In 2004 the High Court considered the meaning of a statutory offence of using insulting words in a public place. Justices Gummow and Hayne held that in the context of the section, '"abusive" and "insulting" should be understood as those words which, in the circumstances in which they are used, are so hurtful as either they are intended to, or they are reasonably likely to provoke unlawful physical retaliation'. Judge Michael Kirby employed similar reasoning. Chief Justice Gleeson took a slightly different approach to the construction of the section, finding that: