There definitely will be. But I don't know it. 'Reasonable person test' will surely make up a part of it.
Edit: Found this, not the kind of legal test a judge would rely on, but a good indication.
While it is not abundantly clear what determines ‘excessive force’ during an arrest, there appears to be a distinct relationship between the force a police officer may be permitted to use, and the behaviour of the person being arrested — whether the person is obstructing an officer in the line of duty, defying arrest, or being physically violent.