the Serious Organized Crime Agency and was repealed when that agency was abolished. England and Wales English law provides for two offences of assault: common assault and battery. Assault (or common assault) is committed if one intentionally or recklessly causes another person to apprehend immediate and unlawful personal violence. Violence in this context means any unlawful touching, though there is some debate over whether the touching must also be hostile. The terms "assault" and "common assault" often encompass the separate offence of battery, even in statutory settings such as s 40(3)(a) of the Criminal Justice Act 1988. A common assault is an assault that lacks any of the aggravating features which Parliament has deemed serious enough to deserve a higher penalty. Section 39 of the Criminal Justice Act 1988 provides that common assault, like battery, is triable only in the magistrates' court in England and Wales (unless it is linked to a more serious offence, which is triable in the Crown Court). Additionally, if a defendant has been charged on an indictment with assault occasioning actual bodily harm (ABH), or racially/religiously aggravated assault, then a jury in the Crown Court may acquit the defendant of the more serious offence, but still convict of common assault if it finds common assault has been committed. Aggravated assault An assault which is aggravated by the scale of the injuries inflicted may be charged as offences causing "actual bodily harm" (ABH) or, in the severest cases, "grievous bodily harm" (GBH). Assault occasioning actual bodily harm The offence of is created by section 47 of the Offences against the Person Act 1861. Inflicting grievous bodily harm Also referred to as "malicious wounding" or "unlawful wounding". This offence is created by section 20 of the Offences against the Person Act 1861. Causing grievous bodily harm with intent Also referred to as "wounding with intent". This offence is created by section 18 of the Offences against the Person Act 1861. Other aggravated assault charges refer to assaults carried out against a specific target or with a specific intent: Assault with intent to rob The penalty for assault with intent to rob, a common law offence, is provided by section 8(2) of the Theft Act 1968. Racially or religiously aggravated common assault This offence is created by section 29(1)(c) of the Crime and Disorder Act 1998. Racially or religiously aggravated assault occasioning actual bodily harm This offence is