Clause
3
The
Boards duty to promote the regulatory objectives
etc
Mr.
Bellingham:
I beg to move amendment No. 206, in
clause 3, page 2, line 25, leave
out
so far as
is reasonably
practicable..
The
Chairman:
With this it will be convenient to discuss
amendment No. 244, in clause 28, page 14, line 9, leave out
, so far as is
reasonably
practicable,.
Mr.
Bellingham:
The amendments stand in my name and those of
my hon. Friends the Members for Huntingdon and for Bournemouth, East. I
do not know why they do not stand in the name of the birthday boy, but
perhaps that can be put right at a later stage.
Amendment No. 206 refers to
clause 3, which concerns the legal services boards duty to
promote the regulatory objectives set out in clause 1(1). Clause 3(2)
states:
The
Board must, so far as is reasonably practicable, act in a
way
(a) which
is compatible with the regulatory objectives,
and
(b) which the Board
considers most appropriate for the purpose of meeting those
objectives.
If one were
to expunge the expression so far as is reasonably
practicable from that provision, Her Majestys
Government could get exactly what they want from the measures anyway.
Surely the expression unnecessarily qualifies clause 1(1). What is the
point of setting out the regulatory objectives in clause 1, if
one does not require the board to respect them in clause
3(2)?
If that
expression were to be left in that provision, the obligation for the
board to act in accordance with the regulatory objectives would be
removed in some circumstances. Surely, clause 3(2)(b) fulfils exactly
what Her Majestys Government ought to want from the provision,
thus not only is the expression so far as is reasonably
practicable unnecessary, but it could, in some circumstances,
undermine the objectives set out in clause 1. It represents a possible
escape provision that could undermine the force of the objectives set
out in clause 1.
Amendment No. 206 is a probing
amendment, and I would like the Minister to comment on what I have
said. I see that her civil servants are nodding, so I must have made a
reasonably cogent point. I am sure that there is an explanation for the
situation that I have outlined.
The amendment is grouped with
amendment No. 244, which fast forwards us to part 4 of the
Bill. We are some way off reaching that part, but amendment No. 244
refers to clause 28, which comes under the
heading:
General
duties of approved
regulators.
So, we are
moving on to a different part of the Bill. Clause 28(2) states
that:
The
approved regulator must, so far as is reasonably practicable, act in a
way
(a) which is
compatible with the regulatory objectives,
and
(b) which the
approved regulator considers most appropriate for the purpose of
meeting those
objectives.
Again, we see
the expression
so far as
is reasonably
practicable.
I
shall not rehearse the arguments in relation to clause 28, but they are
similar to those that I have just made on clause 3. The evening is
pushing on, and I know that it is important to make some more progress,
and on that basis I commend the amendment to the
Committee.
Simon
Hughes:
I have put my name and that of my hon. Friend the
Member for Birmingham, Yardley to the main amendment, although not to
the second amendment. In the Lords, there was a long and rather amusing
debate about whether letters had gone astray, and what had happened to
them. I read the Ministers wonderful response, but I was not
absolutely persuaded that it dealt with the point, so I thought it was
worth bringing the matter
back.
The concern is
simply that we should not say, Here are the objectives. You
ought to follow them, but you do not have to if it is not
practical. We should have a structure that is firm and not
qualified, and the amendment seeks to remove the
qualification.
Bridget
Prentice:
If I may, I shall explain to the hon. Member for
North-West Norfolk why the provision is worded as it is, although I
have to say that I found his argument extremely persuasive, and what I
really want to do is to go away and think about how the provision
works. If I correctly understood him, he argues that we should take out
the phrase
so far as is
reasonably
practicable.
and
concentrate on whether clause 3(2)(b) encompasses what we want to
achieve. If that represents a correct understanding of his argument, I
have quite some sympathy for it.
The Government did not want to
put an absolute requirement on the board and on the regulator to act in
such a way as to be fully compatible with all the regulatory objectives
all the time, because that could result in greater cost and
bureaucracy, and probably in greater intervention by the board in the
regulatory activities of the approved regulatorsnot least
because there would then be a risk of judicial review if they did not
so act.
The flexible
and risk-based approach that Sir David Clementi advocated was the
reason for drafting the clause as it is, such that the right way
forward is to deal with matters on a case-by-case basis. The wording of
clauses 3 and 28 therefore tries to recognise that the objectives might
apply to a greater or lesser extent in the carrying out of functions,
or even, sometimes, not at all.
