Adler v George
The golden rule allowed the words in the vicinity of a prohibited place to include being inside it.
Facts
Section 3 of the Official Secrets Act 1920 made it an offence to obstruct a member of the armed forces in the vicinity of a prohibited place. Mr Adler took part in a demonstration inside RAF Marham, a prohibited place, and obstructed a member of the armed forces there. He argued that he was not guilty, because he was in the prohibited place, not in its vicinity, which he said meant near or close to it.
Legal principle
The Divisional Court upheld his conviction. Lord Parker CJ said that it would be extraordinary and absurd if a person who obstructed members of the forces near a prohibited place committed an offence, but a person who did so inside it did not. Applying the golden rule, the words should be read as in or in the vicinity of a prohibited place, to avoid that absurdity.
Related cases on statutory interpretation
- Black-Clawson International Ltd v Papierwerke Waldhof-Aschaffenburg AG [1975] AC 591
- Corkery v Carpenter [1951] 1 KB 102
- Grey v Pearson (1857) 6 HLC 61
- Heydon's Case (1584) 3 Co Rep 7a
- Inco Europe Ltd v First Choice Distribution [2000] 1 WLR 586
- Jones v Tower Boot Co Ltd [1997] ICR 254
- London and North Eastern Railway Co v Berriman [1946] AC 278
- Magor and St Mellons Rural District Council v Newport Corp [1952] AC 189
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