The One Direction star allegedly caught the girl by accident as he tried to punch a photographer while battling through a frenzied horde of fans, reported Daily Star.
"He was aggressive and made rude gestures as he tried to reach the car," a source said.
The group, which also consists of Harry Styles, Liam Payne, Niall Horan and Louis Tomlinson, is currently in the US to promote their new album Midnight Memories.