I shall consider whether removal
of the relevant phrase would undermine that flexibility in any way and
whether we could rework clause 3(2)(b) to ensure that it would
encompass the principles that we all agree should apply. On that basis,
I ask the hon. Gentleman to withdraw his
amendment.
Mr.
Bellingham:
I am grateful for the Ministers
constructive and positive response and I look forward
to her further comments on those points in Committee. On that basis, I
beg to ask leave to withdraw the amendment.
Amendment, by leave,
withdrawn.
Mr.
Djanogly:
I beg to move amendment No. 213, in
clause 3, page 2, line 34, at
end insert
(4) In
assessing what is proportionate in the regulation of approved
regulators the Board shall have regard, inter alia,
to
(a) the
regulators resources (including voluntary resources) and the
effect on them of the Boards
acts;
(b) the effect on
regulatory fees;
(c) the extent
to which the Boards acts might discourage entry to or retention
in the regulated sector;
(d)
the extent to which the number of persons regulated by a regulator
might be reduced in consequence of the Boards
acts;
(e) the extent to which
the regulator might be disadvantaged and another regulatory might
derive an advantage, in particular through the movement between
regulators of regulated persons as a consequence of the Boards
acts.
The
Chairman:
With this it will be convenient to discuss the
following: Amendment No. 214, in
clause 3, page 2, line 34, at
end insert
(4) The role of
the Board is to ensure that the approved regulators act in a way which
is compatible with the regulatory
objectives..
Amendment
No. 254, in
clause 3, page 2, line 34, at
end add
(4) In considering
what degree of protection may be appropriate for consumers, the Board
must have regard to the differing degrees of experience and expertise
that different consumers may have in relation to different kinds of
regulated
activity..
New
clause 10Boards general duty to
consult
The Board must
make and maintain effective arrangements for consulting representatives
of practitioners and consumers on the extent to which its general
policies and practices are consistent with its duty under section
3..
New
clause
11Consultation
Arrangements
under section (Boards general duty to consult) must include
consultation in advance of the Board setting its workplan for each
year, so as to obtain the views of persons consulted
on
(a) the degree to
which the Boards proposed activities are appropriately targeted
on areas giving rise to the greatest regulatory concern,
and
(b) whether or not the
proposed programme of works is proportionate, having regard to the need
to avoid imposing unnecessary regulatory
burdens..
Mr.
Djanogly:
We come now to the quite serious issue of
proportionality. The amendment was originally suggested to us by the
Chartered Institute of Patent Agents and by the Institute of Trade Mark
Attorneys. My hon. Friends and I propose that the amendment be added as
new subsection (4) to clause 3. In different ways, both amendments deal
with proportionality. Amendment No. 214 addresses the resources and
impact on the regulator. Amendment No. 254 deals with the need to
consider the different types of consumer. Clearly, the concern in both
cases is to avoid a one-size-fits-all
approach.
6.45
pm
Clause
3 deals with the boards duty to promote regulatory objectives
and will require the board to have regard to the principles of best
regulatory practice. Specifically, it refers to the importance of
regulatory activities being transparent, accountable, proportionate,
consistent and targeted only at cases in which action is needed. We
endorse the statement in the White
Paper:
Todays
consumers are very different in the types of legal services they
purchase, how often they engage with legal service providers and their
level of knowledge of both the law and legal service providers. They
need services delivered in ways that are flexible enough to suit their
different needs.
On one
hand, high street practices may advise the inexperienced or the
vulnerable who are unsophisticated in legal matters and, on the other
hand, City solicitors represent a range of sophisticated corporate
clients who often have their own in-house legal teams responsible for
instructing external solicitors. Those consumers require a level of
regulation that is proportionate to their needs and will not
unnecessarily increase their legal costs or lead to unnecessary delays
in transactions. Inappropriate regulation could cause them to look
outside the UK jurisdiction for legal advice, in some cases, and damage
the competitiveness of City firms and other firms throughout the
country.
Proportionality
is such an important issue that guidance should be given about what
considerations the board should take into account. By not listing such
considerations, we are making the Legal Services Boards job far
more difficult. We have told people what to do, now we need to advise
them on how to do it. The amendment would give them such
guidance.
