R. v. Narwal, 2013 BCSC 340
[16] It is clear from the foregoing that the actus reus of the offence set out at s. 264.1 of the Code of uttering threats of death or serious bodily harm is to be analyzed objectively considering all of the circumstances in which the words were spoken, including:
a) the actual words spoken;
b) the circumstances in which the words were uttered;
c) the manner in which they were spoken;
d) the person to whom they were addressed and that person’s situation; and
e) the speaker and that person’s situation
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