 The phrase " really serious harm " was used to describe grievous bodily harm in R v Metheram . The case of R v Grundy confirmed that injuries should be taken in their totality ; that many small injuries may form a serious harm . R v Bollom confirmed the Grundy approach , and also showed that grievous bodily harm against a child was likely to require less bodily harm that that against an adult . R v Burstow extended " bodily harm " to include psychological trauma if it formed a recognised serious mental condition . Simester et al said that this could have wide @-@ reaching consequences , but it is unlikely to be taken to include commonplace occurrences ( relationship breakups , verbal cruelty , broken promises ) – in Burstow , the conduct included a prolonged and intense campaign of harassment . 
