When did "Hands up!" become "Hands behind your head!"?

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When it was realized that 'behind your head' takes a lot less effort to do, so can be held for longer periods.

As an example, try standing on both positions and see which is most comfortable to hold for longer.

So if someone were to be told to stand with their hands above their head, after a short while they will tire and their arms will begin to drop, which to the police could be either fatigue, but also starting to reach for a weapon. Behind your head can be held comfortably a lot longer, so unwanted movement is a lot more obvious.

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