INTRODUCTION TO TRESPASS TO PERSON
The law takes care of the acts which are to be recuperated with compensation or punishment. These acts can lie from a mere intentional touch to one’s person or with an evil intention of intrusion into one’s property without assigning any reason for the action. In such interest, the law has been applied and evolved to strike a balance between private rights to the exclusion of others and public rights and interests.
Hence, the term 'Trespass', can be said to be an action exceeding the limit carved by the law. It is an intentionally directed, unreasonable interference with one’s person and property. The word ‘intention’ here implies committing the wrong voluntarily. Trespass is both a civil and criminal wrong because it can cause injury. It is of three basic types. They are; Trespass to person, Trespass to goods and trespass to land.
However, Trespass To Person being the subject of focus, can be defined as a direct or an intentional interference with a person’s body or liberty. It can also be classified as any unwanted, offensive, or unjustified interference with a person's body, liberty or rights. Formerly, trespass to person can be committed negligently as well as by intention. Nowadays, it requires intention only as laid down by Lord Denning in Letang v. Cooper.
Unlike negligence, Trespass to person are "actionable per se" i.e the plaintiff need not prove the actual damage to his person in order to be able to bring an action. The underlying basis for this is that, trespass actions are concerned with the protection of civil liberties, human dignity and freedom from assault.
It is only available in circumstances where the claimant can show that the harm is the direct consequence of the defendant's voluntary act as opposed to harm which is said to be consequential only.
In the case of Mrs Akacha Bana Sasetu & Anor v. Abuja Environmental Protection Agency (Unreported) Suit No FCT/HC/CV/2287/2013, where the plaintiffs claimed the sum of 5 million naira for the act of battery and assault meted out to them by the defendants. The plaintiffs were threatened and flogged with baton and whip without any just case by the defendant officers. The court held in favour of the plaintiffs and awarded them 2 million as general damages for assault and battery committed against them by the defendants.
Also, even if the injury is as a result of the direct consequence of the act of the defendant, the claimant still needs to prove that the defendant was at fault as the latter may escape liability if he can show that the harm resulted from an inevitable accident.
FORMS OF TRESPASS
Trespass to person has three component which may occur individually or together. They are:
1. Assault
2. Battery
3. False Imprisonment.
All the three aforementioned torts in trespass to person have common elements. They are:
i. That a civil wrong must be direct
ii. The wrong must be intentional and unlawful.
ASSAULT AND BATTERY
Assault is simply an attempt or threat to apply unlawful force to the person of another whereby that other person is put in a fear of violence. It's also defined by Winfield and Jolowicz as an act of the defendant which causes the claimant reasonable apprehension of the infliction of battery on him. It is also statutorily defined in section 15(1) of the Robbery and Firearms (Special Provisions) Act as follows:
“assault” means striking, touching, moving or otherwise applying force, including heat, light, electrical force, gas, odor, or any other substance or thing whatever, if applied in such a degree as to cause injury or personal discomfort to the person of another, either directly or indirectly without his consent, or with his consent if the consent is obtained by fraud, or any bodily act or gesture, amounting to an attempt or threat to apply force of any kind as aforesaid to the person of another without his consent, in such circumstances that the person making the attempt or threat has in fact or apparently a present ability to effect the purpose”
A credible illustration of assault is where Party A pointed a gun at Party B in order to put him in a state of fear of apprehensive battery.
It was further stated by the court in CHIEF ITA OKON AQUA V. ETUBOM I. E. ARCHIBONG & ORS.(2012)LCN/5339(CA),that the burden of proof for the tort of assault is on the person making the allegation and being a civil claim, the standard of proof is on the balance of probabilities or preponderance of evidence as provided for in Sections 131, 132 and 134 of the Evidence Act, 2011 (as amended)
For there to be assault, the following element must be established:
a) In order to establish the tort of assault, it has to be proved that the act of the defendant was intentional.
Noteworthy, the ingredient of intention does not necessarily have to be concerned with creating apprehension in the mind of the plaintiff. The intention could be to cause bodily contact or Injury and such intention not fully realized has caused the defendant to maintain the position that would ordinarily put the plaintiff in fear of such harmful bodily contact
b) The plaintiff must have apprehended immediate physical contact. Therefore, an overt act is required to prove that the defendant has unequivocal and definite intent to commit an assault. The test is however, objective.
