Gambling Harm—Time for Action Contents

Chapter 2: Background and the current situation

Gambling—the statutory definition

Betting and gaming

30.There has been confusion in some of the evidence we have received about the definitions of the different types of gambling—betting, gaming and lotteries. Under the Gambling Act 200529, betting is defined as making or accepting a bet on:

31.Gaming is defined as “playing a game of chance for a prize.”30 A “game of chance” includes:

32.Many of the documents submitted to the Committee in written evidence, and many witnesses in oral evidence, follow the increasingly common practice of using the term “gaming” to describe playing electronic games either on a console or online on a laptop or mobile phone. This can create some confusion, as “gaming” in its statutory sense is governed by the Act and regulated by the Gambling Commission, while video and online games currently are not. In this report we use the word “gaming” in its statutory sense and refer to video gaming and social gaming as such.


33.At its simplest, a lottery is a type of gambling that has three essential elements:

34.Lotteries can only be run for the benefit of good causes, and there are two main types of lottery—the National Lottery and society lotteries. Both are described in more detail in Chapter 9.

Gambling Commission

35.The Gambling Commission was established under the Gambling Act 200531 and assumed full powers in 2007, taking over responsibility from the Gaming Board of Great Britain for regulating commercial gambling in Great Britain, in partnership with licensing authorities. It licences operators and individuals in Britain that provide arcades, gaming machines, betting, lotteries, bingo, remote gambling (both online and over the phone), casinos and gambling software, as well as awarding the licence to run the National Lottery.

36.The Commission is an independent, non-departmental public body sponsored by the Department for Digital, Culture, Media and Sport (DCMS). It is funded by fees set by DCMS and paid by the organisations and individuals it licenses. We examine the Gambling Commission in more detail in Chapter 4.

Legislative background

37.Prior to the Gambling Act 2005, which came fully into force on 1 September 2007, gambling in England, Wales and Scotland was regulated by the Betting and Gaming Act 1960, which was repealed and replaced by the Betting, Gaming and Lotteries Act 1963, the major consolidating statute governing all forms of gambling. As we describe below, major changes to the law on gaming were made by the Gaming Act 1968, and to the law on lotteries by the Lotteries and Amusements Act 1976,32 until the creation of a separate legislative framework for the establishment and regulation of the National Lottery in 1993. The 1963, 1968 and 1976 Acts were largely repealed when the Gambling Act 2005 came into force.33

38.Before 1960, legislation did not try to interfere with private gambling between individuals but attempted to place strict controls on gambling for commercial gain. However, the aim of the Betting and Gaming Act 1960 was to liberalise the law on gaming to allow those who wanted to game to do so, whilst at the same time continuing to prohibit commercial exploitation. To achieve this aim the Act imposed three conditions:

39.Despite these restrictions, commercial gaming was able to obtain a foothold because of what was thought to be a minor concession which allowed clubs to impose a charge to recover the costs of the gaming facilities they provided. There was no requirement that the amount charged should be limited to the real cost of providing such facilities. Nor was the concession limited to genuine members’ clubs and as a result a great number of commercially operated clubs emerged.

40.By the mid-1960s, there were approximately 1,000 casinos operating in the UK, some unscrupulous operators were taking advantage of customers, and criminal involvement was rife. The Gaming Act 1968 was passed to restore order. The Act recognised that commercial gaming could not be suppressed and sought to bring it under strict controls. The Home Office’s “Introduction to the Gaming Act” stated:

“The main purpose of the Act is to curb all forms of gaming which are liable to be commercially exploited and abused. It recognises that commercial gaming cannot now be suppressed, but seeks to bring it under strict controls. The principle on which it proceeds is that no one can claim a right to provide commercial gaming: it is a privilege to be conceded subject to the most searching scrutiny, and only in response to public demand.

The controls have as their common object to purge this activity of its criminal elements, to cut out excessive profits, and to ensure that gaming is honestly conducted in decent surroundings. Beyond that the intention underlying the Act is to reduce drastically the number of commercial clubs providing games other than bingo; to restrict bingo to a neighbourly form of gaming for modest prizes; and to check the proliferation of gaming machines and machines used for amusement with prizes.”34

Budd Report

41.In 2000, the Home Office commissioned a review of gambling, and following changes in departmental responsibilities after the 2001 general election, it was submitted to the Department of Culture, Media and Sport. The review was commissioned to try to understand the “rather more complex world of gambling”35 that had emerged since the Government’s last review in 1978.

