Eighth Report Contents

Drawn to the special attention of the House

Draft Electoral Commission Strategy and Policy Statement

Date laid: 14 December 2023

Parliamentary procedure: affirmative

This draft Statement sets out the strategic and policy priorities of the Government in relation to the functions of the Electoral Commission (“the Commission”) and describes the Commission’s role and responsibilities in enabling the Government to meet those priorities. The draft Statement includes guidance to which the Commission must have regard when exercising its functions. The Government says that the Statement “seeks to ensure greater accountability to the UK Parliament on how the Electoral Commission discharges its functions”, arguing that this will increase public confidence in the Commission’s work. It is clear from the statutory consultation process, however, that there are questions about the necessity and appropriateness of the Statement and concerns about its impact on the Commission’s operational independence. We note, in particular, that the Speaker’s Committee on the Electoral Commission, the body responsible for holding the Commission to account on behalf of Parliament, objects to the draft Statement as “not fit for purpose and inconsistent with the Commission’s role as an independent regulator”. While we are not in a position to adjudicate on these opposing views, we note the strength of the objections to the draft Statement and regret that the Government is taking forward the draft Statement against the opposition of the Speaker’s Committee. The House may wish to press the Minister for a compelling justification for the Government’s approach.

The draft Strategy and Policy Statement is drawn to the special attention of the House on the ground that it is politically or legally important and gives rise to issues of public policy likely to be of interest to the House.

1.The draft Electoral Commission Strategy and Policy Statement (the “Statement”) has been laid before Parliament by the Department for Levelling Up, Housing and Communities (DLUHC). The draft Statement sets out the strategic and policy priorities of the Government relating to elections, referendums and other matters in respect of which the Electoral Commission (“the Commission”) has functions. It also describes the role and responsibilities of the Commission in enabling the Government to meet those priorities and includes guidance in relation to the Commission’s functions to which the Commission must have regard. The Government’s policy priorities in the draft Statement include: tackling electoral fraud; addressing weaknesses in the current absent voting arrangements; improving the accessibility of elections; and supporting participation.

Accountability arrangements for the Commission and role of the Statement

2.The Commission was established by the Political Parties, Elections and Referendums Act 2000 (“PPERA”) as the independent regulator responsible for ensuring that elections and referendums are run effectively and lawfully, for registering political parties and for regulating donations to and the spending of political parties. Its functions are set out in PPERA and the Elections Act 2022 (“the Act”). The Commission is independent of government and accountable to Parliament via the Speaker’s Committee on the Electoral Commission (“Speaker’s Committee”), which was also established by PPERA. The Speaker’s Committee is chaired by the Speaker of the House of Commons. Its current membership consists of the Speaker, four MPs of opposition parties and five Conservative MPs, including the Secretary of State and two other ministers of DLUHC, but only two DLUHC ministers may attend at a time.1

3.The Act empowers the Secretary of State to designate a Strategy and Policy Statement for the Commission. This instrument is the first use of this power. The Act also requires the Commission to have regard to the Statement when exercising its functions. The Government says that the Statement “seeks to ensure greater accountability to the UK Parliament on how the Electoral Commission discharges its functions”, arguing that this will increase public confidence in the Commission’s work.

4.Under the Act, the Speaker’s Committee may assess the Commission’s performance of its duty to have regard to the Statement, and the Commission is required to report on what it has done in relation to the Statement 12 months after the Statement was first designated and every 12 months thereafter, in addition to, or as part of, its existing annual reporting requirements. The Speaker’s Committee may choose to report on the Commission’s performance as part of the Speaker’s Committee’s yearly reporting requirement.

Statutory consultation and parliamentary procedure

5.The development of the draft Statement was subject to a two-stage statutory consultation process. As required by PPERA, the Secretary of State consulted the Commission, the Speaker’s Committee and the House of Commons Levelling Up, Housing and Communities Committee (“the Levelling Up Committee”) on an initial draft of the Statement. This first consultation took place between 22 August and 20 December 2022, with responses received from the statutory consultees as well as from the House of Commons Public Administration and Constitutional Affairs Committee and the Association of Electoral Administrators.

6.The Department revised the draft Statement in light of the feedback received during this first consultation and, as required under PPERA, laid a revised Statement before Parliament, together with an explanation of the proposals and the Government’s response to the first consultation. For a period of 60 days (from 8 June to 14 September 2023) Members of both Houses were able to make representations on the revised draft Statement and consultation report. The Government received representations from the Speaker’s Committee and the Chair of the Levelling Up Committee during this second consultation.

