The words “with strong hand” imply a degree of criminal force, whereas the words vi et armis ("with force and arms”) are mere formal words in the action of trespass, and the plaintiff is not bound to prove any force. The statutes relating to forcible entries use the words “with a strong hand” as describing that degree or force whIch makes an entry or detaIuer ot lands criminal. Brown
Source: Black's Law Dictionary 2nd Ed (1910)
