A prosecution under the Public Order Act 1986 s.4A for describing the president of a Sikh temple in abusive and insulting language was unlawful by virtue of the Human Rights Act 1998 s.3 and the European Convention on Human Rights 1950 Art.10 because it had not been shown that the conduct at issue amounted to such a threat to public order as to require the invocation of the criminal law.

[2005] EWHC 2154 (Admin)