by a golf-ball etc. satisfy directness test. The case often mentioned as illustrating the breadth of the directness requirement is SCOTT V. SHEPHERD (1773) 95 E.R. 1124 where the Defendant threw a lighted squib into an enclosed market house. It landed upon the stall of Y., was picked up by W. to prevent damage to Y's goods and thrown onto R's stall. R. picked it up and threw it into the market where it struck the Plaintiff and exploded, blinding him in one eye. The action against the Defendant was based on assault and battery. Trespass to Land John Fleming (Law of Tort, 5th edtition) has disclosed that from earliest times the common law protected the possessory rights of landlords against unauthorised entry by an action of trespass. In the course of its history, this action of trespass came to be used for a number of different purposes which have left their mark on its conditions of liability. In origin, trespass was a remedy for forcible breaches of the King's peace, aimed against acts of intentional aggression. This early association with the maintenance of public order explains why the action lies only for interference with an occupier's actual possession. Its proprietary aspect became more dominant when it was later used for the purpose of settling boundary disputes, quieting title and preventing the
73 acquisition of easements by prescriptive user. In addition, FLEMING coninues, the action of trespass also came to serve the wholly distinct function of an ordinary tort remedy for material damage sustained by an occupier as the
