Hamidu s/o Udu v. R., (PC) Crim. App. 66-D-67; 26/6/67; Hamlyn, J.

Hamidu s/o Udu v. R., (PC) Crim. App. 66-D-67; 26/6/67; Hamlyn, J.

Accused was convicted, inter alia, of “Brawling contrary to section 89 (1) (b) of the Penal Code, Cap. 16.” He was the sole person involved in the disturbance.

            Held: In English law, the term “brawling” is apparently confined to “improper behaviors in religious building.” The Oxford dictionary, however, defines the verb as “to wrangle or “to squabble “, and the noun as “a noisy turbulent quarrel, a row.” This indicates that two or more persons must be involved, and the conviction, therefore, must be set aside.