In circumstances of public violence involving multiple participants, a police instruction to an arrested person to go to the ground is a lawful part of the arrest process where it serves to calm participants, prevent continuation of fighting, and preserve safety. A verbal refusal to comply with such a lawful instruction alone constitutes obstruction of a public officer under s 172(2) of the Criminal Code (WA). Courts assessing the reasonableness of police force in volatile situations must account for the fact that arrests often occur in circumstances of sudden violence where officers cannot make fine judgments and must act quickly and decisively.
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