This page within Virginia Tort Case Law is a compilation of cases reported by the Virginia Supreme Court and summarized by Brien Roche dealing with the topic of Assault Provocation and the related topic of intentional torts. For more information on assault issues see the page on Wikipedia
Assault Provocation- Cases
1955 Harper v. Commonwealth, 196 Va. 723, 85 S.E.2d 249.
Criminal case. Words alone are never justification for assault.
1947 Baskett v. Banks, 186 Va. 1022, 45 S.E.2d 173.
If plaintiff used insulting or offensive words to defendant, then such may be considered in mitigation of damages.