There is a
danger of the term proportionate being misinterpreted
and being interpreted in a subjective rather than an objective light or
there being an inconsistency in the way that board members assess
proportionality. It is important that we safeguard against any such
confusion. Therefore, we propose that guidance be given to the board
about what matters they should consider when determining whether
regulatory activities are proportionate. In that way, the Legal
Services Board can carry out its job in line with how the Bill
envisioned that it
would.
We have had
strong representations on the amendment, not surprisingly from the
smaller end of the regulators market. The Chartered Institute
of Patent Attorneys and the Institute of Trade Mark Attorneys, which I
shall call the institutes, represent, train and examine more than 2,070
highly skilled professionals in the specialist field of intellectual
property. As I mentioned on Second Reading, there have been few
complaints against those professionals. The institutes support the
amendment. In the House of Lords, Lord Kinsgland asked Baroness Ashton
of Upholland repeatedly about this issue. She refused an amendment on
the grounds that it would define proportionality in legislation,
although she went on to promise to consider guidance on it. She then
admitted that, as an independent body, the LSB would be under no
obligation to have regard to any such guidance issued by the Secretary
of State.
The
institutes continue to believe that this is a vital issue. As two of
the smallest approved regulators in the new system, they strongly
believe that regulation must
be proportionate. They aim to engage closely with the Legal Services
Board to ensure that it fully takes into account the effect that
regulation will have on the entry and retention of regulated persons to
their sector and the effect on fees. However, they believe that the
Bill should state more specifically that the board must act
proportionately with regard to smaller
regulators
Patent and
trade mark attorneys are currently regulated with a light touch and the
costs are low. They have concerns that the board may not sufficiently
take into account the dangers of the over-regulation of the smaller
regulators and their members. Currently, those members place only a
very small burden on the regulatory system. They anticipate the risk
that those who have the freedom to opt out will be over-regulated. That
might restrict entry to, and discourage retention in, the professions
and make the position of the approved regulator untenable.
The institutions are not what
are known as closed professions. Firms that are members of the
institutes need not be on the trade mark or patent registers to
practice, unlike, for example, the situation that applies to solicitors
or barristers. People could simply leave the institutes and practice
unregulated, at no cost. Clearly, that would be against
everyones interests, not least consumers.
Amendment No. 213 focuses again
on proportionality, which was a central theme of the Lords
debates; indeed, it runs through the Bill. There is no doubt that all
who have been involved in the passage of the Bill agree that regulation
should be risk-based and proportionate. The Minister has emphasised
that several times, but how do we ensure that the drafting of the Bill
guarantees that the board acts proportionately? The fact remains that
the board will be more or less free to make its own determination of
what is proportionate, which could lead to disputes about the proper
exercise of its functions regarding the
professions.
The
institutes recognise that proportionality depends in many ways on
particular circumstances and that an all-embracing definition is
perhaps too inflexible. However, they believe that the Bill would
benefit from the inclusion of a non-exhaustive list of the key factors
that the LSB should take into account when exercising its regulatory
function. The also believe that that would benefit the future
relationship between the LSB and the
professions.
The
amendment would not define proportionality, but would set out the
particular factors to which the board should have regard when assessing
what is proportionate in the regulation of approved regulators. The
institutes do not feel that it would be too prescriptive, or that it
would restrict the flexibility of the board. Having given some thought
to the matter, we are of the same opinion. The amendment was tabled
because of the concerns of two of the smallest regulators. They fear
that the LSB, which would get used to dealing with larger approved
regulators, would overlook the limited resources of the smaller
regulators, their low-risk status and their strong track record of good
conduct. Further, there is a perceived risk that regulation would
encourage practitioners to operate outside the regulated sector. That
could have the knock-on effect of driving up costs for the remaining
members, which could make CIPAs and ITMAs positions
untenable.
In recent correspondence with the
two institutes, Baroness Ashton stated that the Government
were
entirely in
agreement that one size does not fit
all
and that a
proportionate approach should be taken by the Legal Services Board. She
also stated that
the
Legal Services Board will need to recognise the position of smaller
regulators,
such as ITMA
and CIPA,
when
exercising functions under the Bill. In doing so, the Board will need
to have regard to a number of factors which may include entry and
retention of regulated persons to the sector and the effect on
fees.
