D cut off V’s ponytail but was acquitted of actual bodily harm since there was no “bruising, bleeding or cutting of the skin”. However CA said that, whatever the biology, hair was still a part of the body and that cutting it off, therefore, was actual bodily harm. Sir Igor Judge P stated that Chan-Fook established that it was not merely physical injuries, but mental ones too that were to be considered. Therefore the traditional limitation to cuts, bruises and bleeding was no longer in effect. Cutting hair off is not trivial or insignificant.