73.There are several possible legislative options, ranging from criminalising specific contempts to a more comprehensive codification of parliamentary privilege. In considering these, we have followed the advice given to us by the Liaison Committee in the last Parliament:
We believe the House should take action on the recommendations of the 2013 Joint Committee to test how usable and effective they might be. If they prove to be insufficient, that will give a firmer basis for pursuing the statutory solution… [In that instance] we would urge your Committee to initiate the process of drafting legislation relating to exercise and enforcement of these powers, so that it may be carefully and thoroughly considered in draft and consulted upon–not least with our colleagues in the other House of course. The range of statutory solutions would seem to run from a full dress Parliamentary Privileges Act to a limited provision engaging the criminal justice system solely in the enforcement of the order of a committee. We are aware that there are a number of international examples on which to draw.
In this chapter we report some findings from our consideration of international examples and provide a summary of some particularly relevant models we have examined in greater depth (see Annex 3 for summary of some key international models). We then outline two UK-specific proposals, formulated in consultation with Speaker’s Counsel, before detailing our proposal in Chapter 4.
74.In the current session, we have researched the arrangements and experience of other legislatures in enforcing committee powers. Our evidence is taken from a combination of questionnaire responses, private correspondence and informal private meetings.
75.In conducting our research, we have also been conscious of the unique circumstances and treatment of parliamentary privilege in the Westminster model. Similarly, we have been conscious of the distinct features of our own select committee system, noting the advice of former Clerk of the Journals, Mark Hutton:
There aren’t very many Parliaments, if any, that I am aware of that have the sort of Select Committee structure that we have, where there is such a wide range of Committees broadly doing scrutiny work of that character, and working in such a flexible and varied way.
76.It is notable that of the over 50 comparator legislatures we have examined, a majority have at least some form of legislative basis for committee powers. Some parliaments have provided powers for specific committees established in their respective constitutions (for example, Germany and France), whereas others have legislated specifically in relation to parliamentary privilege, powers, and contempt (notably Australia and New Zealand). The US Congress stands out as a comparator, with several different types of contempt proceeding, including subpoena powers for congressional standing committees and impeachment.
77.The variation in enforcement powers reflects the varied way in which committees operate in different ways in different Parliaments. In many legislatures, there is a distinction between committees of inquiry (or investigative committees) and standing committees set up on a permanent basis, which typically deal with legislation as well as scrutiny. In the majority of European legislatures, committees of inquiry tend not to be established in standing orders or equivalent, but are set up on an ad hoc basis and have quasi-judicial powers afforded to them under specific legislation (for example, the German Committee of Inquiry Act). These powers are similar in form to powers afforded under the UK Inquiries Act. However, the setting up of committees of inquiry in various European Parliaments requires a lower threshold than our UK Inquiries Act; for example, in Germany, the Bundestag has the right “and on the motion of one quarter of its Members the duty” to establish a committee of inquiry, as well as the right to determine the remit. Comparatively, under the UK Inquiries Act 2005, only a Minister may initiate an inquiry under that act and choose the topic of inquiry.
78.The Australian Parliamentary Privileges Act 1987 perhaps provides the most comprehensive attempt of a codification of privilege and specification of powers. Richard Pye, Clerk of the Australian Senate, explained to us the historic context of the Act:
the 1987 Act was prompted by court decisions which, in the view of the Australian Parliament, made unwarranted incursions upon parliamentary ground. The central task of the Act was to set privilege back to its understood foundation on Article IX.
In relation to committee powers, the Act provides for a range of penalties for offences, including imprisonment and fines (section 7); measures for the protection of witnesses (section 12); and a definition of “proceedings in Parliament” (section 16) in relation to Article IX of the Bill of Rights 1688, which applies to the Australian Parliament and Commonwealth. In the Australian model, both Houses have the power to impose penalties “for an offence against that House determined by that House to have been committed by that person”; in effect, the House acts as both judge and jury when it comes to determining the nature of the offence, and the appropriate sanction. The role of the court is limited (as per section 16 of the Act), although the court is responsible for enforcement including collection of any fine imposed under section 7. Sir Malcolm Jack advised how the provisions of the Australian Act might be suitably adopted in a UK context.
