APPENDIX 4
Supplementary memorandum submitted by
the Parades Commission
TRANSPARENCY
1. The Commission has often been criticised
for its lack of openness and lack of transparency. Arguably these
criticisms may once have been more valid than they are now. Certain
changes have evolved over time, which makes the Commission's practices
particularly open, especially given the sensitive nature of its
work.
2. In a number of engagements in the past,
the Commission found it necessary to emphasise the confidentiality
of the information it received. In doing this the Commission drew
attention to Rule 3.3. of its Procedural Rules which set out clearly
that the Commission must treat all evidence it receives confidentially
and that such evidence and information will be used only by the
Commission and its staff. This gave the impression, and wrongly,
that the Commission would not communicate any aspects of that
information to concerned parties. It seemed as if the Commission
had set its face against a fundamental element of a fair trial—the
right to know the evidence or charges against one.
3. In fact this was not the case. There
are several good reasons to maintain confidentiality. Such a guarantee
encourages people to come forward and share their views frankly
and honestly. There is a clear security dimension here. One cannot
overlook the fact that people, if they are identified or associated
with certain views, would feel that their personal safety had
been compromised. It is likely that only those offering more extreme
views or those in the public view already, would be robust enough
to want to be associated personally with their information or
evidence. This would be unlikely to promote the language of compromise
or tolerance.
4. Sir George Quigley has stated that parties
have no opportunity ". . . to challenge any statement which
may be made by the other side". He also has stated that no
one tells the Loyal Orders that there has been a breach of a determination.
This is inaccurate. The Commission writes to organisers and tells
them of any allegations which it has received in respect of their
individual parades, regardless of the source of this information.
The Commission is careful to point out that these are allegations
and that it seeks to be as well informed as possible as to actual
events. Therefore, the Commission invites the organiser in each
case to respond to quite detailed and specific "charges"
made. In addition, there is always the opportunity to come in
and discuss the matter further with the Commission or its officers.
5. The Commission accepts that it is important
to be open and disclose as much information to protagonists as
possible. This acceptance that organisers have a right to know
the case being made against them does not always mean that there
is a need to attribute remarks to specific individuals, especially
where to do so may endanger those individuals or cause them fear
and anxiety.
6. The Commission encourages participants
in parading disputes to engage directly or even indirectly with
one another rather than the Commission acting as a voice between
them, relaying its understandings of both. This allows more open
communication not filtered by the Commission or anyone else. This
will help to ensure greater transparency. It also will help to
promote the open relationship Sir George talked about—not
to stand in the way of it.
ENGAGEMENT
The Parades Commission is sometimes asked what
constitutes "engagement", or "meaningful dialogue"
and how the Commission would assess it. The Commission is on record
as stating that its preference is for face-to-face dialogue. Members
recognise that other forms of dialogue should not be ignored,
but should be given whatever recognition they would deserve in
specific circumstances.
In its 1999-2000 annual report, the Commission
stated "Engagement by either party represents a real attempt
to address the legitimate concerns of others, and a preparedness
to accommodate those concerns, where it is within their power
to do so." In its 2000-01 report, the Commission provided
an updated version of what each party could be expected to do,
during an engagement, namely:
— enter the process with no predetermined
outcomes;
— listen to and try to understand the
other's concerns;
— show respect to the other, by taking
their concerns seriously;
— be willing to communicate their own
legitimate concerns clearly;
— focus on issues that are capable
of being addressed by the parties concerned;
— demonstrate a commitment to resolving
the problem and addressing legitimate concerns, preferably within
a target timetable;
— be represented by people with the
authority to speak for the protagonists; and
— demonstrate a willingness to consider
some form of third party intervention, such as mediation, if direct
dialogue is not possible.
Clearly the above points are designed to demonstrate
that meaningful dialogue has to be much more than what the Commission
sometimes refers to as a "boxticking exercise". The
aim has to be to understand and reassure local people who have
concerns about parading.
