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This case ([1989] Crim LR 150) demonstrates some of the complexities relating to the question whether it is lawful to resist arrest. The defendant in this case was a minor, but it is doubtful whether this is significant. 'G' and his friends were ejected from a bus, for reasons not reported. They decided to make a complaint at a police station. When the officer on duty asked their names and addresses some of them they refused to tell him, or gave false particulars. One of the juveniles, referred to as 'X' did in fact give a correct address.

Later, during questioning about the incident, G and X became abusive and threatening, and the constables attempted to arrest X to make him answer to charges of violent disorder (contrary to the Town police causes act (1847)). G punched the constable, and was himself arrested and charged with obstructing a constable in the execution of his duty. At trial, both G and X were convicted of the obstruction. It was accepted that the 'violent disorder' was not, in itself, an arrestable offence. The arrest of X was held to be lawful because the constable had reason to suspect the correctness of of his address.

On appeal to the Divisional Court, G's defence was that he was resisting an unlawful arrest. Since it was accepted that the violent disorder was not an arrestable offence, the lawfulness of the arrest hinged on whether the constable had good grounds to suspect that X's address was incorrect. This form of arrest is allowed under s.25 of the Police and criminal evidence act (1984), provided that the arresting officer ...has reasonable grounds for doubting whether an address furnished by the relevant person is a satisfactory address for service [of a summons]. However, the court rejected the constable's submission that generally, offenders did not give correct details. That being the case, it was held that the arrest was unlawful, and that defendant X was entitled to resist. Thus, since a constable's duties cannot, by definition, include unlawful arrests, he could not have been acting in persuit of his duties in apprehending X, so G could not be guilty of obstructing him in his duties. Accordingly, the convictions of both G and X were both quashed.