Test for adequate words for arrest

The Court of Appeal held that when considering whether an arrested person had been properly informed of the true ground of arrest, the test whether the words used were adequate was sufficiently set out in section 28(3) and (4) of the Police and Criminal Evidence Act 1984, article 5(2) of the European Convention on Human Rights, and Fox, Campbell and Hartley v United Kingdom (1990) 13 EHRR 157, paragraph 40.