assault

• s39 criminal justice act 1988
• intentionally or recklessly making the victim apprehend immediate unlawful personal violence
• actus reus - act of putting victim in fear
• words written or spoken can be assault (Constanza)
• silent phone calls (Ireland)
• fear of what the D may do next is immediate (Smith)
• if there's no clear threat then there's no assault (Tuberville)
• mens rea - intentionally or subjectively recklessly putting V in fear of immediate unlawful personal violence
• intention (Mohan)
• subjective recklessness (Cunningham)