In F.B.N V. ONUKWUGHA (2005) 16 NWLR PT. 950 PG. 120, the plaintiff was put in a state of fear and was ordered out of the car by the police at gunpoint, thereafter, the plaintiff was paraded on the street to the ridicule of the people in the neighborhood. Assault was held to have been committed.
However, where the overt act or statement can be interpreted as a negation of the ingredient of intent, then there will be no assault.
c) For there to be an assault, the fear of the victim must be a reasonable one. That is, the plaintiff must have suffered reasonable apprehension of immediate bodily harm. The test is subjective as the victim's state of mind is considered. The seemingly ability of the defendant and the immediacy of the threat must be established before a plaintiff's apprehension can be deemed reasonable.
In MRS AKACHA BANA SASETU & ANOR V. ABUJA ENVIRONMENTAL PROTECTION AGENCY (Supra), the officers without just cause swamped upon the plaintiffs and thereby put them in fear that intentional force will be applied on them. The court held that the act of the defendant amounted to assault. Also, in Ashley v Chief Constable of Sussex Police [2008] UKHL 25, the claimants were the son and father of the deceased. Furthermore, the deceased was shot by a police officer during an armed raid on his home. Consequently, C sued the police Commissioner (s) in a number of torts. These included false imprisonment (during the raid); negligence in the planning and execution of the raid; misfeasance in a public office for conduct after the event; assault and battery in respect of the shooting. The court considered whether the fear of attack was reasonably held by the deceased in self defence. The court held in conclusion, that the assailant’s mistaken belief in an attack had to be not only honestly but also reasonably held.
However, threat by a weak or incapable person would not be deemed to have caused the plaintiff any reasonable apprehension in fear that the defendant would cause harm.
Noteworthy, actual contact is not necessary in an assault, though it is in a battery. But it is not every threat, when there is no actual personal violence that constitutes an assault; there must, in all cases, be the means of carrying the threat into effect.
Battery on the other hand, is the application of force, however slight on another person against his will or an intentional and direct application of force to another. According to Black's Law Dictionary 7th edition, pg. 146, battery is defined as an " intentional and offensive touching of another without lawful justification."
A better definition of battery is that, the defendant, intending the result and without lawful justification or the consent of the claimant, does an act which directly and physically affects the person of the claimant. An instance of battery is where Party B hit Party A with a brick or shot him.
Life would be difficult if not impossible, if all bodily contact were actionable unless it could be brought within a specific jurisdiction or defence. Thus, quite apart from the available defences, bodily contact is not actionable in the ordinary conduct of daily life.
The elements of battery that must be established are as follow:
a) For one to be liable for battery, the act or touching has to be intentional irrespective of the fact that it was not meant to cause injury. If the touching was not intentional it would be categorized as negligence.
In Dr. ROM Okekearu v. Danjuma Tanko (2002) 15 NWLR (pt. 791) 657, it was held that an act does not amount of battery unless it is done intentionally.
b)The contact must be direct. That is, to be liable for battery, the injury must be as a direct result of the intentional act of the tortfeasor.
However, it's not necessary for there should be any bodily contact between the defendant and the plaintiff. It is sufficient to amount to battery if the defendant brings some material object into contact with the plaintiff. For instance, it is a battery to throw stones, project heat, light, or smell to the extent that it causes discomfort or injury to the claimant.
c)The contact with the claimant's body must be hostile.
d)The claimant must not consent to the battery. Thus, where there is consent, there's no battery. Consent can be express or express from the conduct of the claimant. Whether or not there is consent is determined by what a reasonable person would concluded given the claimant's behaviour.
In Grager v. Schudar, 770 N.W.2d 692 (N.D. 2009),Kevin Schudar (Schudar), a jailer, had sex with Michele Grager while she was imprisoned. Grager sued Schudar under claims of assault, battery, intentional infliction of emotional distress, and civil rights violations. The district court instructed the jury that Grager’s consent to the sexual conduct is a complete defense against the claims precipitated by Grager, and the jury granted judgment in favor of Schudar. Grager appealed. The court held that a plaintiff’s consent does not bar recovery on the part of the plaintiff unless the plaintiff’s fault is comparatively greater than the fault of the defendant
Generally and very often, assault precedes battery such that the defendant would have committed assault before battery. But there could also be battery without assault, just as there could be assault without battery. This was evident in the case of AQUA V. ARCHIBONG & ORS. (2012) LPELR – 9293
DEFENCES TO ASSAULT AND BATTERY
The torts of assault and battery have similar defenses due to their similarities in a lot of respects. They are both direct physical trespass to the person of another. For instance when a battery is committed against the complainant, it also includes the tort of assault. This is due to the fact that before the actual infliction of unlawful force, the claimant was put in apprehension(assault). Due to this, a defence to assault could also serve as a defence to battery.