The
statement gave some reassurance that the Government and the institutes
have the same intention, but it is notable that the Under-Secretary
talked about what factors may be included when the board assesses
proportionality. There is no obligation in the Bill that the board must
have regard to such vital issues as entry and retention of regulated
persons and its effect on the regulators fees, not to mention
its resources.
Amendment No. 214 proposes that
the
role of the Board is
to ensure that the approved regulators act in a way which is compatible
with the regulatory objectives.
It is important to state that the
boards role is supervisory rather than advisory. The Government
have modelled the regulatory regime in the Bill on that of the
Financial Services and Markets Act 2000, with the aim of providing a
light-touch regime. That is what business wants, and the regime set up
by the 2000 Act has in part ensured the success of the City in recent
years. The LSB should respect the principle that primary responsibility
for regulation rests with the professional bodies and accept that its
role is merely to ensure that the approved regulators actions
comply with the regulatory objectives. The amendment addresses concerns
about whether regulation by the board will be light touch.
The Bill should provide for the
relative roles of the Legal Services Board and approved regulators. The
amendment reinforces clause 49, about which my hon. Friend the Member
for North-West Norfolk will talk in due course. Clause 49, like the
amendment, strikes the appropriate chord on light-touch regulation, the
importance of which should not be underestimated.
Let us not forget that all the
people that the Bill will regulatefirms of solicitors,
barristers chambers, licensed conveyancers and patent
attorneysall now operate in a global marketplace. If those
firms are not regulated by their approved regulators, such as the Law
Society, and are seen to be directly regulated by the Legal Services
Board, they are at risk of being thrown out of those foreign
jurisdictions. If the Government are going to back-pedal now, surely
they should assure all those practices with an international dimension
that they will not be negatively affected? Have the Government sought
legal advice on that, as well as on their liability for any financial
losses that could result from such a
move?
Following a
lengthy debate in Committee, on Report in the other place, Lord
Kingsland returned to his view that the Bill did not make it clear that
the lead responsibility for regulation should lie with the professional
bodies, with the legal services board exercising its powers only in the
event of significant regulatory failure. Perhaps the Minister will show
us
that those concerns can now be allayed. My hon. Friend the Member for
North-West Norfolk will address that point in some detail when we
discuss part 4, but if the amendment were agreed to, that
would be a good start.
Closely linked with the
amendments are new clauses 11 and 12, which will be proposed
by the Liberal Democrat Members. They concern the need for the board to
consult on its general policies, which is consistent with clause 3, and
on an annual work plan consultation. Generally speaking, the new
clauses, which are covered in a slightly different way by our later
amendments, make sense to me. I shall be interested to hear what the
hon. Member for North Southwark and Bermondsey has to say on
new clauses 10 and 11, and note that the amendments that are
grouped with clause 8 will cover the consultation of practitioners in
greater detail. We will also return to the issue when we debate new
clause 3, as part of our discussion of clause 10.
However, considering the order
of selection today, I should be interested to hear from the Minister
whether the light-touch approach of new clause 10 would be any more
appealing to the Government than new clauses 1, 4, 5 or
6.
Simon
Hughes:
I will be brief, but I want to say a few words
about the new clauses that have been mentioned and to correct the hon.
Member for Huntingdon: I think that he referred to new clauses 11 and
12, but new clauses 10 and 11 are under discussion.
The new clauses are almost
self-explanatory. We are in a section on the general functions of the
Legal Services Board and its duty to promote the regulatory objectives.
It is always a question of degree and of how much ought to be put in
the Bill, and so we
propose:
The
Board must make and maintain effective arrangements for consulting
representatives of practitioners and consumers on the extent to which
its general policies and practices are consistent with its duty under
section 3,
and the other
proposes that arrangements should include consultation in advance of
setting the work, not least to obtain the views of the consultees of
the targeting of specific interest in the board, and getting a view of
what people think are the big issues on which the board should be
concentrating and whether its work has some proportionality. That
starts to open the question of the balance between the second-tier
regulator and the board and the extent to which the board has a light
or heavy touch.
I am
not pretending that the drafting is perfect, but I should be interested
to hear the Ministers general response. The new clauses are an
attempt to see how much we need to include the boards duties,
particularly its consultation duties, in the
Bill.
