KembaraXtra-Case Law-Garwood (1987)
Area of Law: Blackmail (Specifically, Menaces)
Facts:
D accused V of burglary.
D demanded something "to make it quits" for the alleged burglary.
D physically assaulted V (seized shirt, pushed against a wall).
V paid D money.
D threatened V to not inform his parents or the police or he would "get" him.
Issue: Clarifying the meaning of "menaces" in blackmail.

Held:

General Rule: A specific direction on the meaning of "menaces" to the jury is usually not required.
Exceptions (When direction is required):
Exception 1: Threat would affect a person of ordinary stability, but did not affect V.
This implies the jury needs guidance on whether the threat was objectively menacing.
Exception 2: Threat would not affect a person of ordinary stability, but did affect V, and D was aware of the likely affect.
This implies the jury needs guidance on both the objective nature of the threat AND D's awareness of V's particular vulnerability.
Key Takeaways:

The definition of "menaces" is normally left to the jury's common sense.
However, direction is needed if there is a discrepancy between the objective and subjective impact of the threat, especially if D knew about the victim's vulnerability.
"Ordinary Stability" is the standard used to assess the objective nature of the threat.