Robertson J. determined at paras. 14 and 24 that the test used in the trilogy of cases originates from the definition of “obstructing” set forth in Hinchcliffe v. Sheldon, [1955] All E.R. 406 at 408 where Lord Goddard C.J. stated: “Obstructing means, for this purpose, making it more difficult for the police to carry out their duties.”
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