Hello. Welcome, everybody. My name's softer, Mahmoud. And I'm very pleased to welcome you through data law today. The second session on injunctions for personal protection Law practice on procedure. As you know, then this session I'm taking you through somebody key elements surrounding this area of law where we're looking at remedies available, full personal protection, looking at both the Family Law Act of 1996 and also the protection from Harassment Act off 97 Last time you remember we spent some time looking at the Family Law Act. I looked at the two types of all these normal station occupation orders. We looked at the criteria. We looked at the categories of applicant and also some of the aspects need to bear in mind when you're drafting on, apply for these orders. So today, then as of September 2020 what I'm going to be doing is going through some elements, son without notice. Orders were looking at sexual 40 off the Family Law Act to see the use of that and I'll be taking you through drafting and also the procedure in terms of the process through which one applies for disorder right through to conclusion, so we'll have to look at him so without notice orders Ex party as we used to refer to these so this may well be necessary. You may need to seek one of these orders in an emergency in the city, or in a situation whereby it would be disproportionate to give notice to the respondent off your intended application on if so, then. This is where you would need to consider the use of Section 45 subsection one off the Family Law Act of 1996 which does allow without no disorders to be made, but only in one or more off the three situations, first and foremost, if one can show that these and risk any risk to the applicant to relevant child attributable to the respondent if you order not made immediately. So this could be a situation where, say, there's been recent violence or threats of violence on there is a possibility of further abuse on therefore, unless the order is sought almost immediately today, the same day that there is a risk off harm to the applicant relevant chart. If the order is not made immediately. Of course, unnoticed hearings can be listed on DSA, subject to court availability. Availability could be listed sometimes within the same week, but that may not be sufficiently appropriate in the circumstances. It may be that the order needs to be sorted there and then that same day. And that's why you may have to justify seeking the order honor without notice. The other could be where there hasn't necessarily bean recent violence or threats of violence or behavior, which amounts to their being a repetition, necessarily what's happened in the last few days. But instead you may be able to rely upon the second element, which is whether the applicant will be deterred or prevented from pursuing the order if he's not made immediately. So, for example, if your client was to say to you that on What is that? If we give notice to respond off my pending application for unnoticed hearing on what is that they're going to react? They're going to react violently because once to receive paperwork from the court that will cause them to turn on, uh, two try and use violence towards me or threat to me. So really, I need the benefit off the order to be made I saw that once. It's then served upon the respondent time immediately protected. So that's where you may find one relies upon the second limb and the third limits. Sometimes where the evidence is that one is evading service on the applicant or any child will be seriously prejudiced. Mind further delay in so far as that is concerned. So that may also be used as and another reason to seek the order without notice. Okay, very, very important that when you are seeking these orders to be made without notice that you do set out in the statement why you're seeking this to be made without notice. A very, very important to specify that under form fl For the one which is the application form that you would fill in, you would have to take the box at the bottom of the front form to indicate you're seeking the order without notice. On your stated support, you do have to set out why you're seeking this, and that's where reference should be made to one, um, or the factors under Section 45 subsection one of us just mentioned on section 45 subsection one does provide that without notice more orders may be made with a court considers it just too convenient to do so. Okay, so very, very important to specify that right now there's also additional orders under section 40 off the axle. Let's assume that there is an occupation order that's been granted lets US human occupation orders granted that, say to respond is to vacate the property. Andi, the applicant, is to continue to occupy their dwelling house to exclude not a respondent on the applicants days they with the Children. Now, if the applicant was, let's say, the homemaker on Say you. She was therefore entirely depend upon the respondent financially during their period of their relationship so that the applicant in that situation is in the house. But they've got no means to continue to pay the mortgage or the rent or the other bills. For example, then this is where 2 may in structure to also apply for an order under Section 40 of the Family Law Act. On this is where the core can make after making any occupation order on order under four section 40 imposing on either party on obligation to repair the property, maintain the property discharged or enter the mortgage or the other bills. But of course, they do have to take into account of financial ability on needs of both the applicant and respondent. In these circumstances, this could also work the other way. So if I was acting for the respondent on the respondent is concerned that the property may not be maintained once he's excluded from the house for the next say, six months or longer. Then he may seek an order under Section 40 that the applicant continues to maintain the property, for example, on to repair the property so it could work the other way as well. It's not just in order that's