… Thus, the decision in Bellman is reasonably unexceptional in the light of previous case law such as Mattis and Mohamud. On the other hand, it can be suggested that Bellman attempts, so far as it can in following Mahmud, to restrict the operation of the test. In Bellman, the Court of Appeal stress that no suggestion was made that this incident was caused by something personal; whereas the racial motivation was said to be irrelevant in Mohamud, once the Supreme Court was satisfied that the employee was still acting for the employer and thus continuing to act in the course of employment. It is also important to point out that in Bellman the Court of Appeal stressed that liability would not arise often on similar facts; the employee’s standing in the company perhaps being pivotal. Thus the rule that a personal motivation will still take a tort outside the bounds of close connection test, as stressed in Lister, is still valid. Despite this, there is still great controversy as to the fairness and legal reasoning of making employers liable in cases involving the extreme behaviour of employees, and the present decision does nothing to quieten those concerns.
Steve Foster and Samuel Dixon, ‘Vicarious liability for employee assaults: is there any limit to liability after Mohamud?’  Coventry Law Journal 102.