Hello. Welcome, everybody. Welcome back to today's session and this is the Children Law Accreditation Course through data law session to as of November 2025. A warm welcome to all of you. My name's softer Mahmoud. So in this session, then you know that I'm going through a number of elements. So an ink giving you a comprehensive account off somebody key developments in Children law proceedings on, but also somebody related matters surrounding Children or proceedings. So we're looking at private on public law matters, insofar as that is concerned. On this is session to off the 18 sessions that we're looking at, Son. The course has been run by myself, covering the law procedure and practice on then also by Nina Hero at a later date, the Children's Guardian. Okay, I've in the last session, and I made reference to the Acknowledgments, the copyright Acknowledgments and also the acknowledgement. So the provision there in so far as that is concerned. So what I'm going to be going through with you today is we're going to be looking at parentage a bit more detail specifically in so far as the H FDA, the human fertilization on embryology act of 2008 and so on. The changes brought about by that act. Andi, I'm then going to be looking at some of the other elements of private law would be looking at enforcement of child arrangements. Orders will be looking at the use off practice direction 12 j in terms of the relationship between child arrangements and domestic abuse. We'll be looking at some of the law surrounding removal. Andi, then representation of Children. So I'll be looking at both private Children or on public law cases, public Children or cases in so faras representation off Children is concerned. Onda make references to the A. Call the conduct as far as that's concerned on. For the last part off, they'll be looking at some of the elements running When local authorities intervene in families lives will be looking at sections 47 sections. Seven Section 37 of the Children Act on under support provided by local authorities, particularly to Children need, and also the use of Section 20 in England of the Children Act and Section 76 of the social services. And while being bio sacked off 2014 and White House. Okay, so in the last session and you remember I spent some time looking at parental responsibility. We spent some time looking at parentage now Parents Definition of Parents DHF B A Human Fertilization and Embryology Act of 2000 and eight updated the previous act of 1990. On in particular brought about changes swanning to position with second female parents. So this is where I would invite you to look at, For example, sections 42 43 of the act where, as I mentioned, if you have a situation, we have two women who seek to have a child on. They got to a UK registered license, fertility clinic and babies born to them through that process to anonymous sperm donor. Then, of course, a lady who conceives who has gives birth is the child's biological mother and legally has burned to responsibility, of course, but her partner in law is classed as the child second female legal parent. That's where she can acquire parental responsibility. There is the option of marriage, of course, between the two women, the civil partnership between the two women. There's also the possibility of applying for a child arrangements order specifying living with Onda. Uh, there's a PR agreement, so there's a second female legal parent Parental responsibility agreement on. There's also the option off a parental responsibility order under section for Is the day So a number of options available. Time Ondas We wanted it also talked about parental orders and a parental orders. Our orders made provision for under Section 54 h f d A. On initially thes could only be applied for by a couple. So two persons the commissioning persons who were seeking to acquire a parental order But since December 2018 days have now been also permitted to be applied for by a single person on Day three. The essence of a parental orders say you've got a husband and wife. They seek to have their own child. They have tried naturally to have a child. Sadly, it hasn't been appropriate possible for them. They've gone down the route of maybe assisted conception sadly, that that's not been a possibility for them. Adoption, of course, is a possibility. Fostering on another option is through surrogacy. So this is where they may identify Lady who's prepared to be a surrogate mother for them either. In the UK or overseas. And if they were to arrange on 20 an arrangement with a surrogate mother to have a child born through this process, then this is where once and if that child is born to the surrogate mother, that she hands the baby over at birth on, if she's married or in a civil partnership. If her husband and wife also consent, then that's where there would be an expectation for the commissioning family, the husband and wife an example that have been using to then consider applying for a parental order on. They would need to do so pursuant to Section 54 off the act. So if they were to apply for Anakin such a fun ordering or circumstances, Then there must have been what's called total or partial surrogacy, using gametes of at least one of the commissioning parents the need to be agent or over on, either in a uh either married or civil partners or Indian family relationship, not with improved two degrees. Okay, the parental ordered apply for must be applied for the six months, beginning with a day on which the baby was born. Andi, there must have been either dummy sado richly resident in the UK or the Island Man or the Channel Islands, the lady who gave birth. So the surrogate mother there must have, uh, consented to the handing over the child as well as her husband or wife must have consented on unless authorized. But accord no money or other benefit other than reasonably incurred expenses must have been given or received my eyes. The idea of the applicants in consideration of the making of the order, any agreement or handing over of child on the making of the arrangements. So that's the position with Section 54. But, of course, like I say, they have been changes to that eso at There's been cases where by the court has looked at whether or not his possible to acquire a parental order where one applies for it outside a six month regime and there has been cases is a case of X and y, for example, the 2000 and 11 case and later cases which which have emphasized that point. There's the case of Re X by the previous president, Family Division, Sir James Mumby, in reaction. There was also a later case off A and B uh, number two Parental order of 2015 handed down by Mrs Justice thise. And if there's good reason why the person did not apply for the parental ordered doing that stipulated time, for example, they were unaware of that fact. Or in some cases, the child may have been born overseas. And then there's been the difficulties with immigration and ensuring that the child is able to enter the UK for the pips of a parental order being sought. Then that could be a legitimate justification to enable parental order to then be applied for later on on. There was subsequently, but still to enable that to be granted. Aziz, you'll be aware there is the provision under section 54 4, monies to be unless authorized by the court. Any money that exchanged mustn't be anything more than reasonably incurred expenses. Commercial surrogacy under commercials. Eso against the Act of 1995 is not permitted in the UK Onda also in relation to the position. So Annan, who may apply for these orders. As I mentioned there were some changes that came in as a result of the human fertilization and embryology. Parental order eggs off 2018 when they came into affect his December 2018 so that it is now possible for single person single applicant, therefore, to acquire a parental orders or better in mind. There's also been a number of case over the years which have looked at issue off declarations as to parentage being sought. And this is where the previous president of family division, Sir James, mumbled out with a number of cases where sometimes persons were going to do registered clinic and sadly, either the former's were not completed or we're not kept on DSO sometimes have been misplaced on. That's where there were applications being made for parental orders and also for declarations of parentage to confirm parentage on the persons concerned. Okay, so a number of issues there, some of the other matters to bear in mind is that we've got Gender Recognition act. This came into effect in 2000 Onda for the Actors Gender Recognition Act of 2004 and what this, of course, very significant act of providing for is somebody who has transgendered to then be able to apply for a gender recognition certificate from Agenda Recognition Council, which in turn that allows them to change their gender on their birth