The age of the victim is relevant to whether an injury amounts to grievous bodily harm, but only insofar as the injury itself is more serious due to the victim's age (e.g., affecting capacity to heal), not because of the culpability of injuring a young child. Real (as opposed to speculative) risks of future harm are informative of the seriousness of an actual injury, but a finding of grievous bodily harm cannot rest solely on speculative future harm. In circumstantial cases involving multiple injuries to a child, the Crown must prove beyond reasonable doubt that the specific injury relied upon as grievous bodily harm occurred within the particularised time period, even where other non-accidental injuries are established.
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