made on putting obligations upon the respondent. It could also be obligations subject to need and necessity. Obligations place also upon the applicant on these could be then inserted, therefore in occupation orders. So as I mentioned, it could be imposed on either party. The obligations to repair, maintain the property discharge, to rent other outgoings on make other periodical payments in respect of accommodation, for example, so to pay some of the utility bills, for example, upon the properties like may well be necessary in those kinds of situations also on because also be used to grant possession or use of furniture, other contents, for example. And it could also be used to order a party to take reasonable care, furniture, other contents or to keep the dwelling house on the content secure. So you can see this could be very much directed towards the person in possession. Also in that regard. So it does work both ways. Okay, right. Let's now start looking at the application itself. If so, if you are going to be pursuing one of these orders, okay, so if you're going to be going for, say, a occupation on door normal station order, we need to think about making the application some tips here. Firstly very important to weigh up the options on pros and cons of those. So, for example, if a client is saying to you that they've been the victim of the normal station and therefore do is the possibility of going for normal station order, talk to her about the options. Would have warning letters, advice, for example. Have the police been informed? What steps have the police been able to take? Are they able to take what are the other options available? Should it be an application through the protection of harassment? Read, for example, Why should it be the Family Law act? So talk through the options on. Also, of course, you need to bear in mind matters related to say. Does the client need to go into a refuge? For example, did I need to be in a place of safety? What about canceling? What about therapy? So some of those aspects may well be necessary on don't make decisions for the client. After all this, their decision isn't it. You give them the options they need to make that decision. So set out the pros and cons gives them the benefit the options for and against. But let them make the decision, of course, because I sure it relates to them. So some of you may think that based on the information based on, say, the cycle of maybe threats and violence under the behavior you make yourself. Take the view that nothing short of a non molestation orders suffice, but it's not like us. They are decision. It's very much a decision for the client. Once you've given them the options available there on, I would suggest very important to put together a plan which prioritizes the immediate needs. The medium short term needs gives them assurance. So if that means referring them to counseling, therapy, arranging for them to go into a refuge or a safe place or living away from the family home, then if that gives them that immediate protection as well as the benefit for the safety of the Children. Of course, that's what may be necessary on reasonable in the circumstances, of course. Weigh that up also on the fact Be realistic in terms of time scales. How likely is it that they will get a hearing as soon as what's required and sort in the circumstances? Will you be able to get a hearing as quickly as what they are, what they are seeking in the circumstances So that also has to be looked at on D. Wade up in the circumstances also, however, have a look at that. So be realistic with timescales in that regard right in terms of the actual application itself. So then we need to be looking at the paperwork, So if it's a without notice injunction that's been sought, i e. what we used to call X party. If you're seeking order under section 45 family worked, then very important to start preparing applications since possible. So your client may well be at your office. Or certainly you maybe take instructions remotely. Here we are in September 2020 where Covered 19, of course, has had a major impact across the world in so many ways. On, of course, in relation to carry out our duties to clients. It may be that many of you are perhaps still working from home, not going into the office. And therefore you may find that instructions have been taken remotely over the phone or through other but video platforms. So it may not be as easy as certainly interviewing clients in the same way as perhaps what we did before locked down. Some of you, of course, will be in the office, and therefore you may, with sufficient safeguarding, with screens with masks and so forth with gloves on dso fourth, you may find that you are still able to take instructions, but either way, there has to be a route in a means of doing that. Documentation that's required first and foremost the application form the form fl 41. That's the application form that you were feeling so many of you will have access to that very easy to complete its not difficult form, and it will go through some of it with you shortly. Then he also do a statement in support, so that would need to be completed. And I go through some of the things you need to be covering in that shortly as well. Is also preparing a draft order on all sort of position with funding. Now there is no coffee for normal station occupation orders any longer the coffee went in 2014. But of course what about the lawyers casts and therefore either your client may be eligible for public funding, in which case you would need to send to court confirmation of funding by confirming that the armed public funding and you're well exercised delegated functions. Or it might be that your client is paying you privately. But if they aren't public funding, then that confirmation needs to be put in a notes of issue of certificate. You'll also be filing a notes of acting if you're going to be gone on the court record acting for the client in those circumstances. So, like I say in terms of funding, we need to confirm the position there now. This is where many of