Adler v. George
Rule established
Golden Rule applied to extend "in the vicinity of" to include within a prohibited place, avoiding the absurdity of punishing lesser interference while ignoring greater interference inside.
Facts
- Adler obstructed a member of the armed forces inside a Royal Air Force station
- Official Secrets Act 1920, Section 3: offence to obstruct armed forces "in the vicinity of" a prohibited place
- Adler was physically inside the place, not merely in its vicinity
- Defence argued: "in the vicinity of" literally means near but outside
Issue
- Whether a person inside a prohibited place can be guilty of obstruction "in the vicinity of" that place.
Held
- Literal reading would punish those nearby (lesser interference) while exempting those inside (greater interference)
- This produces an absurd result
- Golden Rule applied: "in the vicinity of" extended to include within
- Conviction upheld
Ratio Decidendi
Where a literal reading produces absurdity by punishing lesser conduct while excusing greater conduct of the same kind, the Golden Rule permits extending a word beyond its ordinary spatial meaning.
How to use it in an exam
- Golden Rule applied to extend/widen a word
- Contrast with R v. Allen (narrowing to avoid absurdity) and Re Sigsworth (reading in words)
- Key line: "In Adler v. George (1964), the court applied the Golden Rule and held that 'in the vicinity of' includes within a prohibited place, since it would be absurd to punish nearby obstruction while ignoring obstruction inside."
Source
Source: [1964] 2 QB 7; standard textbook authority
This is an educational summary, not the judgment itself. Cite the reported version in professional or academic work.