42.The Gambling Review Body was chaired by Sir Alan Budd GBE, a prominent British economist whose career included being Chief Economic Adviser to the Treasury, a founding member of the Bank of England’s Monetary Policy Committee, and head of the Government Office for Budget Responsibility. When he gave oral evidence to us on 3 September 2019, he emphasised that the Review Body “produced a report in 2001 and in 2005 the Gambling Act was passed. The Gambling Act reflected a very high proportion of our proposals, but it did not include them all.”36

43.In 2001, the Gambling Review Body’s Report (known as the Budd report) made recommendations to liberalise the regulation of gambling. The report recommended that the demand test for betting shops, bingo halls and casinos should be abolished. The demand test was introduced in the Gaming Act 1968, and stated that:

“ (1) The licensing authority may refuse to grant a licence under this Act if it is not shown to their satisfaction that, in the area of the authority, a substantial demand already exists on the part of prospective players for gaming facilities of the kind proposed to be provided on the relevant premises.

(2) Where it is shown to the satisfaction of the licensing authority that such a demand already exists, the licensing authority may refuse to grant a licence if it is not shown to their satisfaction-

(a) that no gaming facilities of the kind in question are available in that area or in any locality outside that area which is reasonably accessible to the prospective players in question, or

(b) where such facilities are available, that they are insufficient to meet the demand.”37

44.The Budd report also recommended that the membership and 24-hour rules for casinos and bingo halls should be abolished. At the time, all those who wished to gamble at a casino or bingo hall were required to be members, and there was a 24-hour delay between becoming a member and being able to gamble.

45.It was suggested that casinos should be permitted to provide:

46.The report also recommended that bingo halls should be permitted to offer unlimited prizes, rollovers and unlimited linked games, and betting shops should be permitted to have jackpot machines. It was also suggested that credit cards should be approved for gambling purchases with the exception of direct use in gaming machines.

47.The report explained that the aims of the recommendations were to ensure that:

48.The report also suggested that gambling regulation should be simplified, by incorporating all regulation relating to gambling into a single Act of Parliament, establishing a single regulator for all gambling activities, and making that regulator responsible for the licensing of individuals and companies.

49.There has been much retrospective discussion of the approach taken in the Budd report, with some, such as Dan Waugh, partner at Regulus, 39, suggesting that the report’s primary focus was the consumer. Mr Waugh gave oral evidence to us on 3 September, questioning whether the recommendations in the report “could be considered to be truly radical.”40

50.Mr Waugh suggests that the report was interested in how gambling legislation could promote the greatest benefits to consumers while also providing protection against harms to individuals and society. The authors of the report stated that finding this balance was their ‘central dilemma’:

“The most difficult general issue that we have had to solve concerns the familiar dilemma between the desire to permit free choice and the fear that such choice may lead to harm either to the individual or to society more widely” …

“Our proposals generally move in the direction of allowing greater freedom for the individual to gamble in ways, times and in places than is permitted under current legislation. This move to greater freedoms is balanced by rather tighter controls on the freedom of young people to gamble and by some tighter controls over those who provide gambling circumstances.”41

51.The Budd report concluded that the correct balance between restrictions on consumer freedom and the potential for harm suggested setting aside the principle that facilities offered should only respond to unstimulated demand.

52.The report recommended that online gaming should be permitted but also that “only online gambling sites that are licensed by the Gambling Commission should be permitted to advertise in Great Britain.”42 While the Government accepted the Budd report’s recommendation that online gambling be made explicitly legal, it did not become a requirement for remote operators to hold a licence from the Gambling Commission until November 2014.43


53.The Review Body was persuaded by the weight of evidence that children and young people are especially vulnerable to the risks of becoming problem gamblers. As a result, it decided to make various recommendations that it believed would reduce children’s opportunities to gamble. The report highlighted two specific areas of gambling regulation: the ability for children legally to play (low stake, low prize) gaming machines in amusement (so called penny) arcades; and the potential for online gambling to increase gambling participation and problem gambling among children.

54.It described the practice of permitting machine play by minors as “an historical accident”44 but stopped short of recommending a ban out of consideration for the financial impact this would have on seaside arcades. Nevertheless, several recommendations were included for constraining the opportunities for children to gamble on machines, including:

55.Each of these recommendations was implemented by the Gambling Act 2005.