you know that the position with funding has changed somewhat significantly over the last several years. In terms of family law, generally other than, for example, specify Children are proceedings. In many other cases involving finance family cases, there is a requirement to demonstrate domestic violence on your child abuse, depending on what application one is seeking funding for on day. One of the key changes a few years ago, some of you will remember was the introduction of the civil Legal Aid procedure. Amendment number two legs off 2017. Those provisions came into effect in January 2018 on this particular instrument statue instrument removed a time limit upon the evidence that can be accepted. Surprised to this, many of you will remember that in cases of domestic violence, the evidence requirements to satisfied regulation 33 of these civil legal aid amendment eggs was that one could go back in terms of domestic funds up to five years worth prior Tonight was two years in terms of child abuse. One could go back up to two years under Regulation 34 but this statue instrument change that sort of, in fact at the time limit has not been removed. So you can go back to before five years if necessary, to evidence domestic ones and nor child abuse. And also, this instrument increased the different types of evidence that could be obtained to demonstrate domestic abuse. Such as, for example, if you've got evidence. Ah, letter, for example, former housing officer to confirm that declined concern is the victim of abuse or maybe from the immigration officer, for example. So it increased the types of evidence that would be available now because of Corbyn 19. Askew could imagine things had to be huge changes in the way in which we carry out legal services. On insofar as a legal aid agencies concerned, you'll be aware that they have brought about changes to enable business to be conducted a za properly as possible. So I put the links here for you. If you wish to have a look at these at the Legal Aid Agency on, there is the coronavirus covered 19 legal agency contingency response. So for example in this area where you got injunctions that are being sought. Normal station occupation orders you may often if you're publicly funded, be exercising delegated functions. Therefore, granting effectively emergency funding on then submitted natural Legal Agency subsequently for the purposes off payment in, so far as the mostly certificates are concerned as a result of covered 19 legal agency have extended time limit of emergency certificates natter 12 weeks on. Also in relation to working with parents, there's a guidance last updated on the 29th of July in relation to that. So with the evidence requirements, for example, so you still need to get evidence of domestic violence or child abuse and many types of family cases. The legal agency haven't expanded the domestic violence requirements, so it's easier for victims of abuse and child abuse to access public funding. So certain changes came in, such as removing the need for evidence to be submitted on letter headed paper if required, for example, and also for evidence to be obtained on submitted by email. For example, on if you're, for example, seeking evidence from the police in the form of, say, domestic abuse of fence or ongoing investigations, then this is where an email from the police could suffice, as opposed to getting something more detailed, which we had to do previously. So you can see the purpose of this is to ensure that clients are not prejudiced because of the difficulties are being able to access documentation in the same way that we did previously before locked down. In addition to that, on the 15th of May of this year, there was also brought in at the position with the Civil Legal Aid Procedure Amendment REX of 2020. He's came in on the 15th of May so that when it comes to mediation, for example, uh, one can still apply for family mediation, where they would not need to attend the providers premises in person and also expanding the type of evidence of domestic violence that may be used in these circumstances. One of the other things we need to bear in mind when you're really doing when you're dealing with have certainly personal protection applications. Is that in relation to participation in proceedings and also giving evidence? You'll appreciate that in this field clients, by their very nature, by the nature of the application maybe somewhat vulnerable, but there may be intimidated. There may be frightened of attending court may be frightened of giving evidence against the alleged perpetrator in those circumstances. So that's where traditionally we've had the concept of special measures on hearings have been listed to think about what measures need to be put in place. A few years ago, we had part three and part practice direction three a that came into effect sort of across all areas of family proceedings. One has to give her our God to vulnerable persons on their relation to ensuring their participation in proceedings on also in giving evidence. So participation direction, as you can see here, means a general case management direction which is made for the purpose off assisting a person in giving evidence of parties paces, he concedes there to assist not only giving evidence but also in participating in the proceedings or so direction that party witness should have the assistance of one of mortar measures on the court must have regard to this must consider whether parties participation other than by giving evidence is likely be diminished by means of vulnerability, so you can see this is particularly relevant in cases of domestic abuse. So if you've got, say, the mother in a case who does seek to attend court to give evidence against her alleged perpetrator, then we need to think about participation directions that should give evidence behind a screen. Does she give evidence the video link, for example, is she entitled to enter the court building and leave the court building through a different route? For example, is she to have a separate conference room dedicated