Examination of Witnesses (Questions 220
- 239)
TUESDAY 17 JANUARY 2006
MR KEITH
BEST, MR
COLIN YEO,
MR CHRIS
RANDALL AND
MR MATTHEW
DAVIES
Q220 Gary Streeter: Mr Best, you
have said a couple of times that the entry clearance officers
make their decision in just a few minutes. Is it your view then
that, if they took longer and went into more detail and more depth
at the time, they would arrive at a different decision, so is
it more about resourcing and doing the job, if you like, properly
up front than this negative attitude you have been talking about?
Mr Best: Yes, and it also varies
between posts. I have seen good practice in some posts and I have
visited at least 11 posts, some of them several times over the
last few years, and I have sat and watched entry clearance officers
interviewing applicants and making those decisions and spoken
to entry clearance managers and such like. I have seen good practice
where some First Secretaries will make a judgment about fast-tracking
particular applications or will give the benefit of the doubt
to certain ones. I have seen family settlement cases decided on
the papers rather than interviewing people at all where it is
acknowledged that these are likely to be genuine applications,
but that is not true of all posts. I think there are ways in which
the posts themselves can actually organise their own activities
to try to fast-track those that are likely to be genuine and in
the end it comes down to the new nomenclature that is being used
by the Government in this field and that is `risk assessment'
where you have to assess the risk. I think in any system like
this, and I mentioned two other ones as well, there will always
be a risk. It is a question of trying to minimise the risk, but
you will never obviate it altogether.
Mr Davies: I know examples of
cases where the entry clearance officer just has not investigated
a case thoroughly enough and, if they had only taken a few certain
steps, they would have avoided an appeal. One example is where
they had doubted that a marriage was genuine because they said,
"The Islamic marriage certificate does not look to us like
it's a genuine certificate". On appeal, we got the imam at
the mosque to kindly give us the evidence to say that it is a
genuine certificate and, by the time the appeal came round, the
entry clearance officer and their representative here had accepted
that. Now, if the ECO had only made one phone call or made their
own checks, that appeal would have been avoided. In other cases,
for example, of student visas recently in Rio in Brazil, people
are applying for student visas, submitting the applications in
person and they are then being looked at and processed, and the
key decision to take is whether that person intends to return
back to Brazil at the end of their studies, but they are making
decisions on that question without even interviewing the person,
so people are being sent refusal notices, saying, "Because
you are young, because you have got no job here, because you have
not got strong ties, we don't think you are going to come back",
but they do not even interview these people. They can get away
with that in those cases because you have no right of appeal in
those cases, so your remedy, if you can get one, is to go for
judicial review, but many people will be denied that remedy.[1]
That is why we are concerned about the appeals because the appeal
gives the scrutiny and that means that those kind of slapdash
decisions do not get away unchecked and people do not know that
they are being taken.
Q221 Mrs Dean: Mr Best, you argue
that subjective requirements in the Immigration Rules, such as
the requirement that a visitor should intend to leave the UK at
the end of their visit or that a spouse should intend to live
with their spouse, should be removed. Would the removal of this
requirement for spouses be a direct invitation to those who abuse
this system, for example, through forced marriage?
Mr Best: Well, it comes back again
to the whole question of risk assessment. Your whole Committee
will be aware of the Government's proposed new points system which
is modelled broadly on the Australian one and which is based on
objective criteria, but of course ministers here have repeatedly
said that there needs to be retained the subjective element because,
otherwise, you will be allowing into the country those people
who are a risk or at risk of abusing immigration control and likely
to overstay. You are then into the Schengen-type situation where
you have to identify and find those people and prosecute and remove
them from the country, whereas having immigration control at the
entry clearance officer level with the subjective element of their
making an assessment of whether someone is likely to abuse immigration
control or not is the first line of defence. The trouble is that
we do not see any sensible reconciliation between trying to retain
some element of subjectivity, but also moving more towards an
objective test. We feel that the only way you are going to do
that is to err on the side of objectivity rather than subjectivity,
run that risk, and you can assess whether there is greater risk
of abuse in certain posts than there is in others, you can deploy
your risk assessment teams there to try to look at likely forgeries
and such like and deal with things in that way. I suspect, however,
that behind all this thinking on the points system is also an
acknowledgement, that, as you will be aware, there is an enormous
increase, and an inexorable increase, in the number of applications
around the world and some posts are finding it very, very difficult
to cope. The more that applications can be dealt with on the papers
or with the minimal amount of interviewing of applicants, then
that is going to ensure that there will not be backlogs building
up in particular posts.