Bridget
Prentice:
One of my aims in the debates on the Bill and in
my discussions with stakeholders, whether they are from the legal
professions, consumers or colleagues, is to ban the phrase
light touch. This is not about light touch, but about
proportionality. I want everyone, if I can persuade them, not to use
the words light touch or any reference to touch, but
the term proportionate regulation. I will then feel
that I have achieved something.
We very much recognise that the
smaller regulators in particularITMA and CIPA have been quoted
extensivelymight want statutory assurances about how they will
be considered under the new framework. It is perfectly understandable
that they might be concerned about that, but there can be no question
but that an effective regulator must have regard to at least some of
the considerations listed in amendment No.
213.
7
pm
There is
therefore nothing between us on the question of whether regulation
should be proportionate. Clearly it should. Where we differ is on
whether we consider it important to try to define it in the Bill.
Indeed, in quoting CIPA and ITMA, the hon. Gentleman recognised that
the board, the Office for Legal Complaints and the approved regulators
must be able to take a proportionate approach on a case-by-case basis,
which is the aspect on which we should concentrate our attention. I am
concerned that trying to define what the board should take into
consideration might cast doubt on whether other important factors also
apply in a particular
case.
In amendment No.
213, the hon. Gentleman highlights a number of different considerations
that he regards as essential to the exercise of proportionate
regulation. However, the key point is that there might be equally
applicable and important factors that are not contained in the
amendment. Setting out those considerations in the Bill could suggest
that they had greater weight than other, non-statutory factors, which
might be more important in relation to a particular regulatory
decision.
To give the
Committee an example, I am sure that hon. Members are all aware that
the principle of proportionality is well established in legislation.
Section 2(3) of the Legislative and Regulatory Reform Act 2006
establishes
that
regulatory
activities should be carried out in a way which is transparent,
accountable, proportionate and
consistent
and that
they
should be targeted
only at cases in which action is
needed.
Those concepts
are not defined in the 2006 Act, and we have simply replicated that
model in the Bill.
It
is of the utmost importance that the board, the regulators and the
Office for Legal Complaints should be free to consider what is
proportionate when making their regulatory decisions. It is equally
important for the protection of the interests of the consumer, whether
a multinational firm or the man or woman in the street, that
proportionate regulation should be considered on a case-by-case basis.
Placing definitions in legislation of what is proportionate in a
particular case would serve only to restrict the scope of that
principle.
Amendment
No. 254 would ensure that the board could distinguish between those who
are experienced consumers of legal services and those who are not, for
the purposes of determining what level of regulatory control should
apply. It might be considered as risk-based and proportionate to fix
the arrangements in regulations, but fixing the arrangements in the
Bill, so that they could be changed only by primary legislation, would
mean losing that opportunity for
flexibility that we have been carefully building throughout the Bill. I
would argue that the boards regulatory approach is to target
those areas that need
attention.
How a
consumer copes in a given environment, based on their experience, is
only one of the variables that we take into account in determining the
level of protection. We have taken the view that the starting point
should be blanket protection for all consumers, which can then be
adapted to fluctuations in the legal services market and can respond to
consumer needs on a case-by-case basis where
appropriate.
I
appreciate the sentiment behind amendment No. 214. We have
consistently made it clear that we embrace the B-plus model of
oversight regulation. Although I understand why the hon. Gentleman
wants to make that explicit in the Bill, I am not convinced that that
would achieve what he wants. In fact, it would lead only to more
intrusive and burdensome regulation. I am sure that he, of all people,
would not want us to go down that road. There would be a risk of
judicial review if the board did not discharge its own duties to ensure
that the approved regulators acted compatibly with all the regulatory
obligations all the
time.
It is important
that the oversight regulator does not micro-manage and second-guess the
actions of the approved regulators, as Members on both sides of the
Committee will agree. I fear that the amendment would increase the
scope for such micro-management by the board, by giving it a statutory
duty to ensure that the approved regulators act in a particular way
that is compatible with all the regulatory objectives all the time. The
Bill already gives effect to the oversight model of regulation. When
there are adverse impacts on the regulatory objectives, the board will
have the right powers to take action. I do not see any reason or merit
in going further than we have
done.
