Adler v George [1964]

Adler v George [1964] 2 QB 7 is an English public law case that exemplifies the application of the golden rule of statutory interpretation. The golden rule allows judges to depart from the literal meaning of words in a statute when adhering to it would lead to absurd or inconsistent results.

The case involved the interpretation of Section 3 of the Official Secrets Act 1920. According to the Act, it was an offence to obstruct Her Majesty's Forces in the vicinity of a prohibited place. The defendant entered an RAF Station, a prohibited place under the Act, but argued that he was not in the vicinity of the station, as required by the literal reading of the statute. The key issue was whether the defendant, by entering the RAF Station, violated the terms of the Act, given the literal interpretation of "in the vicinity".

In the High Court, the defendant's conviction was upheld under the golden rule of statutory interpretation. The court applied the golden rule to avoid an absurd outcome and extended the meaning of "in the vicinity" to include "in or in the vicinity of".

Lord Parker CJ emphasised the potential absurdity in strictly adhering to the literal rule. He stated that it would be extraordinary and absurd if an indictable offence was created when obstruction occurred just outside the precincts of the station but in the vicinity. On the other hand, no offence would be created if the obstruction occurred directly on the station itself. The judge's use of the golden rule allowed for a more reasonable interpretation that aligned with the broader purpose of the statute.

This case illustrates the flexibility of the golden rule in statutory interpretation. When faced with an absurd or inconsistent result from the literal interpretation of statutory language, judges can use the golden rule to adopt a more reasonable meaning that aligns with the overall purpose of the statute. In this case, the golden rule was applied to prevent a gap in the law that would render certain actions outside the station unpunishable despite their potential threat.
Back to blog

UOL Case Bank

Upon joining, you become a valuable UOL student and gain instant access to over 2,100 case summaries. UOL Case Bank is constantly expanding. Speed up your revision with us now.

Subscribe Now

Where are our students from?

Yale University
Council of Europe
Baker Mckenzie 
University of Chicago
Columbia University
New York University
University of Michigan 
INSEAD
University College London (UCL)
London School of Economics (LSE)
King’s College London (KCL)
University of London
University of Manchester
University of Zurich
University of York
Brandeis University
University of Exeter
University of Sheffield
Boston University
University of Washington
University of Leeds
University of Law
Royal Holloway, University of London 
Birkbeck, University of London
SOAS, University of London
University of Kent
University of Hull
Queen’s University Belfast
Toronto Metropolitan University
Hong Kong University of Science and Technology
University of Buckingham
ESSEC Business School

  • Criminal Practice

    Diagrams and Charts

    Our carefully designed diagrams and charts will guide you through complex legal issues.

  • Criminal Law

    Clear and Succinct Definitions

    Key concepts are concisely defined to help you understand legal topics quickly.

  • Property Law

    Statutory Provisions

    Statutory provisions are provided side by side with legal concepts to help you swiftly locate the relevant legislation.

  • Public Law

    Case Summaries

    We have summarised important cases for you so that you don't need to read long and boring cases.

  • Evidence

    Rules and Exceptions

    Rules and exceptions are clearly listed so that you know when a rule applies and when it doesn't.

  • Company Law

    Terminology

    Legal terms and key concepts are explained at the beginning of each chapter to help you learn efficiently.

  • Case Law

    Case law is provided side by side with legal concepts so that you know how legal principles and precedents were established.

  • Law Exam Guide

    Law Essay Guide

    You will learn essential law exam skills and essay writing techniques that are not taught in class.

  • Law Exam Guide

    Problem Question Guide

    We will show you how to answer problem questions step by step to achieve first-class results.

  • Conflict of Laws

    Structured Explanations

    Complex legal concepts are broken down into concise and digestible bullet point explanations.

  • Legal System and Method

    Legal Research

    You will learn legal research techniques with our study guide and become a proficient legal researcher.

  • Jurisprudence and Legal Theory

    Exam-focused

    All essential concepts, principles, and case law are included so that you can answer exam questions quickly.