Golden ruleIn the vicinity ofQueen's Bench Division

Adler v George

[1964] 2 Queen's Bench 719641 min read
The case in brief30-second read
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.
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)
Principle
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.
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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

  1. 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.

Exam use

How to use it in an answer

  • 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."

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Citation

Adler v. George [1964] 2 Queen's Bench 7

Reported: [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.