and generally acceptable social touching which are not regarded as tortuous and to which there is implied consent include tapping a person on the back as part of a congratulation, or to draw a person's attention, jostling in a crowd, etc. That there was Intention to Apply Force: It is sufficient for the plaintiff to establish that the intention of the defendant was to apply force. It is not necessary to prove intention to hurt the plaintiff. If there is intention to injure any person other than the plaintiff, there is battery, such as where a stray bullet hits a bystander. See the following cases: Wilson v Pringle (1986) 2 All ER 440; Stanley v Powell (1891) 1 QB 86; and Lane v Holloway, supra Battery Need Not Be Violent, Inflict Pain, Nor Injury It is not necessary that the contact be violent or inflict pain and injury need not result. Therefore, touching a person, or touching a person's cloth or anything attached to a person, if done unlawfully, wilfully, or angrily is battery. Therefore there may be battery without violence. Also, a surgical operation when done unlawfully without the patient's consent may constitute battery. Accordingly, battery includes the slightest contact, touch or force, so that harm need not result. Minimum Contact Is Battery: The Minimum Contact Rule The least touch or contact is sufficient to constitute battery. Though a plaintiff may only obtain a nominal award of damages for such contact. In light of this, unlawful application of force to a person, or contact with anything attached to a person may be battery in view of the minimum contact rule. Let us consider some cases. In Scott v. Shepherd (1558.1774) All ER 295; 96 ER 525., the defendant lit a squib "fire work" at a trade fair and threw it at B's stall. B threw