Fred and Marcus had fought because Marcus was angry with Fred for having carved the letter 'F' on to Livia's arm using a penknife. Livia was Marcus's 14 year-old daughter, who had begged Fred to do this as she was in love with him. Fred had reluctantly agreed. The wound was not serious, although it did require one stitch. Fred and Marcus had decided to settle their differences by having a fight. Fred had punched Marcus, knocking him over and causing him to fracture his skull. Fred had run away when the police were called.

The police then caught up with Fred. PC Bill tried to arrest him. Fred pushed PC Bill out of the way in an attempt to get away, causing PC Bill to stagger. In an effort to save himself from falling, PC Bill put his arm out and pushed it through a shop window, sustaining severe cuts to his arm.

Discuss the possible criminal liability of Fred.