7.As required under PPERA, the Secretary of State then laid the final draft of the Statement before Parliament, alongside the Government’s response to the representations received during the second consultation.2 The final draft must now be approved by a resolution of each House within a 40-day period before the Secretary of State may designate the Statement.

8.As the draft Statement only contains provisions regarding the non-devolved functions of the Commission, the Devolved Administrations were not consulted.

Concerns raised about the draft Statement and the independence of the Commission

9.According to the Department, the Statement “does not seek to interfere with the governance of the Commission” which “remains operationally independent”. DLUHC says that the legal duty to have regard to the Statement “does not replace or undermine the Commission’s other statutory duties or give the government powers to direct the Commission’s decision making”, adding that while the Statement articulates “the Government’s view of factors the Commission should have regard to”, Commissioners and the Commission’s executive leadership “remain responsible for determining how the Commission exercises its functions”. This includes “determining the Commission’s strategy, priorities, how it should discharge its duties (including day-to-day operations) and the allocation of its resources, as agreed by the relevant parliaments”. The Department says that, in practice, the duty means that when carrying out its functions, the Commission will be required to consider this Statement and “weigh it up against any other relevant considerations”, and that it will be for the Commission to determine how to factor the Statement into its decision-making processes and corporate documents such as the Five-Year Plan.

10.We note, however, that the introduction of the Statement and the requirement on the Commission to have regard to it have been controversial from the beginning. During the House of Lords second reading debate of the Elections Bill (“the Bill”), for example, concerns were raised about the provision which empowers the Secretary of State to designate a Statement for the Commission, specifically that such a government-drafted Statement could “interfere” with the Commission’s independence.3 Similarly, when scrutinising the Bill, the House of Lords Select Committee on the Constitution expressed concern about the desirability of introducing a government-initiated Statement, stating that this could “risk” the independence of the Commission and “be dangerous if the perception were to emerge that the Commission is beholden to the Government for its operation and delivery”.4

11.DLUHC explains in the Explanatory Memorandum that the Government made changes in response to the concerns raised during the passage of the Bill, including “explicitly preventing” the Statement from making any provision regarding the Commission’s investigatory and enforcement functions in relation to individual cases and requiring the Secretary of State to have regard to the Commission’s statutory duties when preparing the Statement.

12.We note, however, that the statutory consultees still objected to the draft Statement during the two-stage consultation process. In its response to the revised draft Statement from September 2023,5 the Speaker’s Committee welcomed that the Government had made “some substantive improvements to the revised draft Statement in response to some of our concerns” during the first consultation. However, the Committee expressed concern that “the Government believes the most serious flaws do not warrant changes” even though these flaws had been identified “in concert by us, the Electoral Commission, and the Levelling Up, Housing and Communities Committee”. These flaws relate to the rationale for designating the Statement, the extent to which the Statement will facilitate more effective parliamentary scrutiny of the Commission, the potential for the Statement to undermine the independence of the Commission and the appropriateness of the Government using the Statement to provide guidance to the Commission.

13.The Speaker’s Committee found that the revised draft Statement remained “not fit for purpose and inconsistent with the Commission’s role as an independent regulator”. In particular, the Speaker’s Committee criticised that the Government had “not offered a cogent explanation of what it is seeking to resolve through the Statement”, and that the Government’s consultation response “betrays a misguided perception that the Commission is—or ought to be—to some extent, under Government control”. The Speaker’s Committee concluded that:

“[D]esignation of a Statement is a power the Government may use, rather than one it must use. Nothing in the Government’s consultation response changes our conclusion that the draft Statement is neither necessary at this time, nor likely to assist the Commission in its pursuit of the aims and objectives already approved by the Speaker’s Committee and adopted by the Commission.

[ … ] As we also noted in our consultation response, the power of the Speaker’s Committee to hold the Commission accountable for its duty to have regard to that Statement is also optional. Were the Government to proceed to designate a Statement which we consider not fit for purpose, we would need to consider carefully what account we could take of such a Statement, and whether we could legitimately hold the Commission to account for their duty in relation to it.

