If such person forcibly resists the endeavor to arrest him or attempts to evade the arrest, the person making the arrest may use such means as are reasonably necessary to effect the arrest. Section 2(A) of the police Department Order A20, states that the procedure of an arrest should occur without violence. However, if there is a necessity to use force prior or post to such arrest, the use of force shall be minimal and as necessary. In the instance when the students were being arrested, it cannot be observed whether the police acted against the above mentioned legal standard and procedures. When an arrest is made, the suspect must be told why such an arrest is being made under Article 13(1) of the Constitution. Although the complainant maintains they were not made aware of the reason for their arrest, the respondents state that the arrest was due to the breach of Section 140, 153, 314, 316 which has to read together with section 32 of the Penal Code and Section 59(1) of the National Thoroughfares Act No. 40 of 2008. There is not enough evidence to affirm whether the police made the students aware of the reason for the arrest, therefore it cannot be determined whether there was a violation by the police of Article 13(1) of the Constitution. 7.1.4 Freedom of Expression and Assembly Article 14(1) of the Constitution protects freedom of expression, peaceful assembly and association. The Commission considers whether the rights of the students under Article 14 have been violated. Although the students are entitled to these freedoms, the exercise of these rights is subject to the limitations specified under 15(2), 15(3), 15(4), and 15(7). According to the National Thoroughfares Act No.40 of 2008 and Section 77 of the Police Ordinance, any procession in public places has to be notified to the OIC of the nearest police station at least six hours prior to the event. The complainants accept they did not provide any such notice to the police - but the police offered their full co-operation to the protest march from Fort to Ward Place and assisted when the students attempted to meet with higher Ministry officials. The respondents only took measures to disperse the crowd when they began behaving aggressively, therefore there is no evidence to support that there is a violation under Article 14 of the Constitution. However, it is observed that the measures used by respondents to disperse the gathering go beyond the legal limitations. The force used was not minimum or reasonable – it had exceeded what was within their power. 95