Draft Gambling Bill and pre-legislative scrutiny

56.The Draft Gambling Bill was published in November 2003, and listed its licensing objectives as:

57.The Draft Bill also made provision for the establishment of the Gambling Commission, and stated that the Commission should permit gambling in so far as is reasonably consistent with the pursuit of the licensing objectives. The Draft Bill also gave the Secretary of State power to make regulations requiring holders of an operating licence to pay an annual levy to the Commission.

58.In April 2004, the Joint Committee on the Draft Gambling Bill published its report. The Committee stated that:

“Although many of the changes we recommend are aimed at ensuring that the Government proceeds more cautiously than was recommended by the Budd review and as envisaged in the subsequent White Paper, A Safe Bet for Success, we think that the overall framework of the draft Bill is about right.”46

59.The Committee emphasised that it was content that the objectives listed in the Draft Bill were balanced and appropriate, and recommended that they should be included unamended in the final version of the Bill.

60.The report also noted that the Committee expected the draft Bill to lead to an increase in the prevalence of problem gambling: “Almost all of the evidence we have received points to the fact that this legislation would increase the number of people in the United Kingdom with a gambling problem.”47 However the Committee expected that some of its recommendations, if implemented, would contribute to a reduction in the scale of any increase:

“We make several recommendations to reduce the potential impact of the draft Bill, in particular we suggest that no casino should be permitted unlimited numbers of gaming machines. We also comment on key areas in which more research is necessary, including the continued use of low-value gaming machines by children.”48

61.The Gambling Act 2005 was passed in April 2005, but did not fully enter into force until 1 September 2007.

Post-legislative scrutiny

62.The House of Commons Culture, Media and Sport Committee49 published its report on post-legislative scrutiny of the Gambling Act 200550 in July 2012, when it had been in force for nearly five years. The report concluded that:

“Gambling is now widely accepted in the UK as a legitimate entertainment activity. While we recognise the need to be aware of the harm caused by problem gambling, it seems to us that the rather reluctantly permissive tone of gambling legislation over the last 50 years is now an anomaly. Our general approach in this report has therefore been to support liberalisation of rules and delegation of decisions to those most knowledgeable about their likely impacts, local authorities, while keeping national controls to the minimum commensurate with protection of the vulnerable, in particular children.”51

Political shift

63.Prior to the Gambling Act 2005, gambling was seen as an activity that should be tolerated, but not encouraged. This approach to gambling was discussed in the Budd report:

“Much of the existing legislation in the UK reflects an attitude that gambling is, at best, something to be grudgingly tolerated and contained, rather than allowed to be encouraged. This attitude is based either on the belief that gambling is bad in itself (the moral argument) or that it can lead to serious harm (the danger argument). It is for this reason that the concept of “unstimulated demand” (enshrined in the 1968 Betting and Gaming Act) has such a central role.”52

64.This attitude was clearly demonstrated in the demand test, which allowed a licensing authority to refuse to grant a gambling licence unless it was shown to its satisfaction that there was an existing substantial demand for gaming facilities of the kind proposed to be provided on the premises. Where it was shown to the satisfaction of the licensing authority that such a demand did already exist, the licensing authority could still refuse to grant a licence if it was not shown to its satisfaction that no gaming facilities of the kind proposed were available or that they were insufficient to meet demand.

65.The Budd report explained some of the other restrictions on gambling, that showed the Government’s willingness to tolerate gambling, but not encourage it:

“The current state of regulation is based on the view that gambling should be tolerated rather than encouraged. By “encouraged” we mean that the general public should not be faced by unlimited opportunities to gamble and by uncontrolled inducements to do so (e.g. by unregulated advertising). Many forms of commercial gambling can only be conducted on licensed premises and at limited hours. There may be limits on the types of game, on the number of machines, on the size of stake and on the possible winnings. A period of 24 hours may have to elapse before one becomes entitled to play. The numbers and locations of gambling outlets are restricted.”53

66.The Gambling Act 2005 changed the underlying approach to gambling from permitting it, but not encouraging it, to increasing the opportunities for adults to gamble, and treating it as a leisure activity like any other. This move to liberalise the legislative and regulatory approach to gambling can be seen in various aspects of the Act, including:

