Without Prejudice

May 27 2011

In this week’s Without Prejudice podcast, Financial Times General Counsel Tim Bratton joins Charon QC, David Allen Green and me to talk about:

  • contempt of court in the week Twitter typed two fingeredly to the courts
  • privacy law, the media, and that footballer
  • whether we have privacy law, a tort of privacy, or what (including a brief spat between David and me),
  • John Hemming MP, and the use and abuse of Parliamentary privilege, and
  • the role of General Counsel and the in-house lawyer, focusing on Tim’s work for the FT.

We had fun – and I hope you’ll have fun too if you choose to listen. Do please comment about the issues we discussed.

Listen to the podcast here or subscribe through iTunes.

2011-05-27T00:48:59+00:00Tags: , , , , , , |

AlJazeera’s Inside Story on “superinjunctions”

May 26 2011

I appeared on AlJazeera’s Inside Story on Tuesday, to discuss “superinjunctions” – well, anonymous injunctions in fact – with Martin Bentham of the Standard and Stephen Murdoch of Cambridge University. The programme’s now available on the web.

Shiulie Ghosh introduces me as editor of this website – which I suppose I am. I’m also the chairman, chief executive and finance director, mind, and would be general counsel too if I were practising these days. I blink far too much and gesticulate wildly, but if you can bear that, it might be worth watching.

2011-05-25T19:48:53+00:00

Can the Danes ban Marmite?

May 25 2011

Jon Worth (surely Britain’s leading blogger on EU affairs) has the story that it’s now illegal to sell Marmite in Denmark. The Danish embassy has been anxious to stress that Marmite is not banned, but that is, I’m sorry to say, slightly misleading. It’s clearly unlawful at the moment to sell Marmite in Denmark, as the Danish Foreign Ministry admits:

Neither Marmite nor Vegemite and similar products have been banned by the Danish Food And Veterinary Administration. However, fortified foods with added vitamins, minerals or other substances can not be marketed in Denmark unless approved by Danish food authorities.

The Danish Food and Veterinary Administration has not received an application for marketing in Denmark of Marmite or similar products with added vitamins or minerals.

According to the Danish Order on food additives, addition of vitamins, minerals and other substances need to be approved by the Danish Veterinary and Food Administration before the product can be marketed in Denmark.

You might think that sounds reasonable. I think it’s contrary to EU law, though. If I were Unilever, I’d not only be delighted at this publicity (which seems almost perfectly designed to boost Marmite’s “love it or hate it” brand image). I’d also be wondering if potential sales in Denmark made it worth suing Denmark for damages in EU law.

The Danish Ministry of Food says that

According to the Danish Order on food additives, addition of vitamins, minerals and other substances needs to be approved by the Danish Veterinary and Food Administration before the product can be placed on the Danish market.

In addition to the required pre-approval, any fortification with vitamins, minerals and other substances needs to comply with Regulation (EC) No. 1925/2006.

Regulation (EC) No. 1925/2006 does not at this stage specify any maximum levels for addition of vitamins, minerals and other substances. Until maximum amounts are specified in the regulation, the Danish Veterinary and Food Administration will follow the national authorisation procedure as described below.

Here’s Regulation 1925/2006. It’s since been amended, but not in a way that makes any material difference.

Regulation 1925/2006 on the addition of vitamins and minerals and of certain other substances to foods

Article 10 of that Regulation makes its internal market harmonisation purpose clear:

Without prejudice to the Treaty, in particular Articles 28 and 30 thereof, Member States may not restrict or forbid trade in foods which comply with this Regulation and Community acts adopted for its implementation by the application of nonharmonised national provisions governing the addition of vitamins and minerals to foods.

The Danish Order plainly restricts trade in foods. The requirement for prior authorisation is in itself a restriction on free movement of goods. In other words, it’s a “measure equivalent to a quantitative restriction on imports”, or MEQR, to use EU law jargon, under what’s now article 34 of the Treaty on the Functioning of the EU. The concept of an MEQR was defined in case C-8/74 Dassonville as including (para. 5)

All trading rules enacted by member states which are capable of hindering, directly or indirectly, actually or potentially, intra-community trade

which the Danish Order obviously is, since imports of Marmite from the UK are at least indirectly and potentially hindered by it.