Q222 Chairman: I sense a very naïve
approach. If one simply said, "We are going to stop bothering
about whether visitors have got any intention of going back and
stop bothering about whether any marriage is genuine", is
it really sustainable to run the system on that basis? It is hardly
worth having the system at all, is it?
Mr Best: Well, you have already
got significant checks now about marriage. You have got not only
of course the need to seek the permission of the Secretary of
State and the need to go before a particular registrar, but you
have also got the fact that the probationary period has been extended
from one to two years, so there is a significant amount of scrutiny
on marriages at the present time. If you are looking more though
at the temporary admission of people, like visitors and such like,
then I have already said that we feel that the question of detection,
which will be enhanced through embarkation controls, and prosecution
and, as I say, the greater penalty of denial of the ability to
return to the United Kingdom subsequently are likely to have a
more dramatic effect than what is at best a haphazard system of
trying to make an assessment in a few minutes as to whether somebody
has an intention to leave the United Kingdom or not.
Q223 Chairman: It has proved extraordinarily
difficult to identify overstayers and to remove them.
Mr Best: Well, it has at the moment,
yes.
Q224 Chairman: Even if you have embarkation
controls, you still have to find people and you then have to go
to all of the expense of the police and everything else to arrest
them, detain them and then remove them from the country. It is
just hard to believe that what you are saying is actually a credible
approach to dealing with this issue. It is simply just shifting
it from the IND process to another part of the system.
Mr Best: I do not underestimate
that, but what, if I may say so with respect, you are not taking
into account is the deterrent effect of the knowledge that you
will be identified and that, therefore, your name and details
will appear on the computer list for entry clearance officers
around the world so that, when you make an application subsequently,
there is your name as somebody who has overstayed, even if you
have actually not been apprehended in the country and you have
left of your own accord eventually anyway.
Q225 Mr Winnick: So the initial application
for entry clearance, according to you, Mr Best, would be almost
automatic. You would not ask the questions which are now being
asked and which Parliament requires should be asked. If someone
comes along, regardless of circumstances, age and the rest of
it, and says, "I want to go to the United Kingdom for a visit",
your response presumably would be one or two questions perhaps
at most, fine, and, if they overstay, then the penalties that
you mentioned.
Mr Best: No, they have to satisfy
the Immigration Rules. Remember, it is not just me saying this,
but this is government policy to move towards a points-based system
where, as ministers have said, a potential applicant will be able
to look up on the website, assess whether they have sufficient
points to be able to come into the United Kingdom or not and that
will tell them whether they should be given entry clearance or
not. The only other element of that will be this question of risk
assessment of whether then an entry clearance officer feels that
they constitute a risk. The Immigration Rules themselves are already
quite prescriptive in terms of what you have to show by way of
ability to fund yourself or for somebody else to fund you while
you are in the United Kingdom so that you do not have resource
to additional public funds.
Q226 Mr Winnick: But the points system
is not a substitute, as far as I understand it, for the sort of
questioning and the rules which apply now, namely an intention
of whether you are going to leave the United Kingdom and whether
the application is credible. You are not suggesting that the Government
is changing, or is proposing to change, that?
Mr Best: The points system will
be thrown into total disrepute if a large number of people assess
themselves as coming within the points criteria for entry to the
United Kingdom and then get told that they do not qualify.
Q227 Mr Malik: Just to go back to
your point earlier on, is it your view, based on what you have
said, that there is some kind of unwritten policy whereby the
objective is to increase barriers to entry and, by definition,
reduce the number of entrants irrespective of the legitimacy of
their applications?