certificate, and that was particularly relevant when they sacked First came in to enable somebody who has transgender to then be able to effectively marry somebody of the same biological agenda that they were born with so very, very significant act before. So, of course, got a civil partnership. Activity 1004 came to effect in December 2000 and five, which permitted same sex civil partnership, but only for same sex couples At that stage. On therefore, was a compromise between allowing same sex partners to enter into a partnership but not to allow marriage at that stage between same sex parties. But, of course, matters then moved significantly ahead so that we had the married same Sex Couples Act of 2013, which has from 29th of March 2014 permitted same sex marriage for same sex couples, so that has been placed now for some six years. On just recently, a Zoff, December 2019, 2nd of December, we had the regulations that came in which allowed for civil partnership for up 66 couples. So that's another consequence of the civil partnerships, marriages on death registration act of 2019, which therefore has permitted Yeah, uh, the position with civil partnership for opposite sex couples. And many of you will know that that was largely as a result of a case that went order. Actually, Supreme Court a case of Caden and Richardson that some of you will know on that lead to the civil punished off 2000 and four being declared has been incompatible with the European Convention, particularly Article idea Article 14 on which then led to the Act of 2019. Now, when you're dealing with Children cases, it's also very important to bear in mind issue off establishing parentage and the various powers the court may have in relation to that. So in your main notes in Book one, we have put a lot of this information there for you. You'll see that made reference to Section 21 subsection two of the Family Law Reform Act, which allows a child who has attained the age of 60 to consent to a sample being taken for determination off parentage. But if the child is under 16 and he got Section 21 3 of the Act of the 69 act which allows a sample to be taken from somebody who's under 16 if the person who was caring control consents on. Then there was amendment brought about by Section 23 of the Family Law Reform Act of 87 so that the Corcoran Factor examples to be taken to determine parentage. Of course, it's very, very important for Children for purpose, of articulates, to know whether or not a particular person is or is not there parent, whether it be their father or their mother putative father, a PhD mother on, therefore, more likely, not in cases where there is a dispute as to parentage. More likely than not, you'll find that the court we're going favor of determining issue parentage and secondly, to ensure that the child is made aware of that. But what if a person refuses to provide a sample? So this is where Section 23 subsection one of the Family Law Reform Act, takes effect so that, if say, you've got a pH to father who is confident that he's a chance father. But he's refusing to provide a sample than these possible under Section 23 for the court to raise inferences from that to draw inferences from his failure to do so. So there is that. Now there's a number of regulations which relate to blood testing. Take. And there's the blood test Evidence opportunity regs ous far back as 1971 on a more recent regulations off 2015. And these relate to matters surrounding through the actual process through which blood samples have provided, and also the samples and where they are to be kept. So again, make sure you're familiar with some of those regulations which which relate to those provisions. Okay, that then brings me on to some of the other issues that I wish to discuss today, which is that which relates to enforcement. Okay, so let's assume that we've got a case whereby say, I'm acting for the father on he has got the benefit of a child Arrangements Order specifies spending time with or otherwise having contact with the child. Okay, what used to be known as a as a contact or the pursuit of Section eight of the Children Act Andi. His concern is that despite the order being in place, the mother off the child with whom the child lives is blocking the contact, and he's at first he understood that the reason she was given she understood that maybe she got today's mixed up or or the Children were not well. But now he's fearing that actually, it's more than that. He feels that the mother is using every opportunity available to block that contact on that relationship. So, of course, in accordance with the overriding objective, you're trying to resolve matters out psychotic possible. But if not, then you may have to consider enforcement. Make sure you're familiar with the former C 79 which allows you then to bring the matter back before a court to seek provision under Section 11, which was brought in as a result of the Children on adoption at 2006. So that's one method. There are, of course, other things you might apply for. It could be an application of variation of the order that could be an application to switch residence or switch living with, I should say on also, in some cases, or being not very often, there may even be an application for committal, for breach of the terms of the order as well. Now, in terms off to see 79 then seeking enforcement through Section 11. Make sure you're familiar then with the various provisions there. So you got section 11 a, which maids for the fact that if the father was to bring the matter back to court, because there's a warning notice attached on the face of the order, which allows him then to bring the matter back through Form seven to C 79. Theme the sexually 11. A provision for activity, directions and conditions to be attached. So, for example, for the parties concerned, which made the mother and all sort of father to engage in various parenting classes, programs of work counseling, guidance, mediation, mediation, information assessment meetings, domestic violence, perpetrator work on the management work to be participated and to assist the parties with a view to them facilitate in that context. So that's where that provision is very relevant and therefore which may well need to be relied upon. Okay, on. This is where Calf Casanova's family proceeding officer, of course, will play a very pivotal role in terms of monitoring compliance that could be very important to ensure that that is born in mind so that the court could make in order for monitoring by Kafka's or the worst friend of scenes officer to them. Bring the matter back before the court, if necessary. Thio informed quarters to what the position has been there. As I mentioned all orders now, as a result of the Children Adoption Act, all orders as from eighth of December 2000 and eight would have a warning not to touch them. And that's what would then enable you to complete the form C 79 to bring the matter back before the court. But if there isn't a warning notice attached because it's in order before that date, then there is another forms you fill in. But nowadays you're not going to be relying upon this very often, given how old this is now. And that's the form C 78. And that's if you do need for there to be a warning notice attached. But of course, this provision has been in place now for some time on the warning notice is important because it allows the court to make provision under under this act. There's also with another provision which may be relied upon, uh, certainly relation to the fact that there was a warning notice, and that's where you may wish to think about at the use of enforcement orders on enforcement orders. His waved. The court is satisfied beyond reasonable doubt that a person has failed to comply with the terms of a child arrangements order unless they have got a reasonable defense. Satisfying the court on a balance of probabilities on the court can make enforcement order against them. On the beauty of that is, this is where the court and has the authority to impose other provisions effectively a form of community service with a view to than facilitating and assisting the parties with a view to enabling contact to to continue. So you may have to think about that. There's also other options available, such as maybe the use of section 11 0, which is compensation compensation for financial loss. So, let's say, an example of been using. The father has booked a trip to take the Children away for the weekend that he was due to be having his contact on his booked a hotel, his books of activities for them and sadly, the mother without just cause, uh, blocks the contact and therefore he decides to call for enforcement. Now he may claim compensation. So the money is he can't get back safe, for example, for the hotel is booked. Travel the Let's say we're gonna take the Children to theme parks and you can't get that money