Where a security guard is authorised to use physical force and lures a patron back into premises under the ostensible performance of duties before assaulting them, the close connection between the assault and the scope of employment is sufficient to ground vicarious liability. The absence of evidence from the employer as to instructions given to security staff, combined with an admission that the guard was authorised to use force, strengthens the finding of vicarious liability. The various formulations of the 'sufficient connection' test from Lepore (Gleeson CJ, Gummow and Hayne JJ, Gaudron J, Kirby J) were all held to be satisfied on these facts.
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