House of Commons - Home Affairs

Select Committee on Home Affairs Fifth Report

11 LESSONS TO BE LEARNT

536. In this chapter we draw out the lessons that need to be learnt across the immigration system and beyond, not only from the handling of the foreign prisoners issue but also from the whole of our inquiry.

537. The Home Office is currently conducting two reviews ordered by the Home Secretary in the wake of the foreign prisoner debacle: one into the Home Office as a whole, and the other into the IND. Both are due to be published before Parliament's summer recess and both are chaired by the Minister for Immigration, Citizenship and Nationality, Liam Byrne MP. He told us that the IND review is in three phases: the first looking at the strategic objectives of the IND over the next one, three and five years; the second a wide-ranging organisational review looking at "core processes; culture; organisation; IT; and, crucially, human resources" and also the cross-cutting issues of resource allocation and the relationship to the Home Office; and the third phase looking at action plans for the next six to twelve months. He highlighted in particular the need to address the way that processes operate, the culture of transparency and accountability and the need to have the right people doing the right jobs.[533]

538. We are very glad to see that the IND is being reviewed in its wider Home Office context, and emphasise the need for the review to take into account the recommendations of this report.

A culture of accountability

539. In her evidence to us, the Director General of IND, Lin Homer, recognised that staff do not yet feel a responsibility for the overall work of the IND:

I think that is my responsibility, to create that culture in which the organisation believes they share a responsibility with me for the organisation performance of the whole and not, if you like, just the piece they are tasked to do.[

534

540. This was most apparent in how the problems with foreign national prisoners were handled. As we have seen, although junior staff would have been aware that not all foreign national prisoners were being deported, and that this included some serious criminals, they did not—or were not in a position to—recognise the implications of that information or take responsibility for passing it on. The picture has been painted by many witnesses of junior staff struggling to deliver with inadequate resources and leadership whilst neither their own immediate management nor more senior management felt they had the responsibility to insist on an appropriate response being made.[535]We cannot claim to have studied all aspects of the management of IND. But we saw enough during the course of our inquiry to make us concerned that similar problems exist in other parts of the organisation.

541. We believe that the failures of management seen in the IND's handling of foreign national prisoners, when senior management failed to make it clear upon whom and at what level the responsibility lay for identifying and acting upon problems as they arose, highlight a problem that may exist in many parts of the organisation. The failure of the enforcement and removal operation to meet the needs of an effective immigration system, the failure to develop a complaints system capable of improving the quality of customer service and the absence of effective feedback mechanisms from AIT decisions to ECOs are all examples of hard work being undermined by a failure to take responsibility for the performance of the system as a whole.

542. The Home Secretary told us that, while the Home Office is not "intrinsically dysfunctional", it suffers from weak management. He has asked the Permanent Secretary at the Home Office, Sir David Normington KCB, to look at the whole of the management systems and structures across the Home Office.[536] Sir David told us that he wants to ensure that people are held accountable for how they perform.[537]

543. The biggest single management challenge for the immigration authorities is to create clear lines of responsibility and accountability, and to establish a culture at each level where staff are required to feel a responsibility for the overall performance of the system as well as for their own tasks. Without such a profound cultural change, individual targets or performance measures are unlikely to produce the required results.

Joining up

544. Throughout the report we have identified the need for 'joined up' Government, both within the immigration system and between it and other authorities within and beyond the Home Office who deal with immigrants.

WITHIN THE IMMIGRATION SYSTEM

545. "Fragmentation and silos" was one of the issues which Home Secretary identified as a key problem in the Home Office in the light of the foreign prisoner issue.[538] To give one example, he told us that there had been discussion going back at least as far as 1995 on the failure to consider deportation before foreign prisoners were released,[539] but the scale of the problem and the priorities for tackling it did not reach senior managers in IND, still less Ministers. It appears that the channels of communication which should have allowed this were not in place.

546. Other examples of fragmentation we have found within the immigration system are: the differences between targets for ECOs and IND caseworkers; the lack of mutual trust between caseworkers and immigration judges; the difference between overseas and in-country application fees; the inability of the organisation to learn from complaints; and perhaps most vividly the plethora of incompatible databases and reference numbers in the immigration system which make it impossible to determine what has happened to an indivual as he makes his way through the system.