just for her so that she wouldn't need to then bump into the other party at court, for example, that all those kind of things need to be carefully considered and drawn up when you're thinking about participation in that regards are very, very important in this field. In that context, right? Let's now look at drafting in more detail. So the FL 41 as I mentioned, is the application form that will be filling in on on page one perform. You would be in setting out your client's name, address details of their lawyers in terms of their address on page one. If you wish for that to be withheld, that's fine. That could be done that could be withheld. But then you should complete a form called form C eight on That should then be far that court so that the court has the benefit of knowing your clients address. Should it be necessary to contact your client particularly, for example, they have ceased to instruct a lawyer, and therefore the court needs to contact them. It's a page one. The address could be without, But make sure you do that form C eight, as I mentioned earlier. Very, very important. Okay, so that's the form ch that would be done. Okay, also on page one indicate the but on the front page, whether you're seeking both orders, are you seeking number of station order and occupation order? Is it one or the other? And also, as I mentioned earlier, are you seeking the order without notice? So that's where you gotta look at section 45 of the act, as we mentioned earlier. And if so, you take the box at the bottom to indicate that that is the case. Then, as I mentioned earlier pages two and three of this form, you need to pick one of the 15 boxes to confirm on what basis the parties are associate with each other, So that's the application of Section 62 63 of the act that we mentioned earlier. So make sure you take one of the year the boxes there, then page three of the form thesis whereby set out the terms of a non molestation orders he seeks or set up briefly the terms of the order. Many lawyers will also then make reference to the fact that they are also sending in a draft order on this is where, as I mentioned shortly, there is an omnibus of orders that available whereby you can complete those draft orders and provided a court in advance. So set out the terms of the ordering and provided draft order as well. Page three also requires you to set at the address of dwelling House, to which the occupation or he relates to remember. You can only get these waters in relation to a dwelling house. The home that was occupied or intended to be occupied as the family home on Page four requires you to take one of the six boxes, and those other categories for purposes of are often occupation order, so box one relates to Section 33. Box to relates. Destruction 35. Box three relates to section 36 bucks. Four or five related section 37 bucks six relates to section 38. So make sure you take the right one, depending on which category of applicant you are. Okay, so it's that provisioned. There also. Okay, Then he got page five on page five of the form is whereby he would set out details at home. So where this register otherwise on Also, you remember earlier I spoke about sexual 40 or the Family Law Act. So if your client is seeking that ancillary ordered I mentioned earlier under section 40 then you need to set that out as well. Appropriately. Okay. Provide details as to whether the property is subject to a mortgage rented in that regard and also paid six in particular requires you to give details, only special arrangements. Do you need an interpreter participation directions as I mentioned. So this is where Part 38 that I mentioned earlier comes into play in particular. And if there's any other proceedings relating to the parties Okay, so that's the f l 401 The application in in support also needs to be done. Eso That's just a statement in support that he's be completed on in terms of how you go about drafting this. You do need to make sure that you bear in mind the statutory criteria so very, very important to bear that in mind when you're drafting this form. So when you're doing this, put it in a format where there's a chronological account on a chronological account of what has happened. So obviously their names addresses. Unless you're keeping your dress withheld again. As I mentioned earlier, set out the orders you applying for very, very important set out the background. So what? I'm married while they're living together on the civil partners. When did I start a relationship? Put that background there on a deal with each aspect of abuse, relying upon and make sure you put it in some kind of chronological order. Starting with the oldest incident, you don't have to go back too far. Of course. You know if they're bean living married for several years, you don't have to go back necessarily to what happened many years ago because you're seeking to invite the court to make the order on the basis that there is a need for this order. But if you were lying upon an incident which is so historic one in fact since didn't have moved on their life, why then is it relevant? So you do need to You do need to be proportionate in the allegations that you're referring. Thio. Make sure you then go through the criteria for the orders. So, for example, sometimes it's helpful to set out subheadings such as housing needs, resources, financial resources, health conduct, as we mentioned earlier under section 33 6. Why is your client likely to suffer significant harm if the order is always not likely to be made? So it's important to emphasize that judge we want to know has been a warning letter? If not, why not? What effect was that? Judge will want to know what the position of the police has it been in police involvement? What steps have they taken? Has the insufficient going to be further steps to police can take on a summarized why the order is being sought very, very important. Thio Thio therefore, set that out also. Okay, so that's a statement in support on also staying with that set out why the order is being sought without notice. As we said, if it