If you read deep into the story it does say "A spokesman for Avon and Somerset Police said 'Under the Sexual Offences Act 2003, it is not an offence for a person to appear naked in public.
'But it becomes an offence if it can be proved that the person stripped off with the intention to cause distress, alarm or outrage.' "
But Surrey Police said 'If you want to wander around your garden naked and you are overlooked neighbours then you have to be careful - an Englishman's home is not quite his castle and your garden is not exempt from the law.
So which is it since if your sunbathing then you are not trying to cause offence and if you are waving your tackle about then you are clearly not sunbathing?
http://www.dailymail.co.uk/news/article-5911691/Want-sunbathe-naked-heatwave-Make-sure-tell-neighbours-warn-police.html