Which of the following is an example of active resistance?

Active resistance is characterized by a subject's physical actions that oppose an officer's attempts to gain control or compliance. When a subject pushes or pulls away from an officer's grip, they are directly resisting the officer's authority through physical movements. This behaviour involves a willingness to engage in a physical struggle, which elevates the situation in terms of the level of force that may be required by the officer to manage the contact and ensure safety.

In contrast, making a fist while approaching an officer might suggest an intention to fight or threaten, but it does not involve actively resisting the officer's physical control. Simply ignoring commands reflects passive resistance, where the subject does not comply but does not physically oppose. Falling to the ground to avoid arrest can be viewed as a form of submission or non-compliance rather than active resistance, as it often indicates refusal to cooperate rather than an active effort to thwart an officer's control. Thus, the act of pushing or pulling away is a quintessential example of active resistance.