Criminal law – Consent. There was no good reason why body modification should be placed in a special category of exemption from the general rule that the consent of an individual to injury provided no defence to the person who inflicted that injury if the violence caused actual bodily harm or more serious injury. Accordingly, the Court of Appeal, Criminal Division, held that consent of the defendant's customers to the removal of an ear and nipple, and the division of a customer's tongue did not provide him with a justification for removing body modification from the ambit of the law of assault.