[ … ] We cannot support this revised draft Statement, and invite the Government to rethink whether a Statement is needed at all. [ … ] If the Government proceeds to designate this Statement, substantively unchanged, we invite both Houses to heed these concerns, and consider the final Statement carefully during the 40-day approval period.”

14.Given this opposition to the draft Statement, we asked the Department about the role of the Secretary of State and DLUHC ministers on the Speaker’s Committee and whether they had excused themselves from the discussions of the draft Statement. The Department told us:

“In terms of discussions on the [Statement] itself, the Speaker’s Committee’s representation on the Statement was approved at a meeting on 4 September 2023. Ministers voluntarily did not attend this meeting given its primary focus was for the Speaker’s Committee to approve its response to the Government’s Statement. This allowed non-government members of the Speaker’s Committee to deliberate freely about the content of that response. However, that is not to suggest that it is inappropriate for Government members to attend meetings where the Statement or the Commission’s performance are discussed more generally, as they have often done in the past and as intended by Parliament.”

15.The Levelling Up Committee concluded in its 2022 report on the initial draft Statement that “no Statement is necessary at the current time”, and that “no evidence has been provided justifying it”.6 The Chair of the Levelling Up Committee reiterated this criticism in a letter7 to the Speaker’s Committee on the revised draft Statement:

“In summary, the Committee considers that the changes do not alter its view of the Statement [ … ] For the most part the Statement reads as though the Commission were an arm of Government. The Commission is not a government body, and its independence is—as is agreed by all stakeholders—critical to its effective functioning. Any perception that the Commission is being influenced to favour the governing party in exercising its functions could seriously damage public confidence in the democratic process. [ … ]

The Government may have attempted to extricate itself from some of the problems identified with the first draft Strategy and Policy Statement but it has failed, and the new approaches it has tried have let it back into the same quagmire: this reconfirms our Committee’s belief that the Statement will not “bring any tangible benefits to the exercise of the Commission’s functions that would outweigh the serious disadvantages outlined”.”

16.The Commission emphasised in its response8 to the initial draft Statement that:

“The Government should make clear how its statements on priority setting are consistent with the Commission’s independence and with the Act. In particular, it should be clear that the Commission should not be fettered in the exercise of those of its statutory duties that are not covered in the statement and that the Commission remains free to prioritise and resource those other functions in accordance with its independently agreed plans.”

17.Given the strength of these objections, we asked for further explanation of the rationale for introducing the Statement and about the value that the Statement will add to the existing accountability arrangements for the Commission. The Department responded that:

“Throughout the passage of the Elections Bill and since the Act passed, the Government has set out a consistent and clear rationale for the Statement. The Statement is intended to enhance the Electoral Commission’s accountability to Parliament whilst respecting its operational independence.

Before the Elections Act, the Commission was already accountable to the Speaker’s Committee. However, the Committee’s limited statutory remit meant it was only responsible for scrutinising the Commission’s finances and corporate plans. Lord Pickles’ report in 20169 was clear that the existing system of oversight by the Speaker’s Committee did not provide an effective third-party check on the Commission’s performance. While some may have a high level of confidence in how the Commission already exercises some of its functions, others may disagree. For example, the Public Administration and Constitutional Affairs Committee’s report into “The Work of the Electoral Commission” in 202210 identified several areas for improvement, including the support the Commission provides to parties and campaigners and the way the Commission secures compliance with and enforces political finance laws. The Committee’s report listed elements of the draft Statement that addressed those concerns and that it recommended be maintained in the final iteration. The final draft [of the Statement] laid before Parliament on 14 December 2023 does retain those elements.

In order to provide for a more effective third-party check on the performance of the Electoral Commission, section 13ZA of PPERA (as inserted by section 17 of the Elections Act 2022) gives the Speaker’s Committee an expanded role to examine the performance of the Electoral Commission in relation to its duty to have regard to the Statement. Once the Statement is designated, the Speaker’s Committee will have the opportunity to consider the Commission’s actions across a range of areas relevant to the Statement. By improving the accountability of the Commission to the UK Parliament, the Statement will increase public confidence in its work.

The draft Statement sets out the Commission’s role in supporting the Government’s determination to tackle issues such as voter fraud, to improve the accessibility of elections and to increase participation. These are important aims and ones it would be wholly appropriate for an electoral regulator to support. The Statement can also provide useful guidance for the Commission to consider in areas where primary legislation is not explicit and the Commission is exercising a significant amount of discretion.”