67.In recent years, there has been increased criticism of the Gambling Act, as well as the regulatory approach underpinning it. Many witnesses have suggested that the Act is unable to regulate technological developments in gambling. Gambling with Lives, a charity established by those bereaved by gambling-related suicide, stated: “There is a clear need for a new Gambling Act to bring legislation up to date with the rapid developments in technology over the past 15 years.”54 The Gordon Moody Association, which provides intensive residential treatment for problem gamblers, expressed similar views in its evidence, explaining: “When the 2005 Gambling Act was drafted, there was no ability to gamble on mobile devices as there is today, and despite the best intentions, the 2005 Act has proved unable to keep up or adapt to evolving technology.”55

68.Academics, charities, campaigners, politicians and sections of the media have also called for the introduction of new gambling legislation. Some, such as Professor Jim Orford56, Emeritus Professor of Clinical and Community Psychology at the University of Birmingham, have argued that the new legislation should be based on an approach similar to that seen pre-2005, where gambling is once again tolerated, but not encouraged, and is recognised as a dangerous product. Professor Orford told us that “The 2005 Gambling Act is turning out to be sufficiently flawed that a completely new Act, based on a dangerous consumption/public health perspective, is now needed … “57

Gambling prevalence

69.The Gambling Commission’s Gambling Participation in 2019: behaviour, awareness and attitudes report58 gives a broad overview of gambling participation in Great Britain.

70.Overall, 47% of respondents said that they had participated in at least one form of gambling in the previous four weeks. A larger proportion of men (51%) had participated in any form of gambling than women (43%), and this pattern can be seen consistently over a number of years. The proportion of men and women gambling fluctuates, but for both men and women there was a two percentage point increase between 2015 and 2019.

Table 1: Past four-week participation in all forms of gambling



Year to December 2015



Year to December 2016



Year to December 2017



Year to December 2018



Year to December 2019



Source: Gambling Commission, Gambling Participation in 2019: behaviour, awareness and attitudes, Annual report (February 2020) p 8: [accessed 6 April 2020]

71.The age groups most likely to have participated in gambling were those aged 45–54 or 35–44, with 53% of 45–54 year olds, and 50% of 35–44 year olds having gambled in the past four weeks. Those in the youngest and oldest age groups had the lowest gambling participation levels.

72.Participation in National Lottery draws is much higher than for any other gambling activity. Of those who had gambled on one activity in the previous four weeks, 31% had only gambled on National Lottery draws.

73.When National Lottery draw only respondents are excluded, the overall participation rate falls from 47% to 32%. Since 2015, the proportion of respondents gambling on any activity (other than National Lottery draws) has increased by five percentage points. Males were more likely than females to gamble (36% and 30% respectively), and those aged 16–34 were more likely to gamble than other age groups.

Table 2: Past four-week gambling participation (excluding participation in National Lottery draws)



Year to December 2015



Year to December 2016



Year to December 2017



Year to December 2018



Year to December 2019



Source: Gambling Commission, Gambling Participation in 2019: behaviour, awareness and attitudes, Annual report (February 2020) p 9: [accessed 6 April 2020]

74.Overall, 21% of respondents have gambled online in the previous four weeks, which is a three percentage point increase since 2018, and a six percentage point increase since 2015. Online participation was higher among men (25%) than women (17%). There has been a significant increase in those aged 16–24 (17%, a five percentage point increase) and 35–44 (28%, a six percentage point increase) gambling online.

Table 3: Past four-week online gambling participation (including online National Lottery products)



Year to December 2015



Year to December 2016



Year to December 2017



Year to December 2018



Year to December 2019



Source: Gambling Commission, Gambling Participation in 2019: behaviour, awareness and attitudes, Annual report (February 2020) p 10: [accessed 6 April 2020]

75.We discuss the prevalence of problem gambling (as opposed to all gambling) in Chapter 559, and in Chapter 660 we look at the prevalence of gambling, including problem gambling, among children and young people.