79.The powers and sanctions in relation to committee proceedings afforded to the Parliament of Australia under the 1987 Act have not been “fully tested”; no individual has been fined or imprisoned under the Act to date. The Clerk of the Australian House of Representatives explained that:
One reason for this is that most witnesses do not need to be compelled to provide evidence, and usually welcome the opportunity to engage with parliamentary committee inquiries. Another reason may be that, throughout various evidence gathering processes, witnesses are regularly reminded of their rights and responsibilities, with accompanying explanations of the powers of the House to deal with possible contempts of Parliament. Furthermore, while committees are aware of their considerable powers, they generally exercise caution and discretion in exercising these powers. It is considered that the ability of the House to exercise its rights should be carefully weighed against the need to engage constructively with individuals and organisations.
Assessing the effectiveness of the Australian model, the Clerk of the Australian House of Representatives concluded that the 1987 Act provided “significant clarification of the law and practice relating to parliamentary privilege”, and together with Standing Orders, resolutions and years of accumulated practice provides a “coherent framework for identifying, considering, and responding to contempts, and potential contempts, of the House”.
80.The New Zealand Parliamentary Privileges Act 2014 also provides a legislative model for privilege and the operationalising of sanctions. The purposes of the Act are set out in section 3, namely to “reaffirm and clarify the nature scope and extent of privileges, immunities and powers exercisable by the House of Representative, its committees, and its members” and “ensure adequate protection from civil and criminal legal liability for communication of, and of documents relating to, proceedings in Parliament”. Notably, the Act avoids “comprehensive codification of parliamentary privilege” but defines “for the avoidance of doubt, “proceedings in Parliament” for the purposes of Article IX of the Bill of Rights 1688”. In relation to sanctions, the Act provides a power to fine for contempt. Prior to 2014 the power to fine in New Zealand had been exercised on five occasions without statutory power, most recently in 2006 when a State-owned broadcaster was fined NZ$1000 for “disadvantaging” its chief executive on account of evidence he had given before a select committee. After the power to fine was contested, the decision was made to confirm the power in statute. For the enforcement of fines, a certificate from the Speaker that a fine has been imposed requires the courts to treat the matter as if it were a fine imposed for contempt of court. The New Zealand Parliament also has the power to imprison contemnors but this power has never been exercised.
81.In New Zealand, as in other comparator Parliaments that have legislated specifically regarding committee powers, Standing Orders have been used to supplement, support, and clarify legislative provisions. For example, in New Zealand, Standing Orders define “Contempt of House” and spell out examples of contempts, which include “deliberately attempting to mislead the House or a committee” and “failing to obey an order of the House or a summons issued by order of the House or by the Speaker”. In Australia, resolutions of the House relating to principles of fair trial and procedures for dealing with witnesses have been appended to Standing Orders.
82.The Houses of the Oireachtas in Ireland provides another comparator that applies a “dual model” of powers set out in a combination of Standing Orders and legislation. Certain committees of the Oireachtas have the power to compel witnesses and the production of documents; these powers are set out in both legislation and Standing Orders, which are engaged depending on the type of inquiry being conducted. A submission from the Houses of the Oireachtas explained:
The vast majority of Oireachtas committee hearings are conducted solely pursuant to Standing Orders. In practice, it is only when a Committee is seeking to exercise powers of compulsion that it invokes its statutory powers.
Committees that have powers to call for persons, papers and records in Standing Orders can seek to run a “Part 2 Inquiry”, which is a statutory inquiry pursuant to the Houses of the Oireachtas (Inquiries, Privileges and Procedures) Act 2013. There are different types of inquiries that can be conducted under Part 2 of the Act. A Part 2 inquiry allows a committee to make certain defined findings of fact and provides the committee with certain statutory powers including to compel attendance and provision of documents. Like Australia and New Zealand, the statutory powers of sanction are as yet “untested”. However, the House of Oireachtas stated that “the fact […] that such sanctions exist is, perhaps, effective in and of itself, in that compelled witnesses are absolutely clear on the repercussions of non-compliance by them with a committee direction”.
83.Regarding select committee powers, perhaps the most similar international parliament to that of the UK is the Canadian Parliament, where the Standing Orders of the House of Commons and the Rules of the Senate of Canada set out the powers of parliamentary committees to send for persons, papers and records. However, in the Canadian model, the rules and practices governing parliamentary committees are founded in the Canadian Constitution, the Parliament of Canada Act, and in Standing Orders and resolutions. It is also notable that in 2015 a Canadian parliamentary committee assessed that many of the powers to deal with contempts “may no longer make sense or seem relevant in a contemporary context” and that “a further review to assess their adequacy … ought to be considered”.
