What was decided here was that the right of teachers in state schools to administer corporal punishment was not derived solely by a delegation of parental authority (in loco parentis) but was derived from the fact that a teacher in a government school was an agent of the Crown, and derived their powers by delegation from the Crown (the government in other words). When these rulings were first made, they were the reasons why parents could not insist their child not be physically punished – some parents tried to argue that under in loco parents if they did not want their child caned or strapped, a teacher could not do it in place of the parent.

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