Definition: In this task, you need to generate an appropriate title for the given summary of some paragraph. The generated title must be short and should include the main topic of the given text. Your summary should be less than 20 words long.
Input: A toddler died after being viciously beaten and then poisoned with codeine by either her mother or her mother's boyfriend, a court has heard.

Eve Leatherland: Dead toddler was 'beaten and poisoned'