It is clearly permissible to use reasonable force to correct a child, and it is irrelevant that some in our society would outlaw completely the physical discipline of children given the opportunity. However, a parent must satisfy two tests before section 59 is available as a defence. The relationship between the parent and child. The Court of Appeal in R v Drake held that the nature of a parent s relationship to a child is relevant to determining whether the force used was to correct the child, or for example was motivated by vindictiveness. The parent s state of mind at the time that the child was corrected.
Anger is part and parcel of the correction of a child.
What is relevant is not whether the parent is upset, distraught, frustrated, annoyed or angry, but whether the parent is in control of his or her anger or emotions. What is germane is that the parent used the force to correct the child. That what the child did was wrong or dangerous and warranted physical punishment. If there is nothing to correct, then obviously the force was not used for the purpose of correction. So if the child had not done wrong but simply had irritated the parent then it is not open to a parent to use physical discipline.