it can be observed that the HNDA students walked from the Fort to Ward Place peacefully and they waited until they were granted the meeting. From photos and video evidence, it can be gathered that the students started behaving aggressively once they were denied the meeting with a higher authority from the Ministry. They tried to enter the premises of the Ministry by disrupting the barricades. This confirms the fact that, as the respondents state, the power to disperse an assembly for committing any mischief or criminal trespass or other offence is outlined in Section 138 of the Penal Code and for risking a breach of peace under Section 78(1) of the Police Ordinance. It is clear that, the police had erected barricades because of past experiences where students had, in a previous march, destroyed the barricades and entered into the Ministry property and caused damage. It must be considered whether the methods used by the respondents to disperse the students were in accordance with the legal provisions. The respondent states that the provisions to disperse a crowd is outlined in the Police Department Regulation No 18. This regulation outlines how police should act during such civil struggles. However, it is questionable whether the complainants’ assembly comes under such civil struggles. Ethnic discord, religious tensions, social and cast discrimination, inter trade union disputes, political party gatherings and domestic issues amount to civil struggles. Since this incident does not fall under that interpretation, Department Regulation 18 is not applicable The respondent then states they resorted to the police Department Order A19, which outlines how a police officer should act during an unlawful assembly.  Take actions to disperse the crowd in a friendly manner with cooperation.  If it is necessary to use force, the best strategy is a police cordon.  Using this approach, the crowd can be directed to move away. Those who had behaved aggressively calmed down in the face of disciplined Police Force. Therefore, use of force was not necessary. Force cannot be used when the individuals are no longer committing an offence. Additionally, they can only use batons to fulfil their objective if they are confident in their strength, or if an armed group of the police force is prepared to support them. The respondents used water cannons and tear gas to disperse the crowd. From the photos and video evidence, it can be observed that after dispersing the students, the police attacked and chased them using batons. According to 95(2) of the Criminal Procedure Code, although they have the power to use batons in dispersal, that power must be exercised reasonably. It is questionable whether there was a need for the police to attack the students in such a manner since according to the videos and photo evidence, the students were already exhausted after tear gas and cannons had been deployed. 93

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