DCH 55 Field Marshall Sir
John Chapple
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.
Field Marshal
Sir John Chapple
Formerly Chief
of the General Staff 1988 - 1992
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