The expression 'conduct' in s 23(2)(a) of the Crimes Act 1900 (NSW) is not confined to grossly insulting words or gestures; words of threatened violence, blackmail, extortion, or other sufficiently violent, offensive, or aggravating character may qualify as provocative conduct even if they do not constitute an 'insult'. However, mere words of abuse or insult would not normally qualify. The parenthetical reference to 'grossly insulting words or gestures' in s 23(2)(a) is one of inclusion, not limitation.
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