According to the MLRs, the students sustained wounds and injuries on their heads, backs of their heads, backs, spines, shoulders and other sensitive body parts. Thus, it is questionable if the power was exercised by the police reasonably. Furthermore, in order to explain the force used by the respondents, Report No.AG/24/2013 dated 19.02.2014, submitted by the Attorney-General with instructions to use rubber bullets to control civil struggles is highlighted. It also mentions the necessity to use minimum force in such cases. However, even firing rubber bullets could still cause serious injuries and deaths, therefore the decision to use rubber bullets depends on the circumstances of each case. This clearly shows that the minimum force used by the police must be such as to avoid any serious injuries and death. However, the force resorted to by the respondent in this incident is not reasonable according to the circumstance but is an excessive use of force. When considering the respondents’ statement that there is no requirement to use minimum force but reasonable force according to the circumstances, it has to be questioned whether there was a necessity to disperse the crowd by attacking them with batons. The Commission finds that there was no necessity to attack students with batons to disperse them, when they were already weakened by tear gas and water cannons. This fact is collaborated by photo and video footage evidence. The respondents claim they attacked the students with batons to prevent them from regrouping. But the evidence present clearly indicates that after the water cannons and tear gas were deployed, students had started dispersing and some were even weakened and lying on the ground. Since it cannot be determined that the students had attempted to regroup, chasing the students away by attacking them with batons is an excessive use of force. As the respondents acted contrary to legal provisions to disperse the unlawful assembly, this amounts to a violation under article 12(1) of the Constitution. According to Section 59(1) of the National Thoroughfares Act No, 40 of 2008, obstruction of public roads is an offence. However, the respondents did not taken action to interrupt the students in their march from Fort to Ward Place. 7.1.3 Freedom from arbitrary arrest, detention and punishment: Article 13 (1) of the Constitution states that a person may not be arrested except according to procedure established by law The Commission must consider whether the arrest of 39 students was a violation of Article 13. According to Section 23(1) of Criminal Procedure Code, in making an arrest the person making the same shall actually touch or confine the body of the person to be arrested unless there be a submission to custody by word or action. 94