High Court defeat for Home Office over torture policy

The Home Office has lost a judicial review over its controversial change to the definition of torture in a claim brought by unlawfully detained torture victims. In short, the Home Office changed its definition of “torture” in September 2016 to exclude acts of torture committed by non-state actors. This meant that individuals who had been tortured by a non-state group, such as rebel soldiers, paramilitaries or people traffickers, could in future be detained by the Home Office. The judicial review case was brought by several such individuals who would previously not have been detained, but were under the new policy. This new approach was consistent with the definition of torture…

10th October 2017 By Conor James McKinney

BBC Panorama exposes the culture of abuse in immigration detention

Panorama, Undercover: Britain’s Immigration Secrets is required viewing for anyone interested in immigration in the UK. It is also deeply uncomfortable viewing. It documents an undercover investigation into Brook House, one of the UK’s 13 Immigration Removal Centres. The episode shows detainees subjected to severe violence, taunting, and mistreatment. A widespread culture of disdain towards the detainees among staff permeates the detention centre. The investigation sheds light on alarming issues surrounding immigration detention, which have been subject to criticism and legal challenge since the beginning of the proliferation of detention in the UK. This tweet from the Panorama account gives a sense of the programme: WATCH: undercover footage shot by…

6th September 2017 By Thomas Beamont

Systematic abuse found at Brook House Immigration Removal Centre

The latest of what seems a neverending series reports of abuse of detainees in immigration removal centres has come to light. BBC Panorama took undercover footage at Brook House and uncovered the following, amongst other evidence of chaos and incompetence: G4S officers assaulting, abusing and mocking detainees; Asylum seekers being forced to share cells with foreign national prisoners who have completed their sentences. Rife drug use. This is hardly the first time that investigation has uncovered abuse at immigration removal centres. Nor is it the first time that G4S contractors have been involved. G4S has reacted to this by conducting an internal investigation and suspending nine of its staff. G4S could quite easily…

4th September 2017 By Paul Erdunast

£48,000 damages awarded to torture survivor for injuries suffered during deportation attempt

Following a seven-day hearing in the High Court, Mr Felix Wamala, a Ugandan national, was awarded £48,000 in damages for the actions of private security guards contracted by the Home Office in seeking to remove him from the UK. This is the case of Wamala v Tascor Services Ltd [2017] EWHC 1461. The judgment is a mammoth one, weighing in at 558 paragraphs plus annexes. Mr Wamala’s claim concerned the use of force, and the threatened use of force, against him by employees of Reliance, now known as Tascor Services Ltd. Tascor is a subsidiary of Capita. As they say on their website: As part of Capita PLC, we have the…

17th July 2017 By Nath Gbikpi

Independent Monitoring Board release critical report on charter flight removals

The Independent Monitoring Board (IMB) has published its annual review of the treatment of returnees during charter flights. It reported four headline concerns: firstly, that force and restraint had been used without due checks and for too long; secondly, that escorts employed by contractors were in charge of selecting which returnees may speak to the Chief Immigration Officer for advice on their legal rights during the flight, and that on one flight the advice itself was delegated to the escorts; thirdly that returnees were taken to Stansted Airport at night on certain flights; and finally that those who wished to use the toilet either on the coach or the aeroplane…

10th July 2017 By Paul Erdunast

European Court of Human Rights finds vulnerable Zimbabwean national unlawfully detained by Home Office

In a recent decision from Strasbourg, the European Court of Human Rights has found the UK Home Office unlawfully detained a Zimbabwean national. The Court found that the UK authorities had failed to act with sufficient “due diligence” in progressing the Applicant’s case, leading to him being detained for over two and a half years in an immigration removal centre. The case is S.M.M. v. THE UNITED KINGDOM (Application no. 77450/12). Background The applicant was born in Zimbabwe. He arrived in the UK in May 2001 and was granted six months’ leave to enter as a visitor. Fast forward to 2007, (a few driving offences and a failed asylum claim…

3rd July 2017 By Rebecca Carr

Zimbabwean national unlawfully detained after Home Office fails to serve immigration decision