18.Responding to the representations made by the Speaker’s Committee, the Government took the view that the objections of the Speaker’s Committee and others had “either been addressed previously or cannot be satisfied by amending the Statement without compromising significantly its intended effect”. The Government acknowledged, however, that “the Statement must always be compatible with the foundational principle of respecting the Commission’s operational independence”, adding that “the Commission will only be required to have regard to the Statement in the exercise of its functions. This legal duty does not replace or undermine the Commission’s other statutory duties or give the government powers to direct the Commission’s decision making.”

Conclusion

19.It is clear that there are opposing views on the appropriateness and necessity of the draft Statement and concerns about its impact on the Commission’s operational independence. We note, in particular, that the Speaker’s Committee, the body responsible for holding the Commission to account on behalf of Parliament, objects to the draft Statement as “not fit for purpose and inconsistent with the Commission’s role as an independent regulator”. While we are not in a position to adjudicate on these opposing views, we note the strength of the objections to the draft Statement and regret that the Government is taking forward the draft Statement against the opposition of the Speaker’s Committee. The House may wish to press the Minister for a compelling justification for the Government’s approach.

Immigration and Nationality (Fees) (Amendment) (No. 3) Regulations 2023 (SI 2023/1359)

Statement of changes in Immigration Rules (HC 246)

Dates laid: 7 and 13 December 2023

Parliamentary procedure: negative

Amongst other changes, this Statement of Changes in Immigration Rules and associated Regulations introduce new criteria for a family member of a ‘stateless person’ to be able to join that person in the UK. In particular, under the new rules, such family members will ordinarily have to pay the standard application fees for immigration applications and the Immigration Health Surcharge, and meet other criteria including suitability, English language and financial requirements. A submission we have received describes the changes as making the criteria “far more stringent” and significantly diminishing the rights of stateless persons in the UK. However, the Home Office argues that the intention is to promote consistency across immigration application routes.

We summarise below a number of the points raised in the submission, and the Home Office’s responses to our resulting questions. In most of the areas, it is not our role to take a view on the merits of the arguments, although, consistent with our previous comments, we do believe that guidance in one significant area should have been published alongside the legislation. We also expect the Home Office to publish further information on the impact of the changes and on stateless applications more generally. The House may wish to probe further on these points and in other areas discussed below.

This Statement of Changes and associated Regulations are drawn to the special attention of the House on the ground that they are politically or legally important or give rise to issues of public policy likely to be of interest to the House.

Background

20.Amongst other changes to the immigration rules, HC 246 introduces a new appendix that deals with stateless persons, who are people not considered a national of any country. Stateless persons may be granted leave to remain in the UK if they cannot leave voluntarily or be removed because they have no right of permanent residence elsewhere. Prior to these changes coming into force, stateless persons were covered by Part 14 of the Immigration Rules.

21.In practice, the changes mainly affect partners and children of people who have been recognised as stateless. Under the current system, family members of stateless persons can be granted leave to enter or remain in the UK alongside the stateless person, whether or not they are themselves also stateless. Following the changes, this will no longer be the case. Instead, family members will be required to apply under ‘Appendix FM’, which is the general set of rules for family members applying to join those already living legitimately in the UK.

22.SI 2023/1359 introduces changes to immigration fee rules consequent on the Statement of Changes; for example, to remove family members of stateless people from the scope of the exemption to relevant immigration fees.

23.We received a joint submission from Asylum Aid and the Liverpool Law Clinic on the changes relating to stateless persons. The submission is published in full on our website.11 We raised a number of questions arising from the submission with the Home Office. These questions, and the Home Office’s responses, are summarised below and the full exchanges are available alongside the submission on our website.

Settlement criteria for family members of stateless persons

24.One implication of the changes is that dependents of stateless persons will (unless they make a successful application for a fee waiver) have to pay the standard fees for immigration applications, and the Immigration Health Surcharge (IHS). Family members of stateless persons were previously exempt from all such charges. The submission we received notes that, following recent announcements, both immigration fees and the IHS have increased, or will shortly increase, significantly.12 The submission argues that these additional costs mean that an application under Appendix FM “will be prohibitively expensive for a significant number of family members of Stateless Persons: a total of £4,643 in fees per person every 30 months”. While fee waivers are available, the submission contends that the bar for these to be granted is “extremely high” and “it may take weeks or even months to obtain a decision”.

