Police officers must positively consider whether handcuffing is warranted in each case; a mere habit, preference, or internal SAPOL directive is not sufficient justification. The use of inherently dangerous restraint techniques such as the 'figure four leg lock' with full body weight constitutes battery where the subject is already effectively restrained. CCTV footage of high quality may be treated as evidence from which a trial judge can make findings of fact, not merely as material to understand other evidence. Internal police orders or directives cannot expand the lawful use of force beyond what the common law permits.
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