Substantial damages of £10,500 have been awarded to a claimant who was unlawfully detained for a period of 70 days. The Home Office had failed to serve the Claimant with notice of a decision on his application to vary his leave to remain in the UK before detaining him, rendering his detention unlawful. The case is R (on the application of) Godwin Chaparadza v Secretary of State for the Home Department [2017] EWHC 1209 (Admin). Background The Claimant, a Zimbabwean national, entered the UK on 5 September 2004 with leave to remain as a student. His leave to remain was extended on a number of occasions, the last such extension…

7th June 2017 By Rebecca Carr

Indefinite detention does not breach ECHR says European Court of Human Rights

Arben Draga v United Kingdom (Application no. 33341/13) Unlike most other European countries, there is no time limit on immigration detention in the UK. In addition, the law does not provide for an automatic judicial review of the lawfulness of detention. Instead, detainees must proactively challenge the lawfulness of their detention. In an admissibility decision of 18 May 2017, the European Court of Human Rights found that this system does not violate the European Convention of Human Rights, an in particular article 5 on the right to liberty. Factual background Arben Draga is a Kosovan national residing in the UK. He was granted refugee status and indefinite leave to remain in December 2001….

30th May 2017 By Nath Gbikpi

Another successful unlawful detention claim

R (Ademiluyi) v SSHD [2017] EWHC 935 (Admin) concerns a successful claim for damages by an individual unlawfully detained under immigration powers. It is notable for its restatement of the importance of the third Hardial Singh principle, and as a further example of the Secretary of State’s ‘enduring casualness’ [23] when dealing with cases involving immigration detention. Facts On 26 October 2015, Mr. Ademiluyi’s custodial sentence came to an end. He had served time for immigration-related offences, and in particular possession of a false passport, entering a sham marriage and bigamy. The Secretary of State for the Home Department (“SSHD”) had some months previously notified Mr. Ademiluyi that she intended…

9th May 2017 By Nick Nason

Home Office cannot unilaterally modify tribunal bail conditions (updated)

The as yet unreported case of R (on the application of Majera) v Secetary of State for the Home Department [2017] UKUT 163 (IAC) is a thoughtful judgment from the Upper Tribunal gives helpful guidance on the legal status of a First Tier Tribunal bail decision which may have an error on its face. It may be helpful in cases where the Secretary of State appears to ignore the views of the FTT in granting bail and superimpose her own restrictions. The official headnote reads as follows: (1) A defect in framing the primary condition of bail granted by the First-tier Tribunal under paragraph 22 of Schedule 2 to the Immigration Act 1971…

24th April 2017 By Amanda Weston

Detention of Dublin asylum seekers held to be unlawful

Al Chodor and Others (C-528/15) In a highly significant judgment the CJEU has shown, in effect, that the Home Office has unlawfully detained hundreds or even thousands of individuals seeking international protection. The background facts The Al Chodor family are Iraqi nationals. They travelled to the Czech Republic and were subject to a police check in May 2015. During their police interview, they stated that they had fled Iraq via Turkey to Greece. They had continued their journey and were stopped by police in Hungary, where they made an asylum application. The Czech Foreigners Police Section was of the view that they posed a serious risk of absconding whilst in the…

23rd March 2017 By Thomas Beamont

Serious safety concerns raised in report on Morton Hall IRC

There is supposed to be a fundamental difference between custodial incarceration and immigration detention. The former is reserved for those who have committed crimes: its purpose is punitive, to protect the public and to rehabilitate offenders. The latter, however, is meant to be administrative: a stepping stone for those who are to be removed from the United Kingdom. The majority of those held in immigration detention have committed no crime. Blurred Lines However, a report released yesterday on Morton Hall Immigration Removal Centre (IRC) by the Chief Inspector of Prisons finds that the line between the two regimes is becoming increasingly blurred. According to the report, there has been a…

22nd March 2017 By Nick Nason

New consultation on changes to the Tribunal Procedure (First-tier Tribunal) (Immigration and Asylum Chamber) Rules 2014

The Tribunal Procedure Committee (TPC) is interested to receive your views on changes arising from the Immigration Act 2016, in particular to a number of changes to bail, which the Tribunal Procedure Committee considers may make amendments to the rules relating to bail applications desirable. The Immigration Act 2016 (“the 2016 Act”) received Royal Assent on 12 May 2016. It makes significant changes to the substantive law relating to immigration and asylum, including provisions relating to access to services, facilities, licences and work by reference to immigration status. It makes provision for the Director of Labour Market Enforcement; introduces language requirements for public sector workers; amends fees for passports and…