547. We were told about various ways in which people at a senior level 'join up': for instance "UKvisas is fully integrated into IND decision-making structures from the Ministerial Strategy Board downwards…It is fully engaged in IND policy development at all levels".[540] But at a more junior level it appears to be different. For example, before the recent programme of attachments for Home Office Presenting Officers at entry clearance posts (see paragraph 374 to 375), most had no direct experience of how the decisions they are supposed to defend every day are made.

548. Fragmentation and lack of communication is a systemic problem not just within the IND but within the entire immigration system which ought, ideally, to work as a whole. It is not only computer databases which should be encouraged to talk to each other but people, at all levels in all the immigration authorities.

WITHIN THE HOME OFFICE

549. Even within the Home Office there are obviously problems with 'joining up'. The Director General of IND acknowledged to us that there was not "an adequate level of communication" between the IND and the criminal justice authorities over foreign prisoners.[541] Phil Wheatley, the Director General of HM Prison Service, also alluded to these communication problems in his evidence to us,[542] and the former Home Secretary Charles Clarke MP commented in his letter to us of 26 June 2006 that "the problem fell across a key Home Office fault-line".[543] The main problem here was communication between prisons and the IND, but the police also have a responsibility to inform the IND about foreign criminals, and the probation service too when it has foreign criminals in its care. The fact that we still do not know how many foreign national prisoners were released from prison in Scotland and Wales without being considered for deportation shows that these problems are exacerbated when they go across borders.

550. The problems with compiling statistics on foreign national prisoners and with tracking them through and across the immigration and criminal justice systems were caused partly by incompatible computer systems and the lack of a unique reference number.

551. At the moment neither UKvisas nor the IND can run checks on applicants against police databases, though some information from the police is put on the Home Office Warnings Index against which all applications are checked. If fingerprinting visa applicants is to be truly effective, applicants' fingerprints must in the future be checked against police fingerprint databases before issuing a visa.

552. The police and the Immigration Service have started working more closely together to identify vulnerable children, but only Heathrow airport has a joint team.

ACROSS GOVERNMENT

553. Right across Government and beyond there are bodies which have an interest in attracting migrants to the UK and/or need to take some responsibility for dealing with them. This creates both conflicts and gaps.

554. As we have noted, attracting foreign students is very important to the education sector in the UK and the Prime Minister, but this can conflict with the attempts of the immigration control system to tackle abuse of the student route to the UK. The Department for Education and Skills is failing to take adequate responsibility for the students who are attracted to the UK or for maintaining a reliable register of colleges. Neither of these should be left to the IND.

555. Local authority social services departments are not working closely enough with the Immigration Service to identify and protect children who may be at risk. New joint initiatives are only for unaccompanied asylum-seeking children even though there are many children coming through immigration control who may be at risk of neglect or worse, including through private fostering.

556. The employment of illegal workers raises issues not only for the Immigration Service but also for a range of other Government Departments. The Joint Workplace Enforcement Pilot might potentially be a good model for joined-up working, but it has yet to prove its effectiveness.

557. The Department for Work and Pensions has until very recently failed to consider the impact on illegal migration of its policies on issuing National Insurance numbers, and is still offering only a limited response.

558. HM Revenue and Customs has not yet realised that its work against tax and national insurance evasion in the informal sector is essential to reducing the incentive to employ illegal workers. The same applies to enforcement of the national minimum wage: illegal workers are attractive to some employers because they feel they can with impunity pay them less than the national minimum wage.

559. If the Department for Trade and Industry did more to make migrant workers aware of their rights, there would be less of the exploitation of these workers about which we have been told.

560. The Minister for Immigration, Citizenship and Nationality, Liam Byrne MP, told us that he thought it was unrealistic "for any one department or any one locus within government to take full responsibility for managing migration…helping to manage immigration and asylum has to be a bit of everybody's business." [544] We agree that all parts of Government need to recognise their responsibilities in relation to migration, but feel that precisely because there are so many aspects to it there is a need to see the whole picture.

561. The various challenges of working across Government provide one incentive for having a Cabinet Committee which can take overall responsibility for the whole of the Government's efforts to run an effective immigration system. The evidence received in our inquiry on the need for migrant labour, and the economic benefits and drawbacks as well as the social advantages and stresses of migration, also highlighted the disadvantages accruing from the absence of any place within Government with overall responsibility for weighing up these factors—which are sometimes in tension with each other—and for determining the overall migration strategy for the UK. It is generally believed that the Home Office exercises this function but in our view it is not in a position do so effectively. We therefore recommend that a Cabinet Committee with representatives from all relevant Departments should be established with overall responsibility for all aspects of immigration policy.

