Unlawful Eviction and Harassment - General Principles

Hello. My name is Rachel Coyle. Eyebrows to the 36 Greek on I work in the areas off housing, property and commercial To die is a weapon or about local eviction on harassment general principles you will have in front of you some comprehensive nights on this on you also have to interview a power point. Um, detaining first to the second. Powerful is flying, but it's really want to bring to attention difference being a talent. Seen a license. Now this may tell you back in a little bit to any underground political days or GED adult C p. A. Or, if you just are aware, in any event, a tendency eyes the state in land. I'm granted the right. It's great of possession off premises for determinant, fixed or periodic turn out of a superior estate, whereas the license is a mad personal rights to occupy premises that makes lawful what would otherwise be on local occupation. So where is the accommodation is granted for return at a rent with exclusive possession on with Noah tensile services being provided that save in exceptional circumstances? Legal consequence is a creation off a tendency. Now you may know case on that street amounted 1985 appeal cause at page 809. But if you do want to have a look at that case again, if you do know it's already or if you've never seen it before, they do look at progress. 818 c to 814 A. Because the principles that all thieves, firstly parties cannot avoid creator tendency by corn and agreement our license this paragraph 81 c Number two The about the landlord has reserved certain right of entry does not prevent occupant having exclusive possession. That's 818 c three. A talent can exclude everyone, including the landlord, unless the landlord is except exercising a right reserved by the police. And that's 816 c. And finally, that's aggressive. Possession is extremely important factor in determining whether a talent he has being created, and that's a paragraph 818 e. So if an agreement gives the owner control over and access to the property, this main gate, an intention to grant exclusive possession and therefore no Tennessee arises where parties do not in turn to enter into legal relations at all, there are different types of Tennessee and license. For example, a non excluded licensee is someone who occupies a premises, is a dwelling on who is not an exclusive licensee. See Section three A of the Protection from Eviction Act of 1977. It was known as a P E a 1977. Accordingly, non excluded licensing remains a residential occupier until possession orders obtained and executed, that has to be born in mind. When you're thinking about your victim, somebody, Is it a license? Is it a tenancy? It is a license is a non excreted licensee. If you're not sure, do look at Section three a protection from Eviction Act of 1977 so turn them toward lawful eviction and trespass to land, which is a slide three Attendant has a start to write. Remain once the protection from Eviction Act of 1977 Section 31 until the possession order is properly executed. Reach of that act Prince B, Section three Because rice the tools breach of start your duty. The claim can be made for damages pursuant to Section 27 off the Housing Act of 1988. A man not for someone who he or she instructs, commits what's called a taut where he or she won well, hopefully deprives the residential occupier of any premises of his or her occupation of the whole or part of the premises. To attempts are more, please deprived the residential occupier off any premises off his of her occupation off the whole or part off the premises. Three. Knowing or having cause to believe that the conduct is either likely to cause a residential occupy off any premises to give up his or her occupation of the premises really part of them or out to refrain from exercising any right or pursuing a remedy in respect to the premises or any part off them. Does acts calculated to interfere with the peace and comfort off the residential occupier or members off his or her household, or persistently withdraws or withholds services regionally require for occupation of premises, for instance, water, electricity, gas and therefore, as a result of withdrawing those services? Residential occupier gives up their occupation off the premises as a residence because, well, they cannot take it anymore, You could say is akin to constructive dismissal and employment contacts. You're being pushed out by a lot of circumstance, but our circumstances being created by your landlord trying to push you out by all the means of them just physically dragging you out of a property or changing the locks so unlawful eviction can be as subtle as there. So under two sections 27 28 of the Housing Act of 1988 1 could be awarded damages which, forced to be assessed under a valuation exercise governed suppliers is relevant. Try Section 20 81 off the Housing Act 1988 estates. This the basis for the assessment of damages referred to in section 27 3 There's a difference in value determined that the tire meeting before the residents occupies is to occupy the premises and questions his residence between a the value of the interest of the landlord and default determined on the assumption that the residential occupier continues to have the same right to occupy the premises as before that time Andi, be the bar you that interest determined on the assumption that the residential occupier has ceased to have that right. So any unlawful entry I want to land or lawful placing off something on the land constitute the tools of trespass on a lawful eviction amounts to trespass of land if the landlord has retaking possession of property, including prevented the tenant from