84.The US Congress provides for a variety of contempt powers in statute. In the US, both Houses of Congress have the power to invoke different types of contempt proceedings if a committee believes someone is obstructing its investigative powers, in addition to Congress’ impeachment powers. The three types of contempt proceeding are: criminal contempt of congress (set out in statute passed in 1857); “inherent” contempt, which permits congress to rely on its own constitutional authority to punish a contemnor (similar to Parliament’s own historic contempt powers); and congressional subpoenas. Congressional subpoena powers allow both Houses to bring forward a civil lawsuit asking a court (the federal district court) to enforce a witness summons or request for information. These have been used in recent times, including in August 2020, when the Democrat-controlled House Foreign Affairs Committee initiated contempt proceedings against Mike Pompeo for his refusal to comply with subpoenas for documents connected to Ukraine that led to President Donald Trump’s first impeachment.
85.Each of the UK devolved bodies (the Scottish Parliament, the Welsh Senedd and the Northern Ireland Assembly) have powers outlined in their respective devolution statutes to compel witnesses to attend its committees and order the production of papers. For example, in Scotland it is a criminal offence for witnesses to fail to appear before a Holyrood committee or fail to provide evidence. A requirement under section 23 of the Scotland Act 1998 can be imposed by the Clerk giving the person in question notice in writing of the time, place and particular topics on which they are required to give evidence or the documents they are required to produce. If the person to whom a notice is given fails to comply then they are guilty of an offence and are liable on summary conviction to a fine or imprisonment.
86.Although the sanctions provided have never been applied in any of the devolved legislatures, the powers have been used as a threat to secure compliance. Notably, the powers under section 23 of the Scotland Act were used recently on 22 January 2021 when a notice was formally issued to the Scottish Government by the Committee on the Scottish Government Handling of Harassment Complaints instructing the release of documents including private messages between the SNP’s chief operating officer Sue Ruddick and government figures in relation to allegations of misconduct by Alex Salmond. The request was complied with.
87.In legislatures where committee powers are not set out in legislation, the powers tend to be limited in practice to admonition by the committee or the House, and in some instances denial of access to premises.
88.Where there is legislation outlining forms of non-compliance with a committee of Parliament (either standing or investigative) there are always sanctions attached. These tend to include both fines and imprisonment. In examples where parliaments can set up investigative commissions, the sanctions for non-compliance tend to be equivalent or similar to sanctions for contempt of court. In the UK, the maximum penalty for contempt of court is a period of imprisonment not exceeding two years or a fine not exceeding £2,500.
89.The range of fines and prison terms in the international comparators we have looked at is broad. In the three devolved administrations, a person guilty of offence of refusing to provide evidence to a committee is liable to a fine of up to level 5 (currently £5,000) or a period of imprisonment not exceeding 51 weeks in the case of the Scottish Parliament or Welsh Senedd, or three months in relation to the Northern Ireland Assembly. In the States of Jersey a person who disobeys a summons without reasonable excuse is liable to a fine of up to £10,000. In France, failure to appear before a committee of inquiry, or refusal to give evidence or to take the oath is liable to a fine of €7500, or up to two years’ imprisonment. The New Zealand Parliamentary Privilege Act 2014 provides for a fine not exceeding NZ$1000 (around £500). Comparatively, in Ireland, the Houses of the Oireachtas (Inquiry, Privileges and Procedures) Act 2013 provides on conviction on indictment for a fine not exceeding €500,000 or imprisonment for a term not exceeding five years, or both. Notably the Australian Parliamentary Privileges Act 1987 makes a distinction between an individual (A$5000–around £2750) and a corporation (A$25,000–around £15,000).
90.Imprisonment is often included as a sanction alongside fines in the statutory examples examined in this paper. In every case however the sanctions are applied through the courts (either as purely as an enforcement mechanism of a parliamentary decision, or with more procedural oversight over the whole process).
91.We have considered the extent to which enhanced sanctions might be effective as a deterrent. The 1999 Committee recommended that the sanction for failure to comply with a summons should be a fine of an unlimited amount or up to three months’ imprisonment. By comparison, in establishing the power to fine for contempt the New Zealand parliament set itself a limit of NZ$1000. Some have questioned the persuasive effect of such a small amount, particularly when public figures or sector leaders are concerns. The Clerk of the New Zealand Parliament explained:
Although the matter was not widely debated in the House, the sum does reflect an acknowledgement that the power is of symbolic rather than punitive or deterrent value.