back. So whatever compensation he's lost in that regard, hey may claim that the hope is that by doing so, it is hoped that this may facilitate contact in the future. As you could imagine, compensation doesn't always work on. It may not actually be the right way forward. In some cases, each case has to be looked on its own facts. One of things I wanted to mention in this regard, of course, is the use of section 16 of the Children that this is very useful family assistance orders. And perhaps I would suggest these air, sometimes under used on this, is where family assistance orders cannot be made for a period of up to 12 months, as opposed to just six, which they used to be previously on the's are useful, which can be made either alongside the child arrangements, orders or a zone order in its own right on the purpose of this is to direct an office of the service to a new indeed other parties, if appropriate to advise and assist regarding establishing, improving and maintaining contact so effectively, a family assistance in that regard. So sometimes, if Kafka's Onda or social workers, I've to facilitate on that Hospices of Northern and they could assist in the process off handover, for example, on assisting the parties with a view to labor in that contact to be maintained. In addition to that, it's also worthy of note that we have Section 16 a off the Children Act, where the court can actually also ordered a risk assessment to be undertaken by the Kafka's off sort of social worker. Where, if there is a Family sisters order, they then carry out a risk assessment which didn't file a court to confirm to the court. The position has been done to your species off the order, so that could be really helpful as well. In these cases. On these family assistance, orders could be made not just in private Children or cases, but also in a proper cases, public law orders and they are very much akin to supervision orders in many regards. So worth noting that also now, like I say sometimes and in very limited situations, it may be that one considers cometo, which is certainly a possibility. But as you can imagine, it won't be employed. In many cases. Will a person be sentenced to prison for breach off a contact order? Charred arrangements. Well, Theo, answer to that is inappropriate cases. Yes, they can. On this is where you've got cases such as being s, for example, the 2009, a quarter of a Court of Appeal decision that I've put in your notes for you were here. The court did decide to impose, uh, the prison sentence upon the mother in these circumstances. But given the repeated clear, I'm deliberate breaches of the contact provisions. So sometimes, as you could imagine, things will be imposed. But as you can imagine, it's not going to be the first option in many cases, Andi, that's where then we have to start thinking about cases surrounding parental alienation in particular. I'm going to go through this and a bit more detail with you shortly. Okay? Right. Okay. So what do we mean By making the chart available for context? us that sometimes, Really, The question that is asked in these cases on this is where very useful case on that is the case off H b Okay on. But this was a quarter appeal decision. A few years back, 2015 leading judgment was handed down by Lady Justice Black Andi opportunity was taken to We emphasize the importance off chart arrangements on also parental responsibility. The Children involved here were 14 and 16 years of age on. Did it was a case where the father was seeking for the enforcement of contact. Now, one of the things that the president of the Family Division at that stage, Sir James Mumby emphasized, was that sometimes when you've got older Children and of course, they are very much going to be voting with their feet, as as he had in this case. But that doesn't mean that a parent would care should simply be saying that the Children do not wish to see the other parent. There should be trying harder in the proper cases, too, and sure that the contact takes place on it, particularly if you have a look at paragraph 76 of the judgment. His Lordship did say that in appropriate cases, the parent should be, whether it's by argument by persuasion, for example, by sanctions, inducements, confiscation of iPads and iPhones or the Elektronik equipment falling short off Blue Force or combination of all these factors should they should do their level best to ensure compliance. So it's a very useful case which emphasizes the expectation upon a parent and in those types of situations on the other case wants to pick up on its this case of C H and C T. A very important case. Just a couple of years ago on, that is, we've looked at what a warning Nazis, which will be attached to child arrangements orders, which then enables one, then to complete form C 79 bring the matter back for the various provisions under Section 11 of the Children Act that I mentioned. But what if somebody does seek committal? What would they need to do? Well, there would need to be a peanut notice attached to the order, which then informs the person concerned that this is an order of the court butcher, which will entitle the court, then to God, a new finding. That person Andi also under or perhaps even, uh, but potentially subjects Objection that person to a prison sentence. Of course, that option is available, but they do need to be told off that need to be warned off the consequences of breach and hear. What happened is that the application was made by the grand parents for committal. Uh, but they did not do this by over application notice on the part 18. They didn't do a sworn affidavit in support Onda. A nap location was being sought for the mother to be committed to prison. And she was really unaware of this fact that this was the application that was being made on the first instance. Court seemed to mistakenly assumed that the morning notice that was attached on the face of the order uh, was sufficient to give the court of power to make a committal order. But in fact, that wasn't the case. They had to be a penal notes attached on the morning notice had been mixed up with the penal notice. If you're going for committal, I would suggest it's very important for you to comply with Part 37 of the fpr, so make sure you do an application using the Part 18 procedure, so it used to be a notes of application. We set out in number format, a new tabulate or the events which have led to the failure to comply with the terms of the order's effective you're listening to preaches on. Then you need to expand on that in your affidavit in support. The application ordinarily would need to be personally served upon the respondent need to be given sufficient time to then be able to take legal advice on the hearing will ordinarily be hurting public unless the court decides otherwise. Like I say, personal services required. Unless the course otherwise on to seek the committal order one half would have to satisfy the court beyond reasonable doubt that the person has failed to comply with the terms of the orders. He can see how all this fits in. Therefore, it's very important to ensure that there is appropriate provision made for that going forward. Jake right? That brings me on to some of the other elements surrounding enforcement. Now. Many of you will know, of course, that because of the impact of the coronavirus crisis from earlier this year, a zero in England and Wales, particularly from around middle of March 2020. There was a lot of uncertainty amongst the respective clients as to what the position was with contact. So, for example, if he had the benefit of a child arrangements order specifying living with or spending time with were, say, the Children lived predominantly with their mother on. We're having two or three times a week face to face contact with their father then, because of the stay home rules, which were first made available back in March this year, both in England, worlds on the only four situations where one could leave their home during the initial locked down. There was then a lot of uncertainty amongst parents have indeed lawyers under the professionals as to whether one could then honor the contact proposals. And the provision on this is where very timely. Uh, the president of Family Division, Sir Andrew McFarlane, was able to hand down some very useful and necessary guidance in this known as the Coronavirus Crisis Gardens and compliance with family court chart arrangements orders on. But this was put together by the president of Family Division and on the head of family justice as of 24th of March 2020. I wanted the key elements from this is the president did, of course, take the opportunity to remind us that the parents off course in the exercise, their parental responsibility, need to be exercising that parental responsibility so they need to be acting appropriately with each other, which would mean that they need to ensure