Dumbar v The State

Facts

At a public meeting attended by the Prime Minister, a politician and clergyman said he was 'sorry for Sierra Leone', causing a commotion.

Issue

Was this insulting conduct likely to provoke a breach of the peace under section 3 of the Public Order Act 1965?

Held

Yes. Following Ward v Holman, there was ample evidence; the charge was not bad for duplicity or uncertainty. The appeal was dismissed.

Principle

Whether conduct is insulting and likely to provoke is judged in its context, including the audience.

Why it matters

The leading case on section 3 of the Public Order Act.

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