RISK ANALYSIS
OF MAIN
RECOMMENDATIONS OF
QUIGLEY
1. There is a need to place higher on society's
agenda a response to the range of broader contextual issues which
affect, and are affected by, parading. Risk rating: Medium. There
is no doubt that if a creative and thoughtful societal debate
on parading could be developed it could contribute to drawing
more moderate voices into the parading debate and this can only
be helpful. But many of the issues which go to the heart of the
parading conflict involve quite sophisticated legal points about
human rights in relation to the right of assembly, the right to
a parade as an assembly, and the right to a specific route as
part of that parade. Raising the profile of parading again could
also be a means of raising the temperature surrounding issues
about parading which are never far below the surface at the best
of times. The Parades Commission has taken a degree of satisfaction
with the way in which parading issues have departed the news headlines
over the last two years. There is no doubt that this has contributed
significantly to the lowering of the levels of contention at many
of the most difficult parading locations. It is arguable that
raising the profile of the subject among a wider audience plays
into the hands of those (in both traditions) who can easily become
obsessed with the subject.
2. The search for local accommodation, which
is an imperative, should be reinforced through the establishment,
within the regulatory machinery and directly managed by it, of
a Facilitation function, headed by a Chief Facilitation Officer
who would be supported by a local, probably part-time, facilitation
network. Risk rating: High. There is no doubt that demand for
the kinds of services currently provided by the Authorised Officers
will continue to grow as more and more parade organisers begin
to engage with the machinery surrounding the regulation of parading.
The key to mediated engagement is finding mechanisms that are
acceptable to all sides in any particular parading dispute. Given
the ease with which protagonists to parading disputes can become
offended by those who are involved in the mediation or the promotion
of mediation, it is important that a diversity of options remain
available for those wishing to find a way forward through mediated
dialogue. The Facilitation Function may reduce the flexibility
required on this issue, particularly if one protagonist loses
confidence in it. If one party does engage with such a body, the
opposing party may not, thereby replicating, but in reverse, what
is the current position faced by the Commission, given the fact
that, at the moment, some in the loyal orders steadfastly refuse
to engage with it. In addition, the existence of a specific Agency
may act as a magnet for minor complaints, and transform molehills
into mountains. The requirement for the Chief Officer to produce
a Report to the Panel creates considerable inflexibility and establishes
a document about each parading situation that could be the subject
of considerable contention. Quite fundamentally, the Report permeates
the "non-permeable" wall proposed by Sir George between
the Facilitation Agency and the Panel. This is much more than
an academic point. It may be better to have no report at all than
to have a document that triggers the Panel into action on more
occasions than may be wise.
3. It should be made plain on the face of
the legislation that the object of the Facilitation faction is
to build mutual trust and confidence by promoting mediation as
the primary mechanism for resolving disputes. Risk rating: Low.
It may well be that Sir George considers that the present Commission
did not make the objective of mediation sufficiently clear and
that if the protagonists begin to discuss the issues, resolution
is around the corner. There is no doubt, in the context of Drumcree
two years ago, that the Commission wanted to replace the concept
of disorder as the best means to achieve a parade and replace
it with dialogue. This simple message (suitable for those standing
at the back of the Orange Hall) was arguably vital in reducing
the contention around the parading dispute in Drumcree and, indeed,
elsewhere. As the levels of contention have eased, it has become
easier to point in a more sophisticated way to the purpose of
dialogue as being the building of mutual trust and confidence,
that reduces the human rights impact of parades. Nevertheless,
it remains the case that there are those within the loyal orders
who do not consider their opponents in the residents' groups to
be people with whom mutual trust and confidence can ever be achieved.
They would certainly still be slow to negotiate with residents'
groups—even if they agreed to communicate with them.
4. The parties would not be precluded from
agreeing between themselves alternative arrangements for settling
their differences but the Chief Facilitation Officer would have
to be satisfied that, whether using his own services or by other
means, effective steps were being taken to seek resolution of
a dispute. Risk rating: High. It is not clear how this significantly
differs from current arrangements, other than that a single individual,
the Chief Facilitation Officer, would be responsible for preparing
a report to the adjudicating body, thereby formalising the mediation
process. The risk in this particular proposal is also the challenge
presented to the Chief Facilitation Officer in terms of retaining
his credibility on a sustained basis among all parties and at
all locations in the preparation of his reports. It is conceivable
that the turnover of Chief Facilitation Officers could be quite
high.