Social and economic benefits of gambling

Social benefits

76.The gambling industry trade association, the Betting and Gaming Council61 (BGC), emphasised that research has found “not only higher levels of well-being among recreational gamblers than non-gamblers, but also found that well-being increased with gambling engagement”62 except in those instances where problem gambling occurred. It also referred to research which indicates that gambling can involve a range of additional benefits, such as opportunities for social engagement and increases in mental acuity. The BGC also quoted research by Professor David Forrest, Professor of Economics at the University of Liverpool Management School, which states:

“interaction with others is widely regarded in the psychology literature as important to a feeling of satisfaction with life. Much gambling takes place in social settings. The bingo hall can provide its patrons with a sense of camaraderie. Casino players appear to value social contact with dealers and other players.”63

77.The Bingo Association’s evidence also emphasised the social value of bingo, stating that:

“The Ipsos MORI research into problem gambling in bingo in 2016 … concludes that a visit to a bingo club is a crucial lifeline to those whose ‘life circumstances limit their ability to participate in other leisure pursuits’. 92% of bingo customers attend their club with friends or family, and many make connections whilst at the bingo. It is therefore a social support system, where the key motivation for attending is to socialise and relieve isolation and boredom.”64

78.The Rank Group emphasised the health benefits of bingo, particularly for older players:

“Specifically for bingo, a recent University College, London (2019) study (and reported in various news outlets, August 2019) points to the social benefits of playing land-based bingo, with other people, to protect against the development of dementia. The study into “cognitive reserve” reveals a compelling contrast to the scourge of loneliness in society, especially among older-age groups, and builds on the concept of social engagement as a means of delaying (the symptoms of) dementia.”65

79.As explained above, there is considerable academic research that shows the social benefits of land-based bingo halls, but we also received evidence that emphasised the social benefits of online bingo. Phil Cronin, Chief Executive of Tombola, highlighted the importance of its online community:

“All of the games that are available on our sites involve chat communities, where people can meet up and make friends. We have even had people who have ended up getting married, having originally met on our Tombola website.”66

80.Simon Wykes, Transition Director of Gamesys Group, also explained the importance of the online community for its business and customers:

“The other basis of the business has always been community. It has always been about being with people who are like you and who feel like you. … we have had 13 weddings from our chat houses across our business. In our Jackpotjoy brand, 49% of visits to the site do not involve customers spending any money. They come to a place for free games and get entertainment in that way. In 51% of visits, they spend some money. Nearly 30% of our customers actively engage in chat, but a lot of the others just like to observe what is going on in the chat and see what people are saying.”67

Economic benefits

81.The Government’s evidence explained that the gambling industry employs more than 106,000 people68, and that last year it paid £3 billion to the Exchequer in gambling duties. The Treasury’s evidence explained that this £3 billion represents 0.4% of the annual tax take and gave a breakdown by individual sectors of the gambling industry.

Table 4: Exchequer revenue from gambling duty by sector



2018–19 Revenue

General Betting Duty


£619 million

Pool Betting Duty


£6 million

Lottery Duty

National Lottery operator

£853 million

Gaming Duty

Casinos (gaming tables)

£222 million

Remote Gaming Duty

Remote (online) casinos, slots and bingo sites

£531 million

Machine Games Duty

Gaming machine operators

£720 million

Bingo Duty

Bingo halls

£33 million

Source: Written evidence from HM Treasury (GAM0080)

82.The Rank Group’s evidence gave an illuminating example of the tax contribution made by gambling operators:

“At Rank, in the most recent financial year (2018/2019), we made a Group Profit After Tax (PAT) of £29.1 million but paid £191.1 million in tax. In short, we paid over six and half times more in tax than we made in group profit after tax. Of this, £159.0 million was paid in UK tax … ”69

83.The financial contribution made by the gambling industry through taxes must be taken into account when considering the costs incurred by the state and society. We deal with this in full in Chapter 5.70

84.The BGC provided information about the employment benefits of the gambling industry:

“Our members are a key part of the leisure and entertainment industry. Our industry employs over 106,000 people71 and contributes more than £14 billion to the UK economy. Of the 106,000 people employed in our industry, 56% are women and 24% are aged under 24. Jobs in our industry range from retail assistants in betting shops (each shop employing on average six members of staff), skilled croupiers in casinos to high tech jobs in online operators and suppliers. Our members also support training and apprenticeships, which is growing in provision.”72

85.The British Horseracing Authority (BHA) emphasised the beneficial relationship between the gambling industry and horseracing, which is most evident in the Horserace Betting Levy. The Levy is charged at 10% of a gambling operator’s gross profit on British horseracing. The money raised is then distributed in line with three statutory purposes:

