According to the elements of a lawful arrest, what is a "sufficient act of arrest"?

A "sufficient act of arrest" is characterized by the restraint or submission of the suspect. This means that for an arrest to be lawful, there must be a clear indication that the suspect is effectively taken into custody, which is typically demonstrated by physical restraint or by the suspect voluntarily submitting to arrest.

In legal terms, an arrest is not merely an announcement or declaration; it necessitates that the individual being arrested recognizes the authority of the arresting officer and complies with it or is physically restrained. This element is essential to ensure that the arrest is justifiable under the law and respects the rights of the individual involved.

Other actions, such as speaking loudly to the suspect or creating a public scene, do not constitute a lawful act of arrest, as they do not fulfill the requirement of actual restraint or compliance from the suspect. Additionally, simply reporting a suspect's behavior does not constitute an arrest at all, since it lacks any direct action towards taking the individual into custody.