20th February 2017 By Colin Yeo

New report shows detainees in prison denied immigration advice

Hundreds of foreign nationals in the UK are being denied access to immigration advice according to new research from the charity Bail for Immigration Detainees (BID). In their new report, Mind the Gap: Immigration Advice for Detainees in Prisons, BID has found that just 1 in 20 people held under immigration powers in prison have received independent advice on their immigration case. More than 10% of immigration detainees in the UK – some 500 at any one time – are held in prisons rather than Immigration Removal Centres. Source: Detainees in prison denied immigration advice – BID | Bail for Immigration Detainees

15th February 2017 By Colin Yeo

Rules under which over 10,000 fast track asylum appeals decided declared unlawful

The High Court has ruled in the case of R (On the Applications Of TN (Vietnam) & US (Pakistan)) v Secretary of State for the Home Department & Anor [2017] EWHC 59 (Admin) that over 10,000 asylum appeals had been decided under procedure rules so unfair that the determinations could be set aside. Any unsuccessful asylum seekers affected by these rules will now need to apply to the immigration tribunal to have their decision set aside. The critical legal question was whether the Court of Appeal judgment in R (Detention Action) v First-tier and Upper Tribunals (Immigration and Asylum Chambers), Lord Chancellor and SSHD [2015] EWCA Civ 840 applied as much…

23rd January 2017 By Colin Yeo

Blocking detainees’ access to legal advice websites probably breaches Article 10 ECHR

Free Movement has reported twice on immigration removal centres (IRCs) blocking access to websites informing detainees of their legal rights. HM Chief Inspector of Prisons criticised Haslar IRC two years ago for having the websites of Bail for Immigration Detainees and Amnesty International blocked. What are "prohibited categories" of websites in IRCs if they include @BIDdetention Medical Justice @freemvmntblog ?? http://t.co/zyrDF5OcG4 — BID (@BIDdetention) March 8, 2013 The All Party Parliamentary Group on Refugees’ 2015 report on their inquiry into use of immigration detention slammed the detention centres for blocking access not only to the above websites, but also to the inquiry’s own website. We were told that, in practice, detainees…

13th December 2016 By Paul Erdunast

Challenge to Detained Asylum Casework process fails

The Court of Appeal has refused permission to appeal the decision by Mr Justice Cranston in the Detained Asylum Casework challenge test case. The latest judgment is R (On the Application Of TH (Bangladesh) & Ors) v Secretary of State for the Home Department [2016] EWCA Civ 815. You can find the newly released policy equality statement on the DAC process here. In short, this means that the general process challenge has failed, but it is still potentially possible for individuals to show unfairness in their particular case.

10th August 2016 By Colin Yeo

Torture, independent evidence, immigration detention and Rule 35

Two cases regarding evidence of torture, decided on different grounds. The uniting feature is some guidance regarding Rule 35 reports of torture by doctors. Where a Rule 35 report of torture is nothing but a restatement of the Appellant’s account, that will not constitute independent evidence – this is in accordance with what the Guidance entitled “Detention Rule 35 Process” states. 75. There was no more than a recitation of the claimant’s account of torture. For reasons I have given (see paras. 30-33 above), that does not amount to independent evidence. The fact that a doctor does not find the account lacking in credibility is not enough. That is what…

12th July 2016 By Paul Erdunast

Latest on legal challenge to detained asylum cases

Very useful update from my colleague Shu Shin Luh: R (Hossain and Ors) v Secretary of State for the Home Department [2016] EWHC 1331 (Admin) Mr Justice Cranston this week handed down judgment in Hossain & others v SSHD, the test case (with four representative claimants) on the lawfulness of the “Detained Asylum Casework” process established by the Detention: Interim Instruction policy (DII) and the Interim Process Map, which was introduced after the Detained Fast Track was suspended on 2 July 2015. The Interim Process Map was unpublished at the time these proceedings were issued and only disclosed in proceedings, and it is understood, remains unpublished. Two of the claimants were…

10th June 2016 By Colin Yeo

Home Office unlawfully imposes curfew on migrant

Gedi, R (On the Application Of) v Secretary of State for Home Department [2016] EWCA Civ 409 (17 May 2016) is a case where the Home Office took it into their own hands to impose curfew restrictions over and above bail conditions those imposed by the First Tier Tribunal, as well as those they are entitled to impose as afforded to the Home Office by statute. The Court of Appeal were clear they had no such power to do so.

