conduct. "Action on Case" differed from trespass in certain important respects. Action on Case, unlike trespass, was not actionable without proof of damage. In addition, Defendant's conduct must have been wrongful. "DIRECT" and "INDIRECT" The essential characteristic of those torts which stem from the writs of trespass viet armis, de bonis asportatis, and quare clausum fregit was that they concerned injuries which resulted "directly" from the wrongdoer's act as contrasted with "indirectly" (or consequentially). The requirement of direct injury distinguished "trespass" from "case", the latter form of action having been developed for the specific purpose of affording remedies to those who suffered consequential injuries from the wrongful conduct of others but could not succeed under writs of trespass . Despite the importance of the directness requirement, it is difficult to define and to distinguish between injuries which are "directly" produced as opposed to "indirectly" produced. The "direct/indirect" dichotomy is a theme which recurs throughout tort law. In addition to distinguishing "trespass" from "case", "direct/ indirect" is, for example, also an aspect of remoteness tests in the negligence action.
72 Most cases of trespass to persons, goods or land clearly satisfy this test. Battery cases for example, invariably involve immediate acts of violence or offensive contact created by the Defendant without the involvement of other acts- e.g. being struck by a bullet, punched by a fist, stabbed by a knife, struck