that the relationship between the child and the parents is maintained on if it was unsafe for, say, the child to move from one household to the other, safe from the mothers to their fathers. Then, of course, that they need to then between the two of them, agree that that is the case, and it will make joint decisions on if that means then temporarily fearing the order so as to then not required a child to then go to the father's home, for example. Then there should be an expectation to put in place alternative, indirect contact, whether it's to face time, for example, whether it's through email through text, through what's up and so forth. But of course, his Lordship emphasized that sometimes there may be cases where there isn't that level of agreement sold. The mother takes the view that has son or daughter shouldn't be going to the father's home because of the potential risks of co vid on. The Father takes a different view on that. Then his lordship did say that it is possible for the pair would care than to unilaterally vary the terms of the order temporarily. But this is the keep it. They must have a be in a position to be able to justify to the court if they are challenged at a later date as to why they took the steps that it under circumstances on indeed or safety, our challenge body of the parents sort of need to be able to justify their actions on why they did what they did on also to be upset if I'd a quarter, if they did unilaterally vary the terms of the order in those circumstances because of corporate how they then put into place alternative provisions to ensure that the relationship between the child on a non resident pair was maintained, for example, did they set up in direct contact and enable that to be facilitated? Okay, so you can see some of the key things that this guidance has set out. And since March and now we are in November 2020 you can see that they have been cases which have made their way back to the court. Would A court has had to consider the steps that have been taken by the parents in these circumstances and whether they have been appropriate steps that bean taken or otherwise. So I get very important to bear that in mind now. One of the other cases I wanted to bring to your attention is this case of Reem on in private All cases. If, say, you're acting for, say, the father and he seeks contact on a mother is, say, raising allegations off domestic abuse, then you've got the effects of, for example, paragraph 25 of practice Direction 12 J, which relates the fact that when they were undetermined, allegations of domestic abuse sort of court is otherwise list in the matter for determination. Then, unless the court feels that in the interim the contact which takes place will be adequately managed, then they should not be facilitating interim contact in the meantime, unless they are satisfied that the power would care and the child would not be subject to any unmanageable risk of harm. So it could be very difficult for the father in that kind of situation, too. Invite a court to enable face to face contact pending any finding of fact hearing being determined on one of the issues there is good. Even if it was to identify, say, contact center, there may be cost implications there on. Even if he cannot, could there be any provision provided by the local authority or cath cast on? This is where this case of reem comes into place, where the late leading judgments handed down by Lady Justice Black on Her Ladyship in particular stage that section 16, which the Family Assistance Order yes, empowers, uh, the courts to make orders to enable the facilitation. So assisting in the hand office, for example, encouraging, assisting, facilitating that way. But it doesn't empower the court to require contact super visions by local authorities or calf cast Andi. It doesn't go as far a supervising, even though it talks about befriending assisting in that regard. Andi, also the provision under section $11 mention of the Children do not go to that level, either. So in private law, the simple answer This would be that local authority or calf CASS cannot be ordered to supervise contact in a private look Children law case in those circumstances. Okay, so it's important to bear that in mind. That then brings me on to some of the other aspect so adding charred arrangements. And this is where the case of Q and Q number three is very important. This is just one of a number of cases that have been decided over last few years. Well, by the then president of family divisions of James Mumby, uh, tried his level best to ensure that some contact could be maintained between the child and the father. This was a child with the father of the child, had sexually abused a 12 year old nephew. And even though it's served time in prison, he showed very little remorse. But what he had done on the mother of the eight year old child, the son, I felt that the father should not be having any further contact with his son on this was the case where the judge felt on the circumstances that any further contact would in fact, be detrimental to the chance welfare on there for the contact was stopped altogether. So you can see this is somewhat of an exceptional step to take. But sometimes it may well need to be taken, given the particular circumstances on. With that in mind, this is where the concept of parental alienation is particularly relevant. So, as I mentioned earlier, you're getting more more cases now. There has been over the last few years cases involving Parental Nation, where there is that level of implacable hostility demonstration in the case where by the resident parent, a parent care is alienating the chart from the non resident parent. Now this is where the case of re hate his particularly helpful. This is a relatively recent case handed down by Mr Justice. Kian, sitting in the High Court of Justice family division in October 2019 on a case itself, involved a 12 year old. We're by the father of the 12 year old sort for switching off residents in his favors of switching off living with aunt. He did say that if the court did go with this ordered I sought bone reminder Matter had been in court for a number of reasons on this was a subsequent set of proceedings, and there's been a lengthy set of litigation between the parents. The father did say that if the chart was to be allowed to live with him under the auspices of a living good order, he would make sure that he would honor the face to face contact with Mother when it was safe to do so. On the fact the court got expert evidence on this case from a from a court directed expert who was able to give some very useful information about the impact of parental alienation upon Children. Not only does it affect them in terms of emotional harm, but also in terms of a more longer term harm in terms of them cutting them off from the paternal side of the family, in this case and also the father, also on also later on in life, it's going affect them in building relationships and potentially can even leave lead to long term depression so you can see very important to address the ship parental alienation. Early on, the court had the benefit of an independent social worker who was able to provide a transition plan here in terms of transitioning the movement of the charge from mother to father. The mother was living in one city, father in another child was going to one school, had been living with mother since birth. On on the facts, the court felt that the child's best interests would be best served by living with the father. And there was a transition plan to enable that to happen, with a view to then some months day after allowing the mother to have face to face contact once it was appropriate to do source. It's a very good case on one hand on the fax. Worked successfully, so have a have a look at that when you get a chance right now in private, low case in particular. We will, of course, come across more mawr situations where we have litigants in person, in public Children or cases by virtue of the availability of legal aid. Uh, in the case of it being non means and merits tested certainly for parents and persons with parental responsibility, we won't have as many litigants in person, in public Children or cases, but in private laws, you know, because of the requirements of lesbo legal aid, sentencing and Punishment Offenders Act of 2012 and a meat to demonstrate not just a means but also the merits in terms of domestic funds or a child protection. It may not be possible then to acquire public funding, in which case you may have litigants in person who therefore running the case themselves on. With that in mind, you've got this very useful guidance that became available back in June 2015. This was guidance, which was made available by the Law Society and also by the bar cancer, and also selects on thistles guidance that was put together, a za part of recommendation