Criminal law – Cruelty. The defendant's conviction for cruelty was unsafe, as absent a clear instruction that, in the present case, the jury had to be sure both of an assault and of humiliation, it might have thought that humiliation had been, of itself, enough. The Court of Appeal, Criminal Division, further held that his conviction for assault occasioning actual bodily harm was unsafe, as no tailored and qualified direction that complaints were cross-admissible had been given.