In Smith v. Hughes (1960), prostitutes attracted the attention of passers-by from balconies and…

Lord Parker began by asking what mischief the Act was aimed at, and held that it was meant "to clean up the streets so that people could walk along them without being solicited, and it mattered little where the prostitute stood". The decision rests on the mischief rule, not on any claim that a balcony is literally part of a street.