The defences to the tort of assault and battery are:
1. Parental or Other Authority:
A person who is purported to commit battery or assault under lawful authority cannot be held liable. A parent or guardian would not be held liable for battery or assault for inflicting corporal punishment on their child. Provided that the force used is a reasonable one and it is proportionate to the wrong committed by the child.
Similarly, school teachers also have the same right to punish student in their charge by moderate corporal punishment. This based on the premise that school teachers have an independent right to chastise pupils for the purpose not only of training then in good behaviour but also of maintaining order and discipline in the school as an organization.
Police officers are authorised by the statute to use force if it is necessary in carrying out their duty. However, their actions should be within the confines prescribed by the law.
2. Consent:
The court in OGUNDIPE v. ODUWAIYE & ANOR (2013) LPELR-20474(CA) defined Consent”_ with the help of the Oxford English Dictionary as, “Consent merely means to agree or to permit someone to do something."
If a claimant has consented to the assault or battery inflicted on him, his action for battery or assault cannot succeed. This is encapsulated in the maxim “violenti non fit injuria“. The consent may be express or implied. Thus, a person who participates in a contact sport like rugby or football cannot complain of assault or battery if he suffers injury which is permissible within the rules of the game. However, deliberate acts of violence on the playing field, though, do not fall within this defence.
It should be noted that in medical treatment, the consent must be real as implied consent has presented more difficulties in that area. This means that the patient must understand what it is he is consenting to.
3. Necessity:
Where it is necessary to prevent harm, trespass to persons can be allowed. It can also be used in medical cases to justify the treatment of a person who lacks capacity.
In Chatterton v Gerson, 1981 QB 432 (QBD) the defendant doctor operated to block a sensory nerve to treat Miss Chatterton’s chronic pain. As a result of the operation the plaintiff lost the sensation in her right leg, she claimed that her consent was invalidated as she had not been made aware of the risk. Bristow J held that in this case no battery was committed.
4. Self Defence
An assault or battery is justified if committed in self defence or in defence of another person. However, the force used must be proportionate to the threat posed. Each case must be considered on its own facts. For example, if a person is attacked with a knife it may be reasonable for them to defend themselves also with a knife, but not necessarily with an automatic pistol. It will be for the courts to decide what is reasonable.
Self defence is thereby reasonable depending on the circumstances. In relation to that, two principles are clear:
a) The battery must be committed in actual defence from attack and not by way of retaliation after an attack
b) The self defence must be reasonably commensurate with the attack
Self defence was extensively discussed by the Supreme Court in Amala V. State (2004) 18 NSCQR 834 with the view that,
“if a man attacks me, I am entitled to defend myself, and the difficulty arises in drawing the line between mere self defence and fighting. The test is this: a man defending himself solely to avoid fighting. Then supposing a man attacks, and I defend myself, not intending or desiring to fight, but still fighting in one sense to defend myself, and I knock him down, and thereby unintentionally kill him, that killing is accidental.”
5. Invasion Of Privacy:
As a general rule, there is no tort of invasion of privacy at common law. So, where the plaintiff alleged an invasion of privacy, it's a defence to say that no tort exist.
6. Defence To The Property:
Assault or battery is justified if committed in defence of one's own property, whether land or chattel or property which one is defending as an agent of the owner but the force used must not be more than necessary.
FALSE IMPRISONMENT
False imprisonment is a tort as well as a felony, which connotes denial and total restraint of a person's freedom of movement or personal liberty without lawful justification or excuse. It was defined by the court in EBULUE & ORS v. EZEBUO (2018) LPELR-44685(CA) as thus,
"An act of restraining or restricting or confining the movement of a person within an area without lawful or legal authority or justification. It is an unlawful act for a private person or a law enforcement agency or any governmental agency to restrict the movement or exit of a person from an area against his will without any lawful justification."
