A transverse process fracture of a vertebra described by the treating doctor as 'minor' (3/10 severity), requiring no operative treatment, no ongoing medical consultation, no permanent injury, and involving only short-term hospitalisation, does not constitute 'grievous bodily harm' (really serious bodily injury) even where the victim experienced pain for several weeks and some residual pain at trial. Garling J (in obiter, with R A Hulme J expressly declining to address the point) held that only the injury itself and its direct physical effects — not personal, social or economic consequences — are relevant to the grievous bodily harm assessment.
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