Memorandum by Professor Malcolm Grant,
University of Cambridge (PI 34)
INTRODUCTION
1. I welcome this opportunity to provide
evidence to the Committee in its study of the Planning Inspectorate.
I note that the terms of reference that have been set by the Committee
relate mainly to operational and detailed matters, and not to
the broader question of the overall role of the Inspectorate,
or its future in a changing world. Nonetheless, there is a reference
to the impact of human rights legislation, and I propose therefore
to use that as the framework on which to construct a broader view
of the options for the future.
THE HISTORIC
ROLE OF
THE INSPECTORATE
2. The Inspectorate plays a central role
in the land-use planning system in England and Wales. It handles
an extensive caseload every year with increasing efficiency and
a good level of customer satisfaction. Yet, as I have sought to
demonstrate in Chapters 9 and 10 of my recently published research
report, Environmental Court Project: Final Report[54],
it is a role which has developed not from any intellectual design
of an ideal dispute-resolution system, but from a process of pragmatic
development and adjustment over the post-War period.
3. The operational origins of the Planning
Inspectorate lie in various attempts during the nineteenth century
to assist Parliament discharge its obligation of inquiring into
disputed matters arising in Private Bill proceedings, by appointing
inspectors to undertake local inquiries and report back. That
was the model that was then institutionalised with the Housing,
Town Planning &c Act 1909, which empowered the Local Government
Board "to cause such local inquiries to be held as the Board
see fit". A corps of inspectors was established. An inspector's
function was to conduct a local inquiry and to report back to
the Board (and subsequently, from 1932, to the Minister of Health).
The inspector's report was secret, and any recommendations in
it did not bind the decision-maker.
4. This model was inherited and extended
by the Town and Country Planning Act 1947. Local inquiries were
to be held for examining objections to development plans, for
planning appeals and for miscellaneous other functions where the
legislation conferred rights of objection against local authority
action, such as the compulsory purchase of land, or the modification
or revocation of planning permission. These were not voluntary
concessions: all parties directly affected were given a right
to be heard, which, unless waived, had to be satisfied either
through a hearing or a public local inquiry.
5. Yet even in this extended model, the
inspector's role was modest. It was as an assistant to the decision-maker,
a civil servant employed by the Minister for the purpose. The
inspector was the Minister's representative, dispatched to the
locality to inquire and report back. The decision was made by
the Minister (or, more commonly, by some other, more senior civil
servant, on his behalf); not by the inspector.
THE PRESENT
ROLE OF
THE INSPECTORATE
6. The role of an inspector today is greatly
different from that of 1947. In practice:
(1) The inspector no longer merely reports:
the inspector decides. In 99 per cent of planning appeals, jurisdiction
has been transferred entirely to the inspector. The inspector's
functions have become more akin to those of a judge than to those
of an assistant to the decision-maker. The transfer of jurisdiction
is not complete: called-in cases are still reserved to the Secretary
of State[55]
(and take much longer); as are other cases such as compulsory
purchase and advertisement control. But in most cases both the
responsibilities and the approach resemble those of a specialist
judge. The difference is that an inspector is not simply making
findings of fact and applying rules of law to those findings,
but also applying and advancing policy, often in a way that requires
highly subjective judgement, such as on aesthetic considerations.
(2) The range of issues which stand referred
to inspectors has broadened. Inspectors today decide or report
on a wide range of land-related matters, from highways and footpaths
to consents and permits relating to environmental pollution; from
housing matters to local plans. These are not, strictly speaking,
matters that are transferred to the Planning Inspectorate, because
it has no separate legal identity. The Inspectorate is the agency
that administers the process, undertakes the recruitment and training
of inspectors, operates managerial case management and ensures
quality control, but it lacks any standing jurisdiction of its
own.
(3) The character of planning disputes has
changed. The decision to implement the European Directive on environmental
impact assessment primarily through the planning system, rather
than setting up a separate or different consenting regime, means
that local planning authorities and planning inspectors are increasingly
involved in the application of European environmental law.
(4) The procedures of the public local enquiry
have become increasingly legalistic. Extensive participation by
lawyers in inquiries has inevitably led to their moulding the
process in their own image. This creates an impression on the
part of the parties that, if they succeed in the forensic debate,
they deserve to win the case. Although the Secretary of State
can and sometimes does reject inspectors' recommendations in cases
where jurisdiction has not been transferred, it is inevitably
a controversial decision and frequently leads to High Court challenge.