5. The facilitation stage be characterised
by good faith efforts to resolve the issues involved. Risk rating:
None. This is an aspiration and deserves no risk rating, though
it could easily be argued that since it is not likely to be quickly
achieved, the assumption is a high-risk one. Sir George has considerably
under-estimated the issues at stake in relation to mediation and
dialogue about parades. Engagement will not quickly resolve all
parading problems in the way that was possible in Londonderry,
particularly if the loyal orders continue to see the parade route
as an absolute route not to be negotiated and whilst a nationalist
parade in strongly loyalist areas would remain problematic.
6. Agreements reached at the facilitation
stage should be committed to paper to avoid misunderstanding and
should be formally registered so that they have the same force
as a determination. Risk rating: Medium. This is common practice
already. There have however been occasions over the past few years
when some agreements were successful because they were not written
down, so it would be essential to retain some flexibility on this.
7. In line with Article 11(1) of the European
Convention on Human Rights (ECHR), the Public Processions (Northern
Ireland) Act 1998 should be amended to affirm that everyone has
the right to freedom of peaceful assembly, defined to include
peaceful procession. Risk rating: Low. There is no great difficulty
with this recommendation, though we may wish to take a legal opinion.
It does nothing to resolve the outstanding issue of the right
to a particular route.
8. In line with Article 11(2) of the ECHR,
S8(6) of the 1998 Act should be replaced by a provision that such
a restriction shall be placed on the exercise of the right of
freedom of peaceful assembly as are necessary in a democratic
society (i) for the protection of the rights and freedoms of others
or for the protection of health or morals or (ii) in the interests
of national security or public safety or for the prevention of
disorder or crime. Risk rating: High. It could be argued that
the ECHIR standing alone is unduly simplistic in the context of
parading in a divided society like Northern Ireland, with the
subliminal (and not so subliminal) messages that it sends. Removal
of the criterion about relationships in the community may, in
the end, prove largely to be disadvantageous to parading organisations
as well as to local communities. The purist human rights approach
advocated in the Panel may either find that in most circumstances
the parading route is seen not to be particularly relevant to
the right of assembly and is therefore easily restricted, in which
case far more parades than at present would be restricted (residents
groups may have to become imaginative in devising traffic problems!),
or it may find that the right to the parade is a higher priority
in most cases and nearly all parades would be allowed (subject
to the police determination). In those circumstances one can only
imagine the impact that such development would have on relationships
between the two main parts of the community in Northern Ireland.
The current mixed model in Ardoyne for example, (with "wins"
and "losses" for both sides) might well become much
more difficult to maintain. "Relationships in the community"
provides considerable room for manoeuvre in assuaging perceptions
of unfairness, which so often play into disorder at a later stage.
Essentially a "one size fits all" approach to human
rights flies in the face of the judicial approach adopted by the
Strasbourg Court which by its decisions over the years has given
a firm basis to the concept of a margin of appreciation being
left in the hands of States in order to take specific account
of local problems. This, so that the blunt instrument of human
rights, absolutely enforced, can be tempered to encourage progress
in such contentious issues.
9. New Guidelines should be prepared setting
out primarily the factors to be taken into account at the Determination
stage in assessing the extent to which a planned parade would
affect the rights and freedoms of others under any Article of
the ECHR or any other international agreement to which the United
Kingdom is a party or under the general law. Risk rating: High.
The risk associated with this particular proposal relates primarily
to the exclusion of the disorder criterion from the thinking of
the Determining Body. It is not easy to see how this would be
possible in practice. The police would have to repeat the work
of the Panel, but taking public order and police safety into account.
The Panel might well quickly become perceived, in a final analysis,
if not sooner, as an ineffective white elephant.
10. Where good faith efforts will not produce
the settlement at the facilitation stage, the Determining Body
should arrange a hearing. Risk rating: High. The recommendation
itself is not different from current procedures. But the detailed
description of it in the body of the report makes it difficult
to imagine how a process could be devised which is more poisonous
to the prospect of satisfactory resolution of parading problems,
and one which is so likely to exclude the moderate, reasonable
interests from coming forward when it is those interests that
any system should be most at pains to encourage and nurture.
11. Proceedings should be as informal and
user-friendly and procedures as simple as possible. Risk rating:
High. This kind of procedure will be "meat and drink"
for hardliners. The stated aim of "creating an atmosphere
giving all parties confidence in their ability to participate
in the process and with them leaving the procedures feeling that
they have had a fair opportunity to put their case" is difficult
to imagine in practice. The proceedings are more likely to be
infested with lawyers, acrimonious and time-consuming. It could,
and probably would, become a procedural nightmare. It is also
possible that some parties will have better access to lawyers
than others, giving them an advantage. Finally, if at the end
of it all, having secured, at some cost, in terms of money and
time, a good result, it is easy to imagine the reaction of fury
if the police, on the grounds of public order, render the decision
nugatory.
