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As long as you provide a space in front of the closing slash, most older browsers will muddle by; in fact, the space in front of the closing slash is recommended specifically for backwards-compatibility. <br />, <img />, and <hr /> all render fine for us on Netscape 3. Of course, what renders isn't the same as what's valid, but then W3C's validation engine may deserve more weight than third party software or plugins.
<br>> Luckily, no browsers (AFAIK) render it in this way. However, you are dependent on the browser's error-handling. It has to be said, when you're sending XHTML with a
text/html mime type, the same situation applies. In the real world, you are very unlikely to encounter any problems, but if you want your HTML4 to be "correct" (not just pass the validation), you should use
<br>.