Public inquiries perform best when there is great public interest
in a proposal, and not only the parties but also the general public
wish to be heard; and also where there is technical or other disputed
evidence that needs to be closely tested. But they have proved
to be too slow, too formal and too expensive for most appeals.
Although costs are not awarded on the "loser pays all"
basis of the civil courts, they are used as a penalty against
parties who fail to play by the rules.
(5) The public local inquiry is no longer
the principal mode of inquiry. There has been a wholesale shift
on the part of users of the planning system, encouraged by successive
Governments, to reliance on written representations or informal
hearings in preference to public local inquiries. Public local
inquiries are now used in only 8 per cent of all planning appeals.
Informal hearings have grown steadily in popularity (now over
16 per cent), and the remaining decisions are taken on the basis
of written representations and a site visit.
(6) The inspector's accountability in the
courts has deepened with the growth of judicial review. Inspectors
are directly accountable in the High Court, through the processes
of statutory appeals and judicial review, for the manner in which
they handle inquiries and for the reasons they provide for their
decisions. They are not accountable in this forum for matters
of policy, nor for the balance that their decisions strike between
competing considerations. But they are expected, as a matter of
law, to apply relevant policy (from the development plan or Government
circular or PPG) or give adequate and relevant reasons why they
have not. If their reasons are found to be inadequate, or contradictory,
or to disclose some error of law in their approach to their task,
the High Court may strike the decision down, and remit it for
redetermination.
7. These changes, which have taken place
incrementally over many years, mean that there is now a tension
between the theory and the reality of the Planning Inspectorate.
In theory, the process remains one of political accountability.
All decisions are still made by or in the name of the Secretary
of State (or, in Wales, the National Assembly). In practice, most
decisions are made by inspectors, and political accountability
for them is strictly limited because it does not sit easily alongside
the need for the inspector to be, and to be seen to be, independent
of political pressure. Accountability for process, through the
High Court, is of greater practical significance than accountability
for substance through the Secretary of State.
8. This means that the Secretary of State
is now faced with a dilemma. He has progressively delegated most
of his decision-making powers to independent inspectors, yet they
are all still directly employed by him through the Planning Inspectorate,
which remains an agency based within his Department and subject
to his direction. Planning decision making is historically an
administrative process, in which decisions are made on the basis
of policy and the pursuit of some greater public good through
a politically accountable process. But in reality, it is a process
which balances the collective and individual rights of citizens.
Is the Present Role of the Inspectorate Sustainable?
9. An important issue is clearly whether
the future development of the Planning Inspectorate should continue
along the pragmatic lines of the past, or whether a more fundamental
appraisal is now warranted. This is an issue for the forthcoming
Financial Management and Performance Review (FMPR) of the Inspectorate,
but it is a matter on which the Committee may also wish to reflect.
There are two factors in particular that may affect its future
role.
THE HUMAN
RIGHTS ACT
1998
10. The first is the Human Rights Act 1998.
Various provisions of the European Convention affect town and
country planning. They include:
(1) Article 8, which establishes a right
to respect for private and family life and the home, and which
prohibits interference with it by a public authority except where
it is (1) lawful; and (2) necessary in the interests of such matters
as public safety, national economic well-being and protection
of health. It was sufficient in Lopez Ostra v Spain[56]
to found a claim that the construction of a waste treatment plant
next to the applicant's house, which had caused severe local pollution
and health problems, was in violation of the applicant's rights.
This was the case even though the State did not own the plant;
it was sufficient that the municipality had allowed it to be built
on their land and that the Government had subsidised it. Similarly
it was held to be a material provision in a claim in respect of
aircraft noise from London's Heathrow Airport, though there was
found to be no violation of the Convention in the policy measures
that had been adopted[57].
(2) the anti-discrimination provision, Article
16, which was at issue in Buckley v United Kingdom,[58]
where it was claimed that English planning legislation was discriminatory
against gypsies and their traditional way of life by prohibiting
them from stationing caravans on unoccupied land. The Court held
for the Government, but its members were deeply divided, and the
majority took a different line from the Commission for Human Rights
which had conducted a preliminary review of the case. This Article
has also been pleaded in national courts as a defence by gypsies
to eviction proceedings;
(3) the property protection provision of
Article 1 of the First Protocol, which provides protection from
extreme restrictions on property rights, such as 20 years of planning
blight[59].
