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Santa-Bermudez v DPP [2004]

Facts

  • A policeman searched the defendant, who claimed he did not have any needles in his possession
  • The policeman was stabbed by a needle in the defendant’s pocket

Issue

  • Was the defendant guilty of committing battery?

Decision

  • Yes

Reasoning

  • Extending the R v Miller [1983] doctrine, battery can be caused as part of a wider, continuing act
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