He noted that the Privileges Committee in New Zealand, when recommending the exercise of the power to fine in 2006 stated that, while the power to fine was necessary beyond “merely accepting an apology”, the “quantum of the fine we recommend is less significant than the fact that Privileges Committee, for the first time in 103 years, is recommending that a fine be imposed”. He argued that the same feature was true of Parliament’s contempt jurisdiction more generally; “the infrequency of the exercise of Parliament’s penal powers only serves to enhance its symbolic impact”.
92.International examples of contempt of parliament or equivalent are very rare. Most correspondents told us that compliance with parliamentary orders is very high, despite the need for applied pressure (via threatened sanctions) in some cases.
93.A significant exception to that rule in recent times has been the US, where congressional powers, including subpoenas and impeachment have been used recently. Michael Stern, a former senior counsel in the House of Representatives, highlighted recent examples to us where Congress has had problems enforcing its subpoenas and demands for information against non-members, and particularly against current and former officials in the executive branch.
94.Michael Stern suggested that the recent US experience might point to some of the dangers of a legislative model, especially with regards to the courts passing judgment on actions taken by the legislature. He highlighted the recent Trump v. Mazars USA, LLP case (July 2020), in which the Supreme Court considered the use of congressional subpoenas issued by committees of the House of Representatives to obtain the tax returns of President Donald Trump. Whilst the ruling reaffirmed Congress’ broad authority to conduct investigations for legislative purposes it also demonstrated the Court’s ability to assess and evaluate the validity of a congressional subpoena. The Supreme Court rejected the explanations offered by the congressional committees for why they needed the President’s personal financial information and strongly implied the subpoenas were politically motivated stating that they “[did] not represent a run-of-the-mill legislative effort but rather a clash between rival branches of government over records of intense political interest for all involved”.
95.A separate recent case study we have considered carefully is that of Ms Angela Kerins’ dealings with a parliamentary committee in Ireland. After a failed attempt by the Public Accounts Committee of Dáil Éireann to summon Ms Kerins to provide further evidence, Ms Kerins subsequently took legal action against the Clerk of the Dáil and members of the Committee. An initial High Court ruling ruled against Ms Kerins, arguing that the case was not justiciable and on the grounds that the proceedings of the Oireachtas were protected by the principle of exclusive cognisance. However, on appeal, the Supreme Court ruled in favour of Ms Kerins declaring the actions of the Public Accounts Committee unlawful. The Supreme Court ruling led to a major review by the Houses of the Oireachtas Service into the protocols and procedures concerning witnesses appearing before a Parliamentary Committee, which reported in December 2020. We received a private briefing from officials on the working group.
96.The case of Ms Kerins has presented several significant considerations for our own inquiry. First, the Supreme Court’s ruling provides a recent international example of judicial oversight of parliamentary proceedings in relation to the activity of a parliamentary committee. As explained in evidence submitted by representatives from the Oireachtas:
Whilst our written Constitution provides for the exclusive cognisance of Parliament, and provides members and witnesses with absolute privilege for their utterances in parliament, the Kerins case proved that judicial oversight of the exercise by Parliament of its functions can occur when Parliament is engaging with non-members or strangers.
Second, the Kerins case highlights the importance of effective safeguards for witnesses and due process in relation to committee proceedings. As a result of the Committee’s initial hearing with Ms Kerins, which lasted seven hours with one short break, she suffered from shock, stress and anxiety. After her appearance she was hospitalised from the 2–11 March 2014 and attempted to take her own life on 14 March 2014. The Oireachtas’ review on the back of the Supreme Court’s judgements has subsequently made several changes to Standing Orders, including new remedies for persons adversely affected by parliamentary utterances.
98.We consider that analysis of various international models and equivalent arrangements in the devolved legislatures supports our conclusion that new legislation to provide Parliament with appropriate powers is the most desirable of the three options available to the House. We believe it is possible to draft legislation that simultaneously strengthens the powers of Parliament, encourages compliance from witnesses, is consonant with human rights legislation and maintains the careful constitutional balance between Parliament and the courts.
99.Assisted by Speaker’s Counsel, we have formulated and considered two possible legislative models appropriate for a UK context, which we call the “contempt of court” model and the “criminal offence” model.
100.An initial sketch of the “contempt of court” model can be found in an annex to the memorandum submitted to the Committee by Daniel Greenberg CB, Counsel for Domestic Legislation, Office of Speaker’s Counsel.
