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
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