He went on to say: He said that juries "should not be directed that an assault which causes a hysterical and nervous condition is an assault occasioning actual bodily harm". This was followed by the Court of Appeal in R v Constanza, and the House of Lords which confirmed the principle in R v Burstow, R v Ireland. Ireland caused three women to develop psychiatric illnesses. Burstow's victim was fearful of personal violence and was diagnosed with a severe depressive illness. The best medical practice today accepts a link between the body and psychiatric injury, so the words "bodily harm" in sections 20 and 47 were capable of covering recognised psychiatric illnesses, such as an anxiety disorders or a depressive disorder, which affect the central nervous system of the body. However, to qualify, those neuroses must be more than simple states of fear, or problems in coping with everyday life, which do not amount to psychiatric illnesses. Venereal and other communicable disease See R v. Dica [2004] EWCA Crim 1103 The Law Commission stated its view that "the deliberate or reckless causing of disease should not be beyond the reach of the criminal law" and there is continuing debate over whether the transmission of HIV is covered as grievous bodily harm or under sections 22 to 24 of the Offences against the Person Act 1861. In R v Clarence, it appeared that at a time when the prisoner knew, but his wife did not know, that he had 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. Lord Coleridge CJ., Pollock and Huddleston BB., Stephen, Manisty, Mathew, A L Smith, Wills and Grantham JJ., held that the conduct of the prisoner did not amount to an offence under either section 20 or section 47. Field, Hawkins, Day and Charles JJ. dissented. Wills J. said "the facts are ... that he infected her, and that from such infection she suffered grievous bodily harm". Hawkins J. said: Field J. said (a footnote has been included in the body of the text, indicated by "(1)"): Unconsciousness See T v. DPP [2003] EWHC 266 (Admin), [2003] Crim LR 622. Hair See DPP v. Smith [2006] EWHC 94 (Admin) Pain or hurt such as persisting headaches, vomiting, pains in