101.Under the contempt of court model, powers would be given to the High Court or the Court of Session in Scotland to grant remedies for a failure to obey a summons or a request to provide information or documents from a select committee, by issuing an injunction in response to a request made by the Speaker of the House of Commons. If the individual were to breach the injunction issued from the court, the matter could then be treated as if for a contempt of court. In principle, the proposal would be similar to the use of congressional subpoenas in the US where Congress can seek a civil judgement in the relevant court declaring that the person withholding information is legally obliged to comply with the subpoena.
102.The statutory process under the contempt of court model would be triggered by a decision of the House to send a written certificate from the Speaker to the relevant court. Prior to that stage there would be a process set out in Standing Orders to ensure due process before certification. Any internal process would be included in Standing Orders and not on the face of the bill to preserve parliamentary privilege in respect of proceedings of the House.
103.Under this proposal, once the certificate had been sent by the Speaker, the responsibility for enforcement would lie with the courts, not Parliament. The enforceable sanction would be for contempt of court (although it would be confirmed by that stage that the individual would have committed a contempt of Parliament). The proposal therefore cedes the power of Parliament directly to enforce a sanction of a fine or imprisonment for contempt of Parliament to the court. However, the House would retain the initiative to admonish and would be able to address a failure to comply with a committee summons by seeking an injunction from the relevant court. The maximum sanctions for breach of a court injunction is imprisonment for two years and a fine of no more than £2,500, as set out in the Contempt of Court Act 1981.
104.The Counsel for Domestic Legislation advised that
The principal advantage of this [model] is that it would remove any suggestion that Parliament was granting to itself dictatorial and oppressive powers. Although it would be for Parliament to seek an injunction, this would as always be a discretionary remedy, and it would be for the court to determine whether and how to use it. So long as the judiciary of the High Court continue to be perceived as independent of government and Parliament, the use of a judicial remedy with all the safeguards that this entails should avoid reputational damage for Parliament … At the same time, the High Court injunction could be a fast and effective way of preventing people from withholding cooperation from Select Committee inquiries.
105.The main disadvantage of the model is that it would give the courts jurisdiction in relation to proceedings of select committees. As made clear by the evidence from the former Lord Chief Justice, the courts could not “simply be instructed by Parliament to give judicial effect to a Parliamentary Order” and would necessarily “have to be able to question that which Parliament is seeking to achieve by its Orders”. The courts would therefore be able to, if necessary, question the nature of a summons in the context of the Committee’s inquiry, and in doing so be able to examine proceedings currently protected by Article IX. Daniel Greenberg provided an example of how this might work in practice:
(a) Were a Select Committee to summon the CEO of a multinational company to give evidence about an aspect of policy of the company, the High Court might refuse an injunction to compel attendance on the grounds that the presence of the CEO herself or himself was not necessary to the inquiry, where they had offered to send an appropriately knowledgeable and experienced representative.
(b) In another case, however, where a Select Committee had decided to investigate on an ad hominem basis, the judge would be expected to conclude that anybody other than the witness summoned would be incapable of giving the information required by the Committee; whether or not the Committee was wise to conduct an ad hominem investigation, would not be something on which the court could opine.
106.The “criminal offence” model would create a criminal offence of failure without reasonable excuse to comply with a summons issued by a select committee of the House of Commons to attend the committee to answer questions, or to provide information or documents. In making failure to comply with a summons a criminal offence Parliament would be securing enforceable powers to punish contempt by means of a fine or imprisonment and would be aligning itself with the devolved Parliaments, as well as the Australian and New Zealand Parliaments.
107.The statutory process would again be triggered by a written certificate from the Speaker of the House of Commons to the relevant court that an individual has failed to comply with a summons. Prior to that stage there would be similar checks set out in Standing Orders, as under the contempt of court model above.
108.The significant difference between this model and the contempt of court model is that failure to comply with a summons from a select committee of the House of Commons would be a criminal offence, with the individual liable to a fine, imprisonment or both. A certificate from the Speaker to the relevant court would be taken as conclusive of the fact that the individual had failed to comply with the summons.
109.To ensure compliance with Article 6 of the European Convention of Human Rights (right to a fair trial), the courts would still need to be able review the committee’s proceedings so as to determine whether the person had a reasonable excuse not to comply and to determine what punishment to impose. However, the statute could expressly state the matters which the Court could or could not consider, thereby preventing any consideration of committee proceedings not relevant to the summons and protected under Article IX of the Bill of Rights.