Improving management information and statistics

562. The Director General of the IND, Lin Homer, stressed to us that developing proper performance management information and targets were central to her strategy for the IND:

I suspect it will continue to take us a number of years to become as strong on performance management as I would want and expect us to be… I do not believe we yet have a good enough set of performance management indicators for it to be easy for me to track every key area of business every week, every month, and be confident that things have not slipped under the radar.[

545

563. Ms Homer also recognised that performance management indicators are not enough on their own. The Minister for Immigration, Citizenship and Nationality, Liam Byrne MP, confirmed that in his view more and better targets were needed.[546] In our evidence and visits we found case after case where a poor selection of targets or their interpretation by management are making the immigration system less effective than it should be.

564. The immigration system seems to be managing on the basis of available information rather than relevant information. Reliable and meaningful management information is essential both to selecting and setting targets and to assessing performance against them. The NAO raised this issue several times in relation to UKvisas in its June 2004 report on Visa Entry to the UK.[547] It had also made a number of recommendations about statistics on asylum, migration and enforcement in an earlier report, and many of the asylum recommendations there could apply equally to immigration statistics.[548] There was no reference to improving performance information in the subsequent UKvisas business plan.

565. A serious problem with the accuracy and reliability of Home Office statistics is recognised at the most senior levels. The Home Secretary told us that the lack of numbers is in his view one of the main obstacles in the way of effective immigration control.[549] The Director General of the IND, Lin Homer, admitted that "the truth of the matter is our data collection systems are not good…the importance of good quality accurate information being collected, being used and being shared is clearly no driven through my organisation yet".[550]

566. Once again, the foreign prisoner issue provides a good example. In 1990 the Home Office effectively admitted it did not know how many prisoners were subject to orders for their deportation at the conclusions of their sentences or otherwise liable to be deported ("The information requested is not recorded centrally and could be obtained only at disproportionate cost.").[551] It was only in 1999 that the Home Office began keeping any records in this area.[552] In July 2005 the NAO found that the IND "did not have figures available on how many failed applicants had been released from prison because removal could not be arranged".[553] By March 2006, the Public Accounts Committee had been told that 403 foreign nationals had been released from prison between 2001 and 2005 without deportation proceedings being completed.[554] In April 2006, it emerged that the figures given to the Public Accounts Committee had been wrong and the true number (going back as far as 1999) was given as 1,023.[555] By 23 May this had been revised to 1,019, following the discovery of some duplicates,[556] and then to 1,013 on 29 June 2006,[557] but this figure still does not include those released before 1999, those released from prisoners in Scotland or Northern Ireland, or foreign criminals released from secure hospitals.

567. When the Home Secretary appeared before us he warned us about the vagaries of Home Office statistics: "I do not think I could remember a fact or figure I have been given in the past fortnight that has not been revised quickly".[558] He did not have to wait long for his prophecy to be fulfilled. That very night he found out that some of the figures he had given us on progress with dealing with the foreign criminals identified were wrong, because 11 of them had been released on bail by the AIT over the previous ten days.[559] Even once further checks had been done, the figures supplied to us still came with a warning that they would "inevitably be subject to a margin of error".[560] A letter from the Director General of the IND to our Chairman of 29 June 2006 says that an investigation had concluded that there were "insufficient management information systems and data to ensure the provision of up to date and accurate information".[561]

568. When giving evidence to the Public Accounts Committee on 26 April 2006, Sir David Normington, Permanent Secretary at the Home Office, was still unable to say whether the target of removing 85% of foreign prisoners within 28 days of their release was being met.[562] The Director General of IND, Lin Homer, could tell us that the IND seeks deportation orders in about 60% of the cases of foreign criminals it considers, but could not tell us how many of these are actually deported because of the way the statistics are gathered and presented.[563]

569. A Home Office review of immigration statistics is being conducted at the moment, run by an independent consultant, but the most recent publication related to it (an "early findings" paper) was from August 2005.[564] This publication, drawing from the results of a user questionnaire, noted the low profile given to any strategic consideration of the data needed to efficiently and effectively develop, implement, monitor and evaluate immigration control policy and its effects. A particular issue is that current statistics are process-based rather than person-based.

