Here the applicant had been prosecuted under section 75, as being an "unauthorised person" for the purpose of election expenditure incurred "with a view to promoting or procuring the election of a candidate" in the 1992 general election, over the allowable £5 limit. She was acquitted because the summons was issued out of time. She however bought an action to the ECHR and alleged that section 75 constituted a breach of Article 10, which protects the freedom of expression. The ECHR noted that section 75 did not directly limit the freedom of expression, but was instead aimed at prohibiting unauthorised expenditure during election campaigns for the purpose of promoting a candidates' election. The Court also recognised that the aims of the Representation of People Act 1983 i.e. the promotion of equality between candidates was a legitimate aim. However, the requirement of the promotion of equality between candidates and the freedom of expression had to be balanced.

On the facts of the case, the court ruled (by a majority of 14 to 6) that here Mrs. Bowman had had no other effective means , within the period of the election campaign, of communicating information to the electorate on the candidates' attitude to, and voting record on, abortion. Section 75 thus operated a s a total ban on her freedom of expression (although admittedly within a narrow time frame). On the facts, the court felt that it was not necessary to achieve equality between the candidates, to limit the applicant's expenditure to £5, especially in light of the lack of financial controls at a national party political level. Thus, the Court felt that the restriction posed by section 75 on the facts was disproportionate to the aim pursued. It was therefore a violation of Article 10 of the Convention. Following thus decision, the Committee on Standards in Public Life (Fifth Report, on "The Funding of Political parties in the United Kingdom, 1998) recommended that the limit should be raised to £500, and section 75 amended accordingly.