returning, knows plate. The essence of a tendency as a state before is that the talent has the rise of exclusive possession that is the right to kill. Everyone, including Lanotte, has to give notice if they intend to cause the property, for example, to do a spot check to do with gas to do an inspection for some reason or another, providing to legitimate, of course, rather just to be difficult internal on the spot given written notice every single day that every day you're Tennessee today, they're going to go around for the next guy, this right off its greeting. Everyone extend to explain the normal so it's not necessary for any claimant in such a case or, if you'll bring it on your predictions. A counterclaim to show any harm in order to sue for damages for trespass, which is what it is. The fact that there has been a trespass is efficient to give rise to a claim for damages. So, for instance, changing the locks going into the property on rummaging through items, going to the property, rummaging through items, then putting me and being by and then put in the bin bags outside of the door. Those are the kind of cases that are obviously on your prediction cases. But then, of course, you've got other cases where I gave examples before where you have a disconnection of services because your landlord has decided they just want to doing it to try and drive you out. And then you actually leave because you just have simply How do you know that is also your prediction? So I trust Pass is essentially what more prediction is. And pursuant to section 27 on 28 off the house, not to 1988 it enables e former tenant all went on to clear licensee Teoh be able to bring a damages claim, and it's available to Ward hadn't to occupy the property that has bean act as but wearing so even acts also by the defendant agent receiving the landlord is defending. Or it might be part 20 fanatical witnesses a counterclaim ah, such as before a couple agents could be lesson agents. It could be a locksmith changing the lock or the plumber renting the property without consent. Turn off the plumbing works. One of them means that than a note is liable. They are the agents off the land more. If you want to know the case for that, it's Sampson Wilson, 1996 Chancery Division at page 38. We can look in the House and no reports in 1996 29 Page 18 course appeal. So, in essence, under Section 27 of the 1988 act, the claim it tenant months cleared licensee Just, uh, part 20. Climate is untouched compensation from the landlord because he or she has caused him or her to leave as a result of attempted to monopoly victim. And that is the damage is therefore calculated by the mechanism allowed for in Section 28. Now, what they almost had about Section 28 is that you will often find that you'll need a valuer. Um, someone who's qualified to give evaluation are essentially the value of the three occupation before, So I was evicted in the body operation after they've been evicted in the different Jenna to used in section 28 as as the rule of salt, Mr How toe how to work that out. But you would need somebody if you do cases like this to actually be able to be an expert on that to shed light on it. So then turn into slide for is another strand off a multi eviction on trespass aligned. And also it's a strong harassment as well. So it ties in with both, which is a subjective weapon on now, the common quiet enjoyment. If you found that being a breach, he can claim special damages. Trapped it. So, for example, if you had items damaged because somebody decided to just let your property and temple on everything and you're right to be damaged and that person was not authorized and it was the models agent you cannot claim for special damages for those items that have being ruined by being trampled on. Now it is a term herbal tendencies that the landlord promises. In turn, it shall be allowed to use the premises without interference. This promise is automatically implied into every tenancy, even if it does not express the stated and does not cease to the town of breaches the terms. The Tennessee, for example, not paying ground doesn't mean that the landlord could just suddenly go knocking on the door and just walked into the property or going to property themselves just because sometimes not paid Ram. That's not how this works on the case. For that, for the authorities about it would fall. Learn not a ton of looseleaf edition tweeted Maxwell paragraph 11.267 So, according all tenants may stay for breach of the continent of quiet enjoyment. If that happens on an agreement type of which expresses right to quiet, joining to be conditional on a tenant performing his or her obligation to the agreement is off. No facts. So if you do see that in the tenancy agreement that's no effective, the common quite enjoyed, it should not be conditional. So even if, for example, time isn't a rest, but I'm still entitled to the common require enjoyment again would fall. Man of Internist is the authority for that paragraph 11.280 so that doesn't have to be necessarily a disposition or particular difference with property itself indifference, even with the comfort local. But whilst family is suppression you don't need to necessarily thing on someone's head to be considered to be different bearing. You don't need to necessary being banging and hammering the door down. The very fact that you decided to come to property unannounced, um, is, you know, really, especially if you don't interest entering with that threshold between the communal area or public highway Andi than the actual property. It's so if you want to know the case for that, you've got a case of Suffolk in honor of our accounts in Tana River has