R. v. Mitchell, 2004 ABPC 59
[25] Even where a citizen makes a lawful arrest, the force used in making that arrest must be reasonable and proportional in all the circumstances. Some factors to consider include the seriousness of the offence, the size differential between the citizen and the person arrested, the presence of weapons, the availability of other methods of arrest, the age and character of the person to be arrested, the force already employed by the person to be arrested.
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