Mr Davies: In certain categories
of people, I think that is where the culture of disbelief comes
in. There is a view that we are going to refuse. For example,
the example I gave earlier is of a spouse who was actually joining
someone who was recognised as a refugee here, a Somali refugee,
who subsequently married another Somali in Kampala in Uganda and
it was a genuine marriage. In my view of that case, the approach
was always to try and find ways to refuse this visa. There was
a very, very short interview, but they still managed to say, "We
don't believe that this is a genuine marriage", or they did
not ask many questions, doubting the genuineness of the marriage
certificate without making any enquiries. That case went all the
way to appeal and we won the appeal. She is still not here and
they still created a new barrier to her, saying, "We won't
recognise your Somali passport". Likewise, with the Brazilian
student, yes, you feel with certain posts there is a view, "Well,
there are lots of young Brazilians going to London and some of
them overstay or work when they shouldn't", and you kind
of feel that there is a knee-jerk response to your particular
applicant. He does not quite look right. It probably meets that
matrix of the kind of person who might overstay. Yes, they need
to be satisfied under the Rules that someone intends to return,
and that is part of the Immigration Rules, but my concern is that
the investigation and the inquiry is not thorough enough for those
that they are deciding to refuse, and that decision to refuse
can have major implications for an individual. The first time
you are applying for a visit visa, a student visa or a working
holiday visa is really important for a young person because, if
you are refused, that is going to stay on your record and, if
you try applying for another visa, first of all, they are going
to say, "You were previously refused", and it is of
interest the number of asylum-seekers you find here who, if you
actually look through their case, at some point applied for a
visa and were refused. For young people particularly who want
to travel, who have money, who are middle class in their own country,
and you would have to be to pay the visa fee, they feel there
are barriers to their travelling. One refusal that has not been
properly investigated could make that person someone who in the
end is people-trafficked here to claim asylum because that is
the only way they can ever experience a bit of travelling abroad.
I think the key is having a proper investigation before refusing
someone on intention, to put your concerns to the person before
you refuse them and to give them an opportunity to rebut the initial
view of the entry clearance officer. We said in our brief that
there should be a "Minded to refuse" stage when someone
is told, "Well, for these reasons at this point in time we
think we might refuse you. What do you say about that?"
Q228 Mrs Dean: Can I just go back
to you, Mr Best, and can you clarify that when you say that you
do not think there should be subjective requirements regarding
a visit, you actually still do believe that, if someone is coming
here as a spouse, they need to prove that they are married with
all the other necessary paperwork to prove that, and that, if
they are applying for a visitor's visa, they would need to demonstrate
why they were visiting and all the other requirements regarding
that?
Mr Best: Yes, I hope I did not
say that I advocated stripping away all subjective controls. What
I hope I said is that subjective criteria and objective criteria
in a points system are inherently irreconcilable, that if you
are moving towards a points-based system, unless you are going
to bring it into disrepute by retaining such a subjective element
that those who, nevertheless, would otherwise qualify on the criteria
assessed, as ministers have said, hopefully ultimately just by
them being able to access it on the website and doing their own
calculation as to whether they would be successful in applying
for entry clearance, if they are then to be refused on a subjective
element, it is going to bring the system into disrepute. If ministers,
however, wish to retain that front line of control through a subjective
element, then I would agree with what Mr Davies had to say, that
that has got to be applied in a much fairer way where entry clearance
officers are aware of the need for natural justice to give people
an opportunity to confront some of their concerns. I sat behind
an entry clearance officer in Islamabad, looking at a student
application where the student had not particularly helped himself
because the bank information was not completely up to date. She
refused him on that basis and she gave him no opportunity to explain
why that was the situation, I assume because she was fairly young
and inexperienced. I turned to her afterwards and I said, "You
realise that will be overturned on appeal if there is a rational
explanation as to where the money is or what's happened to it",
and she said, "Oh well, so be it". I am not saying that
that is indicative of the attitude of entry clearance officers
throughout the world, but to find that kind of example is disturbing
where in effect the entry clearance officer is saying, "Well,
if it is going to be overturned on appeal, then so be it"
rather than wishing to conduct a thorough examination at that
stage or maybe being given insufficient time and targets which
are incompatible with the ability to investigate thoroughly that
kind of thing and to give an applicant an opportunity to rebut
what may be a belief in the mind of the entry clearance officer.
Q229 Mrs Dean: Mr Randall, you have
suggested that the IND staff ought to be accredited in immigration
law under the same schemes which operate for all advisers and
solicitors who provide publicly funded immigration and asylum
advice. Why do you think this is necessary?
