Many police practitioners will pause on learning that they are instructed in a case involving an arrest for breach of the peace. The reason being – that the law on when an arrest can be made is not always well understood by arresting officers. That is not to be discourteous to the police. Rather, it is a recognition of how complicated this issue can be. The Supreme Court in the case of R (Hicks) v Comr Metropolitan Police  UKSC 9 gives some assistance to the police where they seek to arrest persons in light of an imminent breach of the peace and provides a simpler statement of the law than did the Court of Appeal.