never intended the victim to discover the devices warrants a lower sentence than stalking involving direct confrontation.
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