S had thrown a glass of beer over a woman and the glass broke cutting the victim, leading S to be convicted of wounding contrary to s.20 1861 Act. CA upheld conviction. P was found guilty of wounding his baby son and the trial judge directed that he merely needed to have foreseen some harm. CA allowed P’s appeal, saying that the question was not whether he did in fact see harm, but whether he ought to have foresee harm. HL allowed the crown’s appeal in P, but dismissed S’s appeal in the first case. Lord Ackner says that “maliciously” implies merely some foresight of wounding was necessary, not actual foresight of wounding itself. This was established in Mowatt. Similarly Roberts (above) shows that one does not have to intend a result in the same category of the actual result (Roberts did not necessarily intend actual bodily harm, though this is what he foresaw and what could reasonably be foreseen. Cunningham establishes that foresight of the possibility of harming someone was enough to convict on the basis of endangering life (even though this was not intended).