How has the term "great bodily injury" been interpreted in the context of section 461 of the California Criminal Code?

The decisional law that has interpreted the term "great bodily injury" is somewhat in conflict. The first case construing the enhancement provision of section 461 is People v. Wells (1971) 14 Cal.App.3d 348, 92 Cal.Rptr. 191. Noting that a burglary is escalated from the second to the first degree when it involves an assault upon an occupant of the premises, the court reasoned that the great-bodily-injury provision "was designed to [21 Cal.3d 579] impose a higher punishment on the perpetrator if he inflicts injuries more serious than those incurred in a simple assault." (Id., at p. 357, 92 Cal.Rptr. at p. 195.) ⁸