from the report of the Financial Remedies Working Group of July 2014, when they were looking at recommending some changes to financial remedies on one of the aspects off. This guidance is in so far as lawyers duty to the court whereby lawyer needs to ensure that when they are negotiating and discussing the matter with the litigants in person and when they are drafting the orders when they are in court, to need to be able to certainly spell out some of the terms that I referred to. So, for example, when you do have a litigant in person, do you sort of phraseology file and serve may not be appropriate. And instead one has to spell it out on the order to make sure that litigant in person understands that finding and serving would mean that they would need to send the papers to the court at this address and then send copies off development paperwork to the other parties. So very important, therefore, to bear that guidance in mind. Let's now look at the positions surrounding domestic abuse, and it's into relationship with child arrangements on This is where, as I mentioned earlier, we've got this very important practice direction, which was updated once again by the then president Family division back on a second off October 2017. So this is practice direction 12 j chart arrangements and contact order, domestic abuse on harm and this updated a previous practice direction 12 J that we had on. Insofar as this is concerned, it's got a number of key elements to it on just really by way of summary somebody aspects I wanted to pick up on, insofar as this is concerned, is firstly in relation to some of the key amendments. Eso, for example, His Lordship, Sir James Mumby, specifically took the opportunity to inform us that we should be using the term domestic abuse and not domestic violence in these cases to make sure it's as broad. And why does it should be on? Also, we need to bear in mind that there are different forms off domestic abuse, not just what has been referred to previously and in the government definition. Of course, as we know, it covers a number of issues such as physical abuse, sexual abuse, emotional psychological, financial abuse. We know it covers controlling coercive behavior, Uh, in that regards that covers a number of issues, but also his Lordship said, it also covers culturally appropriate forms of abuse and therefore including, but not limited to, for example, force marriage on a base, violence, marriage, abandonment and also what's called diary relation. Abuse, marriage abandonment would be transnational marriage. Abandonment would be where if so, you've got a spouse from England, Wales who may go to overseas get married overseas, and they deliberately they're deliberately abandoned their spouse in the country overseas without allowing them to exercise or acquire any rights it to property or like to remain, for example, so that is also seen as a form off domestic abuse in itself. Now there's also the position surrounding the presumption of parental involvement, so that the president did say that if they are allegations that are being raised as to domestic abuse, then that in itself doesn't rebut the presumption off parental involvement. But of course, given the nature of the allegations that the court has to keep a careful I am whether or not that presumption should in fact be rebutted or not, so that is what needs to be looked up. The third element is about mandatory duties upon the court. As far as this is concerned, what we're looking at is the situation where say you've got an order that's made by the court and with his allegations of domestic abuse that be raised. But if they are safe, findings made all the concessions made and it's very, very important for those to be carefully documented them, and therefore to run with the orders so that the parties concerned no, the basis upon which decisions are being made thereafter. Then there's this position surrounding assisting the victim. Now. This is where traditionally, we will have referred to this as special measures. But of course, a few years ago, we've we had what was brought in through the family procedures Part three and practice direction three. A relation to participation directions to make sure that both witnesses and also parties are able to fully participate in proceedings, whether it's giving evidence or in terms of communication or being involved in the proceedings. So, in case of domestic abuse, for example, and showing that if a victim does require se special measures such as maybe giving evidence behind a screen, maybe being allowed to enter and leave the court building through a different route, for example, giving evidence or being participating through a video link, for example, in all of those matters need to be dealt with accordingly. So very important to ensure that that is done on. Then it's a position surrounding interim orders, which I mentioned earlier services paragraph 25 off P. D. 12 j so that when the matter does go off to any finding of factoring, for example, the court should not be, uh in a position to require any interim arrangements for contact unless they feel that it would not subject a child on the pair would care to unmanageable risk of harm. But in terms off, looking at contact interim contact, I would suggest you also look at paragraphs 26 27 off the practice direction on that on. Then you've got risk assessments. You got paragraph 38 of P D 12 j, which relates to the fact that if a risk assessment has determined that parent does pose a risk the child or to the other parent, then contact via supported contact Central, supported by parent or relative, would not be considered appropriate. So again, very important looking at provisions as well. So these are some of the provisions which therefore apply when you're looking at the inter relationship between child arrangements on domestic abuse, right, Okay, Now linked with that, Then we've also got the position swanning cross examination off the alleged victim body alleged abusers. So this is where we've had a number of cases of the last few years which have looked at the situation surrounding cross examination. Re A was one of the cases early in 2017 and then the later case a year afterwards. PS on BP if perhaps look at the P s case with you. And this is one whereby it was a case where, by the father of a young child who was age three, saw contact with the child concerned and a mother opposed on the basis that she made various allegations off domestic abuse which he alleged the father had subjected it to on This is where the mother claimed that they were numerous incidents of domestic abuse which the father has subjected her to The court required her to limit those to the two most significant allegations. And she relied on those two, which were firstly, that she alleged that the father of the child had raped her on second issue, alleged that he had attempted to strangle house, obviously two very serious allegations that were being raised. Now this was a case where the father sought contact. So he put in applications for child arrangement spending time with otherwise, I'm in contact the mother opposed on. But this is where the court was then faced with Liston matter for finding off fact hearing. Mother was fully legally represented, But the father was a litigant in person. The father happened to be a serving police officer, so he was quite used to interview suspects. And in that regard, he wanted to do his own cross examination. He had his questions ready that he wished to put to mother. But the court took the view that, bearing in mind the previous case of Ri a Andi the concerns that were raised about the fact that effectively, when one allows the alleged perpetrator to cross examining Court Three alleged victim that in itself could also be seen as a form of domestic abuse, particularly if they are being allowed to cross examine indoors. Exact reasons why I think the matter has been listed. So that's where the trial judge decided to take. Take his own decision and say to the father in PS that I'm not going to let you cross examine mother yourself. You're a litigant in person here. I'm gonna lawyer. If you give me your questions, I look at those. I'll rephrase that when I'm going to be putting those questions to the mother myself, and that's what the judge did. But the manner? The way in which the judge put those questions to the mother. The father later objected. The father suggests that those questions were put in a way which were not as robust as they should have bean on. Therefore, it affected his right to a fair trial. In that regard, the father was therefore arguing that he's right and Article six was compromised, which led to the appeal on this is where Mr Justice Hayden looked at this situation and of course, said that this is the unsatisfactory situation that we currently find ourselves in Children proceedings because sadly, unlike