Memorandum from Field Marshal Sir John
Chapple (DCH 55)
Re: Written evidence submitted by the Independent
Services Agency Ltd on the draft Charities Bill
I wish to support the written evidence submitted
by the Independent Services Agency relating to the draft Charities
Bill.
The submission relates to two deficiencies in
the present drafting. First is the omission to include a specific
reference as a charitable head to "the defence of the realm
and the furtherance of the efficiency of the armed forces of the
crown." This has long been included as a charitable head
in one form or another, but despite categorical assurances from
both the Home Office and the Charity Commissioners that there
is no threat, in the Bill, to the status of Service Charities,
there remains much of concern if there is no specific mention
in the legislation. This concern stems from the fact that future
Ministers can change their mind when guiding policy; and that
officials interpret or re-interpret Acts of Parliament which do
not spell it out; and that certain other specific charitable definitions
are included (animal welfare, social housing etc) which only tend
to emphasise that the efficiency of the armed forces is not deemed
to be charitable.
May I advise that this is looked at again and
some suitable phrase is included.
The second concern relates to the excepted status
of some services charities. This is more of a technical, but important,
point which if not addressed as set out in the submission, will
lead to an extra administrative load and more bureaucracy. It
also contains an aggravating difficulty in treating service charities
in Scotland and Northern Ireland separately from those in England
and Wales.
I suggest that this should be re-examined.
June 2004
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