Answer
An employee (a ‘bouncer’) assaulted the plaintiff twice – once, during the course of a fracas inside his employer’s premises, and a second time, outside the night club. Whilst the employers were held liable for the first assault inside the club, they evaded liability for the second. This was seen as an act of personal revenge and was, therefore, outside the course of employment. (It was also a criminal act. The general rule is that criminal acts are normally outside the course of employment – see below.)