Mr Randall: I think that there
is a problem with the quality of staff and the motivation of staff
at IND and that has been identified by the quality initiative
work that has been done in relation to asylum decisions, but I
think the argument works just as well for non-asylum decisions
as well. It is a difficult area to work, it is not a very popular
area to work and there is a problem in recruitment. Now, we need
to improve the quality of decisions and there are various ways
you can do that, but clearly some of the reasons why we are getting
poor-quality, in-country decisions is a lack of knowledge of the
law and a lack of knowledge of the policies that exist that should
be being applied. Now, how can we get decision-makers to be making
better-quality, in-country decisions? One way to do that is to
train them better. Now, of course there is training already, though
there is not very much, but there is some. It would certainly
be possible to have the same kind of testing (to see whether people
have actually learnt from their training) applied to in-country
immigration officers making decisions as is now applied to all
individuals who are providing publicly funded legal advice. It
will require an investment of time and energy by IND, but certainly
we think that something like the kind of accreditation scheme
which starts at the most basic level, which would not have to
be identical and there might be areas which are different, would
be one way of really getting a grip on the issue of poor-quality
decision-making. You have heard the issue of poor-quality decision-making
from probably every person who has given evidence to you and over
many years. It has not been solved and this would require something
of a sea change in the way that the Home Office looks at its staff,
but we think for the staff, when they have got qualifications,
it will also give them a career structure, it will give them means
to move on to other things and we think it would be a good idea.
Q230 Mr Clappison: Could I come back
to Mr Best in terms of the question of immigration advice overseas.
You have already mentioned that you are establishing advice overseas
in the light of the advice which is given by some advisers overseas
which, it is not difficult to imagine, may not be very good advice
in the light of the activities of some advisers in this country.
I wonder if you can say a little bit more about the background
to that.
Mr Best: We opened our office
in Sylhet in Bangladesh in the year 2000. I see that Ms Lindsley
refers to that not only in her oral evidence to you, but also
in her 2004 report in glowing terms for which I am very grateful
because clearly we are offering a good service there. We did that
as a result of a large number of representations from the British
Bengali community, expressing concern at the number of refusals.
This was principally around family visits and the fact that there
was inadequate existing advice in the Sylhet area. There are all
sorts of people who often call themselves "travel agents"
and purport to give immigration advice. I think sometimes it is
negligent and sometimes it is knowingly wrong in the fact that
they just do not bother to find out about current immigration
law in this country which, after all, is quite a task in itself
because it is changing so rapidly. Therefore, we opened that office
in Sylhet and it has prospered ever since. Armed with that knowledge
and the success of that office, we have decided to open up other
offices based on the criteria that I mentioned earlier in giving
my evidence and we in fact opened another office in Lahore at
the beginning of October of last year. I am pleased to say that
in Bangladesh we get a great deal of support from the High Commission,
the Visa Section there, and, when we recruit somebody here as
an adviser to go out to Sylhet, they will spend a week in the
British High Commission Visa Section, getting to know the practices
and getting to know the entry clearance officers so that they
are in a better position to be able to advise applicants of exactly
what the requirements are when they come to us before they make
an application. Hopefully we can say to people, "Don't bother
to apply" if we know they are going to be refused anyway
because they do not meet the essential criteria. I would hope
that we may get that kind of support from Islamabad as well. It
is early days yet, but certainly we do need to have support from
the FCO in terms of being able to advertise our facilities when
we open our offices overseas so as to be able to offer that service
to a wider audience.
Q231 Mr Clappison: Bearing in mind
what you have just told us about advising some people perhaps
not to make an application or perhaps going back to the earlier
example you mentioned of the young man who had not got his papers
in order, would I be right in thinking that you would feel that
you had saved some time and money for entry clearance posts and
possibly on some appeals?
Mr Best: Yes, it is very difficult
to quantify. It may well be that you are part of the Committee
that is going out to Dhaka and, if you speak to the entry clearance
officers there, I think they would endorse this view, that an
application that has been through our hands is in good order and
makes it much easier to grant than one that has not, and of course
it is so much cheaper to grant than to refuse in any event. We
are not asking for money from the Foreign Office, although we
would never say no to it.
Q232 Mr Clappison: In fact do you
get any funding from them?
Mr Best: Mr Winnick will remember
that when he used to work in our predecessor organisation, UKIAS,
in fact there was money that came from the Foreign Office for
overseas offices and latterly I did receive some money towards
the office in Sylhet before the High Commission opened up its
own liaison office in Sylhet as well.
Q233 Mr Clappison: Do you get any
at the moment then?
