The force need not be applied directly. Most batteries are inflicted directly e.g. by the defendant hitting the victim with or without a weapon or throwing a missile at the victim. However, a battery can be indirect. R v Martin (1881) 8 QBD 54 FACTs: The defendant closed the exit doors of a theatre. As the people were about to leave, he turned off the lights and panic ensued. HELD: This was an indirect battery. The court also gave the example of D digging a pit which V then falls into as being an indirect battery.