R v Surette,  Y.J. No. 149:
20 As to the argument by Crown counsel that words cannot constitute a use of force within the definition of self-defence, I find that accepting this position could lead to illogical or absurd results. As an extreme example, if an individual is threatened by the use of force against him which could result in grievous bodily harm or death, to the extent that he is justified in repelling that force with deadly force, and he possesses a loaded firearm, it would be a defence to that individual if he shot the aggressor but not if he only threatened to shoot the aggressor. The defence of self-defence allows for the increased use of force to repel an unlawful assault proportional to the threatened harm. A threat to use a gun is a lesser response to an unlawful assault than actually firing the gun; therefore, a more restrained response.