no Civic on a Birdhouse and Mills Last 2001 where I am one of the people of court paid one on. It was also a case that was approving on more old case called Kanye Preen, whose 1963 William one page right volume one on the Queen's bench, 499 to page appeal. So tired and then Teoh another strand, which is trespass to goods. This is value in damages. Uh, this is it's right. Fine. Trust Past of goods is a direct interference with another person's belongings. It coexists with conversion, which is found in a torts interference with God's act of 1970 seven, in which a person is entitled to the possession off goods, which is put in which that if they are being permanently deprived off that possession of the goods and then converted to the use of somebody, someone else. In other words, someone's taken your items in the black bin bag. They ran it down the stars. They have effectively taken your goods. They have interfered wrongly with your goods without your commission, and it might even be that. Then they go on and sell it. That's conversion, and therefore there is intention there to permanently deprive. There's very similar definition, perhaps with theft. Act 1968 is actually 11 I think my memory serves me correct. Needs actually won three. Happy to stand corrected on that one. But it's very similar wording to that. So if you do find that there has been a mournful interference with goods out of your client, when your own items, then this is a cause of action to bring on. It typically is in tandem with the damages claim that brought your prediction on in tandem, also with a damages claim for harassment, which is the next slide that slide. Six. Harassment in civil contact. Not talking about criminal contact. We're talking about the civil contacts. So the Protection from Harassment Act, the 1997 act on the Criminal Justice and Police Act T. J P a 2001 prohibit harassment, reach of which is actually in the civil Nicole. Of course, we are only concerned with pH I Protection of it Protection from Harassment Act of 1997. Because if you don't get section want sexually, one of the 99 7 act prohibits a person from quote the sooner course of conduct which amounts to harassment of another on which he was. He or she knows or ought to know a matter. Harassment of the other now reference to a person in the context of the harassment off a person or offenses to an individual. That's Section seven Fine, which was inserted by a serious Organized Crime and Police Act 2000 and fine. That is, in fact, only and no no definition off harassment. The government shows not to include one because it took the view that harassment as a concept, had been tempted regularly by the courts and the public Order Act of 1986 section For A you're thinking, Why are you saying that? Where'd you get that from? You'll find that in by the home secretary and you find out the hand side. There's ahead. Secretary's comment on that. Its PhD volume 287 calling 784 17th of December 1996 There isn't on point definition and again with harassment that doesn't have to be a disposition or physical interference with property itself. Again. The case for that is it so that a lot of our council on Tanna or right before a council mills it includes but is not limited. Teoh alarming or causing distress to a person conduct need not, therefore calls actual alarm or distress in the case without is Mad. Rosky, Andi Guy's and ST Thomas's and HS Trust 2001 In World Court Appeal, Civil Division paid 1233 paragraphs. Look at our Paris 29 30 So although it would be tired, it as an individual and B. Keiper has caused alarm in distress. The main point being is that unreasonable conduct at which merely irritates the noise or causes small adults that isn't harassment. It's it's the fact that there is a distress is the fact that bean distill extent calculated aunt, also that it's also alarming as well. But it's a fine balance because some people might find it. What? Something more alarming to me out. So it can be very difficult. Teoh walk that quite tight, tight break, really, but really safer then, or media in a small act which slightly irritates isn't going to be enough on the case. On that, UH, also is town autonomic records to that and also a Section 75 kind of a loose to that world about actually the degrees of war harassment. What would constitute harassment until the actual actions themselves? Because it is the court of assess on a particular case by case basis, whether behavior is unacceptable on unreasonable and a contact in which to conduct occurred. It's likely to assist the court well into turning if it constitutes harassment in the case without his con and Sunderland can. It's under the City Council 2000 on seven England Wales Court Appeals Civil Division 1490 two, Some case law just assist you in top in another and Microsoft Corporation LTD. Another 2000 times 15 from 15 November in the Queen's bench division. The court stated that the 1997 act is directed at the prevention of stalking and social behavior on harassment Absolute on racial harassment help today in the case of Doubts and on others and Chief Constable Northumbria Police in 2010 in the Whale's High Court, 2612 Queen's bench division, Simon J. Offered a very helpful summary of what must be proved in order for a claim of harassment to succeed. But what he said, this is there must be conduct which occurs on at least two occasions, which is targeted at the claimant, which is calculated an object of center to cause alarm or distress, which is objectivity judged to be aggressive and unacceptable. What is oppressive and unacceptable may depend on the social or working contacting which the conduct occurs. A line is to be drawn