570. There is a serious problem with the way immigration statistics are compiled, presented and used to evaluate and improve performance. We recommend that the Government should conduct or commission a thorough investigation, based on the ongoing work of the review of immigration statistics, to determine which statistics are needed to produce a meaningful picture of the effectiveness of the immigration system as a whole. The IND's statistics must be not only up-to-date and accurate but also capable of providing information about whether targets are being met and about how people move from one stage of immigration control to another.

Targets

571. The problems which may be caused by a Home Office reliance on targets were highlighted by the former Chief Inspector of Prisons, Lord Ramsbotham, in a Guardian article dated 26 May 2006:

"At the heart of all this [dysfunction] is what is called the "cult of managerialism", the erroneous belief that results can be achieved by the issue of written instructions, targets and performance indicators. No one can fault the Home Office for the amount of these that spew forth. But their individual merit is clouded by the fact that the impact of any one on any other part of the system never seems to be worked out."[

565

572. We have seen four different ways in which targets have had unintended impacts on other parts of the immigration system: (1) major political targets on asylum meant other work may have been sidelined or even deliberately manipulated; (2) targets were set for only one part of a system without consideration of the effect elsewhere; (3) targets on speed had a negative impact on quality; and (4) targets were being met without having any impact on the underlying objective.

ASYLUM TARGETS

573. As Stephen Boys Smith, Director General of IND from 1998 to 2002, told us, "asylum and all the problems associated with it were the dominant issue for IND". This appears still to be the case: the only two "key priorities" in the Asylum and Immigration High Level Delivery Plan 2005-06 to 2008-09 were to deliver the asylum "tipping point" target, by removing more failed asylum seekers than the number of new unfounded applications; and to make a further substantial reduction in asylum support costs. We fully recognise the need for and effectiveness of these asylum targets, as set out for us by Sir John Gieve, former Permanent Secretary at the Home Office.[566]

574. However, our concern is that this overriding objective may detract from other important matters. Sir John Gieve told us that resources were not moved from other areas of the IND in order to meet asylum targets: "there was no explicit trade-off".[567] Stephen Boys Smith said that although asylum was given top priority because otherwise it would escalate beyond control, ministers were told about other areas of weakness.[568] Home Office officials assured us that asylum targets do not skew the system because they try to balance priorities "to get the right result in terms of maximising our impact on the risks that have been identified."[569] However, there are many examples of how, in practice, other work may be affected by asylum targets.

575. The NAO found in 2004 that the Government's decision to prioritise asylum cases had led to a build-up of 7,000 entry clearance appeals.[570] Mr Justice Hodge, President of the AIT, has pointed out that the legislation, particularly the procedure rules, still prioritises the handling of asylum cases over immigration cases,[571] even though there are now nearly as many immigration appeals as asylum ones.

576. The Director of Enforcement and Removals at the IND, Dave Roberts, told us that asylum removals were his top priority, and this is reflected in the very small proportion of enforcement work devoted to illegal working, sham marriages and abuse of the student route (see paragraph 415).

577. It has been suggested that the immigration authorities deliberately did not initiate deportation action against foreign national prisoners, in case this generated more applications for asylum and made it harder to meet the 'tipping the balance' target. A former senior immigration officer was quoted in the Sunday Times as saying

572

578. At Prime Minister's Questions on 3 May, the Prime Minister insisted that this was not so.[573] Mr Boys Smith told us that if officials had deliberately not initiated deportation action against foreign prisoners in case this generated more asylum applications, this would have been unknown to him: "That would constitute massaging of the targets and that was not acceptable conduct to me or my senior colleagues".[574]

579. There is no doubt that the achievement of successive asylum targets has been a notable success of the IND, and the criticism we make in this report should not detract from that. It is difficult to avoid the conclusion, however, that the existence of and single-minded focus on the asylum targets contributed to an environment in which the foreign prisoner problem was not recognised early enough.

ISOLATED TARGETS

580. If a target is set for one part of the system in isolation from the rest, meeting that target can cause problems around it.

