"Causes" / "Inflicts"

"Causes" / "Inflicts" 

It was formerly generally thought that the word "causes" was wider in scope than "inflicts"; however, the distinction between the two was reduced almost to vanishing point by the decision in an English case. The question is now simply one of causation: was the harm brought about by the defendant's conduct? 

In a Hong Kong case, the court held that a "wound" may be caused even where the defendant did not make direct contact with the victim. In that case, a volunteer, Y, and the defendant became involved in a dispute after the defendant was suspected of setting his dog on a cat. When the defendant tried to leave, Y prevented him from doing so. The defendant then directed his dog to bite Y, which it did, causing abrasions to Y's thigh, penis and scrotum. The court held that, even assuming Y had no power to prevent the defendant from leaving, the defendant's setting the dog on him went far beyond the bounds of any reasonable force. It was a plain and unlawful deliberate act, and the dog was merely the "instrument" by which the defendant caused the harm. The defendant was accordingly convicted of wounding under section 19.