Police – Unlawful conduct. In finding that a police officer's actions in striking the respondent with a baton during an arrest had been disproportionate, the trial judge had erred in expressing specific findings as to whether the officer had intended to injure the respondent. The Queen's Bench Division held that there had been a lack of express reference by the judge of her findings and it was accordingly right to remit the matter for those matters to be considered afresh.