Haystead v CC Derbyshire [2000]

Court: Divisional Court

Facts: The defendant, Haystead, punched a woman who was holding her baby. The force from the punch caused the woman to drop the baby onto the floor. Haystead was subsequently charged with battery against the baby. He appealed, arguing that battery should require direct physical contact with the victim or through a medium controlled by the defendant, such as a weapon.

Issue: Whether battery necessitates a direct application of force through physical contact with the victim or can involve an intermediary.

Held: The Divisional Court dismissed the appeal, affirming the conviction for battery against the baby.

Key Judicial Statements: Laws LJ stated that “as a general point, battery did not require the direct application of force,” explaining that in this case, the application of force was transmitted through the mother as a medium, resulting in the baby being dropped due to the defendant’s punch. He further clarified that “no distinction could be drawn between using the mother or a weapon as the relevant medium save that the latter involved intention and the former recklessness.”

💡 Leveluplaw: broadened the traditional interpretation of battery by establishing that force does not need to be directly applied to the victim for a battery charge to be valid. The judgment highlights that an intermediary (in this case, the mother) can transmit the force, leading to liability for battery against another individual (the baby). This nuanced understanding allows for a more comprehensive application of battery laws, acknowledging the implications of actions that cause harm through indirect means, whether intentional or reckless.