between conduct which is unattractive on unreasonable on comet, which has been described in various ways as torment of the victim, often order which would sustain criminal liability. So the 1997 Act does not express Rigoberta concept off targeting as a necessary element in the started retorted harassment, but it has emerged from judicial interpretation of the statute definition off the taught in the case of Thomas, A New Script Newspapers LTD. 2001 England and Wales Court Appeal, Still a division 1233 where a Paragraph 30 North Phillips Master the role said that harassment is generally understood as describing conduct targeted at an individual. Rix LJ I returned Dowson and others and Chief constable of Northumbria Police in the case of Levi, another, M. Bates and others in 2015 England Wild Court appeals Double division praise 206 in Levi abates. The cause appeal clarify. And that's while in most harassment cases, the claimant will be the intended target of the perpetrators. Course of conduct are suggested by Simon J. In previous cases, it may infrequently happen as a course of conduct, which, because it is targeted him her it's clear harassment has against a cause is just so much alarm. Distress to be, even though be, is not the intended target of the perpetrates misconduct, although foreseeably likely to be hard by. So, for example, in this case, harassment to the claims husband had foreseeably infected his wife. There's no reason why parliament, in the absence of express words, should by implication be found to have deliberately excluded from protection the act persons who are foreseeably alarmed and distressed by a course of conduct but the targeted type contemplated by the word harassment. If verbal threats are sufficient to make a victim ill, they amount to an actionable tort as well. And to see the case of Khorasan, Dijon on Bush, 1993 Queens French division page 727. Now the onus does not have to be physical, but maybe recognized psychiatric illness or their emotional distress board short of another is not sufficient. So someone merely suffering distress we'll have a cause of action on the Protection of Harassment Act of 1997 that Section three or Section three a. Now I've provided in the notes the full Section three for your benefit. I'm not going. Teoh read that out to you, but you'll see it's quite a lengthy section. But of course the most important part, remember, is no events. Section 11 which I will return again, is that a person was not pursue a course of conduct. Which of mount a restaurant of another, which he knows a rock to know, amounts to harassment of the other. So what the case or has established is you've heard Simon James help principles about targeting, but also it's now being brought in to actually mean as long as it's foreseeable that someone else might be affected by the harassment of that you're causing. Do you somebody else I example of husband and wife you might really be harassing. The husband was foreseeable. It can affect the world. You might only be harassing the Children, but it's foreseeable. You're going to upset the parent, and that would cost you harassment, too. So it's not just necessary targeting the actual victim. It's who hours could be forcibly brought into that bracket to have bean affected by your actions. So the closest thing we have to harassment being defined in the act is indeed Section seven, which you'll see is looted Teoh at Powerful. It's live seven and hey, it's actually seven defines harassment as including causing a lob or causing distress and say that course of conduct was involved conduct on at least two occasions. That's Section 73 The axe need not be off the same nature. It is the course of conduct that was, the amount of harassment was apparent to individual instances of conduct. The case or not, a Geek bar and Dean Manson's Listers 2011 in a World Court appeal Civil division that page 123 So whilst the conduct need not be more than two occasions where there is only a small number of incidents, conduct will need to be more severe to sustain the grand top. For example, on injunction, which is another thing that can be done in case of unlawful eviction and harassment so you can go down the reach of trying to get damages. So, for example, with perfection, Um, it's a difference of by between you before you'll stay on after your stay on with baited with a lot of value, there just disaster. The sections 27 28 Housing Act 1988. You also got special damages, which can be claimed if there's bean items. Damage would have been a bridge common required enjoyment. You've also got damages which can be sort emission to interference with goods, items like Oh, but also. But what of those on harassment? While you could also pursue an injunction, you might want to turn back the property. You might want your items back you might want. Teoh stops me from continuing, reaching the common to quiet enjoyment. You could got injunction as well on. So that's also an option and not merely damages. Or you could use it the way we would like to get an injunction. But in the alternative good like damages, if that's not doable or both, Ah, damage is being If, for example, injunction successful, it's really is allowed back into property. Your damages would be on up until that point in time boy sample. So harassment. Just do it Section 73 So it doesn't. It can be that the wide apart, the wider, the instant to spread apart, the last like it is that there would be a finding of harassment. The most important thing is how many times it occurred. How serious is on each occasion. What's the spread between each incident? Because the more close together they are, the more you can imagine as