V consents to harm at the level of battery but D inflicted actual bodily harm accidentally, though it was unforeseen to D that greater damage would occur. In this instance consent was deemed by Judge L to be a defence. Surely this was incorrect in law: where actual bodily harm occurs, outside the exceptional categories, Brown showed that consent was no defence and, given that only some harm need be foreseeable under s.20, he ought to have been convicted.