A confrontation between rival supporters of two São Paulo football clubs recently resulted in the deaths of two young fans who were killed by shots fired during the disturbance. It is sad to report this type of occurrence is far from occasional or exceptional and it suffices to watch any sports match on a Sunday to witness the unfortunate practice of fighting between supporters of rival teams. These melees often result in significant losses and injuries that must be indemnified. But indemnified by whom? How does one substantiate causation of the harm suffered and impute liability to the individual alleged to be responsible?

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