well it kinda depends on the position, doesn't it?
I mean if the guy was bein spooned then yea, it was a stupid move.
but if he was spooning his girl and did it? big whoop, she rolled over, probably got pissed, and knocked him off. There's a fault that isn't his.
And she would have every right to knock him off of her if he tickled her and she didn't want it. It's not unreasonable force to push someone off of them if the force exerted against the pusher is tickling. It's not like she took a bat to his head. She merely pushed him, and he unfortunately injured himself more severely than could be foreseen.