But hang on! Can’t Denmark rely on article 17.3 of the Regulation? It says

Member States may, in compliance with the rules of the Treaty, continue to apply existing national provisions on maximum and minimum amounts of vitamins and minerals listed in Annex I added to foods and on the conditions applicable to this addition until the adoption of corresponding Community measures in accordance with Article 6 or under other specific Community provisions.

The answer, I think, is no. If the Danish Order were a provision on maximum amounts of vitamins and minerals that set rational, justified limits, it would be permitted. But it seems not to set maxima at all. In fact it appears to restrict the free movement of foods such as Marmite regardless of the amount of vitamins and minerals they contain. This simply cannot be a proportionate exercise of the article 17.3 derogation. On the contrary, it plainly undermines the purpose of Regulation 1925/2006.

Jon Worth makes the point that Denmark has been here before, in case C-192/01 Commission v Denmark, in which a Danish law making the sale of vitamin-enriched foods subject to proof of nutritional need was ruled disproportionate and unlawful. It may be that the Danes are trying to achieve a similar result here, by other means.

I mention damages because, under the principles laid down in cases C-46/93 and C-48/93 Brasserie du Pecheur and Factortame, member states can be liable for serious breaches of EU law that cause damage. See paragraph 51 of the judgment.

I’m not confident Unilever would succeed in obtaining damages in a case like this, in spite of Denmark’s “form” on hindering imports of enriched foods. Denmark might be able to persuade the courts it acted in good faith by applying its existing measures on vitamins, even if on any reading (whether literal or purposive) they cannot be reconciled with article 17.3 of the Regulation, so that the breach of EU law is not sufficiently serious.

What I’m more confident of is that the Danish Order breaches EU law, in the shape of Regulation 1925/2006, and in all likelihood Regulation 178/2002 (because not proportionate as required by article 7.2) as well as article 34 TFEU.

If I were advising the Danish government, I’d say the Order cannot survive legal challenge. If they do manage to defend it successfully in the ECJ, I’ll eat … not my hat, but the biggest Havarti and Marmite toastie I can make.

2011-05-25T17:27:17+00:00Tags: , , , , |

Hemming does his worst

May 23 2011

As I think readers will surely know by now, John Hemming MP used Parliamentary privilege today to name the footballer whose anonymity is protected in this privacy case by an injunction, which the High Court decided earlier today to maintain in force.

Since then, first Sky News and now the BBC have named the footballer on air. They’re clearly making a judgement that although the law is unclear on whether it’s legally safe to report what’s said in Parliament that flouts a court order, the risk of any successful legal action against them for contempt of court is so low that it’s well worth taking the residual legal risk.

As I write at nearly 7pm, I’ve read on Twitter that the injunction has still not been discharged, after a second attempt today by lawyers for The Sun – which surprises me. I imagined the hour or so after John Hemming’s outburst had finished it: once SkyNews and then the BBC decided to name the footballer, I assumed the court would find there’s nothing left to enforce. But the order stands, and I’ll wait for the it to be discharged before I name him.

There’s nothing wrong with the privacy law Parliament enacted in the Human Rights Act 1998, and which the judges are loyally applying – except that redtop newspapers want to breach and destroy it in their own commercial interests, and that many internet users have allowed themselves to be persuaded to flout it by a one-sided, self-serving and ill-informed media onslaught. I find it astonishing that, against the background of the News of The World phone hacking scandal, so many people swallow the claim that it’s judges who are out of control. As Alastair Campbell has implied in what he’s tweeted, what’s happened today is no victory for free speech, but for the worst of British journalism.

Just as important as privacy law, though, is the question of Parliamentary privilege and John Hemming’s conduct today. In response to John Whittingdale’s urgent question about injunctions, the Attorney General Dominic Grieve was right to remind MPs of the importance of the rule of law. Hemming, though, was having none of that, deliberately naming the footballer to the clear disapproval of other MPs and of the Speaker, who told him that the purpose of privilege was not simply to flout the law.

In doing so, Hemming has set himself up as the ultimate judge in this case, which I don’t think even involves one of his constituents. Without knowing the full facts, he has effectively given judgment in favour of the tabloid press – just because he feels like it. His sheer arrogance is breathtaking. Hemming plainly abused of Parliamentary privilege today, as he has before as part of his campaign against the family courts. Anyone who thinks the rule of law is important should oppose his antics.

