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"Devastation of Earth" is a title based upon conjecture.
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The Fifth Doctor once fought the Daleks, as well as Davros, in a battle that ultimately devastated entire worlds and left the Earth a charred ruin. Eventually, amongst the rubble of several fallen buildings, the Doctor and a Dalek representative finally agreed to disagree. With Davros in attendance, the Doctor shook hands with the Dalek's suction cup to signify the creation of the ceasefire. (NOTVALID: Doctor Who? 194)