Police use of force during arrest must be evaluated stage by stage against the circumstances as they developed, not with hindsight. Where an arrest is lawful and the arrestee resists, the police may escalate force proportionately through wrist locks, arm locks and handcuffs. An allegation that an arrest was for a collateral purpose must be directly put to the police witnesses at trial; failure to do so is a significant obstacle to raising the issue on appeal.
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