283. Crowds and demonstrations.

The European Court of Human Rights has held that for the purposes of determining whether members of the public have been deprived of their liberty¹ it is relevant to consider the context in which they might be called upon to endure restraint in the course of the policing of protests or other large gatherings². Commonly occurring restrictions on movement, such as when travelling by public transport or on the motorway or attending a football match, will not qualify as deprivations of liberty provided they are rendered unavoidable as a result of circumstances beyond the control of the authorities, are