These substantive provisions are now part of
the legal framework within which inspectors are required to act.
11. However, the most significant provision
affecting the Planning Inspectorate as an institution is Article
6, which protects the right to a fair trial: "in the determination
of his civil rights and obligations or of any criminal charge
against him, everyone is entitled to a fair and public hearing
within a reasonable time by an independent and impartial tribunal
established by law. . . ."
12. How does this apply to the Planning
Inspectorate? To understand this, we need to break the criteria
down into their five components:
(1) civil rights and obligations;
(2) an impartial tribunal established by
law;
(3) an independent tribunal established by
law;
(4) a fair and public hearing;
(5) within a reasonable time.
(1) civil rights and obligations
13. It is clear that the rights of landowners
under a planning system are "civil rights and obligations".
This was accepted by the European Court in Bryan v United Kingdom[60],
and it appears to have been conceded in a recent case involving
the Deputy Bailiff of Guernsey, McGonnell v United Kingdom[61].
It is not clear that the rights of objectors would necessarily
be similarly regarded. Much would depend on the context in which
the question arose, but it is not inconceivable that they might,
for example in a case where the proposed development might cause
serious blight on adjoining property.
(2) impartiality
14. This is a fundamental requirement under
national public law for those exercising judicial or (as with
a planning inspector) quasi-judicial functions. Those who take
decisions under statutory powers must avoid any conflict of interest
or other possibility of bias[62].
The doctrine applies to Law Lords[63];
and it applies also to planning inspectors[64].
However, Article 6 has recently been held to go further than current
national practice. In McGonnell v United Kingdom[65],
the European Court held that the fact that the Deputy Bailiff
of Guernsey had presided over the process through which a planning
policy document was adopted, was capable of casting doubts on
his impartiality when he subsequently determined, as the sole
judge of law in the case, the applicant's subsequent planning
appeal. That ruling lays the basis for a fundamental challenge
to the way in which planning has traditionally been undertaken
in this country, as a process in which decisions on planning applications
are taken in pursuance of policy, and therefore conveniently taken
by the local planning authority, or the Secretary of State, with
responsibility for adopting the policy in the first place.
(3) independence
15. This means independence in two dimensions:
independence from the parties and independence from the Executive.
In relation to the Executive, the issue is not one of the actual
acts or predispositions of the decision-maker, but of the structures
governing the decision-making process. The European Court has
held that, in determining whether a body is "independent",
regard must be had, inter alia, to the manner of appointment of
its members and their term of office, to the existence of guarantees
against outside pressures, and to whether it presents an appearance
of independence[66].
Except to the extent that it is a component of impartiality, independence
has not been a requirement of national law, and it is therefore
an aspect of current practice which will be subject to reappraisal
under the Human Rights Act. There have already been some early
casualties. In Smith v Secretary of State for Trade and Industry[67],
the Employment Appeal Tribunal expressed doubts about the independence
of the employment tribunals. They concluded that it was something
of an anomaly that the employment tribunals should have such close
links with an executive arm of government. They were paid for,
largely appointed and administered by the employment appeal service,
a DTI agency. There was "a real and troubling question"
as to whether employment tribunals might properly and lawfully
adjudicate on claims made against the Secretary of State, having
regard to Article 6 of the Convention. The matter is on its way
to the House of Lords.
16. Then the Scots High Court of Justiciary
in Starrs v Procurator Fiscal, Linlithgow[68]
pronounced that it was unlawful for a prosecution to have been
brought before a judge who had no security of tenure and whose
appointment was subject to annual renewal, because such a judge
was not independent for the purposes of Article 6. The fact that
appointment of deputy sheriffs was made by the Executive, following
selection by the Lord Advocate, was not in itself objectionable.
However, it was necessary in criminal cases that the court of
first instance was independent and impartial. The Court held that
appointment for a term of office expiring not on the completion
of a particular task, or the cessation of a particular state of
affairs, but at the end of a fixed period of time of relatively
short duration, was liable to compromise the judge's independence
if the appointment could be renewed. This relationship of dependency
upon the Executive pointed strongly away from the independence
required by Article 6. It meant that the temporary sheriff's security
of tenure depended upon an assessment by the Lord Advocate of
what should be regarded as grounds for removal from office, or
for not renewing an appointment, or for declining to allocate
work to the temporary sheriff.
