This is a phenomena of mob violence which has been stoked up by individuals and social media.
PSNI Chief Constable Matt Baggott added it was fortunate nobody had been killed or seriously injured last night, and he praised police for doing a "magnificent" job.
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The party know their breakthrough in the North of England may be a longer-term project than originally thought.
The number of dead includes 35 civilians, according to reports.
Noye is serving a life sentence for stabbing electrician Stephen Cameron, 21, to death in a road rage attack in 1996.