 The required causation may be quite oblique . As well as weaponry held in the hand , weaponry thrown is included , as is causing people to touch each other by creating a sense of panic . The general law on liability for omissions also applies to batteries , for example those of the continuing act ( as in Fagan v MPC ) and of a duty of care . However , in R v Ireland the court ruled out psychological injury by means of a telephone as a form of battery , although it was not an important point in the case as other charges were brought . Poisoning is not a battery where there is no accompanying violence . 
