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Following the Principle of Original Horizontality, he could say that whatever forces caused the deformation, like an earthquake, must have occurred after the formation of all the rock strata.
Relative dating cannot establish absolute age, but it can establish whether one rock is older or younger than another.
Relative dating requires an extensive knowledge of stratigraphic succession, a fancy term for the way rock strata are built up and changed by geologic processes.
Let's say, in this set of rock strata, that we found a single intrusion of igneous rock punching through the sedimentary layers.
We could assume that this igneous intrusion must have happened after the formation of the strata.