6th June 2016 By Chris McWatters

High Court strikes down unfair decision in DFT of vulnerable victim of torture

In the first judgment of its kind since the suspension of the Detained Fast Track on 2 July 2015, the High Court struck down the Home Secretary’s refusal and certification of an asylum claim which was made in the structurally unfair and unjust Detained Fast Track (DFT) and ordered the Home Secretary to remake the decision afresh without regard to material obtained in the unfair process. The case is R (on the application of Zafar) v The Secretary of State for the Home Department [2016] EWHC 1217 (Admin). The High Court also directed the Home Secretary to pay substantial damages for falsely imprisoning the Claimant, a vulnerable victim of torture, for…

25th May 2016 By Shu Shin Luh

“The Claimant is not a particularly worthy, likeable or sympathetic individual…”

I said during the course of the hearing words to the effect that the Claimant is not a particularly worthy, likeable or sympathetic individual, and that there must be at least a risk that any award of damages would not be put to good use. I do not withdraw those observations. Another way of looking at this case, however, is to point out that the Claimant is vulnerable, that he probably suffers from paranoid schizophrenia, and that only those obligated to an adherence to the rule of law would be likely to vindicate his rights. This alternative viewpoint is based not on any subjective preferences but on the loyal discharge…

25th May 2016 By Colin Yeo

When will there be a new Detained Fast Track for asylum seekers?

Not in the foreseeable future, suggests Jerome Phelps of Detention Action over at openDemocracy. The Home Office had proposed new fast track procedure rules but have been politely rebuffed by the Tribunal Procedure Committee: The political pressure on the TPC must have been intense. Ministers have repeatedly made clear the importance they attach to a Fast Track. Few of us doubted that a way would be found for new Rules to restart the Fast Track. Not so. In a courageous display of judicial independence, the TPC has politely declined to create new Fast Track Rules. Without Fast Track Rules, there is no Fast Track appeals process, and no Fast Track. True,…

24th May 2016 By Colin Yeo

Independent Monitoring Board slams Heathrow Immigration Removal Centres

What were Harmondsworth and Colnbrook Detention Centres have been brought under the same management, and are now called Heathrow Immigration Removal Centres. Nonetheless, as the Independent Monitoring Board’s report shows, detention centres by another name still have their same old problems. The Board’s recommendations focus on treatment of vulnerable people, both mentally and physically. The first point noted is that due to lack of facilities and care, the physically disabled are unable to live with respect and dignity in the detention centres. The Board note that matters have not improved since 2014. Given that the Board reported two years ago that access for physically disabled detainees needed to be improved,…

23rd May 2016 By Free Movement

Immigration detainees banned from Twitter and Facebook

A new Detention Services Order 04/2016 about internet access for detainees has just been published. This is the first time the Home Office has set central guidelines on internet access for immigration detainees. The Order makes clear that all detainee internet usage is monitored and centrally recorded. The Order states that detainees should have access to “personal internet based email accounts” and “ready access” to any non-prohibited category of website (see paragraph 8), such as education, legal and news websites, to assist with maintaining links with friends, families and legal representatives and to prepare for removal. DSO 07/2013 sets out more general guidance for staff on welfare provision in IRCs. The prohibited…

17th May 2016 By Colin Yeo

New Home Office instruction on risk assessment for immigration detainees

A new Detention Services Order, DSO 03/2016, has been issued by the Home Office. The name is innocuous — Considering detainee placement — but we can hope that it will have a significant impact because what it really requires is a proper risk assessment before a person is accepted into immigration detention. And about time too. We have in recent years seen some appalling and utterly in humane detention decisions, at least one of which appears directly to have led to the death of a very vulnerable elderly man, Alois Dvorcak. DSO 01/2003 is replaced. This also concerned risk assessment but included no statement that detention might not be suitable;…

9th May 2016 By Colin Yeo

Algerian detained over seven years awarded £3,750 in his latest claim

The High Court has awarded damages of just £3,750 to an Algerian man for a period of five months of unlawful detention. This was just the latest period of immigration detention for Mr Sino, though, who has been detained for a cumulative total of seven years and two months. Mr Justice Hayden had said in an earlier judgment Such a time span is a disturbing period for the executive to detain an individual under purely administrative powers. It would appear to be one of the longest aggregate periods that HM Government has ever detained an individual for in such circumstances. The new judgment, R (on the application of Sino) v…