False Improvement is said to be false since it is not justified and also constitute a breach of the fundamental human right of a person to personal liberty as guaranteed by Section 35 of 1999 CFRN (As Amended). Therefore, False Imprisonment transcends beyond its literal connotation as “Incarceration in a security or correctional facility”. It entails the restriction of an individuals freedom and movement not necessarily a Security Holding Facility. As Coke CJ rightly said:
"every restraint of the liberty of a freeman is an imprisonment, although he be not within the walls of any common prison."
False Imprisonment is a tort of strict liability and the plaintiff need not prove fault on the part of the defendant or that he was unlawfully detained or harmed by his detention. Civilians as well as law enforcement officers are subject to being charged with false imprisonment. A false imprisonment tort charge consists of intention, restraint, and awareness without consent on behalf of the imprisoned party.
The two elements of false imprisonment are:
i) There must be total restraint of the liberty of the person. Partial restraint is not sufficient. The restraint may be actual or constructive i.e by mere show of authority.
It is also submitted that where a detained person has the means of escape but does not know it, his detention is nevertheless false imprisonment. The test for this is whether a reasonable man could have known the outlet.
ii) The detention must be unlawful.
In Gusau & Ors Vs Umezuruike (2012) LPELR - 8000 (CA), the Court held:
"...that detention, no matter how short, can lie a breach of fundamental right. But that can only be so if the detention is adjudged wrongful or unlawful in the first place; that is, if there is no legal foundation to base the arrest and/or detention of the applicant."
Similarly, In ENE & ORS v. BASSEY & ORS (2014) LPELR-23524(CA) the court held that an arrest properly made cannot constitute a breach of fundamental rights. A citizen who is arrested by the police in the legitimate exercise of their duty and on grounds of reasonable suspicion of having committed an offence cannot sue the police in Court for the breach of his fundamental rights.
Once these conditions are satisfied, the basis for which detention continues is immaterial.
It has been established that when an unlawful arrest or detention is claimed, the burden is on the person who effected the arrest and detention to prove the legality of the arrest and detention. This rationale was adopted by the court in ANOLIEFO v. ANOLIEFO & ORS (2019) LPELR-47247(CA)
In KLM ROYAL DUTCH AIRLINE V. TAHER (2014)2 NWLR 137, the court stated that to succeed in an action for the tort of false imprisonment, the plaintiff must establish that the defendant was instrumental in setting up the law in motion against him. Thus, in Taylor v. Johnson, 796, S.O. 2d 11(L O App. 3 Cir. 2001), a pharmacist and his Pharmacy were found liable by a trial court for false imprisonment, the appellate court reversed the judgment because it believed the elements of false imprisonment were not met. In that case, the defendants stalled for time and instructed a patient to wait while simultaneously and without the patient’s knowledge calling the police. The pharmacist was suspicious of the patient’s prescription, which her doctor had called in previously. When the police arrived, they arrested the patient while the patient was in prison, the police verified with the doctor that the prescription was authentic, and that it was meant for her. After the incident the patient sued the pharmacy and its employees, she received $20,000 damages. But, on appeal, it was reversed
The tort of false imprisonment can be committed without any force or coercion of any kind. Also, a person may be liable for false imprisonment not only when he directly arrests or detains the plaintiff, but also when he was active in promoting or causing arrest or detention.
However, the position of law is that private individuals will not be liable for false imprisonment if he merely provided information which led the police on their initiatives to arrest a suspect. In the case of ISHENO v. JULIUS BERGER (NIG) LTD. S.C. 256/2002, the Supreme Court held that, where on a report made by an appellant to the police, the appellant was asked whether he suspected anyone. He replied that he suspected the respondent who was consequently arrested and detained by the police for inquiry such expression of opinion is said to be no more than putting the police on a trail upon which they can work. Giving such information to the police cannot therefore form the basis for any action for false imprisonment or false prosecution by the police since it would be the duty of the police, after receiving such information, to make investigations themselves which may or may not lead to an arrest. This was also upheld in FBN Plc v. Onukwugha (2005) 16 NWLR (Pt. 950) 120 that passing information to the police is not enough in an action for tort of false imprisonment
Also, it was further established in Nwangwu & Anor v. Duru & Anor (2002) 2 NWLR (Pt. 751) 265, where the Court of Appeal held per, Amina Adamu Augie, J.C.A, that where an individual has lodged the facts of his complaints to the Police and the Police thereupon on their own proceeded to carry out arrest and detention, then the act of imprisonment is that of the Police.