is, you must set done out. And also, if you're seeking a power off arrest to be attached to the occupation order, what is the evidence of violence or threats of violence which is necessitating you? You then seeking a power off arrest to be attached to the occupation order. The power of arrest of a normal station order will be attached automatically anyway on the sexual 42 capital A of the Family Law Act. So it's just the occupation order that you need to make that the need for a power off arrest to be attached different appropriate now, as I mentioned earlier, this is where there is thes omnibus off normal station orders. A few years ago, these were put together by Mr Justice months must in the omnibus of normal station occupation orders. Back in 2014, these were put together prepared by the family Orders project. On a few years, they were after in 2017 2018 that was put together to practice garden standard Children and other orders. I'll put the link there for you on these were issued by the then President of Family Division, Sir James Mumby. And these have been updated since these are excellent orders that very, very good and highly recommended by the court service to be able to use these because I give you some very useful, uh, orders basically that are to be used in all areas, not just of Children matters, but in these other areas. So they standard orders for Andi phraseology for normal station orders of occupation orders for forced marriage protection orders for female Gento, which elation orders, for example, for forced marriage protection order doesn't mentioned on also many other forms of injunctions that may well be sought so very, very good. These orders on therefore should be used. So when you are therefore drafting the order or the undertaking, for example and there are some key aspect in relation to the order sort which you need to bear in mind. So I've just given you a flavor of some of the things to bear in mind when you're drafting the normal station order, for example, So something like this, I mean, doesn't have to be this This is just some examples I have given you. So some flight from the moment at which the order the responders made aware of the terms of the order. They are forbidden whether buying stuff from by instructing, encouraging any other person. That's very, very important so that therefore they do not instruct. 20 encourage any other person to do what they are themselves prohibited from doing so to prohibit use of fighting of violence okay towards the applicant and the Children to prohibit harassing, pestering and intimidating, communicating or otherwise interfering. So you can cover all of those. Okay, then some lawyers go further. They would then specify some examples of that rather than just leaving it as her ass. Best intimidate, communicate. So some lawyers would go further and even give examples, and some courts would invite you to do that. So, for example, instance, examples of normal station could be not to swear not to shout at the person, not to communicate with them through telephone, including voicemail. Not the same text messages, not to email them or the contacting with so many Social net week working sites such as Facebook or Twitter, for example. So you can't even particular eyes that in there, if needs be, not to belittle the applicant, not to communicate with them except the lawyers or perhaps for the purposes off, say, uh, communicating with them Well, if you decide to not contact, for example, with the Children, so you can see the orders could be very wide in that regard. And the more clear they set out, the more comprehensive they are, then it should, in theory, certainly make it more difficult than to be able to argue that that order wasn't clear to that person. So that day they should. They should have obviously complied with it. And if you wish to apply for occupational dishes, set out a draft off the order that's been sort in that regard. So some of the terms could be something like this. So it could provide for the fact that the respondent is for quite a vacate the former family home, for example, See, put the address within, say, 24 hours. You may want to give him longer. It may be necessary to give them 48 hours. Sometimes it maybe they need to be vacating forthwith. As soon as the order was served on him again. Each case it's on its own facts wants to have vacated. Then you may wish to forbid them, whether by themselves, by instructing, encouraging other person to enter or even attempt to enter the property. So you may wish to put down in or to prevent them from coming within, say, 100 m of the property, say, for the purposes of agreed arrangements for contact or otherwise. But because 100 m may not be clear for people are 50 m. What sometimes happens is rather than meters of yards. Sometimes you may put other provisions in there, such as a pendant map. I'll just come on to that shortly. But the order could also provide for the applicant on the child should be entitled to return on. Like I say, if you want a power off arrest, attaching to the occupation ordered and you do you need to make provision for that in the draft order. So, like I say in relation to the yards or meters, some courts may seek for exclusion element there in terms of excluding for a perimeter around the property to in fact, then provide for reference to a map for example. So there may be a map protecting at the streets on the roads that they are not allowed to come onto, for example, so it could be that as well, right in terms of directions then. So if the matter is listed, say there is an unnoticed application listed or there was a without noticed and there's a return date and it's listed for contest, then sometimes it could well be directions Made four. Filing after further evidence of, for example, one has to think about what happens. An interim. Do we continue with the order that we continue with the undertaking? For example, what about corroborative evidence? Do we need evidence from GP hospital, school police, local authorities So it could be directions for evidence to be adduced