12. Determinations should make clear the
conclusions reached on each of the Guideline factors in light
of the evidence from parade organisers, those registering objections
and any other interested party. Risk rating: Medium. The main
difficulty here is that the Guideline factors are distorted in
relation to the FCHR by the exclusion of the disorder factor beyond
"evidence of intention to organise a parade which will be
peaceful". Finally identifying in any determination what
was the decisive evidence either way could, and probably would,
place those to whom it could be attributed, in physical danger.
13. Where frequency of parades is at issue,
the parading interests should have an opportunity to arrange their
own priorities (including the priority to be given to traditional
parades). Risk rating: Medium. There are a number of problems
with this, notably the possibility of a real difficulty for parading
organisations managing even to agree amongst themselves which
parades should not go ahead (given their assertion that the right
to parade cannot be negotiated). More fundamentally, it is difficult
to square the assertion that more traditional parades should have
priority with dropping the traditionality criterion on the grounds
that it is not compatible with equality provisions. It is probable
that parading organisations would fail to agree in this area.
14. The Determining Body should be empowered,
at its discretion, to make rulings for periods of up to five years,
subject to review if there is any material change of circumstances.
Risk rating: Low. The scope for review is important given the
timescales involved.
15. Determinations should be binding and
alleged breaches should be reported to a Compliance Branch within
the Determining Body and promptly brought to the attention of
parade organisers and investigated. Risk rating: Low. This is
a good idea requiring an investment in the resources available
to the determining body.
16. Organisers of parades should notify
their intention to parade no later than 1 October each year for
the following season but, where this would allow a period of less
than six months before the date of the parade, the notice should
be required to be submitted no less than six months prior to that
date. Risk rating: Medium. The risk in this recommendation is
not that it is not desirable, but that it may not be realistic
for a great many parades organisers. The Commission already deals
with a substantial number of late notifications with a 28-day
notification period. There would have to be, at the very least,
a facility for many parades to be notified late. It is possible
that this recommendation would be considered by the courts to
be unreasonable, though that would not preclude, say, organisers
of traditional parades from voluntarily agreeing to notify early
so that the process could commence in good time.
17. Those objecting to a parade should be
offered the opportunity formally to register their objections
within one month of an intention to parade being notified. Risk
rating: High. This proposal fails to take account of objections
that may arise closer to the time of a parade, for example, due
to sectarian attacks in an area or a problematic parade earlier
in the season. The deadline for protest notification needs to
be related to the date of the parade rather than the notification
date to deal satisfactorily with many genuine protests that may
arise.
18. Copies of all objections should be made
available to the organisers of the procession. Risk rating: High.
This proposal would cause strong objections from people fearful
for the safety of their property or persons.
19. The right peacefully to protest, like
the right peacefully to process, should be affirmed in the 1998
Act and should be subject to similar restrictions. Risk rating:
Medium. This power would signal greater balance in those areas
where protests are perceived by some to be carefully organised,
but it brings with it the incentive towards more protests that
are organised by specific groups.
20. Protest meetings should be brought within
the scope of the Determining Body, as protest processions currently
are. Risk rating: Medium. As at 19.
21. Guidelines should be prepared indicating
the factors which the Determining Body would take into account
in determining whether restrictions should be placed on a protest.
Risk rating: Low. Guidelines would be necessary in these circumstances.
22. Notice of any protest parade or meeting
should be lodged within 14 days of the issue of a Determination.
Risk rating: High. This proposal would not be feasible for protests
that arise from circumstances closer to the time of a parade.
The period required for protest notifications should be related
to the date of the parade, not the date of determination. A five-year
determination would require five years' notice of protest!
23. Breaches of Determinations in respect
of protests should be reported and investigated in accordance
with the arrangements where parade Determinations are breached.
Risk rating: Low. This would seem appropriate, given the arrangements
proposed.
24. To promote public civility between the
two traditions, Public Processions legislation should provide
that, in the exercise of their right to freedom of peaceful assembly,
all have a right to have their honour respected and their dignity
recognised and must themselves respect the honour and recognise
the dignity of others. Risk rating: None. This seems appropriate.
