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In their co-authored judgment, Lord Sales and Dame Siobhan Keegan provide a rich analysis of how the courts should consider the welfare of children in an immigration context. In doing so, they clarify the meaning and effect of Section 55 of the Borders, Citizenship and Immigration Act 2009 (“Section 55”) and its interaction with Article 8 of the European Convention on Human Rights (“Article 8”). The judgment provides a guide for how the appellate courts should assess decision-making by the Secretary of State, her officials, and the First-tier Tribunal.
In this guest post, Rajiv Shah argues that the provision of assisted suicide in the England and Wales via the NHS would constitute a substantive breach of the negative obligation imposed on the State under Article 2 of the ECHR.
Introduction
Article 2 of the ECHR protects the right to life. That article contains two distinct substantive obligations: “the general obligation to protect by law the right to life, and the prohibition of intentional deprivation of life, delimited by a list of exceptions.” (Boso v Italy, at [1])
That first obligation is a positive one and requires States to take steps to protect life from third parties and even from individuals themselves. The precise content of that obligation is necessarily nebulous and the Court affords States a margin of appreciation in deciding what that obligation requires, and how it is to be fulfilled. So, in two recent Chamber decisions – Mortier v Belgiumand Karsai v Hungary – the Strasbourg Court held that this positive obligation does not require States to forbid assisted suicide and euthanasia, but that if it does want to allow it, it must create legal safeguards to ensure that the decision of individuals to end their own life/or be killed by third parties is freely taken.
The ECHR’s Additional Protocols 4, 7 and 12 have never been ratified by the UK and are not included in the schedule to the Human Rights Act 1998. This post suggests that the new government remedy this. It also sets out part of the history to the Additional Protocols, what the rights in those Protocols include, a summary of the relevant jurisprudence and a brief note of what effect they might have in the UK.
In the run up to the 1997 general election and during the drafting of the Labour Party’s policy on what was to become the Human Rights Bill there were discussions within the Shadow Cabinet about whether or not the remaining Protocols 4, 6 and 7 to the European Convention on Human Rights that, were not currently binding on the UK as a matter of international law, should be signed and ratified and, as a result, bind the UK at an international level.
At the time the Labour Government said ‘It will be possible to ratify Protocol 4 only if the potential conflicts with our domestic laws can be resolved. This remains under consideration but we do not propose to ratify Protocol 4 at present.’[1] The then government had concerns that Articles 2 and 3 of Protocol 4 may confer rights in relation to passports and a right of abode on categories of British nationals who do not currently have a right to reside in the UK.[2] In a subsequent Joint Committee on Human Rights report, the Committee noted that the terms of Article 2 of Protocol 4 are ‘substantially similar to those of Article 12 ICCPR, which the UK has ratified subject to reservations regarding disciplinary procedures for members of the armed forces, and regarding nationals of dependent territories and the right to enter and remain in the UK and each of the dependent territories.’[3]
In contrast, it was eventually agreed by the new Labour Government that Protocol 7 should be ratified and added to Schedule 1 of the Human Rights Act:
“4.15 In general, the provisions of Protocol 7 reflect principles already inherent in our law. In view of concerns in some of these areas in recent years, the Government believes that it would be particularly helpful to give these important principles the same legal status as other rights in the Convention by ratifying and incorporating Protocol 7. There is, however, a difficulty with this because a few provisions of our domestic law, for example in relation to the property rights of spouses, could not be interpreted in a way which is compatible with Protocol 7. The Government intends to legislate to remove these inconsistencies, when a suitable opportunity occurs, and then to sign and ratify the Protocol.
4.16 The Secretary of State will be able to amend the Human Rights Act by Order so as to insert into it the rights contained in any Protocols to the Convention which the United Kingdom ratifies in future. The Order will be subject to approval by both Houses of Parliament. The Bill also enables any reservation to a Protocol to be added, but as with the existing reservation it will have to be reviewed every five years if not withdrawn earlier.”[4]
Changes which resulted in the ability to comply with the provision of equality between spouses in Article 5 of Protocol 7, were only made in 2010.[5] However, once these changes were made, the 2010 election came along and Labour was out of office. Protocol 7 remains unratified.
Procedural safeguards relating to the expulsion of aliens
Right of appeal in criminal matters
Compensation for wrongful conviction
Right not to be tried or punished twice
Equality between spouses
The right in Protocol 12
Any right set out in law shall be secured without discrimination
Protocol 4 and 7 add rights to the ECHR, at least in part, to make up for deficiencies in the ECHR itself when compared to the United Nations International Covenant on Civil and Political Rights (ICCPR) – the UN’s equivalent of the ECHR. The UK ratified the ICCPR in 1976 (and now 172 countries across the World have ratified it).
The right to free movement and the prohibition on the collective expulsion of aliens contained in Protocol 4 are also set out in Articles 19 and 45 of the EU’s Charter of Fundamental Rights. The prohibition against double jeopardy and the equivalence between men and women contained in Protocol 7 are set out in Articles 23 and 50 of the Charter and the general prohibition against discrimination in Protocol 12 is contained in Articles 20 and 21.