What’s depressing is that many on the internet will now lionise Hemming, who’ll now no doubt gain a wider audience for his onslaught against social workers and family judges. A series of far better contributions to the debate on privacy today was made by a series of far better MPs – Chuka Umunna, Matthew Offord, Gisela Stuart, Tom Watson, John Whittingdale and the Attorney himself. But people will remember the worst.

2011-05-23T19:02:30+00:00Tags: , , , , , , |

No bail-out for Strauss-Kahn

May 16 2011

The IMF boss and front-runner to be the French Socialist Party’s presidential candidate next year, Dominique Strauss-Kahn, has been refused bail by a court in New York, according to the BBC. As has been widely reported he’s facing a charge of attempted rape. It may be that the defence can appeal the decision on bail; but subject to that, he’ll be in custody until his next court appearance on Friday.

The refusal of bail may surprise many people. I’m no expert in the criminal law of New York, but I’m not as surprised as all that. He’s charged with a very serious offence, of course, and is a foreign national. While it’s true that Strauss-Kahn – or “DSK” as the French call him – could be required to surrender his passport and live at home in Washington or with his daughter in New York, the prosecution said in court (some of the proceedings were live on France 24) that they didn’t know how many diplomatic travel documents he has. He was arrested at JFK airport, on a plane to Paris.

Perhaps most critically, France does not extradite French citizens, under Article 696-4 of the Code de procédure pénale. That means that if somehow he did make it to France, as long as he stayed there he would be beyond the reach of the New York courts. He would be subject to possible prosecution in France, though, under Article 113-6 of the Code pénal.

So it’s not that surprising the prosecution has opposed bail entirely, and initially succeeded. Whether he remains in custody is another matter: when the position on travel documents is clear, the courts may be satisfied, as it was here in Julian Assange’s case, with a tough package of bail conditions.

On another legal point, there seems to be disagreement about whether any diplomatic immunity might be available to DSK. The BBC cite Jovan Kurbalija, director of DiploFoundation, as saying he may technically enjoy absolute immunity from prosecution for anything he does; Kurt Taylor Gaubatz of Old Dominion University thinks he only enjoys “acts” immunity – in other words, immunity covering any acts performed in his official capacity, rather than anything he might or might not have done in a hotel room. I’ve not been able to research this for myself yet – but I’d be surprised if he enjoyed more than “acts” immunity. In any event, both experts agree the IMF board can waive any immunity he may enjoy.

Everything seems to be collapsing around DSK: it seems he may now also face proceedings in France about a previous incident, years ago. He must be presumed innocent of course, but his story shows on a grand scale how merely being accused of a serious offence can turn your life upside down.

It’s difficult to see how he can recover politically from this, even if he’s acquitted. The primaries for the French socialist “nomination” come in October. DSK’s momentum having now been arrested, a woman – either Martine Aubry or Ségolène Royal – may well be the political beneficiary.

2011-05-16T18:58:20+00:00Tags: , , , , |

Discussing privacy law with Roy Greenslade and Max Clifford

May 16 2011

I took part in Sunday Sequence on BBC Radio Ulster yesterday, discussing privacy law with Roy Greenslade, who’s professor of journalism at City University as well as being a former newspaper editor, and Max Clifford. The discussion starts at 34’20”, and lasts for about 20 minutes.

I think what Roy Greenslade says about this, both during our discussion and in his blog, is especially interesting: he’s a well-known figure in journalism of course, and takes a much more balanced and legally informed view than the standard red-top campaigners who get so much air-time on this. I doubt he’d have agreed with it, but I’m sorry he didn’t get a chance to respond to my idea of voluntary prior clearance of privacy stories, with legal protection from claims for any material given clearance.

2011-05-16T17:19:07+00:00Tags: , , , |

Mosley v UK

May 10 2011

Max Mosley has lost his case in the European Court of Human Rights, in which he claimed that the UK breached his right to respect for private life under article 8 of the ECHR by failing to impose a legal duty on the media to notify him in advance of a story that violated his privacy.

Mosley v. United Kingdom

This is unsurprising – it was always a bold claim to make that the UK had a positive obligation to have such a particular kind of system in order to satisfy article 8. I think that must be right: if article 8 required this in the UK, it’d require it all over Europe. I think to find in Mosley’s favour would have been to set rigid policy for the entire continent, ignoring the margin of appreciation (as the Court has tended to do on the subject of prisoners’ votes, for example, about which I’ve been very critical). So the ruling is sound legally, and difficult to argue with.