I remind the
Committee that the Government tabled amendment No. 6, which puts the
board under a statutory duty to publish a policy statement setting out
how it intends to have regard to the principle that its principal role
is the oversight of approved regulators when formulating its policy
statements. That provision, which also requires the board to take into
account the desirability of resolving matters informally whenever
possible, might provide the kind of principle that the hon. Gentleman
seeks. Our position is that policy statements remain the best place to
set out the relationship with the approved regulator; they can be
adapted as necessary to ensure that the consumer is afforded the
protection of proper regulation for the services that they pay
for.
Turning to new
clauses 10 and 11, we have discussed amendments to the boards
duty to consider the views of approved regulators, as well as of
consumers. The Government have made clear their position on the issue.
The Bill provides equal opportunities for representations by consumers
and practitioners, through the approved regulators, to be considered by
the board. That has been expressed differently in the Bill, according
to the bodies involved, and for good reason. Unlike the legal
profession, which already has in place well-established, well-organised
and well-funded bodies that are more than capable of representing the
views and interests of its members,
consumers do not have such a voice [Interruption.] I sound
as if I am about to lose mine. We therefore thought it necessary to
establish the consumer panel to represent consumers interests
to the board.
Approved
regulators already have sufficient opportunities under the Bill to
represent practitioners views. For example, in addition to the
provisions requiring the board to consider representations, clause 3
specifically requires the board to have regard to key principles,
including any other principle that appears to represent the best
regulatory practice. In line with such practicethe Better
Regulation Executives code of practice and consultation, for
examplethe board should consider representations, especially if
they come from those affected by its functions. We do not need to set
out any practice in the Bill which could, in effect, become outdated
and irrelevant. It would narrow the focus of the boards
consultation too much if it were limited to the extent to which its
general policies and practices were consistent with its duties under
clause 3, or to the degree to which the board proposed activities and
targeted them appropriately, whether or not the programme of work was
proportionate.
Those
principles apply, too, to any work plan, and it is unnecessary to put
that duty in the Bill. The board has a duty under clause 3 to ensure
that its activities are targeted and used only when appropriate and
necessary. Given the duty for the boards accounts to be laid
before Parliament, there is sufficient financial accountability, so I
urge the hon. Gentleman to withdraw his
amendment.
Mr.
Djanogly:
I thank the Minister for that thoughtful
response to the amendments, and I shall go away and have a good read of
what she said. My immediate thought is that proportionality is not
simply a word that can be defined on the spot. It is an idea, and ideas
are open to interpretation. If someone is given an idea about putting
something together, they are given instructions on how to go about
doing so. That is the sort of principle that we intended to follow. We
are not dictating how the job should be done, but merely suggesting
guidelines to be considered when performing it. If board members each
use different criteria to judge proportionality, there could be a
problem. Our intention is to ensure that a consistent approach is taken
by each regulator. The Minister confirmed that she does not believe
that the one-size-fits-all approach is appropriate, which is important.
If she has thought about whether guidance could be a more appropriate
way to define what is meant by proportionality in the context of legal
services, I should be grateful for her
views.
The Minister
does not like the words light touch, but patent and
trade mark attorneys, for example, like light-touch regulation. They
believe that they have a light- touch regulatory existence at the
moment, which allows them to compete effectively at an international
level, so they have concerns about the proposal. The minimum regulatory
cost to members is a registration fee for each register of about
£70 a year. Costings suggest that the combination of a
regulatory levy and operating costs as an approved regulator are likely
to increase the annual regulatory cost to £750 to £1,000
a head, assuming that the number of registered attorneys remains at
current levels, and those figures make no
provision for set-up costs. For regulators, the concept of a light touch
is a real one, as it will hit them in their pockets, so I hope that the
Minister will consider that further and comment on whether guidance is
appropriate.
Bridget
Prentice:
I will certainly consider issuing guidance, but
I am conscious of the fact that if the Government started to do so we
would get back into the argument about Government interference in
regulation. I want to make it absolutely clear that the LSB is
independent of the Government, and that it
must be seen to be so. However, I will consider whether there is a way
of using a code of practice or issuing
guidance.
Mr.
Djanogly:
On the basis of the Ministers helpful
answer and her offer to consider guidance, I beg to ask leave to
withdraw the
amendment.
Amendment,
by leave,
withdrawn.
Clause
3 ordered to stand part of the
Bill.
Further
consideration adjourned.[Mr. Michael
Foster.]
Adjourned
accordingly at fourteen minutes past Seven oclock till Thursday
14 June at Nine
oclock.
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