Mr Best: We do not get any at
the moment, but what we are asking for is support in the ways
I have indicated, being able, for example, to advertise our services
in the courier offices because I think the Committee is aware
that applications now in India are done through Visa Facilitation
Services and in Pakistan through Gerry's/FedEx, the courier service,
and people go to the courier service's offices and make the application.
Those courier services are able to help people complete a form,
the application form, but they cannot give, indeed they are specifically
prohibited by the High Commission from giving, any kind of legal
advice as to whether people are likely to succeed or not. Although
of course we cannot stop people making applications, we can seek
strongly to deter them on the basis that they will waste their
application fee if we know that they are not likely to qualify
within the Immigration Rules.
Q234 Mr Clappison: Are there any
other changes or improvements, do you think, which could be made
in the operation of entry clearance in Bangladesh?
Mr Best: Well, I have seen some
good practice in Bangladesh, which I mentioned earlier, some time
ago where, for example, in order not least to get rid of the waiting
time for family settlement cases, a large number of them were
being decided on the papers. Now, that is a judgment that has
to be made by the Visa Section, by the First Secretary. Of course
there is always an element of risk there, but unfortunately, with
the number of applications and with the way immigration control
is fixed at the moment, it seems to me that there is always going
to be that calculated element of risk that has to be taken. You
are never going to get a wholly perfect system. If you do, if
you are going to have every applicant examined for half an hour
in a quasi-courtroom situation, then you will never get through
the number of applicants and it will cost an absolute fortune,
so it has to be a trade-off so that you can try to stop the abuse,
but at the same time you do not clog up the system.
Q235 Mr Clappison: On the subject
of other people acting as overseas immigration advisers and other
sorts of advice, the Government has said that it wants to regulate
overseas immigration advisers. Do you think this is a good idea
and, if so, how could it be done?
Mr Best: In principle, I think
it is a good idea. It is very difficult to achieve because of
course one is dealing with people who are outside the UK's jurisdiction.
Some of these advisers have influence in very high places as well.
I do think that the only way really it could be done is to limit
those organisations and agencies which would be entitled to make
representations to the High Commission, though very difficult
to achieve, but I think in principle it is something that is worthwhile
looking at.
Mr Yeo: I just wanted to build
on why it is that our advice is helpful in Bangladesh. It is because,
as Keith has explained, we spend time with the High Commission
and we know what their criteria are for a successful application
and also for an unsuccessful application and we are able to pass
that advice on to our clients and say to them, "Well, you
need certain types of documents and either you have got them or
you haven't basically". It goes back to this issue of transparency.
The Immigration Rules are extremely sketchy. They just list certain
issues, and there is wide discrepancy of approach, quite properly,
between different posts around the world because local conditions
vary, but the Immigration Rules do not really reflect that, nor
does the guidance to the entry clearance officers. If perhaps
UKvisas were more transparent about the criteria that are applied
in different areas and what their expectations are of the kind
of document that they are willing to accept, whether it has gone
through a certain type of bank or a specific bank, for example,
if you are trying to present evidence of what your savings and
financial means are, what kind of documents are required to show
what your income is, these kinds of things, then you would get
better-presented applications and again applicants would know
right from the outset whether they actually stand a chance of
success or they are wasting their visa fee in the first place.
Mr Best: Just coming back on the
notion of regulating overseas advisers, we think that would be
very difficult because of the fact that they are in a different
jurisdiction, particularly because regulation involves not just
looking at what is in an application to be registered, but it
involves looking at office systems, it looks at safeguards and
it involves supervision of staff and things like that. One method
would perhaps be to look at those organisations abroad which are
themselves the subject of a supervisory jurisdiction within the
country itself which is satisfactory, but there will very soon
be judgment calls about either organisations or those supervising
them and I suspect that the disquiet, annoyance and offence caused
by the attempt to regulate might well outweigh any good that was
achieved by the regulation.
Q236 Steve McCabe: My questions are
to the representatives of ILPA. First of all, you said in your
written evidence that you are not satisfied with the Legal Services
Commission funding arrangements and you go on to say that they
are actually a disincentive to solicitors and others who want
to offer advice. I wonder if one of you could just tell us briefly
why you say that. What is the disincentive and what is the problem
with the funding arrangements?
