Wrong placement for a patch?

Is this patch not supposed to be on the upper arm or shoulder of the battledress?

There has been a lot of discussion about the wearing of patches in this manner. It is an unauthorized use of the 21st Army Group formation sign, but is seen on uniforms. Some information suggests that they were worn in this manner to indicate the service in Northwest Europe. (Many tunics for Cdns who served in Italy wore the 8th Army patch in the same manner, to indicate their service in "sunny Italy". It has been suggested the 21st AG patch was worn for a similar reason, service in NW Europe.) Another explanation has proposed that the 21 AG patch was worn as such by those who were taken Prisoner of War. How that would be regulated is an interesting question.