- The defendant sent 538 racially abusive letters to various recipients
- Did this constitute a public nuisance?
- No common effect on all of the recipients
- A public nuisance is an act not authorised by law which omits to discharge a legal duty and endangers the life, health, property, comfort or public rights of a class of persons in a common way.
- Judges should not put criminal offences to unorthodox uses, but should prefer slow, incremental change and prioritise the use of statutory offences over common law offences