4th May 2016 By Colin Yeo

The Supreme Court’s decision in Nouazli v SSHD and Lawful Discrimination

As if Michael Gove MP needed further reminding, in wake of Colin Yeo’s appearance on World at One on Wednesday where he pointed out the fundamental error of the Justice Secretary’s assertion that Britain cannot deport EEA nationals with a criminal record, the Supreme Court in R (on the application of Nouazli) (Appellant) v Secretary of State for the Home Department (Respondent) [2016] UKSC 16 makes clear that EEA nationals can be deported by virtue of regulation 19 (3) (b) of the EEA Regulations 2006 ‘if the Secretary of State has decided that the person’s removal is justified on grounds of public policy, public security or health…’ However the issue…

25th April 2016 By Chris McWatters

BBC investigation into unlawful detention claims

Excellent report by Catrin Nye into unlawful immigration detention and the compensation paid to those wrongfulyl detained. Good to see Conservative MP Tim Loughton speaking out on the wastefulness of the process, the pointlessness of detaining then releasing, as occurs in 60% of cases, and referencing the recent Shaw Review. The stand out quote is from Jerome Phelps of Detention Action: In prison, you count the days down. In detention, you count the days up.” Written article version here.

20th April 2016 By Colin Yeo

Family member of EU national awarded £136,000 damages against Home Office

A High Court judge has awarded the family member of an EU national a total of £136,048 in damages. The award consists of £76,578 for false imprisonment and £59,470 for breach of EU law. The Home Office is also criticised for having made “inaccurate and misleading” submissions to previous judges on multiple occasions and the damages include not just compensatory damages for lost earnings and distress but also special damages, aggravated damages and exemplary damages. On the breach of EU law, the judge, Mrs Justice Laing, held that the Home Office had acted in an “outrageous, oppressive and unconstitutional manner” and to have displayed “a blatant disregard for the law.”…

30th March 2016 By Colin Yeo

What is happening with the Detained Asylum Casework challenge?

Following the last post on FM on this, Cranston J heard argument from the Claimants on 25 and 26 February 2016 but, having done so, adjourned the hearing, on the application of the Home Office, on the grounds that the SSHD was not ready to proceed.  A case management hearing then took place on 10 March 2016 at which a further two days were set aside on 22 and 25 April 2016.  Cranston J maintained the stay of proceedings he had imposed on all claims for judicial review challenging the lawfulness of the Detention Interim Instruction and associated policies.  However, he also ruled that, pending judgment in Hossain & others,…

29th March 2016 By Anthony Vaughan

Tribunal retains jurisdiction to vary bail conditions unless bail is finite

UPDATE: overturned by the Court of Appeal in R (On the Application Of Raza) (Pakistan) v The Secretary of State for the Home Department [2016] EWCA Civ 807. R (on the application of Raza) v Secretary of State for the Home Department (Bail – conditions – variation – Article 9 ECHR) (IJR) [2016] UKUT 132 (IAC) is a very interesting judgment on the law of immigration bail from the President. These issues are rarely aired and it is good to see some logic and rigor being brought to bear on the issue. The standard practice in the FTT seems to be to grant bail for a defined period ending with a…

14th March 2016 By Colin Yeo

Detention of Somali criminal for political reasons ruled unlawful

The High Court has in the case of R (On the Application Of Mohammed) v Secretary of State for the Home Department [2016] EWHC 447 (Admin) ordered the release of a Somali national with a number of very serious convictions on the basis that there was no prospect of his being removed and therefore that the Home Office had no legal power to detain him. The case is unusual for the honesty with which the Home Office put its case, in essence accepting that the detention was political in nature. It was impossible to remove Mr Mohammed in the foreseeable future because he had a pending asylum claim. There was…

9th March 2016 By Colin Yeo

Inspectors: Refugees held in “wholly unacceptable” conditions in freight shed

An unannounced inspection of short term detention facilities for refugees and migrants crossing the Channel into the UK has revealed that hundreds, including many children, have been held in “wholly unacceptable” and insanitary conditions. Many were held in a disused freight shed and forced to sleep on concrete floors, with no food, drink or clothing provided. The increase in numbers making the crossing to the UK in the summer of 2015 was found to have “overwhelmed” the Home Office and contractors but the emergency arrangements were still in place several months later, when the inspection took place. The increase in arrivals over the summer was predictable and the report questions why…