581. When the AIT set its targets for clearing the backlog of immigration and entry clearance appeals, it did not appear to take into account the problems this would cause posts in preparing bundles (see paragraphs 381 to 390) or the High Court in handling subsequent reconsideration applications.[575]

582. The former Entry Clearance Monitor, Fiona Lindsley, suggested to us that focusing resources on people who do not have a right of appeal against entry clearance refusals, not enough time is spent on paperwork and the processing of appeals leading to backlogs there.[576]

583. A related concern is the "black holes" - if the target of, say, dealing with 90% of applications within 14 weeks is met, what happens to the remaining 10% is irrelevant from the point of view of meeting targets (see paragraph 223 to 224).

584. The setting of individual targets must take into account their likely effect on the performance of the organisation as a whole.

SPEED TARGETS

585. A general point which has been made repeatedly throughout the inquiry, and during the Committee's visits, is that targets which stress the need for speed can have a negative impact on quality. We saw this most clearly in visa applications (see paragraphs 141 to 153) but also in the same-day 'premium' service at the IND (see paragraph 222 above). In both cases the time targets dominated the work of those making the decisions and they acknowledged that this meant they were unable to carry out the proper checks. We were also told that performance indicators for IOs at ports also focused on speed rather than quality of decisions.[577]

586. Beverley Hughes MP resigned as Immigration Minister in 2004 after revelations that hundreds of visa applications from Eastern European migrants were approved without proper checks because officials had rushed through applications in order to meet targets for clearing a backlog.[578]

587. As we have emphasised throughout the report, targets which focus only on speed must be balanced with those which emphasise quality.

MISDIRECTED TARGETS

588. Other targets may simply be based on the wrong goal. The Director General of IND, Lin Homer, told us that the target of 12,000 non-asylum removals per year was set not on the basis of how many people need to be removed but according to the resources available and as an improvement on the previous year's performance.[579] Dave Roberts told us he was content with the level of removals to the extent that the target had been met or exceeded;[580] but this is clearly going to make little impact even on the continuing accretion of illegal migrants let alone the number of people estimated already to be in the country illegally.

589. Written instructions, targets and performance indicators are certainly important but they must be very carefully set and monitored so that they deal with real issues of concern over immigration and do not have negative impacts on other parts of the system.

Guidance

590. The foreign national prisoner issue highlighted problems with the guidance given to staff on immigration issues. Guidance on what to do with foreign prisoners is set out in a surfeit of documents from various authorities:

guidelines for criminal courts deciding whether or not to make a recommendation for deportation;[581]
a Prison Service Order which requires prisons to notify the Immigration Service as soon as a foreign national is received into prison;[582]
instructions to prisons to notify the Immigration Service of their release dates once calculated;[583]
a Home Office Circular to the police from December 2004 which advises them on liaison with the IND, reporting of convictions to the IND and deportation procedures;[584]
the Immigration Rules which list factors which will be taken into account in deciding whether or not to deport;[585]
an unpublished Home Office notice, DP3/96,[586] which provides guidance to officials on whether or not removal action is likely to be appropriate in all cases of people who are liable to be removed or deported but who have married a person who is settled in the UK.
IND instructions to caseworkers which record the circumstances in which the police may bring foreign criminals who may or may not be in prison to the Home Secretary's notice;[587]
IND guidance on enforcement;[588]
IND guidance to asylum caseworkers;[589]
IND guidance on deportation of EEA nationals.[590]

591. The Home Secretary criticised the guidelines for deportation. In his statement of 23 May 2006 he said that "the criteria governing which individuals should be considered for deportation appear to have been varied over time on authority which is unclear".[591] He also said that the Immigration Rules' criteria for deportation "currently go wider that the requirements of the Human Rights Act and the European Convention on Human Rights would stipulate". Lin Homer told us "it is clear…that we did not help the case workers by having…clear, concise, easy to understand interpretation of our guidance in place".[592] The Home Secretary approved the issuing of new guidance in yet another form - a "Process Communication" which instructs caseworkers that if they are minded not to deport on compassionate grounds outside the Human Rights Act, the case must be referred to Ministers for a decision.[593] The Immigration Rules themselves have not been changed, nor have any of the other pieces of guidance.

592. A lack of coherence and consistency in immigration guidance is by no means confined to the foreign prisoner issue. For instance ECOs we met in Pakistan raised with us the difficulty of finding the right information in amongst the range of guidance they are issued, and would prefer to see all the relevant guidance combined into one source.