25.In addition to the fees and costs, the new system will ordinarily require family members of stateless persons, if not stateless themselves, to meet other criteria that do not currently apply, including suitability, English language and financial requirements. For partners, the financial requirements would include the minimum income threshold, which will also be significantly increased following recent announcements.13 The submission argues that, in combination, these changes introduce criteria for acceptance of an application that are “far more stringent” than those currently in place.

26.We put these points to the Home Office, which disputed the characterisation of the changes as introducing “far more stringent” criteria. The Home Office said instead that the policy change “will achieve greater consistency across immigration routes to the UK”. We note that it is possible for both views of the policy to be correct.

27.The Explanatory Memorandum (EM) to the Statement of Changes did not include any impact information that might have helped to assess the practical effect of the changes; for example, the current number of applications from family members of stateless persons and the acceptance rate, compared with estimates of these numbers after the changes come into force. The EM to 2023/1359 said only that “as the volumes of individuals affected by this legislation are small, the impacts, including financial impacts, are expected to be minimal”. When we asked the Home Office further about impacts, it replied that “we do not currently publish statistics on the number of stateless applications or decisions, but we plan to include this in future data releases”. We note that this may be too late to assess the effects of the change; the House may wish to press the Minister on whether there is any further information that can shed light on this question. We welcome the Home Office’s commitment to publishing statistics in the future.

Position of children who are not themselves stateless

28.The submission argues that there is a “significant omission” in the new rules, which results in children who are not themselves stateless, but whose parents are stateless, having no route to apply to join or remain with their parents. The submission states that this arises because children may only apply for entry clearance or leave to remain if one of their parents is also applying for, or has received, permission under Appendix FM, but, in the future, stateless parents will be applying under the new Appendix Statelessness.

29.In response to our questions on this, the Home Office agreed that for a child to meet the “core requirements” in Appendix FM, the parent must have permission under Appendix FM. However, the Home Office said that “where the child does not meet the core requirements, the caseworker will consider whether there are exceptional circumstances”, including whether a refusal would breach the right to family life under the European Convention on Human Rights (ECHR) (The exceptional circumstances test is discussed further below.) Again, it would be helpful in understanding the effects of the change if the Home Office published statistics and analysis in this area.

Identity requirements

30.A new aspect of the rules requires a stateless person to ‘establish their identity’ before their application for leave to remain can be considered. The submission argues that this is not compatible with the policy intention of providing protection to stateless people, particularly given that the only appeal route on this aspect of the rules is via Judicial Review, and given that stateless people are “very likely to have no personal identity documentation”.The Home Office stated that the new requirement to “satisfactorily” establish identity differs from the usual immigration requirement, which is to provide a passport or other travel document, and that this difference reflects the difficulty that stateless applicants may have in providing a document. The Home Office also said that it retains discretion to accept applications as valid where one or more of the validity criteria is not met; and that guidance will set out how stateless applicants without documents can meet the requirement. The Home Office stated that this guidance will be published on the day that the new rules come into force (31 January 2024), but, as we have said previously,14 guidance relating to significant areas of the policy should be available at the time the legislation is laid before Parliament.

Permitted length of stay

31.Under the previous system, a partner of a stateless person who successfully applies to join them would be granted permission to stay for five years, following which they could apply for settled status. Under the new system, a successful applicant would normally be granted permission for 30 months, after which they would need to reapply (with associated costs), before being eligible for settled status after five years.

Exceptional circumstances

32.If an applicant does not meet the standard criteria, they may still be granted permission if there are “exceptional circumstances”, such as that refusal would breach the person’s rights under Article 8 of the ECHR (the right to respect for private and family life).15 The submission stated that, in practice, the “vast majority” of family members of stateless persons are unlikely to meet the new criteria, by the nature of being in such a position, and would, therefore, need to rely on exceptional circumstances. In response to this point, the Home Office said:

“As Appendix Statelessness does not come into force until the 31 January, we do not know the proportion of applicants who will not meet the core criteria. We anticipate that some dependants of a stateless person may not be able to meet the financial or English language requirements and will need to rely on an Article 8 exceptional circumstances test under Appendix FM.”

33.We expect information on the application of the exceptional circumstances test to be included in the data that the Home Office has said it plans to publish on stateless persons.

