A youth court erred in concluding that a youth who made masturbatory gestures towards a police officer and called him a "wanker" was guilty of using threatening, abusive or insulting words or behaviour with intent to cause harassment, alarm or distress contrary to the Public Order Act 1986 s.4A, as there was no evidence that the police officer had been caused emotional disturbance or upset by the behaviour or that the youth intended to cause distress.

[2006] EWHC 1375 (Admin)