False imprisonment can occur whether or not the claimant has knowledge of it at the time it occurred. This position was established in the case of Merring v. Graham White Aviation Co. Ltd. It should however be noted that if a person is not aware that he has been falsely imprisoned and he has suffered no harm, he can only be able to recover nominal damages.
Noteworthy, every confinement of a person by any means whatsoever is an imprisonment, whether it is a common prison or in a private house or even detaining someone in the public street. A person can also be falsely imprisoned even if they have a means of escape but it is unreasonable for them to take it; for example, if they are in a first floor room with only a window as a way out.
The liability of a principal for the act of an agent in causing false arrest or imprisonment depends upon whether the principal previously authorized the act or subsequently ratified it or whether the act was within the scope of the employer’s or agent’s employment. However, an employer will not be held liable for false imprisonment for the actions of an employee which are outside the scope of employment. In ZANG & ANOR V. ITUMA & ORS (2014) LPELR 23521 (CA), the court held that the doctrine of vicarious liability in civil action of tort has its foundation in common law position that a master is liable for any wrong committed by his servant while acting in the course of employment and that a principal is also to be responsible for the acts done by his agents in the discharge of the authority of the agency. This position was also upheld in F.B.N v. ONUKWUGHA (Supra)
DEFENCES TO FALSE IMPRISONMENT
1. Lawful Arrest and Detention:
Any arrest made in accordance with the provisions of the law cannot amount to false imprisonment. A police officer is still protected even if the arrest was made in error, provided it was reasonable. The onus of proving lawful arrest however rests on the defendant. Arrest may be either with warrant or without warrant.
For arrest with warrant, a police officer or private person who arrest within the terms of a warrant issued by a magistrate or any court having civil or criminal jurisdiction has a complete defence to an action for trespass to person. Problems may however arise where the warrant is defective, issued without jurisdiction or where the police arrest the wrong person. However, by virtue of section 258 and 359 of the Criminal Code, criminal responsibility does not lie.
Also, police officer can arrest without warrant due to the powers given to them by the Police Act. Where the defendant arrest on reasonable suspicion of the commission of an offence, he must show that he has a reasonable ground for such suspicion at the time of the arrest. Similarly, the defence of the defendant will fail if he claims to arrest without warrant on the authority of other statue, unless the true construction of such statue gives him such a power of arrest.
In respect of arrest through agents or ministerial officers, the defendant will only be liable for false imprisonment if he shows that he directed or authorized the arrest. However, if the police officer acted on his own initiative, the defendant will not be liable. Whether or not the defendant directed the arrest us a question of fact in each case.
It should be noted that the detention of a person should however be reasonable and justified. If not, liability could arise for false imprisonment. Thus, in Ekpu vs. Attorney-General of the Federation (1998) 1 HRLRA (Human Rights Law Report of Africa), where the respondents offered bail to the applicants on April 10, 1994, then their continued detention after that date was held not to be unlawful. This same position was upheld in ENIANG EDEM EKPO ENE & ORS v. BASSEY & ORS (2014) LPELR-23524(CA.
2. Detention For Mental Purposes:
The detention of persons suffering from mental disorders is legalized by the Mental Heath Laws of various countries. However, such detention must be in accordance with the law or it would amount to false imprisonment.
3. Reasonable Condition:
It is not a tort of false imprisonment o prevent a person from leaving a premises because he has not fulfilled a reasonable condition subject to which he entered. For instance, where a person entered a park on the condition that he would pay before being allowed to pass. He can not successfully bring an action for false imprisonment in such instance.
5. Contributory Negligence:
This defense will apply where the damage which the claimant has suffered was caused partly by their own fault and partly by the fault of the defendant. In order to establish the defense, the defendant must prove that the claimant failed to take reasonable care for their own safety and that this failure was a cause of their damage. If contributory negligence is established, the modern position is that the claimant will have their damages reduced by the court in proportion to their fault. Noteworthy, contributory negligence is a complete defence.
