The defendant had made hundreds of obscene telephone calls to at least thirteen women. The defence argued each telephone call was a single isolated act to an individual. Tucker J rejected the argument at pp. 370–371: This was followed in a number of cases such as R v Holliday and Leboutillier (2004) EWCA Crim 1847 in which two animal liberation activists made a large number of telephone calls to employees and shareholders of certain companies whose activities the appellants opposed. The calls were designed to jam the company telephone switchboards, and some of them were threatening and intimidating. The common law offence of public nuisance was abolished by section 78 of the Police, Crime, Sentencing and Courts Act 2022. The law reviewed In R v Goldstein and Rimmington (2005) UKHL 63 two separate appeal cases were considered together. The Lords began their judgment with a detailed review of the law and its history. Two arguments were raised by the defence. The first was that most of the factual situations that might otherwise have been criminal public nuisances had now been covered by statutes. Thus, for example, s. 1 Protection from Harassment Act 1997 would now be used in cases involving multiple telephone calls, and s. 63 Criminal Justice and Public Order Act 1994 confers powers on the police to remove persons attending or preparing for a rave "at which amplified music is played during the night (with or without intermissions) and is such as, by reason of its loudness and duration and the time at which it is played, is likely to cause serious distress to the inhabitants of the locality". These statutes had, in effect, made the common law offence redundant and it should no longer be considered an offence in English law. The Lords agreed that, as a matter of practice, all alleged offences falling within the remit of statutes would now be charged under those statutes. It also accepted that this left only a very small scope for the application of the common law offence. But, just as the courts had no power to create new offences (R v Withers), and could not widen existing offences so as to retrospectively criminalise conduct (R v Misra and Srivastava (2004) EWCA Crim 2375), it equally had no power to abolish existing offences. However, cases such as R v Norbury and R v Johnson (Anthony) would now be charged under