It’ll be a shame though if Mosley’s idea of pre-notification is now dismissed, though, as impossible or unworkable. I’m not sure it, or something like it, is unworkable at all – and the judgment doesn’t rule it out if the UK wanted it – it just says we’re not required to have such a system. I think Mosley’s idea has some merit, and should not just be forgotten about. A system of voluntary prior notification for instance – with special legal immunity from any financial or other claim for journalists and media organisations who do give prior notice – would actually be much less chilling of free speech that our current “publish and be damned” culture, which leads to excessive self-censorship for fear of money claims after the fact.

2011-05-10T10:55:59+00:00Tags: , , , |

Breaching so-called “superinjunctions” on Twitter: is this how low we’ve sunk?

May 9 2011

The BBC has reported that someone on Twitter has purported to “out” a number of celebrities who have supposedly obtained “superinjunctions” to protect their privacy.

It’s unlikely of course that all of them are “superinjunctions” at all, which are injunctions the existence of which cannot be reported. And who knows whether any of what’s been tweeted is true at all. As the BBC reported in the piece I’ve linked to, Jemima Khan says it’s not true in her case. It may all be false.

In any event, I absolutely condemn this latest move in a diffuse but vociferous campaign by some people in the mainstream media and on the web against the right to respect for private life, a right guaranteed by the European Convention on Human Rights, and legislated into our domestic law by Parliament in the Human Rights Act.

It’s not so-called “superinjunctions” that have gone too far. What has gone too far is the nasty, prurient public hounding of people for their sexual behaviour, and the self-serving campaign by some to defend their “right” to hound as some sort of free speech cause célèbre.

Quite apart from the possible contempt of court these tweets represent, they’re also utterly irresponsible. How can the person know they’re true? Haven’t they considered for a moment the partners, children and parents of the people supposedly “outed”? It’s also worth mentioning that in one case, some of the Twitter  remarks and “jokes” now being aimed at one of those “outed” have a really horrible racial component. I won’t quote or link to them for obvious reasons. This is the gutter into which media red-topism, allied to self-righteous anti-privacy militancy, has dragged us.

As I’ve watched this so-called “superinjunction” debate take its course over the last few weeks I’ve been exasperated, frustrated and depressed to see how a word originally coined against the background of really legitimate concerns about the behaviour of a company and its lawyers has been commandeered by journalists to campaign against privacy generally, in cases not involving superinjunctions at all; and used by John Hemming MP in particular of course to further his own personal campaign against the family courts. Depressed and frustrated too by how gullible so many people seem to have been in apparently accepting the conventional media shtick about “a back door privacy law”.

But this latest move makes me ashamed of my fellow citizens and internet users, and angry too. What we have here is the shameless indugence of gossip and rumour-mongering dressed up as championship of free speech. Some of it is really disgusting, and all of it is an insult to those really denied free speech, in Iran, say, or China. Journalists ought to be shouting about their inability to witness important events in Syria, instead of campaigning for voyeurism here.

Two further points about all this have struck me for a while, and may be worth mentioning.

First, it’s interesting that in other contexts, many people have been whipped up into concerns about their own privacy that are completely unjustified. Take DNA, for instance. No one will ever be able to out you as anything, or for doing anything, because your DNA is a on a database – if it ever is. The invasion of privacy involved in keeping your DNA profile is completely theoretical. And there’s a real public interest – the attempt to catch criminals – justifying whatever slight invasion of privacy there is. In contrast, media exposure of people’s relationships, sexuality and so on involves a real invasion of privacy, usually without any public interest justification whatever. Yet this real privacy many people think should merrily be ignored. I find that strange.

Second, a reason sometimes trotted out as a justification for outing people’s private lives is their supposed “hypocrisy”. Well, there may be something in that in a very few cases. But the biggest hypocrisy of all is to argue that other people should have no privacy, if you wish to retain any at all for yourself. I would take the whining of anti-privacy injunction campaigners more seriously if they were prepared to publish on the internet all the most intimate details of their own private lives, hour by hour. It can be done now using blogs and Twitter, and I think anyone who argues against any legal protection of privacy at all should do so. If not, aren’t they the hypocrites?

