Assault

• S39 Criminal Justice Act 1988. 
• Intention (Mohan)
• Intentionally or recklessly causing someone to apprehend immediate unlawful violence. 
• D was subjectively reckless to putting the victim in fear of immediate unlawful violence (Cunningham)  
• Can be through words (Constanza)
• silence (Ireland)
• Immediate meaning V does not know what defendent will do next (Smith)
• no immediate threat= no assault (Tubervile)