the position we have in criminal proceedings, where you've got the provision for an advocate to be appointed by a section 36 38 here, we don't in family cases. So if somebody is not eligible for public funding, we wouldn't have the opportunity of having an advocate appointed. To put those questions to the alleged victim was in criminal proceedings you would on in the meantime, until the law changes on that Mr Justice Hayden did say that there's no presumption against allowing in this case, he alleged, perpetrated across examined the alleged victim can be done in a proper cases. But if the judge felt it was not appropriate use on the facts. Given the nature of the allegations and what it was, and the particular circumstances that we should judge takes that responsibility themselves, then it must make sure that they do so robustly and they should do so properly. This is one of things Mr Justice, Hayden said, should be dealt with by way off a grand rules hearing that should be listed before the main hearing to then determine how the evidence is going to be tested. Okay, so some very, very important point is coming out of this case are linked with that. We've also got the draft domestic abuse bill now. This was originally introduced, uh into has a parliament back in January 2019. Uh, but as a result of the political challenges in 2019, we, of course, had the ongoing issues surrounding Brexit. We had the Prague aeration of parliament, which was late and declared unlawful on. Then we had the general election that led to this particular bill not going through various stages. So it was reintroduced in March this year. In fact, in March 2020 on day, one of the things that this bill seeks to remedy is the fact that we currently do not allow in family cases. For an advocate to be appointed in, for example, is finding a fact here is to put those questions to the alleged victim. So it wants to address that those issues that were raised in PS on BP on board with that in mind, with a view to enabling the Lord Chancellor's department to enable funding to be made available to enable an advocate to be appointed in these circumstances, it also seeks to limit quite significantly the circumstances whereby the alleged perpetrator will be able to cross examine the victim in these circumstances. So make sure you're familiar with the bill. Make sure you're following it through. It's gone through various stages and the Commons it's As of now it's going through the Lords with future than this, getting royal assent in due course on then, obviously being implemented thereafter. So have a look at that in more detail when you get a chance. Now, when you're running private Children or cases, uh, but make sure you're familiar with the Mayan requirements, so you've got the Capital Child Arrangements program practice Direction 12 B on also got you got the position surrounding my arms, which came into effect a surly as the family procedure was when they came into effect in April 2011. But my arms were then certainly refined funding the Children and Families Act of 2014. So in relevant family applications which in this context includes the private Children law cases, unless one is exempt unless they come within one or more of the various exemptions, there's a requirement for the intended applicant to attend the Myanmar Mediation Information Assessment Meeting. The proposed respondent will be invited to attend also to look at on information being given to them about alternative methods of resolution other than the court on also to look the possibility off. But certainly alternative methods, whether it's mediation or otherwise, are very important to bear this in mind on Do look at the situations where this may well be necessary, it relation to remove her from the jurisdiction. Make sure you're familiar with Section 13 1 off the Children Act, whereby when there is a child arrangements or especially fine living with nobody can cause a child to be known by a new surname, Naughty consent or cause to allow the child to be taken out of jurisdiction without the consent of everybody else with PR or leave of the court. But, of course, 13 to is the exception to that sort of person who's favored of living with Audrey's. They could do so for a period off. Less than a month of that provision is, of course, provided for their make sure you're familiar with the fact that the references to residents and contact orders now substituted with the words child arrangements orders does also, of course, the position surrounding remove it from the jurisdiction in so far as a child reduction act is concern of 1984 Section One of the act does make it a criminal offense for a person to cause. You allow a child under 16 to be taken at the UK without the consent of all other persons with PR. So that's why so you got a husband and wife who and I divorced. There's no child arrangements, orders in place. The Children live with mother. She seeks to take the Children at the jurisdictional beat so temporarily she does require the consent of the father with behind or circumstances given his the former husband on. He does retain his parents responsibility unless she was able to, of course, give his consent or get the benefit of a living with order on Live. Staying with that this number of consultations which are currently going through as well, which are worth noting as I mentioned in session one earlier this year. In March this year, there was the consultation, the second report made available by Mr Justice Garb on behalf of the private Law Working Party relating to the need for change the time for change. The case for change in so far as private law case, he's are concerned private Children or cases are concerned. There are proposed changes to the practice direction 12. B on potentially to practice direction 12 j in relation to child arrangements with a view to ensuring that those private Children okay so dealt with mawr appropriately, really making sure in less time and therefore reducing delays so far as that's concerned on also ensuring that Moyes done before the first hearing and also when it comes to enforcement. The idea is to bring in essentially a attract system like we would have in financial remedy cases and in the CPR, the so called fast track procedure, for example, the accelerated scheme, so as to ensure that there is that level of judicial continuity on matters can be dealt with more swiftly. Onder a properly. So have a look at those consultations going forward. This is where we're looking at the position surrounding judges meeting Children. Now, this is where you'll be familiar that we've got this guidance which goes back over 10 years now. We had the gardens which came in back in April 2010 about judges meeting Children on This could be both in private on public law cases. So it may be a case where, say, in a private law case, uh, such as in any which we're looking a bit there is an application for removal from the jurisdiction on a judge decides to meet with the Children. Now the guidance the guidance of April 2010 does make it very clear that the judge should not see the Children alone. There should always be somebody else in the courtroom. So often there maybe the guardian, the Children solicitor. The hearing must be recorded. There should be very clear agenda in terms of what the judge is going to be discussing with the child on. Also, the purpose of this meeting is not to gather evidence because us, through all of Kafka's, undo the social workers. The purpose of this meeting is to enable a child to understand the process the court processes to enable them to be reassured and satisfied that the judge at least, has taken on board what the Children's views are not necessarily to go with what the child wants, but at least so like the child feels reassured that day voice has been heard on. This is where they are cases like KP, which is one whereby it was felt that although a number of questions were put to the child in those circumstances in a very short period of time has felt that the way in which theme the case was the handled by the judge, there was needed to be a distinction between gathering evidence on one hand on the communication. Otherwise, this was way on the fax. It was felt that the way in which the questions were developed and ask it was more about gathering evidence. But in the later case, of DNA. This is one where the father was seeking permission to remove the Children from the jurisdiction on In this particular case, it was one whereby the judge did decide to the two Children Thio get an insight and understanding us thio their views there on also to ensure that the Children understood what this meant if they were to leave the jurisdiction permanently to go with the father. And even though the father later challenged the judge in so far as the way in which the meeting with the Children was conducted on balance, the quarter people felt that, uh, wasn't the type of probing that father was suggesting. Therefore, the way in a manner which they judged out with this was in fact appropriate. Now, as you can imagine, meeting Children isn't just limited to private Children in cases, you may well have this in public law cases on some of the cases I've had is where, for example, there's this case is for save education, for example of had it in cases where there's a discharge application, discharge of care of educational placement toward a, for example, those types of situations. But Waits felt that it would certainly help the judge a child to understand the process, and the man in which the case has been dealt with and handled right for the last part of today than what I want to do is spend some time going through with you somebody elements surrounding representation of Children. And also we'll look at some of the duties in so far as local authority duties. So as you can imagine, when we're looking at representation of Children, we've got private on public law cases. So in private law cases, we've got Rule 16.4. What used to be called room 9.5 of the family proceedings was of 91 on April 16. 