a judge, the impact it's having on on your individual or your family intimidate on your hand. If that's included, well, it can consist of anything from threats by words or actions, which in turn to make somebody do something that causes damage either to the intimidating person or to some other person. And there is a very old case that defines intimidation that Allen of Flood 18 98 pure courts that page one in the House of Lords. The threat must, however, be intentional and must be a threat to do something or normal do constitute a breach of tort contract. Or indeed, a crime. In that case is ropes, and not in 1964 pure course paid 1 1029 in the House of Lords. So if there is a threat, what if it's caresses? Well, it must be a coercive threat, not merely persuasion. There's a subtle difference, and it must be coupled with the demand, so threat does not need to be carried out, but it must be effective to make the person intimidated. Why the person entitled to sue for intimidation, though, is the person who saw this the damage rather the person intimidated, although it is often one and the same person. But again it goes back to the case are need by Basit about who is foreseeably, the one actually suffering harassment here. So, notwithstanding these references to the actual constructive knowledge off the defendant, landlord handled agent neighbors, whoever it might be, the House of Lords has, of course, make clear that an employer can be held by curse, live and damages the commenters employees, do you? The case of Majority Majora Ski and Guy's and ST Thomas's NHS Trust referred to earlier a citation being 2006 UK House of Lords Patiently 30 four. But that's an example where it is clear that the course of conduct may have Bean pursued either by one employee will buy more than one employee each arse on different occasions. Furtherance some other joint design. That is a great that's from Daniels and commissioner Police for the topless 2000 sick Anna Wells High Court 1622 page paragraph. This paragraph nine reason why in reference to employment law is because it's civil kind of thing. You've got none. Loyalty might have an agent. There are somewhat akin to be an employee. Is that stretching that element of agency drawing a crowd of what with vicarious liability? Because you can't have cases where unemployed, how responsible what? It simply has her off somebody and therefore they employed How responsible as a result, So damages. Return Teoh Slide eight about damages. You'll see that this four distant that special damages general damages aggravated damages on exemplary damages. So both late in this kind of situation, you try and click damages for having suffered distress and anxiety, as was also the unlawful eviction or breach of common core enjoyment or taking your guards converse in your girls, damaging your goods and also any harassment. So damages can be claimed rule of these as well as an injection, but that there only some damage as you can get with certain principles. No, great. That's a minute. Inter developed eviction and general damages in particular. Just very mind. When I talk about general damages or special damages, Joe damages it's not really a thicker propped up here, but I probably dress up more in a moment. But special damages in particular can include Maybe you haven't to pay more money for an alternative living arrangement that might not otherwise have to do. Take time off work on the lost wagers, that kind of thing. That's the kind of love of special damages, the contacts with more conviction that we are talking about. Um, but most importantly, order the damages they had to write directly naturally from the results of your local conduct. So special damages. So you know what it is? Thes are designed to compensate for any identifiable, quantified loss. So if you're good to be damaged, you could prove that you earned them. But you bought them great. You can try and claim that the loss there it might be the diminished devices he bought them that might be taken to count when you want to claim damages. For that, um, special damages again. Another example. A lot of earnings time off sick that you might otherwise have had arranged alternative living arrangements. Getting another locks without yourself to interlocks those kind of losses. Mother was very particular damages. General damages is, uh, normally, these have given where there is a loss of enjoyment resulting from being deprived of the use of possession if not cable being quantified. as claimed as general damages. That the case for that is rammed up on a daily in 1993 at 25 has a house in lower courts. Page two, women 73 The quarter appeal. Do you have a look at page 276 off the judgment? We talked about general damages, but basically we're trying Teoh, um, trying to basically compensate for something you can't really put. They got an exact figure on which is the loss of enjoyment s Watson joined as a result of being deprived of the use of the possessed off possession of the property. But because it can't be quantified come a difficult. So we now have general damages so gentle damages is essentially awarded for harm has comfort lost enjoyment, pain, suffering, shock, inconvenience and is recoverable in taught and not being contract. Um, from the first day myself in 13 the proper level damage jump general damages in these types of cases. So harassment or any of the talks like nuisance, for example, which causes suffering, inconvenience or distressed individuals. It's increased by 10% in the case of after Simmons on castle in 2012 in Wales could appeal. Still a division page 1000 and 30 nine if you turn to now to slide. Nine. This is Internation to the