8th March 2016 By Colin Yeo

Inspectors reveal desolate, appalling conditions at Harmondsworth detention camp

The new HM Chief Inspector of Prisons is not holding his punches. Peter Clarke’s first report is on the Harmondsworth detention camp used for short and long term detention of migrants near Heathrow airport. In an unannounced inspection his team found “appalling” and “desolate” conditions for detainees. You can access the full report here. The last inspection was in 2013 and was highly critical even then. The situation has since deteriorated. Conditions in some residential “units” (presumably meaning the cells) were found to be “appalling”, dirty and run down, overcrowded and poorly ventilated, with toilets and showers in a “seriously unsanitary condition”. Clarke writes that the centre “should never have…

1st March 2016 By Colin Yeo

Detained asylum claims: new test case listed

This is just a quick note to update everyone that Cranston J has listed four cases for hearing on 25 and 26 February 2016 challenging the lawfulness of the Detained Asylum Casework (DAC)/ Detained Non-Suspensive Appeals (DNSA) system (i.e. the post- July 2015 incarnation of the system formerly known as the Detained Fast Track). The cases are Hossain (CO/5275/2015), Auleear (CO/4046/2015), TVC (CO/4572/2016) and MNK (CO/5615/2015). Cranston J has stayed all “current and future” DAC JRs until Hossain is decided. Para 3 of his order in Hossain dated 4 February 2016 says: “All other cases seeking to challenge the lawfulness of the DAC/DNSA process be stayed pending the resolution of…

8th February 2016 By Anthony Vaughan

Court of Appeal grants permission in 2005 Detained Fast Track rules case

Quick note from S Chelvan of No 5 Chambers: Lord Justice Treacy has granted permission to appeal in proceedings which seek to challenge refusal of a fresh claim, but also seek to challenge Detained Fast Track determinations made under the 2005 Detained Fast Track Rules.  Underpinning the three decisions under challenge in the fresh claim, is a May 2014 determination of the First-tier Tribunal (IAC) made under the 2005 Detained Fast Track Procedure Rules.  Treacy LJ granted permission to appeal on this ground of appeal, noting Nicol J’s finding in the successful 2015  Detention Action claims challenge to the ultra vires of the 2014 Rules, the modification between the 2014…

5th February 2016 By Colin Yeo

Babbage: Court orders release of Zimbabwean foreign criminal, criticises Government lawyers

In the case of R (on the application of Babbage) v Secretary of State for the Home Department [2016] EWHC 148 (Admin) Mr Justice Garnham ordered the release of a detained Zimbabwean foreign criminal. In the process, he was corruscating critical of the conduct of Government lawyers acting for the Secretary of State for the Home Department. The case has received press coverage because Mr Babbage is still considered a risk to the British public; the press reports fail to mention that there was simply no prospect of removing Mr Babbage from the UK and therefore there is no power to detain him. Zimbabwean criminal Andre Babbage freed despite ‘significant risk’ to…

3rd February 2016 By Colin Yeo

Detention of mother and 3 children in breach of policy found unlawful

In the case of Onos v The Secretary of State for the Home Department [2016] EWHC 59 (Admin) Mrs Justice Laing held that the decision to remove a Nigerian lady and her three children was a lawful one but that the decision to detain the family at the Cedars facility prior to removal was unlawful. Notice of removal was served on the family with insufficient notice (Wednesday for a flight on Saturday) and the period of detention exceeded that permitted under the policy, which was 72 hours. Ministerial authority or authorisation for the detention was not lawfully sought or given. Compensatory damages were awarded. The judgment emphasises that strict adherence to the…

28th January 2016 By Colin Yeo

Three years immigration detention for Polish national found lawful

A Polish man detained in immigration detention for three years while his appeal dragged on and on was found not to have been unlawfully detained. Apart from anything else the case illustrates the excessively leisurely pace of immigration appeals, particularly in the Upper Tribunal in this instance. Source: Machnikowski v The Secretary of State for the Home Department [2015] EWHC 54 (Admin) (22 January 2016)

22nd January 2016 By Colin Yeo