160.4 is where the court, in a proper cases in the private case, can actually join the child as a party to the proceedings. So you got part 16 of the fpr, which covers the rules relating to Children. On it, particularly got 16 point forward. A child could actually joined us a party in those private law cases on which in turn would then ordinarily enable, if appropriate, for that child in to have a benefit off appointment through a guardian on all sold in the legal representative, a solicitor or charted legal executive or otherwise. If you look at paragraph 7.2 of 16.4 gives the situations in which the May will be a need, then for at the child to be joined. And there are a number of situations in paragraph 7.2, for example, where there's an intact, intractable dispute over child arrangements were contact has seized all together, where there's a rather irrational on implacable hostility towards contact. So it could be those kind of parental alienation type of cases, for example, where contact us seized altogether. It could be where you've got an older child who is opposing a cause of action. It could be with this complex medical or mental health issues to be determined on does need for separate representation. Sometimes it's where there's, uh, international international aspect and where there's an application for removal and you've got maybe an older child who wants to express his or her views on. Important thing is, if there is therefore 16.4 appointment, they like to say that Charlie's joined as a party, and then this is where they would have to benefit them off, having a voice through the Guardian and also, in many cases also through a legal representative. Also, we've also got to then consider the position off representation of Children. Public law proceedings suspect Children Public charge child kept ceilings e. When we're dealing with care proceedings, supervision orders on in particular thesis where make sure you're familiar with, for example, ruled 16 point to one of the fpr where, if it appears to the guardian that the child is instructing a solicitor directly or intends to conduct proceedings on the own, uh, then the Guardian must inform the court of that fact. Okay, so is that provision. Guardians, as you know, will be appointed under section 41 of the Children act, uh, to be the voice of a child unless the court fields, it's not necessary to do so. But this is where we then have to understand the situation where there may be a need for separate representation. So typically, what we would have is in a care case, For example, you would have a child who is, of course, a party to the proceedings in public law proceedings. They would then have a guardian appointed who would be a voice for the child and that guardian with them. Be giving instructions to the child solicitor or child. Illegal executive All council on behalf the child. So hence when you are the solicitor appointed for the child, you are therefore the child solicitor. So you therefore represented a child. But you're taking those instructions from the Guardian. But sometimes it may be that there is such a level of conflict between the theme, the Guardian and the child, that there is a need for separate representation. And this is where Route 16.29 comes into play in. So far as that's concerned, sort of maybe a need for separate representation. If you look at Rule 16.29 in particular, you've got the provision under Rule 16.29 sub paragraph two, for example, which which makes provision for this and you can see here on this slide. It in particular, provides for the fact that under rule 16.29 subsection two, if a solicitor considers having had taken into account matters in Paragraph three, which I look at in a bit that the child wishes to give instructions which conflict with those of the guardian on secondly, that child is able having regard to the child's understanding to give such instructions on the child's on. Behalf of this lister must conduct a proceedings in the corners with instructions received from this list from the child, so you can see for the purposes off separate representation. Rule 16.29 sub Paragraph two provides that having had regard to matters in sub Paragraph three, which are these which are firstly, the views of the Guardian on also any direction given by the court concerned Apart to be taken by the Guardian. Haven't got to consider those views of the guardian if this lister is off the view that the child's wishes, uh, to give instructions conflict with those of the guardian. So if there is that level of conflict between them and it's not just where Children may disagree on the one thing or the other, it's it's in practice. You find it's going to be quite significant conflict between them. So if that's firstly met and secondly, having regard to the Charles level of understanding level of maturity. So this is where the Gillick competence requirements coming to play again. If the solicitor is satisfied that the child is able to give instructions on if they are able to understand implications off their instructions on what they seek on, they conduce on their own. Then the solicitor that is expected conducted proceedings in accordance with those instructions received. And that's where you got separate representation on. Ordinarily, what tends to happen is this. Lister will then branch off on the Guardian on take instructions directly from the child, so hence they will be their child's solicit. They were retained as a child solicitor, of course, but they were take instructions directly for the child. The Guardian does have a remain involved in. The proceedings on the Garden was Still, Farley reported, was still put forward what they believe is in the child's best interest, even though they won't be taken. Instructions seemed charge in the same way, because that would be done now directly by the solicitor. Sometimes guardians may have to benefit off having funding provided to them through Kafka's legal to enable them to then have they abused, put a record. But it does depend very much in practice upon a level of experience and expertise of the Guardian as to whether they would have that facility or not. So this is where we look at the issue off separate representation. Now. It's also important to note that when you look at 16.29 sub paragraph four, this provides that were no guardian has been appointed or the condition in Section 41 is satisfied. So we have got a guardian solicitor appointed must represent the child in accordance with instructions received from the child in those circumstances are the way you've got that separate, uh, instructions being given on one of the other questions, of course, is a solicitor must ensure that they represent a child in their best interests on Sometimes the question that's asked is, What's the position with paperwork? What can I share with the child if I'm separately instructed? And this is where sub paragraph six is particularly helpful, which provides that, uh, the blister should accept service of documents on behalf. The child on where the child has not been served separately on does have sufficient understanding, advised a child of the contents of any documents so served so again have have a look at that because that's really helpful to to note. Or so now. How frequent is it the case that one would then have to be looking at separate representation? But this is where if we go back to annul the case one case that was decided some years ago now, actually, it's really a case. 10 years old now re a 2010. This'll was a case involving a 12 year old on, but it was one involving a quarter of peel. Andi theme views of the child did conflict with that off the Guardian, and there was there was agreement, disagreement