... strength or energy. Reena actions must have caused the consequence. The act was removing the screws off the chair, which lead to the consequence of Chloe suffering the bruises. The authority for the actus reus of battery is Fagan v. Metropolitan Police Commissioner1. Reena did apply force indirectly which was unlawful. Can battery be committed by indirect application of force? This can be where, for example, the defendant creates an obstruction for someone or removes the screws of a chair as Reena did which resulted in force being applied to the victim. There are established judicial dicta in favour of liability in these circumstances. The outcome of the case DPP v. K2 confirmed this. It does not have to be personal contact. The force applied was unlawful because Chloe did not consent to it; it was not a form of defence or by a principle of necessity, the accused was ...

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