593. Caseworkers rely heavily on guidance throughout the immigration system, and yet there is such a mass of documents in so many different series that it is very difficult for them to find the correct, up-to-date and most authoritative information. All immigration guidance must be consistent and coherent across the various relevant authorities, and each section must always have a clear owner at a senior level who has approved it and checked it with owners of other sections.

Following up recommendations

594. The Home Office receives reports almost every week urging it to act, from Inspectorates, the NAO, the Audit Commission and independent monitors, not to mention Select Committees. A list of recent reports relating to immigration is appended to this Report.

595. As we have noted above in relation to the NAO report on the entry clearance operation (paragraphs 179 to 182), there may be a lot of work going on to implement recommendations, but it is very difficult to determine this let alone to assess whether the steps being taken do actually meet the requirements.

596. In other cases recommendations go unheeded, particularly if they come from an unexpected quarter. It was perhaps because warnings to the IND about foreign prisoners came from HM Inspector of Prisons that they were not adequately followed up (see (paragraphs 522 to 525).

597. Sir John Gieve, former Permanent Secretary at the Home Office, told us that whilst there was no comprehensive system for following up recommendations, there is generally an action plan and monitoring:

It depends what the report is on, who it is from and what it is about. Generally, there will be a directorate or senor official who is responsible for that area of work. They will prepare a response because nearly all these reports have responses. They will know that there will be a follow-up. The Inspector of Prisons is making many annual reports and will come back to these later so they know there is a follow-up. Usually, an action plan is drawn up. We decide what we are going to do in whichever area it is and then there is a monitoring process to make sure it happens.[

594

598. Given the stream of reports and recommendations relating to immigration which appear every year, a clear method for keeping track of the Government's progress in responding to each of them is essential. Annual checklists should be published showing what progress has been made across Government on recommendations from independent monitors, audit committees, the National Audit Office, Select Committees and other official reports.

Oversight: an Independent Immigration Inspectorate?

599. At the moment there is very little independent oversight of the immigration system, and what exists is fragmented, under-funded and with very limited powers. There is a race monitor, but only for some types of decision; and a monitor for entry clearance, but only for refusals where there is no right of appeal. There is also a series of audit committees for the IND, on finance and governance issues, complaints and the Immigration Service.[595] In addition the Parliamentary Ombudsman, HM Prisons Inspectorate and the Commission for Racial Equality have certain immigration-related roles.

600. Both Mary Coussey, Independent Race Monitor, and Fiona Lindsley, former Independent Monitor for Entry Clearance Refusals, told us that they had "no budget".[596] Mary Coussey added that she does not have any powers to ask for things to be done, merely to make recommendations, which the Government can simply reject.[597] Fiona Lindsley recommended that there should be a monitor of the whole visa system not just for people without rights of appeal, in order to look at the system as a whole including how focussing on one area of the system impacts on others.[598]

601. The IPPR has suggested that a "Managed Migration Policy Committee" be set up, an independent or autonomous or semi-autonomous body that could oversee immigration control and immigration statistics and report to Parliament. Sir Andrew Green, chairman of Migration Watch UK, agreed that this may be a possible means of reassuring the public about immigration.[599]

602. We have not taken enough evidence to form an opinion on whether immigration policy should be set by a body at arm's length from Government. However, the evidence does point towards the clear need for specialist comprehensive oversight of the immigration control system.

603. We recommend that the Government establish an Independent Immigration Inspectorate with oversight of every stage of immigration control: overseas, at the border, in-country, enforcement (including detention) and appeals. It should be looking for high-quality decisions, active management, clear lines of responsibility and of reporting, easy communication within and across authorities, meaningful statistics, effective and non-distorting targets, excellent customer service and promotion of good race relations. The Inspectorate must be independent, properly resourced and with the authority to make recommendations to which the Government has to respond.

533 Q 1142-1143, 13 June 2006 Back

534 Q 946, 6 June 2006 Back

535 Q 944, Q 973, Qq 1101-1102 and 1117, 12 June 2006 Back

536 Qq 868-71, 23 May 2006 Back

537 Q 869, 23 May 2006 Back

538 HC Deb 23 May 2006 col. 81WS Back

539 Q 867, 23 May 2006 Back

540 Ev 48, para 38, HC 775-II Back

541 Qq 971-2, 6 June 2006 Back

542 Qq1065-1070, 6 June 2006 Back

543 Ev 399, HC 775-III Back

544 Q 1146, 13 June 2006 Back