86.The BHA explained that:

“the majority of Levy expenditure is reinvested by the Horserace Betting Levy Board (HBLB) for the improvement of horseracing, funding prize money which acts as the lifeblood of the industry–supporting participants, keeping more horses-in-training and improving the popularity of the sport as a socially responsible betting product.”73

87.Camelot stated that since its launch the National Lottery has raised £40 billion for good causes. This represents “565,000 grants, 200 per postcode right across the UK74” with 70% of grants being for £10,000 or less. Camelot also highlighted the benefits to the Treasury and retailers:

“Some £17 billion has been raised in 25 years for the Treasury, and as importantly, about £6.5 billion for retailers. We play a really pivotal role in keeping our independent retailers open. We have 44,000 retailers. We rely on them and they rely on us. We continue to pay about £300 million a year in commission.”75

88.We acknowledge that gambling of all types is a source of enjoyment, and that some forms foster a strong sense of social cohesion among players. Gambling makes an important contribution to employment and to the economy. Throughout this inquiry we have borne this in mind, and in formulating our recommendations we have sought to impact on the benefits of gambling only to the extent that is required to achieve the objective of making gambling safer for all.

29 Gambling Act 2005, section 9

30 Gambling Act 2005, section 6

31 Gambling Act 2005, section 20

32 This was a consolidating Act, consolidating the lotteries provisions of the 1963 Act with the Lotteries Act 1975, which was repealed on its entry into force.

33 The provisions remaining in force are those relating to contributions for the benefit of horseracing by bookmakers and the Totalisator Board.

34 Home Office, Introduction to the Gaming Act (1968)

36 Q 37 (Sir Alan Budd GBE)

37 Gaming Act 1968, schedule 2, paragraph 18

39 Dan Waugh, ‘Budd Revisited—Gambling in Great Britain 15 Years On’, UNLV Gaming Research & Review Journal, vol. 20(2), (2016): [accessed 18 May 2020]

40 Q 37 (Dan Waugh)

43 Gambling (Licensing and Advertising) Act 2014

45 Department for Culture, Media and Sport, Draft Gambling Bill, Cm 6014, November 2003, p 1: [accessed 16 June 2020]

46 Joint Committee on the Draft Gambling Bill, Draft Gambling Bill (Report of Session 2003–04, HC 139-I, HL Paper 63–I)

47 Ibid.

48 Ibid.

49 Now the Digital, Culture, Media and Sport Committee.

50 Culture, Media and Sport Committee, The Gambling Act 2005: A bet worth taking? (First Report, Session 2012–13, HC 421)

54 Written evidence from Gambling with Lives (GAM0098)

55 Written evidence from the Gordon Moody Association (GAM0032)

56 Written evidence from Professor Jim Orford (GAM0019)

57 Written evidence from Professor Jim Orford (GAM0019)

59 Chapter 5, paragraphs 262–268

60 Chapter 6, paragraphs 414–421

61 The Betting and Gaming Council, which has been operational since November 2019, is an industry association for betting and gaming representing 90% of the UK betting and gaming industry.

62 Written evidence from the Betting and Gaming Council (GAM0068)

63 Ibid.

64 Written evidence from The Bingo Association (GAM0013)

65 Written evidence from Rank Group Plc (GAM0029)

66 Q 100 (Phil Cronin)

67 Q 100 (Simon Wykes)

68 Written evidence from HM Government (GAM0090) dated 6 September 2019, gave the figure of 106,000. However, the Gambling Commission’s latest statistics published in May 2020 show that in September 2019 98,000 people were employed in the gambling industry : Gambling Commission, Gambling Industry Statistics: April 2015 to March 2019 updated to include October 2018 to September 2019 (May 2020) p 9: [accessed 15 June 2020]

69 Written evidence from Rank Group Plc (GAM0029)

70 Chapter 5, paragraph 280

71 Written evidence from The Betting and Gaming Council (GAM0068) dated 6 September 2019, gave the figure of 106,000. In its latest statistics, published in May 2020, the Gambling Commission gives the figure as 98,000: Gambling Industry Statistics: April 2015 to March 2019 updated to include October 2018 to September 2019, p 9

72 Q 128 (Brigid Simmonds)

73 Written evidence from the British Horseracing Authority (GAM0065)

74 Q 119 (Nigel Railton)

75 Ibid.

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