statue talks with breach in particular, off harassment. Chechen Morris. An act of 1997 whereby the conventional approach for the top two cases is that damages harassment should be approached the same way as those awarded for injury to feelings in discrimination cases. So this is the correct that is endorsed. Indicate of Martin's and Chowdhury in 2000 seven. Uh, but appointment also made in US on D property investments in this boat on both of those cases basically say that it's wrong to apply precise the same as award as discrimination there. So involved award for the humiliation of being treated different on the grounds of protected characteristic. It depends. What this case is trying to say is, when you're talking about harassment, the contact of housing on property should be approaching in the same but not not been the same or similar way as implicated but not matter because of protected characteristic um, discrimination cases are just two examples where general damages is awarded in cases where involved injury to feelings. The D better in mind when it comes to you. General damages in particular, there are medication I want to draw upon. Um, case of Chowdhury. Garcia is a good case in 2013 in Wales, House in England and Wales High Court Page 3283 Queen's Bench Division product. If I basically gives an idea of about 150 pounds to £250 per day for whether being a breach comma, quiet, join burnt, where there's been a more conviction and therefore general distress that caused you somebody or agree for people's their most common communicators. Thin margin that worked where there's normally considered in in a mobile of pure prediction cases, huh? Unless I for harassment harassment, you may find cases such as Wynne Jones and Bickley Slight turned. To be particularly helpful is an example again as Cindy Property in this but and also the case of Joins and Ruth Things gives you an example. £7290 awarded in the case of Jobs and Ruth because I was intermittent harassment over several years. Remember, I said that must be at least two incidents and the close. Together you are, the better. Well, if it does go over a long period of time if they're not close together, but they're intermittent. That is also something that is constant. Constant harassment reason being is because you're essentially on tenterhooks, so you might go for a couple months when nothing happens. And then about stuff that happened over caused a couple of days, we must turn our and that doesn't happen again. And that happens maybe another six months down the line. This happened often enough that you can't be too sure it's not ever going to happen against you are on tenterhooks. That's why the courts have had to be wary of including those types of cases. The case of this that is an example. Weathers seven Instant seven months. That's example. The case where there's a lot of instance every short period and when Jones Bickley is an example of abusive language combined with action combined with inaction, actually could cost you a nuisance as well. Sometimes nuisance calls injustices. Well, in that case, it was about somebody dumping debris on Marlin, saying How you go on open was W on your name because I just wanted to and I want to. Hiroshi tension over people may not be very words. Um, so those are the types of cases you may want to look out. That's just this is a dark, great many cases in harassment and unlawful eviction to look out when it comes to turn in general damages. But it gives you a very, very good idea of the kind of figures you could be talking about. Uh, they're just team will, which is aggravated damages on example. Damages aggravates damages. These rewarded to compensate a claimant or a part 20 claimant injury to your feelings off dignity and pride for aggravation. Generally, a good case for that good definition is found in RAM. Death in Dudley in 1993 25. House of Law House No reports Page 273 in the Court of Appeal Page 277. That's right. Card up 277. Uh, it is worst night that the aggravated damages and normally awarded for talks assault, trustbuster, London deceit Exactly. Damages, however, are designed to be Senator, and she'll be awarded to punish and deter the perpetrator from doom staying behavior again. So example damages could be anything from under pound Teoh £2000. It just depends on how much and how bad they really beat and how much the court really want to go unpunished this person for what they've done. So I do have that being useful. It's a very whistlestop tour, slightly lengthy webinar than usual for this, but it is quite a quite a meaty area. I have to find a peaceful to run. This case is right. You might have found that you're being evicted properly in the end, but actually already gone through an on off election process. Do you want stuff or this is actually the mental counterclaim. Which one is a compliment? We can also bring out a claim I damages under an injunction. If it did, you want to go back to property. What do you do? You want you right back. Where do you just want to stop coming up the property whenever they choose? It does happen. So do be aware. But do ask your clients if you're absent in talents that if you are representing landlords, do be aware, are what constitutes harassment. Um and do you consider whether or not what may be a lashing accounts claim could be taking pictures so little now away off the likely damages that may or may not be awarded against the up. Whether it worked for Syria, for example, rent arrears, if that's what the landlord's original gone to for before this a counter play make women. So thank you very much. Do you have about the evaluation form? I do help. That's also how helpful to you.