We investigate an implication of the most recent observation of a second J π = 2 + state in 12 C, which was measured using the 12 C(γ,α) 8 Be (g.s.) reaction. In addition to the dissociation of 12 C to an α-particle and 8 Be in its ground state, a small fraction of events (2%) were identified as direct decays and decays to excited states in 8 Be. This allowed a limit on the direct 3α partial decay width to be determined as Γ3α < 32(4) keV. Since this 2 + state is predicted by all theoretical models to be a collective excitation of the Hoyle state, the 3α partial width of the Hoyle state is calculable from the ratio of 3α decay penetrabilities of the Hoyle and 2 + states. This was calculated using the semi-classical WKB approach and we deduce a stringent upper limit for the direct decay branching ratio of the Hoyle state of Γ 3α Γ < 5.7 × 10 −6 , over an order of magnitude lower than previously reported. This result places the direct measurement of this rare decay mode beyond current experimental capabilities.