there, on which witnesses are required to attend? A swell, as I mentioned earlier, the need for consideration off participation directions also, as I mentioned earlier. So when you've got the paperwork together three fl four to understand and support the draft order knots of funding, knots of issue, all of that's then provided to the court. If the order is made or if it's listed on notice, then the notes of hearing the form fl 401 must then be personally served upon the respondent, and normally they're expected to be given at least two clear days. Notice off the return date hearing. Sometimes it may be necessary to a bridge time for service, and that may be necessary to a bridge that time. So, like you have a hearing sooner. Very important, I would suggest to inform your inquire agent that the application has been heard and therefore to alert them that if the order is made, it may require serving as swiftly as possible. And make sure, of course, your client is remain safe, unable to get to court now. This is where there's been a few changes here in relation to the position with service because of covered 19 and, of course, with particularly court bailiffs not being able to do as much in affecting personal services what they were previously doing, given the limited availability, uh, there have been some recent changes that came in under third of always 2020. This particular practice direction will cease to have effect on the third of May 2021 basically what this is requiring the courts to now do up until certainly next year, is this provides for the course of direct and consider other methods of sales for applications under Part four family law orders, which is obviously what we're looking at today other than personal service. So rather than requiring personal service because of the limited availability of court bailiffs to think about other methods of service eso it could be that one looks at service through post, for example, service through maybe social media through maybe text email. What's that? For example, those kind of methods on also the police should be notified of. Northern wants to respond, has been informed of its terms. It's a very, very important to make sure that the police have been aware so that they may have to then think about taking action if there was an alleged breach of the order, for example. So that's where that provision comes into play. There's also in this other pilot that is coming to play also, uh, this came into effect on the 26th of June this year on This expires on the 31st of March next year on basically because of limited court hearings at the moment because a lot of our hearings are still done remotely. Although we are moving more towards hybrid hearings and face to face hearings. In some cases, this has temporarily suspended a requirement to announce an open court or in public specified orders where these were made without notice. So this was a provision that came in some years ago requiring the terms of the order that were made without noticed didn't be announced in open court at the first available sitting, but because of covert 19, limiting the opportunity for open court announcements to be made. There's been a temporary suspension off this provision, so that's where that comes in. Now, when you do go to the court for the hearing, very important to link the fax to a law indicate widely order is needed. As we said, Be realistic. As I mentioned earlier. It's not easy getting without notice occupation orders because off their very nature, these are very draconian. Well, the respondent could potentially be quite a vacate the property, based on simply the case the case has put forward by the applicants, so it has to be done very much on a realistic base in terms of take into account of both factors there. Okay, Andi conduction Return date. If there is a return date, then bear in mind that thea unnoticed application must be served no less than two clear days before the hearing. It is possible to have short service, for example, in those circumstances. Okay, Andi also ensure you bear in mind that the notice for the occupation order must also be served on a landlord or mortgage by first class post if necessary, so that could also be done. And it needs to be done in that situation. Also on once far once served. So either the process serve or the bailiff needs to find a sworn statement of service to form FL 415 to confirm that they were served in the manner in which they were now in terms of the return date. Then what happens depends upon whether the respondent turns up. If they do not turn up and of course, the court, maybe adviser and continue with the order. If it's if it's an order that was made, it just continues or there may be invited to then extending order. It respondent does attend than is there scope at that hearing to have a contested hearing. That may be, but more times not to return date, maybe a mention hearing, which is only limited for listed for a limited period of time, maybe listed for contest thereafter. Is there compromises the way of looking at maybe an undertaking being given or compromise there. So that might be a possibility in particular. Could be respondent off for the court and undertaking. Is it something that would be accepted in those circumstances? So that might be an option in that regard on again, Bear in mind your client safety and well being in that regard. It may be that if an order is made, then you're looking at possible re service of the order on the filing of any power off the rest. Okay. Right. Okay. So that thing covers this session where I wanted to cover some of the procedure. Would you then in terms off running thes thes orders. So we've looked today, It without no disorders, use of Section 14 particular funding. We've looked at drafting and also some of the procedure off seeking his orders. So well, progress this further in the next session where we'll start looking at some of the case law developments in so far as this areas concerned. Thank you very much indeed for listening on that. Speak to you next time. Thank you. Bye for now.