110.The principal advantage of this model is that it would provide clarity for select committees, witnesses and the public. It would restore the historic position that a grave contempt of Parliament (such as failure to comply with a summons issued by a House of Commons select committee) could result in severe sanctions beyond admonition. The model would however necessarily allow the courts a degree of review over parliamentary proceedings when considering what sanctions to be imposed, which would be a departure from the principle of exclusive cognisance. To preserve the relationship between Parliament and the courts, the House’s internal processes would need to be rigorous to ensure the overall process was human rights and natural justice compliant, and to prevent the courts from needing to question the lawfulness of any parliamentary proceedings.
128 Dr Sarah Wollaston (), page 2
129 We have published all material referenced in this report on our website.
130 [Mark Hutton]
131 Noting this, our questionnaire made reference to “investigative committees” rather than select committees, as select committees is a less well-known/used term.
132 German Bundestag EP reply (4450) (); see also
135 Inquiries Act 2005,
137 Richard Pye, Clerk of the Australian Senate ()
139 Sir Malcolm Jack (; see also Daniel Greenberg () for further interpretation of the Australian Act
140 Claressa Surtees, Clerk of the Australian House of Representatives ()
141 Claressa Surtees, Clerk of the Australian House of Representatives ()
142 Claressa Surtees, Clerk of the Australian House of Representatives ()
143 New Zealand Parliamentary Privileges Act,
144 New Zealand Parliamentary Privileges Act,
145 New Zealand Parliamentary Privileges Act,
146 David Wilson, New Zealand Clerk of the House of Representatives (), page 3; the 2013 Committee noted that the privileges held by the New Zealand House of Representatives are defined as those enjoyed by the United Kingdom House of Commons in 1865 (para 56).
147 David Wilson, New Zealand Clerk of the House of Representatives ()
148 See David Wilson, New Zealand Clerk of the House of Representatives (); (pp. 494–501) also clearly sets out the powers the New Zealand Parliament has in relation to inquiries.
149 David Wilson, New Zealand Clerk of the House of Representatives (), page 3
150 New Zealand Parliament,
151 See for example, appended to their standing orders; See Paul Evans evidence () for further on this.
152 Ireland, Houses of the Oireachtas ()
153 , Part 2
154 , Part 2, Sections 7–11
155 Houses of the Oireachtas ()
156 Houses of the Oireachtas (), p. 12
157 For overview see Library of Parliament - Canada ()
159 Senate, Standing Committee on Rules, Procedures, and the Rights of Parliament, , Seventh Report, 2nd Session, 41st Parliament, June 2015, p. 57.
160 Congressional Research Service, , 12 May 2017
161 “”, U.S. House of Representatives Committee on Foreign Affairs, August 28 2020; “”, Guardian, August 28 2020
164 Scotland Act 1998,
165 Scottish Parliament (), Q.2
166 “”, BBC, 23 January 2021
167 See Israeli Knesset ()
168 For example the German Inquiries Act, see Bundestag ()
169 Contempt of Court Act 1981,
171 States of Jersey (Powers, Privileges and Immunities) (Scrutiny Panels, PAC and PPC) (Jersey) Regulations 2006, ; see also Mark Egan ()
172 French Senate (), p. 1
173 New Zealand Parliamentary Privileges Act,
174 Houses of the Oireachtas (Inquiry, Privileges and Procedures) Act 2013,
175 Australian Parliamentary Privileges Act 1987,
176 Joint Committee on Parliamentary Privilege, , HC 241-I, para 324, also 310–311
177 For example see Dame Louise Ellman () para 9
178 David Wilson, New Zealand Clerk of the House of Representatives () p. 4
179 David Wilson, New Zealand Clerk of the House of Representatives () p. 4
180 See for example Scottish Parliament ()
181 Michael Stern (), para 3
182 Michael Stern ()
183 See ; see also Michael Stern (), paras 12–14
185 For overview see Houses of the Oireachtas ()
186 Houses of the Oireachtas (); Houses of the Oireachtas, (December 2020); see also Oireachtas Library and Research Service, “”
187 Houses of the Oireachtas ()
188 Houses of the Oireachtas (); See also Houses of the Oireachtas, (December 2020)
189 Daniel Greenberg () see Annex
190 Clerk of the House [Dr John Benger] (), para 14
191 Daniel Greenberg (), paras 6–10
192 Lord Thomas of Cwymgiedd (), para 7
193 Daniel Greenberg ()