But back to the serious argument. Of course we need freedom of expression. Freedom to publish cartoons mocking religion. Freedom to take photographs in the street. Freedom to publish novels without being threatened with death. Freedom to put on a play without it being closed by a mob. All these are important, insufficiently protected in this country and insufficiently debated in our trivialised, infantilised media.

But as well as free speech, we need a decent public space in which private lives are respected where there is no good reason to invade them. We need, too, a media that is itself worthy of respect. The current law, voted for by Parliament with its eyes open and being applied correctly by the judges – if anything in a way that leans towards freedom of expression – is the right way to achieve these things. If we’re ever to get them, then this campaign of outrage and outing over “superinjunctions” must stop.

2011-05-09T12:09:39+00:00Tags: , , , , |

Without Prejudice

May 6 2011

In our latest Without Prejudice podcast, the editor of Legal Week Alex Novarese joins Charon QC, David Allen Green and me to discuss:

  • the legality of the killing of Osama bin Laden
  • the inquest into the death of Ian Tomlinson, and what happens now
  • the Bribery Act 2010, and
  • City law firms and social mobility, the “up or out” culture and the big law business model.

Once again, I hope you’ll listen and let me know what you think of the issues we discussed.

Listen to the podcast here or subscribe through iTunes.

2011-05-27T00:35:15+00:00Tags: |

John Hemming, sub judice and the public interest: “no abuse of parliamentary procedure”?

April 27 2011

Yesterday afternoon there was speculation that John Hemming MP was planning to “break a superinjunction” in the House under cover of Parliamentary privilege.

Then, not long after 5 o’clock, John Hemming made a point of order in the Commons [update: hyperlink removed – see comment 12 below], naming a woman, and a local authority, who he said had tried to imprison her for speaking at a meeting in Parliament. I’m not going to name either of them: as I explain below, I’m not sure it’s in the public interest to do so. I ask you not to name them in comments and to avoid writing anything that could identify them.

John Hemming (Birmingham, Yardley) (LD): On a point of order, Mr Speaker. [******] … , was the subject of an attempt by [******] council to imprison her for speaking at a meeting in Parliament. There was discussion earlier today as to whether that case was sub judice. An application was made to the court, a copy of which I have provided to your office. Additionally, I have provided to your office a copy of the court order in which it was deemed that she would not be jailed. I assume, therefore, that the case is not sub judice, in accordance with sub-paragraph (b)(ii) of the relevant resolution:

    “Any application made in or for the purposes of any civil proceedings shall be treated as a distinct proceeding.”

Mr Speaker: I am grateful to the hon. Gentleman for his attempted point of order and for notice that he was to raise the matter this afternoon. I do not intend to have a discussion on the Floor of the House, notwithstanding what he said about documents that have been deposited, on whether a particular case is or is not sub judice. One of my duties is to uphold the resolution of the House with respect to sub judice issues. As far as this particular matter is concerned, I am perfectly prepared to discuss it privately with the hon. Gentleman. I will not take any further points of order on this matter today, and I feel sure that he will take his cue from the clear response that I have given.

Some interpreted this as the Speaker having “gagged” Hemming.

Later, John Hemming posted about his point of order on his blog, saying “Gag Removed – Job Done” [update: hyperlink removed – see comment 12 below] and making clear his objective was to identify the parties in the case.

So what was going on here? And is there any cause for concern?

It’s worth remembering that yesterday’s news agenda was dominated by Andrew Marr – bringing “superinjunctions” into the media spotlight yet again. This was the day John Hemming chose to make his point of order, and although the case he mentioned doesn’t involve a superinjunction at all (applying John Hemming’s own definition of that term [update: hyperlink removed – see comment 12 below]) reporting of what he did makes the connection. We can only speculate about how anyone came to make a link between what Hemming was planning and the issue of superinjunctions, and how they came to think he was planning to “break” one. Admittedly, Hemming went on in a second point of order to mention the case of AMM, but as the fact that I am able to link you to the ruling shows, that case didn’t involve a superinjunction either. To be fair, Hemming apparently indicated a few days ago that he intended to raise this case in the House, so his timing may not have been opportunistic. But the apparent connection undoubtedly increased the attention he was able to draw to a case that’s probably in truth (as I explain below) about the “family court secrecy” he campaigns against.