between the Guardian what the garden was suggesting on behalf. A child what child sought on the court did say that the test of separate representation was whether the child's wishes, when conflict with those of the guardian on whether the child was able to light of day understanding, give instructions to Sister. So he concedes, famous in line with what we've now gotten. The Route 16.29 sub paragraph for as I mentioned on that, the court here did say that although the child was bright and articulate, the child wasn't mature enough to be able to weigh up all the complex considerations that had to be taken to account in that regard sold the application. Four separate representation was refused. And one of the things that law just to store present at the Court of Appeal was that lower courts should be slow toe order, separate representation one given the additional cost it entails. But also there will be cases where you've got polls pube it'll unless a rebellious Children who, um for whom? There. Maybe that conflict. But that doesn't necessarily mean that if there's a conflict, you should be then looking at separate representation. In every case, each case very much has to be looked at on its own facts. Of course, the later case of Re Hagia of 1993 does emphasize the fact that the level of understanding that enables a charted, making informed decision does really depend upon, uh, the individual circumstances of that child, for example, there under a disability or otherwise on. There was also the case of re W. The later case of 2016 we're here. The court again took the opportunity to remind us about issues surrounding separate representation, where one has to be satisfied that there is that conflict on, then. Secondly, whether or not bearing in mind the child's level of understanding of maturity, whether it's appropriate and possible for that child to give separate instructions UH, from from that of the Guardian so again worth looking at these cases when you get the opportunity on the reason Case Eyes is also another useful case of 2018, which was handed down by he's on a judge. Bellamy Onda again, where there was a conflict between the child and a guard in relation to welfare had come in this case, and also in the position surrounding sharing and disclosure of documentation. If you got separate representation, so have a look at that case or so now. Some years ago, we had difficulties, uh, faced, particularly when there was a shortage of guardians across England, Wales, which meant that sometimes Children's listers were pointed but without a guardian being available on, That's where sometimes we would have directions being sought for Kafka's to make a garden available by the time of the next hearing. For example, on this is where this case of our and others 2011 case does make it very clear that there is the criminal justice and caught so selective 2000, which imposes a duty on cath cast to appoint a guardian insofar as is reasonably practicable, but not to ensure that there is a guardian made available for particular child in any particular case. So it's a It's a kind of national duty to provide a guardian and appropriate cases, and the court appeal confirmed that position right. They want to spend some time just reminding you about the positions surrounding the survey. So as you can imagine when some of you may then decide to apply for membership on, then if you are then, uh, credited and you're taking instructions from the Guardian on Behalf a child, and that's one thing. But secondly, of course, you have situations where you may then have separate representation on day for you. Take instructions directly from the child. Now, if that's the case, then bear in mind, of course, whether it's the separate representation or whether it's the guardian, bear in mind that the code of conduct is very much there, just like you would have with an adult. You would have the same level of confidentiality when it comes to take instructions from Children's are very, very important to bear that in mind. Andi. Yes, there are limited situations. We can, uh, certainly breach confidentiality if it's in the public interest to do so in order to protect Children at risk of serious harm. Uh, in those circumstances. But other than that, very important to ensure that you are certainly comply with the duty of disclosure less like, say, come within any of the very limited exceptions one key one like, say, being if there was a serious physical harm to a child or some other person on sometimes it may be necessary to bring the S L. A. On Have a discussion with the ethics committee. If you're not sure on you see some guidance on this. Okay. And with that in mind, ah, this is where by we've got, of course, the changes that came in the last year in November 2019 to the code of conduct. You've now got a separate called for individuals and you've got a separate code for firms. A za result of the changes to the code from November 2019. So very important to keep yourself updated with those changes Andi in relation to their so called off conduct. So, like side of duty of confidentiality very much remains in that regard. Uh, andi also, insofar as conflict of interest is concerned confidentiality on disclosure. So, for example, in relation to conflict of interest where you may, for example, have a case where you are instructed by, say, the mother and father where both of the mind of polar perpetrators in a care case, then of course, you gotta bear with minor conflict to issue. This is where paragraph 6.16 point two of the cold is particularly important, where you must not act if there is a own interest, conflict or significant risk off such conflict in that regard. So there are, of course, the limited exceptions where you can act for two or more parties. Uh, but in many cases in these matters, you you will not on. There's also the issues who had in confidentiality. Czar, paragraph 6.36 point five. You need to keep the affairs of current and former clients confidential. Less disclosure is required or permitted by law in those circumstances. So you've got somebody limited exceptions there. Andi certainly in relation to Children. For example, if a child was to make an allegation, for example and one that has not been reported before, you may feel that in those cases there may be need to look at your duty. So any confidentiality, particularly if you believe as the S o a cold, provides that you have reason to believe that serious physical or mental injury because to your client to another. If the information is disclosed in those circumstances, for example Okay, so have a have a look at that. Just to satisfy yourself has to what the position is. So handing disclosure. Okay, so there's somebody aspects, uh, eso adding those aspects that we need to be familiar with. Right? Okay, So what we're gonna be doing in the next session is I'm going to be going through with you more so at the position surrounding the format off running public law cases. So in the next session, and I'll be taking you through in more detail some of the situations surrounding thes different types of orders so we could be looking at emergency protection orders in more detail. Onda also the use of child assessment and care and supervision orders. I'll be taking you through some of those in the next session on in particular in the next session. When we begin, I'll be taking through the use off. Section 47 Section 37 7 of the Children Act will see how these 15 on in particular, I'll see how the Eastern time, with the positions surrounding local authorities, support for families, Section 17 in particular and also duties in relation to accommodation. So we'll have to look at that on some of the changes that are common as a result of the Children leaving care provision, particularly on also general support. Also in so far as that's concerned. And this is where we've had some changes in England in particular, as a result of the Children on social work, Act off 2017 will be taking you through some of those elements. Okay, right, So just to summarize today, Conceive covered a fair bit today looking enforcement, looking at domestic abuse and charred arrangements, looking at the issue of representation on like saying in the next session I'll be looking at some of the duties in more detail on then we'll be looking also at the position at surrounding emergency applications. Andi also injunctions also. Okay, so thank you very much indeed for listening. I hope this second session has been useful for you. Andi, as I mentioned in the last session, if you have a good look at this session again, give yourself a good up to date as to what we've discussed on go through in some detail. And then I'll discuss the next area with you in the subsequent section. Thank you very much indeed. And I'll speak to you next time. Thank you. Bye. For now.
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