17. Significantly, the Court dismissed appeals
to past practice as a justification for the present system. Although
successive Lord Advocates had operated the system with integrity
and sound judgement, free from political considerations, it could
not always be assumed that the Executive would observe these restraints,
and past assumptions need not necessarily hold true following
Scottish devolution. Good faith, practice, tradition and public
opinion were inadequate substitutes for legislative protection.
The decision has not been appealed.
18. The position of planning inspectors
is no doubt closer to that of employment tribunals than Deputy
Sheriffs. They do not hold judicial office, but the great majority
have security of tenure in their employment as civil servants.
Yet they are appointed by the Secretary of State, and they operate
within his policy framework. Jurisdiction can be removed from
them by the Secretary of State at any time. Can they be said nonetheless
to provide an independent and impartial tribunal in the determination
of citizen's civil rights? In Bryan v United Kingdom[69]
the European Court was not satisfied that the inspector was an
independent and impartial tribunal. Whilst it was true that he
was required to decide an enforcement appeal in a quasi-judicial
manner, and to act independently, impartially and fairly, it was
also true that the Secretary of State could at any time issue
a direction revoking the inspector's powers to determine the appeal.
The Court held that in the context of planning appeals the very
existence of this power available to the Executive, whose own
policies might be an issue, was enough to deprive the inspector
of the requisite appearance of independence, notwithstanding the
limited exercise of the power in practice and irrespective of
whether its exercise was or could have been in issue in the present
case.
19. However, the Court maintained that it
had previously accepted[70]
that such defects in relation to a tribunal could be overcome
if it were subject to the supervision of a judicial body that
had full jurisdiction and itself satisfied the requirements of
Article 6. It believed that these requirements were met with a
planning inspector, because there was a right of appeal to the
High Court, and the grounds of review were wide enough to provide
the necessary safeguards. They therefore dismissed the claim.
20. This finding is unsatisfactory. If the
initial hearing was, by definition, conducted by a tribunal which
lacked the requisite independence from the Executive, it is impossible
to understand how that defect can be corrected by a right of appeal
to a body which does not possess the power to rehear the matter
afresh[71].
The inspector possesses a power of rehearing in the case of appeals
from the decisions of local planning authorities, but the High
Court does not. If the threat to the inspector's independence
stems, as the Court found, from his or her proximity to the Secretary
of State, then appeal to the High Court on a point of law offers
no escape from the violation.
21. This was a conclusion reached for reasons
more of pragmatism than of principle. The Court recognised that
it was a frequent feature of judicial control of administrative
systems found in different countries that an appeal tribunal would
have responsibility for findings of fact, and that a higher court
would not have power to substitute its own findings of fact. Indeed,
the Court concluded, "the subject matter of the contested
decision by the inspector was a typical example of the exercise
of discretionary judgement in the regulation of citizens' conduct
in the sphere of town and country planning". But this is,
in effect, to deny either that "civil rights and obligations"
are at stake at all in planning and similar regulatory processes,
or that independence from the Executive is necessary in their
determination.
22. However, certain things follow from
the Bryan ruling that "civil rights and obligations"
may be involved in planning disputes, not least that the Executive's
ability to remove the right to be heard, which has from time to
time been mooted, must be taken to be severely restricted, if
not foreclosed altogether, by Article 6.
23. Secondly, the Human Rights Act crystallises
the issue of inspectors' de facto and de jure independence in
determining planning matters. The British planning system has
traditionally been based on political decision-making and political
accountability. This derives from the time when it was Parliament,
through the private Bill process, that held the balance between
private landowners and the promoters of major projects. The independence
from the Executive that planning inspectors have today is a relatively
recent development, and they are, constitutionally, part still
of the Executive. The procedural rules that advance their fairness,
impartiality and openness, operate so as to ensure that parties
are (if they wish) properly heard before decisions are taken,
but that government policy and the provisions of the development
plan will prevail unless good reason is shown to depart from them.
