In the case Williams v AG, the plaintiff was leaving the Montego bay police station with a friend

who had shortly before been released on bail, when the station guard, in hurrying them out of
the station, used obscene and insulting language. The plaintiff remonstrated with the officer,
whereupon the defendant constable held the plaintiff, pushed him against the wall so that his
head and elbow struck against it, hit him twice in the stomach and pushed him out of the
station. Such conduct clearly amounted to battery by the constable, but the Jamaican Court of
Appeal treated the plaintiff’s as one for assault rather than battery may be due to the fact that ,
in criminal law, the offences of common assault and aggravated assault connote the application
of physical violence to the person.