A close relative who was not present at an assault and battery but who witnessed its aftermath may recover damages for psychiatric injury under the Wilkinson v Downton principle as extended by Battista v Cooper, provided the relative was within the range of foreseeable risk of psychiatric injury. The Wednesbury unreasonableness standard does not apply to determine whether police officers used reasonable force in civil assault claims; the correct question is whether the force was shown to be reasonable, not whether it was so unreasonable that no reasonable authority could have sanctioned it.
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