You have not covered anything like all cases these, and the article makes it clear "breaching a buffer zone" was standing silently while praying.

> Poole Magistrates' Court heard the former serviceman had his head bowed and hands clasped outside the British Pregnancy Advisory Service in Ophir Road.

> The court was told he had been praying for his unborn son, who he said died from abortion 22 years ago.

In a declared buffer zone, after announcing he intended to this, and after an hour or more of refusing to move on.

It was deliberate disregard of a buffer zone that applied to all that had no business within the abortion centre, whether he was praying in his head or not we'll never know and it's immaterial to the reason for the arrest.