staircase forcing those in front against the iron bar; he "inflicted" injuries which resulted by reason of the pressure and struggling of the crowd thus created on the staircase. David Ormerod said that the effect of the decision in R v Gibbins and Proctor appears to be that the offence of causing grievous bodily harm under section 18 can be committed by an omission. In R v Mandair, Lord Mackay of Clashfern LC said, with the agreement of the majority of the House of Lords, "In my opinion ... the word 'cause' is wider or at least not narrower than the word 'inflict. In R v Burstow, R v Ireland, it was held that an offence of inflicting grievous bodily harm under section 20 of the Offences against the Person Act 1861 can be committed where no physical violence is applied directly or indirectly to the body of the victim. Lord Hope of Craighead said "the word 'inflict' implies that the consequence of the act is something which the victim is likely to find unpleasant or harmful." He said that, in the context of a criminal act, the words "cause" and "inflict" may be taken to be interchangeable. Lord Steyn described the actions of Burstow as follows: "During an eight-month period in 1995 covered by the indictment he continued his campaign of harassment. He made some silent telephone calls to her. He also made abusive calls to her. He distributed offensive cards in the street where she lived. He was frequently, and unnecessarily, at her home and place of work. He surreptitiously took photographs of the victim and her family. He sent her a note which was intended to be menacing, and was so understood." Neither offence requires that a common assault be committed. 1983 to 1997 In R v Wilson, R v Jenkins, Lord Roskill said: Before 1983 In R v Clarence, it appeared that at a time when the prisoner knew, but his wife did not know, that he was suffering from gonorrhoea, he had "connection" with her; that the result was that the disease was communicated to her, and that had she been aware of the prisoner's condition she would not have submitted to the intercourse. Clarence's conviction under section 20 was quashed by the Court for Crown Cases Reserved by a majority of 9 to 4. Wills, A. L. Smith, and Stephen JJ specifically said that