24. The McGonnell case (though on personal
impartiality rather than institutional independence) advances
a quite different model of a planning system. Given the dominant
role of the Executive in the British planning system, which is
not a characteristic of some other countries, it may not be sensible
to conceive of a decision making process that is completely independent
of Government. Ministers have to be accountable for so major an
area of social regulation, both in policy terms and in relation
to projects of national significance, particularly where these
have effects for parties not represented in the decision-making
process.
25. However:
(1) relatively few matters going to planning
inspectors are in this category. For the bulk of the Inspectorate's
work there is no countervailing justification for maintaining
the present lack of independence from the Executive;
(2) the sentiments of the Scots Court of
Session have resonance here. Although successive Ministers may
have operated the system with integrity and sound judgement, it
cannot always be assumed that the Executive will always observe
these restraints, and, as with Scotland, past assumptions need
not necessarily hold true following Welsh devolution, nor in England.
Good faith, practice, tradition and public opinion are inadequate
substitutes for legislative protection; and
(3) the independence issue is most acute
in those matters where the Secretary of State is directly a party
to proceedings. Examples include highways inquiries (where, in
order to allay fears about the lack of independence to which this
may give rise, inspectors have since the mid-70s been drawn from
a special panel maintained by the Lord Chancellor); compulsory
purchase for government purposes, and the revocation by the Secretary
of State of a planning permission granted by a local planning
authority.
26. Questions must therefore remain as to
whether the independence of the Planning Inspectorate from the
Executive is sufficient, and in all cases, to survive a challenge
under the Human Rights Act 1998. There are alternative models,
including a specialist Environmental Court, which could overcome
this problem[72].
(4) Fair and public hearing
27. Fairness, openness and impartiality
have been both the mission and the hallmark of the Planning Inspectorate
since they were adopted by the Franks Committee in its review
of inquiry procedures in 1957. The public local inquiry itself
is still a remarkably flexible format. Inspectors have the capacity
to adapt between adversarial and inquisitorial styles, as appropriate
to achieving the best opportunities for participation by represented
and unrepresented parties alike. The right to have all evidence
heard in public and all documents open to public inspection is
secured by primary legislation[73],
and although there is a power for the Secretary of State to direct
to the contrary in any particular case[74],
it must now be doubtful whether its exercise could survive challenge
under Article 6.
(5) Decision in reasonable time
28. It is not easy to forecast the impact
of this criterion. The legislation provides applicants with a
remedy against slow decision-making by local planning authorities[75],
but not against the Secretary of State (or a planning inspector
acting in his name). Appeal decisions taking several years, or
even a shorter period in a case with important implications for
an applicant (for example, an application for a dwellinghouse
extension to house a kidney dialysis machine), are potentially
challengeable under the Act.
ACCESS TO
ENVIRONMENTAL JUSTICE
29. The second relevant matter affecting
the future role of the Planning Inspectorate is the broader issue
of access to environmental justice. The UK Government is a signatory
to the Aarhus Convention, concluded in 1998 under the auspices
of the UNECE[76].
There are certain obligations in the Convention which will require
the UK to review its present arrangements. There is, for example,
an obligation to ensure access to a review procedure before a
court of law and/or another independent and impartial body established
by law, to challenge the legality of certain decisions, acts or
omissions specified in the Convention. These extend broadly to
planning decisions that are subject to environmental impact assessment[77].
30. Second, there is an obligation to allow
access by members of the public to administrative and/or judicial
procedures to challenge acts and omissions by private persons
and public authorities which contravene provisions of its national
law relating to the environment.
31. There is widespread concern about two
aspects of the British planning system to which these provisions
are relevant. The first is the lack of balance in the right to
appeal. Developers may appeal against a refusal of permission,
but objectors may not appeal against a grant of permission. Their
rights are limited to complaining to the Local Government Ombudsman,
who has no power to set the permission aside; or by application
to the High Court for judicial review, which is confined to questions
of law and not of merits. These arrangements reflect the assumptions
of 1947 about the relationship between property and the state
and third parties. They do not reflect the ideals of a participative
democracy of the 21st century, and they are not mirrored in the
planning systems of other European or common law countries. That
third party appeals could cause delay and administrative problems
may be true, but is no answer to the question of principle as
to whether such a system is needed. If it is, then administrative
reforms need to be designed to accommodate it.