25. The Code of Conduct, which has been
produced by the Commission, should be revised in consultation
with all the relevant interests to require that: (a) the organiser
of a parade should be clearly identified and should be a senior
officer of the parading organisation; (b) the organiser prepares
a risk assessment fur each parade; (c) all marshals receive training
so that within three years it can be made a Code requirement that
all parade marshals have at least basic training; (d) parade organisers
discuss with the police where marshals' responsibilities end and
those of the police begin; (e) no parading organisation employs
bands with paramilitary trappings; (f) no item of clothing is
worn or any article worn, carried or displayed in such a way or
in such circumstances as to arouse reasonable suspicion that a
person is a member or supporter of a proscribed organisation;
(g) parade organisers arrange for adequate toilet facilities;
and (h) parade organisers encourage those accompanying parades
to desist from unruly behaviour. Risk rating: Medium. The Code
of Conduct could indeed be revised, but some of the changes proposed
may not prove to be helpful. It seems unfair to force an organisation
to use a senior officer as parade organiser, if someone more professional
were available. Risk assessments may be asking too much of many
parade organisers and may simply be wholly unrealistic in many
situations. Other suggestions would benefit from a police view.
26. There should be a separate Code of Conduct
for bands and there should be a requirement for bands which fail
to subscribe to it or to an approved Code or are guilty of non-observance
to be registered under a Government registration scheme. Risk
rating: Medium. Police advice would be valuable in assessing the
registration issue. The role recommended for the Orange Order
may no longer be within its capabilities in terms of control of
the bands' issue. Bands are a part of many parades that do not
involve the Orange Order and the rules should be the same for
all—including nationalist bands.
27. Legislation should be introduced to
make it an offence for a person knowingly to allow alcohol to
be carried on to a public service vehicle if he is the operator
or the person to whom it is hired. Risk rating: Medium. A matter
for police advice, but initial soundings from police contacts
are not positive about this proposal.
28. A Parades Facilitation Agency should
be established which would have general oversight of parades but
no responsibility for Determinations or Compliance. The Agency
should: (a) provide a Facilitation function; (b) prepare Guidelines,
Procedural Rules and Codes of Conduct; (c) appoint parade monitors;
(d) undertake an education role; and (e) prepare an Annual Report
to be laid before both Parliament and the Northern Ireland Assembly.
Risk rating: Medium. The title "Parades Facilitation Agency"
is likely to prove a negative feature for many nationalists many
of whom may wish to see less parading overall. The idea of a cross-community
Board involving protagonists to the parading dispute may be ahead
of its time, given the lack of trust between the two main parts
of the community on the issue of parading. On the other hand the
implication of greater resources for mediation and education may
be timely. Again a flexible model is best—one that can respond
to an increasing desire for engagement.
29. The Agency should pursue an active Education
role, including support (or encouraging support by other agencies)
for "single identity" initiatives where the Agency has
a direct interest in development work contributing to greater
mutual understanding. Risk rating: Low. The only risk is that
the investment might be wasted if parading organisations engage
inadequately or not at all.
30. A separate independent Rights Panel
should be established to be the Determining Body in respect of
Parades and Protests, charged with deciding whether restrictions
should be placed on the exercise of the right to freedom of peaceful
assembly for the protection of the rights and freedoms of others
or for the protection of health or morals. The panel should: (a)
comprise a Chairman with legal qualifications who is appointed
by the Lord Chancellor and two other members drawn from a list
of suitable persons; (b) have a Compliance Branch to monitor adherence
to Determinations; (c) produce an Annual Report; and (d) be enabled
to contribute to the legal costs of parties taking cases that
raise points of general importance in regard to clarifying the
application to parades or protests of Human Rights law. Risk rating:
High. Fault lines run throughout this recommendation. The panel
would have no responsibility for considering disorder issues,
which are returned to the police in isolation from other factors.
