ABSTRACT
There is little guidance in the Protection from Harassment Act 1997 as to what is meant by a ‘course of conduct’. Section 7 specifies that a course of conduct requires conduct on at least two occasions2 and states that conduct can include speech3 but, other than this, there are no statutory limitations as to what form of conduct is prohibited and what circumstances constitute a course of conduct. Therefore, the wording of the statute suggests that any two incidents of behaviour may amount to a course of conduct – the first stage of liability for harassment. There are, however, various issues associated with this that require consideration.