In Vellino v Chief Constable of Greater Manchester [2002] 1 WLR 218, where the Claimant was a known offender and had a string of convictions. He was seriously injured when he jumped out of a second floor window having just been arrested. The police were aware that he was likely to escape and had done so on several previous occasions and could also sustain injury but did nothing to prevent him.The Claimant suffered a fractured skull, brain damage and tetraplegia which rendered him totally dependent on others for support. The police were excluded from liability on the ground of ex turpi causa
ACT INTENDED TO CAUSE PHYSICAL HARM OTHER THAN TRESPASS TO PERSON
As a general rule, the action in trespass is confirmed to the intentional and direct infliction of harm. However, over the years, it has been established that where the harm is intentionally but indirectly inflicted, liability will arise. This rule was established in the case of Wilkinson vs Downtown (1897) 2 QB 57. The rule deals with the infliction of physical harm not by assault, battery or false imprisonment. In the particular case, the defendant, who knew it to be untrue, falsely told the plaintiff that her husband had been seriously injured in a motor accident. Due to this news, the claimant had a nervous shock which subsequently inflicted physical illness on her. The court held that she had a cause of action. Lord Wright J Held:
“… The practical joker in this case itself was liable on the basis that he had willfully done an act calculated to cause physical harm to the plaintiff.…”
The claimant must however prove actual loss. Liability is imposed in the following circumstances:
a) Where a person intentionally or recklessly inflicts emotional distress on another.
b) The defendant’s conduct was extreme and outrageous.
c) The harm intended is severe.
d) The actual resulting emotional harm is also severe
In C V D & ANR, CA (CIV DIV) 23/2/2006, a headmaster was liable under the principle in Wilkinson v Downton (1897) 2 QB 57 for psychiatric injury caused by an act of sexual abuse against a pupil that had not involved touching.
On the basis of the above, intentional infliction of emotional harm is a complementary form of liability covering cases of intentional but indirect causes of physical harm
REMEDIES FOR TRESPASS TO PERSON
The usual remedies available to a claimant in an action for trespass to person are often Damages and Injunction.
1. Damages: Damages are pecuniary compensation, obtainable by success in an action for a wrong which is either a tort or a breach of contract, the compensation being in the form of a lump sum awarded at the time, unconditionally and generally.
According to Black’s Law Dictionary, 6th Edition, Damages can be either general or special damages. General damages is described as such as the law itself implies or presumes to have accrued from the wrong complained of, for the reason that they are its immediate, direct, and proximate result, or such as necessary result from the injury, or such as did in fact result from the wrong, directly and proximately and without reference to the special character, condition, or circumstances of the Plaintiff. They need not to be proved as they are presumed by law.
Special damages on the other hand are those which are the actual, but not the necessary result of the injury complained of, and which in fact follow it as a natural and proximate consequence in the particular case, that is, by reason of special circumstances or condition. They are damages that are alleged to have been sustained in the circumstances of a particular wrong. They must however be proved.
In EBULUE & ORS v. EZEBUO (2018) LPELR-44685(CA), the court held that
“Any unlawful attack or application of force or violence to the person of a claimant with or without actual injury constitutes assault for which the claimant is entitled to damages in a civil action".
In NDIBE & ORS. V. NDIBE (2008) LPELR – 4178 CA), the court entered judgement in favour of the Plaintiff in which the defendants are to pay the Plaintiff the sum of N300, 000.00 (Three hundred thousand Naira) jointly and severally for the injury sustained on his right ear.
Also, there is exemplary damages which are awarded in order to punish or deter the defendant from engaging in similar conduct in the future.
2. Injunction: An order of injunction may be granted by the court on behalf of the plaintiff in order to compel or prevent the defendant from doing something. An order of injunction may be interim, perpetual and interlocutory.
CONCLUSION
In conclusion, trespass to person, being a form of trespass more directed to the intentional infliction of injury suffered by a person and the recuperation of compensation for the damages suffered in such respect has been a thriving aspect of law in both criminal and civil law in Nigeria. Its effect is evident in the protection and preservation of right to liberty of persons as enshrined in the 1999 Constitution of The Federal Republic of Nigeria (as amended) especially where the injuries are inflicted without any just cause.
REFERENCES
1. https://www.lawteacher.net/free-law-essays/jurisprudence/trespass-to-person.php
2. https://www.lawhub.com.ng/tort-of-false-imprisonment-trespass-to-person/
3. https://legalideasforum.com/2020/09/an-exposition-of-trespass-to-person.html
4. https://tort.laws.com/intentional-interference/with-a-person/with-a-person
5. https://lawexplores.com/trespass-to-the-person-2/
6. https://blog.ipleaders.in/trespass-meaning-nature-types-defenses-case-laws/