34.We also note that if an applicant is accepted based on exceptional circumstances, they would be able to settle only after a 10-year qualifying period, with associated costs for reapplications every 30 months in the meantime.

Breaches of human rights conventions

35.The submission includes a number of arguments asserting that the policy changes more widely are incompatible with the ECHR and other relevant international conventions. In response to our questions in this area, the Home Office said:

“We are confident our changes are compatible with international obligations such as the UN Statelessness Conventions and the ECHR. A caseworker must consider for example whether refusal would breach Article 8 ECHR as part of an Appendix FM application, therefore there is still a path for families to reunite or stay together. We separately engaged with interested stakeholders and sought legal advice in advance of laying Appendix Statelessness.”

We note the Home Office’s response, but are not in a position to take a view as questions of legality are outside the scope of this Committee.

Conclusion

36.This Statement of Changes and associated fees instrument introduce changes to the regime governing stateless persons, including strengthening the criteria that need to be met to allow family members to join an existing stateless person in the UK.

37.A submission we have received argues that the changes “significantly diminish the rights of stateless persons in the UK”. A number of the issues arising from the submission are summarised above. In general, these are not questions on which it is appropriate for us to take a view, but they may indicate areas in which the House might wish to probe further. We also expect the Home Office to review the effects of the changes and to publish the results of such reviews, as well as to begin to publish regular statistics on stateless applications.


2 Department for Levelling Up, Housing and Communities and the Electoral Commission, ‘Final draft Electoral Commission strategy and policy statement’ (14 December 2023): https://www.gov.uk/government/publications/final-draft-electoral-commission-strategy-and-policy-statement [accessed 15 January 2024].

3 See Elections Bill Lords second reading: HL Deb, 23 February 2022, col 244 [Lords Chamber].

4 Select Committee on the Constitution, 13th Report (Session 2021–22, HL Paper 164), paras 35 to 44.

5 The Speaker’s Committee on the Electoral Commission, Response to the draft Strategy and Policy Statement for the Electoral Commission, 3rd Report 2023, HC 1809.

6 House of Commons Levelling Up, Housing and Communities Committee, Draft Strategy and Policy Statement for the Electoral Commission, (4th Report, Session 2022–23, HC 672).

7 House of Commons Levelling Up, Housing and Communities Committee, ‘Letter from the Chair to the Speaker’s Committee on the Electoral Committee concerning the draft Strategy and Policy Statement for the Commission’ (26 June 2023): https://committees.parliament.uk/publications/40636/documents/198144/default/ [accessed 15 January 2024].

8 Electoral Commission, ‘Response to the UK Government consultation on a draft Strategy and Policy Statement for the Electoral Commission’ (16 September 2022): https://www.electoralcommission.org.uk/news-and-views/our-responses-consultations/response-uk-government-consultation-a-draft-strategy-and-policy-statement-electoral-commission [accessed 15 January 2024].

9 Lord Pickles, ‘Securing the Ballot: Review into electoral fraud’ (August 2016): https://assets.publishing.service.gov.uk/media/5a8058bd40f0b62305b8a9d3/eric_pickles_report_electoral_fraud.pdf [accessed 15 January 2024].

10 House of Commons Public Administration and Constitutional Affairs Committee, The Work of the Electoral Commission (2nd Report, Session 2022–23, HC 462).

12 Immigration and Nationality (Fees) (Amendment) (No. 2) Regulations 2023 (SI 2023/1004), which we drew to the special attention of the House in 55th Report (Session 2022–23, HL Paper 263), paras 65-89; and Draft Immigration (Health Charge) (Amendment) Order 2023, drawn to the special attention of the House in 5th Report (Session 2023–24, HL Paper 24), paras 1-20.

13 Home Office, ‘Net migration measures—further detail’ (21 December 2023): https://www.gov.uk/government/news/fact-sheet-on-net-migration-measures-further-detail [accessed 12 January 2024].

14 For example, see 1st Report (Session 2023–24, HL Paper 3), paras 23–34.

15 There is existing guidance on the application of the exceptional circumstances test, at: Home Office, ‘Family Policy: Family life (as a partner or parent) and exceptional circumstances’ (15 May 2023): https://assets.publishing.service.gov.uk/media/6464f2b8d3231e000c32db8a/Family_life__as_a_partner_or_parent__and_exceptional_circumstances.pdf [accessed 15 January 2024].




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