Stephen Green, an evangelical Christian with a distinguished record in protest, was arrested at the beginning of February and charged, after holding a placard depicting words that mentioned a womb (taken from Psalm 139) within the statutory buffer zone near an abortion clinic.  

Reflecting on the precedent of the government of the day silencing religious protestors, some commentators have looked to events during 1670 in Britain. Back then, Quakers William Penn and William Meade were arrested and put on trial for a silent religious act in a public street, which was an apparent contravention of an Act of Parliament that prohibited gatherings of more than 5 people.