Mr Davies: Well, the first thing
is the rates of pay. They have not gone up for the last five years,
despite inflation, et cetera, and, as a partner in a firm, you
have to meet your growing expenditure with less income coming
in, so the bottom line is whether you can make it work as a business.
Secondly, the Legal Services Commission, the way they fund it
is that they give you a certain amount of money and in return
under the contract you are meant to do a certain number of cases
and then, when you do the cases, you are meant to report to them
to say you have done the cases and how long it took. With the
amount of money they give you per month, you should be, as it
were, spending that amount of money each month in terms of hours
spent. Then, once a year, they come to your firm and they take
20 files and they look at those 20 files and, if they find more
than 10% of those files where they think you have spent too long
on a case, for example, which is a classic one, "You shouldn't
have spent two hours doing that. A reasonable solicitor would
only have spent one hour", so if they find 10% or more that
they think you should not have done, they want 10% or more back
from your whole contract, all the payments they have given you,
including 10% of every barrister you have paid, 10% of every interpreter
you have paid. That is what is called the "costs audit"
and the larger you are, the greater you are at risk and firms
have closed down, or decided to close down, because of that risk
where every year they may be asked to hand back a lot of money,
so it is difficult to "business-plan", as it were, so
that is one reason why people are dropping out. For those that
stay in it, one of the main difficulties is that the way it is
worked is that you are only allowed to do work up to a certain
level, so you can only spend a certain number of hours on a case
and, when you have used up your hours, you are going to have to
get permission from the Legal Services Commission by filling in
a detailed form where you need permission to do more work and
where you need to say exactly what you want to do and how much
it is going to cost, so there is this kind of bureaucracy that
stops you from getting on with the work. Then, when it comes to
appeals, you can only have legal aid for an appeal if you, the
solicitor, think that the prospects of success are more than 50%,
so if you, the solicitor, think the prospects of success are less
than that, you have to say to your client, "Well, I can't
grant you legal aid". Now, some firms do not have the power
to grant it themselves and they have to apply to the Legal Services
Commission for permission to actually give the legal aid for the
appeal, so a lot of firms are actually taking on particularly
asylum-claimants and they run the asylum claim, but when the claimant
is refused, they say, "We can't help you with your appeal
because, in our view, your case is not over 50% in terms of success
rate", so you are ending up with appellants who are unrepresented
for their appeal because of that merits test. We, in ILPA, very
much believe that that merits test should be reviewed, particularly
in fast-track cases where literally you claim asylum on day one,
you are interviewed on day two, you are refused, unless you are
granted, on day three, your appeal is listed for a hearing on
day seven, and solicitors are having to say, when they get to
read through the refusal, if it is over 50% or not, and it is
very difficult to make that kind of judgment when you have only
had literally a day or so actually to look at a case.
Q237 Steve McCabe: Is the essence
of that point then that if, in your professional judgment, you
do not think a case has more than a 50% chance of success, you
would like to be paid to pursue it anyway, but you would not like
to put your own money up against it? Is that not what you are
telling me?
Mr Davies: Well, we do put our
own money up against it in one area—
Q238 Steve McCabe: But in the example
you have just given, you say you drop cases because they do not
meet the 50% threshold, but, if the taxpayer was willing to pay,
you would pursue them. Is that not roughly what you said?
Mr Davies: Well, we consider ourselves
in many ways to be like public servants, that we do this work
because we believe in it and we believe in helping these clients.
We already do what is called "at-risk" work. When you
lose before an immigration judge and you apply for a review and
reconsideration, that is at risk. That was a change brought about
under the last piece of legislation, so we are already doing that.
I can say that we are spending quite a lot of what we call "pro
bono free hours" on cases already as it is.
Q239 Steve McCabe: But am I right
to think from your answer that the major disincentive is money
and that, if you were paid more, you would not feel there was
a disincentive? Is that what your original answer was? You also
have some arguments about the supervision arrangements of that
money, but in essence, if you were paid more, you would not feel
there was a disincentive?
Mr Davies: If the rates were higher,
more firms would consider doing it and less firms would drop out
of it. The average hourly rate that a legal aid firm gets is £55
per hour and that is not money in the pocket of the solicitor,
but that is for all the overheads. In London, the average high
street solicitor would charge anything from £100 to £300,
if you are in the City, and there is private immigration work
around, you do not have to do legal aid work.
1 Note by Witness: Many people are denied that
remedy because they are unaware of it. Back
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