## Facts

- Haystead struck a woman who was holding a child.
- As a result of the blows, the woman dropped the child, causing injury to the child.
- Haystead was charged with battery against both the woman and the child.
- The main legal issue was whether Haystead could be liable for battery against the child, despite not directly touching the child.

## Issues

1. Whether battery can be committed through indirect application of force when the defendant’s actions intentionally result in unlawful force to another.
2. Whether a direct causal link between the defendant’s conduct and application of force to the victim is sufficient for liability.
3. Whether intervening acts by third parties can break the chain of causation and affect liability for battery.

## Decision

- The Court of Appeal upheld Haystead’s conviction for battery against the child.
- The court found that Haystead’s intentional act of striking the woman directly caused the force applied to the child.
- The judgment confirmed the existence of a clear causal link between Haystead’s actions and the injury suffered by the child.
- The court distinguished this case from those where an independent act would have broken the chain of causation.

## Legal Principles

- Battery can be established by indirect application of force if the defendant’s intentional actions foreseeably result in unlawful force against another.
- A direct physical contact by the defendant is not required for battery if causation and intent are present.
- The chain of causation may be broken by intervening acts, but only if such acts are independent and sever the direct link between conduct and harm.
- Liability for battery depends on both the actus reus (application of (unlawful) force) and mens rea (intention to apply force or foresight that force will result).

## Conclusion

The Court of Appeal’s decision in Haystead v Chief Constable of Derbyshire clarified that battery liability extends to indirect application of force where there is intent and a direct causal connection, shaping the legal approach to causation and intent in battery law beyond cases of direct contact.


Haystead v Chief Constable of Derbyshire [2000] 3 All ER 890