32. Secondly, the ineffectiveness of planning
enforcement. Experience suggests that administrative systems of
enforcement are less effective than the mechanisms of the civil
courts. In the case of planning, there is a monopoly of enforcement
power in the hands of local planning authorities[78],
and a lengthy process of enforcement notices and appeals that
is capable of being used to delay the impact of effective enforcement
for years. Because it has no standing jurisdiction, the Planning
Inspectorate has no enforcement powers, beyond determining appeals
against enforcement notices. There is presently no means to meet
the Aarhus obligation to allow access by members of the public
to challenge acts and omissions by private persons and public
authorities which contravene national environmental law.
IMPLICATIONS
33. Its review of the Planning Inspectorate
provides the Committee with an opportunity to reflect on these
broader issues. No structural change should be allowed to prejudice
the values and processes that are presently guaranteed by the
Inspectorate, and by individual planning inspectors. In some respects
(such as the presentation of expert evidence) these have shown
the way forward for reforms in the civil justice system more generally.
But satisfying the needs of the future may go beyond that which
can be achieved by yet more pragmatic adjustments to old structures.
February 2000
54 DETR, February 2000. Back
55
In Wales, the power to call-in, or recover jurisdiction from
an inspector, is exercised on behalf of the National Assembly
by the First Secretary, or the Environment and Local Government
Secretary; and the functions of determining planning appeals are
exercised by the National Assembly through ad hoc Planning Decision
Committees: for details, see the February 2000 Monthly Bulletin
of the Encyclopedia of Planning Law and Practice. Back
56
Case of Lopez Ostra v Spain (41/1993/436/515); 9 December 1994;
20 EHRR 277. Back
57
Powell and Rayner v United Kingdom (1990) 12 EHRR 355. See also
Guerra v Italy (19 February, 1998): failure to provide information
to local people about nearby chemical factory. Back
58
26 September 1996; [1996] JPL 1018; [1997] 2 PLR 10; 23 EHRR
101. Back
59
Sporrong and Lonnroth v Sweden (1982) A 52; 5 EHRR 33. Back
60
[1996] EG 137; [1996] 1 PLR 47 (ECHR); 21 EHRR 342. Back
61
Judgement 8 February 2000; The Times 22 February 2000. Back
62
See eg R v Gough [1993] AC 646; R v Secretary of State for the
Environment, ex p Kirkstall Valley Campaign Ltd [1997] 1 PLR 8. Back
63
R v Bow Street Metropolitan Stipendiary Magistrate, ex p Pinochet
Ugarte (No 2) [1999] 1 All ER 577. Back
64
See eg Halifax Building Society v Secretary of State for the
Environment [1983] J.P.L. 816: inspector too hostile; Cotterell
v Secretary of State for the Environment [1991] 2 P.L.R. 37: inspector
too generous. Back
65
Judgement 8 February 2000; The Times 22 February 2000. Back
66
Bryan v United Kingdom [1996] 1 PLR 47. Back
67
The Times, 15 October 1999. Back
68
The Times, 17 November 1999. Back
69
[1996] 1 PLR 47. Back
70
Langborger v Sweden (22 June 1989, Series A No 155) 12 EHRR 416. Back
71
See eg De Haan v Netherlands (1997) 26 EHRR 417 where the European
Court held that a breach of article 6 arising from the composition
of the original tribunal had not been rectified by a right of
appeal to the Central Appeals Tribunal, because that body was
not able to reassess the medical evidence and thus decide itself
the issue in dispute (para 53). Back
72
See further Malcolm Grant, Environmental Court Project. Final
Report. DETR 2000. Back
73
Town and Country Planning Act 1990, s.321. Back
74
Town and Country Planning Act 1990, s.321(2). Back
75
Town and Country Planning Act 1990, s.78(1), which allows the
applicant to appeal as if the application had been refused. Back
76
Ratification by 16 states is required to bring the Convention
into force. At the time of writing, the EU and four states (not
including the UK) had ratified. Back
77
These are listed in Annex I, and although the list is based upon
the amending Council Directive 97/11 on environmental assessment,
it includes as projects where assessment is mandatory not only
those projects listed as mandatory in Annex I to the EC Directive,
but also some projects drawn from Annex II of the directive where
assessment is a matter for the Member States to determine their
own thresholds. This approach is based on the IPPC Directive. Back
78
With a long-stop, and rarely used reserve power for the Secretary
of State: Town and Country Planning Act 1990, s.182. Back
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