Yet these issues impact on each other in a complex way. The likelihood
of disorder feeds through into issues, for example of police safety,
which feeds through into the kind of police operation required,
which in turn can have a significant impact on freedom of movement
for local people. The Panel seems well placed for duels between
the two main traditions that would leave other interests standing
on the sidelines. It seems well placed to attract only the political
activists and the hardliners, institutionalising the sectarian
dimension. It is a recipe for excluding totally the voices of
moderation. The complete isolation and consequent crystallisation
of the disorder issue will focus the debate once again on the
relative weight of disorder from each tradition. This is also
an inflexible model, because of the requirement to separate out
each aspect of the debate. It will neither provide for the occasional
Loyal Order parade through nationalist areas, nor for the occasional
restriction to show balance and hence reduce tensions in the community.
In terms of the operation of the Panel, Sir George considers that
the openness of the procedure would address the natural justice
question. But the discretion proposed by Sir George in relation
to confidentiality recreates essentially the same situation. Having
three people decide on the rights involved seems to suggest a
model with two locals—one from each main tradition—and
an independent outside Chair. This places a huge pressure on the
two locals who might be seen as "representing" their
community in the decision-making process. The small numbers involved
may well make it less attractive for people of standing to become
involved. There will probably be a need for a second Chair, in
case of illness or other unavoidable absence. The issue of how
and which individuals are picked for the Panel could become a
matter of contention (unfair "panel picking"). A Chair
will always have his own favoured panel members. More available
individuals would build up a stronger stock of knowledge than
others, which may disadvantage some parades. Each case must take
one to two hours, which would represent a considerable investment
of time and resources, particularly if the number of contentious
locations continues to grow, as seems likely in the new absolutist
ambience.
Overall, this proposal has the potential to
set back the clock by about six years, particularly if extreme
elements focus on the central role of disorder in the final decision.
31. The police should determine whether
any restriction needs to be placed on the exercise of the right
to freedom of peaceful assembly in the interests of national security
or public safety or for the prevention of disorder or crime. Risk
rating: High. The police will have their own views on this. It
places the police in a difficult position, because they will be
asked to assess only one aspect of Human Rights law, when in reality
all factors interact. Sir George makes no reference to the safety
of police officers and the decisions that have to be made to protect
those officers that may in turn play into other human rights restrictions
(eg sealing off an area). It is difficult to see how in practice
the police will not in effect have to repeat the consideration
of the other human rights criteria involved, thus duplicating
the work of the Panel. Protagonists may quickly decide that the
Panel is a white elephant, with the real power having been restored
to the police. It is arguable that a cross-community body is better
placed than the police to decide on occasions when a parade should
go ahead in the face of likely disorder (though leaving the police
a decision-making role in extreme circumstances as at present).
32. Monitors should be under an obligation
to bring to the attention of the Determining Body any aspects
of the policing of an event which merit review. Risk rating: None.
No difficulties with this. A compliance function should pick up
this issue.
33. The law should be vigorously enforced
in respect of offences and Codes of Conduct should draw attention
to the law concerning processions and protests and to other relevant
legislation. Risk rating: Medium. Any risks associated with this
issue will be matters for the police. The Commission likes to
see tight enforcement in respect of parades, but a zero tolerance
approach in present circumstances could potentially have unintended
consequences.
34. The staff of the Parades Facilitation
Agency and the Rights Panel for Parades and Protests should be
within the jurisdiction of the Ombudsman. Risk rating: Medium.
No case nor any rationale is made for this proposal. Lacking any
rationale, the Commission felt unable to comment with any degree
of assistance, save a remark that it would be seen as yet another
way of seeking to challenge the operation of the bodies involved.
It could be counter-productive in day-to-day practice.
GAPS
In addition to the above reservations, the Commission
would have additional concerns about some areas that would benefit
from further consideration. These include, most significantly,
— Design of parade notification forms
(related to the possibility of a more overt declaration of the
responsibilities of a parade organiser).
— Identification of parades for further
consideration by the Commission (currently called "contentious"
parades).
— A holistic, thought-through response
to the challenge of bands and band parades—covering bad
behaviour and sectarianism by bands, the culture of late band
parades, the low levels of musicianship and high levels of alcohol
consumption and associated social and environmental problems.
— Need for fuller assessment of the
"traditionality" criterion, with a view to taking into
account the symbolic significance or cultural importance of a
parade, as well as "grandfathering" parades.
— Need for fuller assessment of the
importance of the "relationships in the community" criterion.
— Handling of "ordinary"
parades.
— Responsibility for banning parades
(for example in circumstances of high parade frequency).
— Lack of distinction between the right
(to parade) and the route (of the parade).
31 March 2004
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