The first important question is whether the full letter and spirit of the House’s own rule on sub judice has been respected in this case. The House has resolved – this is not something imposed by law or the courts –  that subject to the Speaker’s discretion,

Cases in which proceedings are active in United Kingdom courts shall not be referred to in any motion, debate or question.

See the House’s Standing Orders (page 181) and this House of Commons Library note from 2007. The principle served by the rule, as the Joint Committee on Parliamentary Privilege said in 1999 (see the Library note, page 3) is that

the rights of parties in legal proceedings should not be prejudiced by discussion of their case in Parliament, and Parliament should not prevent the courts from exercising their functions.

John Hemming said, in relation to the local authority case,

There was discussion earlier today as to whether that case was sub judice

which is enigmatic but may be a reference to a discussion between him and the Speaker or a clerk. Hemming seems to have taken steps to demonstrate to the Speaker that the case is not sub judice, and said he assumes it is not, relying on paragraph 1(b)(ii) of the House’s resolution:

Any application made in or for the purposes of any civil proceedings shall be treated as a distinct proceeding

but from what the Speaker said, it seems he thought the matter is not so clear, and that his duty to uphold the sub judice rule led him to require the matter to be dealt with privately.

By the time the Speaker had said this, though, the case had in fact been mentioned – with the risk that rights could be prejudiced, and the working of the courts interfered with.

I commented at LibCon yesterday, asking John Hemming questions including these:

Normally, shouldn’t an MP wanting to discuss a current court case ask the Speaker, privately, to exercise his discretion in favour of allowing the case to be debated – and wait for that ruling before raising the case in the House? Let me know if I’ve got that wrong, or if I’ve misunderstood where things are up to in your discussion of the case with the Speaker.

What I’m concerned about is whether, by raising the case today in the way you did, and by naming the council and the person involved, you effectively pre-empted the Speaker’s decision and circumvented Parliament’s own rules on sub judice, which are intended precisely to avoid court cases being affected by publicity, and people’s rights being prejudiced.

Can you reassure us that you’ve not circumvented proper Parliamentary procedures?

John Hemming has said to me today in response to those concerns that:

There is no abuse of parliamentary procedure.

Is that a satisfactory answer? I’m not sure. Also in response to my inquiries today, a spokesman for the council involved said that

This is a matter which is before the court and the council must keep this matter as confidential as it can to protect the individuals involved in the case. For that reason the council cannot comment further.

So they seem to think the matter is active. Yet it was raised in the House without, apparently, the Speaker or House authorities having ruled whether it was sub judice, and whether even so it could be debated.

Secondly, it’s worth asking what John Hemming is attempting to do more broadly in relation to this case, and whether what he’s doing is in the public interest.

The meeting at which the woman spoke, and which apparently led to her being threatened with prison, must I think have been this meeting of the All Party Parliamentary Group on Family Law on 29 March. The APPG’s website says

Audio from the Questions & Answer session and the full meeting audio will be available soon … Due to legal reasons some content has had to be edited from the original recording.

The meeting seems from the photos to have been chaired by John Hemming himself. Did he invite the woman to attend? When I put that question to him earlier, this was John Hemming’s reply:

I did not list a number of people and specifically invite them although formal invitations were sent out to people who expressed an interest.

What we know about the case is that a local authority is involved, and that the woman involved apparently discussed it at a meeting about family law. We also know that John Hemming campaigns against “family court secrecy” and has been known to complain about the conduct of local authorities in child care cases. Is it obvious, then, that keeping this case confidential implies some wrongdoing by the council or the court? Or might there just conceivably be a good reason why the council, or the court, or someone else, would want her not to discuss it at a public meeting?

The council spokesman I quoted above said it

must keep this matter as confidential as it can to protect the individuals involved in the case.

It seems, from what John Hemming has said, that the woman he named is subject to an order made by a judge which prevents her from discussing the case in public. And since this appears to be a family case involving a local authority, it’s reasonable to suspect it’s a child care case in which section 1(1) of the Children Act 1989 applies. The court probably therefore had the welfare of a child at the front of its mind when making that order. That’s why, in spite of John Hemming’s view, I’m not sure it’s actually in the public interest to name either her or the council involved.

I’m not sure either that it’s in the public interest for an MP, in his self-imposed role as a critic of the family justice system (as Lord Justice Wall put it), to use Parliamentary privilege in this way.

2011-04-28T12:53:53+00:00Tags: , , , |
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