Currently, Protocol 4 of the ECHR has been signed and ratified by all bar four of the 46 Member States of the Council of Europe (Greece, Switzerland, Turkey and the UK have not ratified the Protocol). Protocol 7 has been signed and ratified by every one of the 46 Member States except for Germany, Netherlands and UK. If ratified, art.4 of Protocol 4 could be an important tool in challenging the effects of the Nationality and Borders Act 2022 and Illegal Migration Act 2023 domestically and in Strasbourg. Despite inconsistent applications of art.4 of Protocol 4, the Court’s jurisprudence is one of the few legal protections against European externalisation policies and a way for those affected to challenge domestic decisions.
Protocol 12, the general anti-discrimination provision, is also a right already contained in the ICCPR[7] but is missing from the main body of the ECHR itself. Article 14, in the main Convention, only prohibits discrimination where this relates directly to the other rights in the Convention. Protocol 12 is, however, a ‘stand-alone’ provision and has a much wider remit. Protocol 12 has been ratified by twenty Member States although it only came into force in 2005. It is accepted that it would have been more difficult for the UK to ratify in 2005. Concerns were raised regarding its potential breadth, though the Joint Committee on Human Rights considered that these concerns were unwarranted.[8] In addition, the Labour Government’s Equality Act of 2010 has now resolved many of any remaining difficulties with compliance. As a signatory to a wide variety of international human rights instruments concerning equality and non-discrimination, the United Kingdom has already accepted the main principles enshrined in Protocol 12.
As with all the Convention Rights, these rights come with protections and caveats to protect the wider public interest and the interests of society more generally. This is already clear from the fact that they are all tried and tested by being part of the ICCPR, ratified across the World and by the fact that so many countries in Europe have agreed to be bound by them.
It is also clear that, all these rights are all already largely protected by provisions of domestic law. Further, to assuage concerns regarding overreach, many of the rights in these Protocols are subject to limitations or restriction. For example, restrictions which:
“are in accordance with law and are necessary in a democratic society in the interests of national security or public safety, for the maintenance of ordre public, for the prevention of crime, for the protection of health or morals, or for the protection of the rights and freedoms of others.”
“may … be … imposed in accordance with law and justified by the public interest in a democratic society.”
“[are] necessary in the interests of public order or is grounded on reasons of national security.”
“shall not prevent the reopening of the case in accordance with the law and penal procedure of the State concerned, if there is evidence of new or newly discovered facts, or if there has been a fundamental defect in the previous proceedings, which could affect the outcome of the case.”
Many of the provisions impose important but relatively restricted ‘due process’ rights – rights to a fair procedure which is already largely set out in UK law or provided by the common law created, in large measure, by judicial review.
In relation to Protocol 12, the prohibition of discrimination, consistently with the Equality Act 2010, “distinctions for which an objective and reasonable justification exist do not constitute discrimination.”
Conclusion
The focus of protecting human rights in the UK must, at the very least, be the preservation of the Human Rights Act without any erosion of either the rights or the remedies it provides. Nevertheless, the threat to the Act will hopefully disappear now that the Labour Party is in government. It is, therefore, an important step to consider adding the further protections that are set out in Protocols 4, 7 and 12 and to bring the UK in line with most of the rest of 46 countries of the Council of Europe and the 172 countries that have ratified the ICCPR.
In the context of more the authoritarian rhetoric in politics[9] and, particularly, the regressive steps taken by the previous Government towards those seeking asylum and refuge in the UK and increasing isolation from Europe, the new Government should, at least, send a clear signal that there is a new approach being developed and indicate this by ratifying Protocols 4, 7 and 12. This will hopefully provide a way to rectify some of the damage done by recent legislation and pre-empt further attacks on human rights.
John Wadham is Human Rights Advisor to the Northern Ireland Policing Board
Fiona Byrne is an Independent Human Rights Consultant and previously Human Rights Officer at the Northern Ireland Policing Board
The views expressed are those of the authors alone.
[1]Rights Brought Home, October 1997, CM 3782, para 4.11
[2] Department of Constitutional Affairs, Report of the Outcome of an Interdepartmental Review Conducted by the Department of Constitutional Affairs, July 2004, p. 40
[3] Joint Committee on Human Rights, Review of International Human Rights Instruments, Seventeenth Report of Session 2004-05, para 38
[4]Rights Brought Home, October 1997, CM 3782, paras 4.15 and 4.16
[5] By sections 198 to 201 of the Equality Act 2010.
[6] For more detailed analysis of this provision and the applicability on legislation such as the Nationality and Borders Act 2022 and the Illegal Migration Act 2023, see John Wadham, Fiona Byrne, More Human Rights: Protocols 4, 7 and 12 of the European Convention on Human Rights and the Human Rights Act 1998, European Human Rights Law Review 2023, Issue 6.
[8] Joint Committee on Human Rights, 17th Report (2005–2006), HL 99, para 33
[9] For example, in 2023, the UK has been downgraded from ‘narrowed’ to ‘obstructed’ civic freedoms in a new report by the CIVICUS Monitor, a global research collaboration that rates and tracks fundamental freedoms in 197 countries and territories: https://monitor.civicus.org/country-rating-changes/uk/
The applicant in the ECtHR case of Karsai v Hungary, Mr Karsai, a 47-year-old human-rights lawyer who lives in Budapest, was diagnosed in 2022 with amyotrophic lateral sclerosis (ALS) – a neurodegenerative disease that causes a progressive loss of motor neuron function leaving the patient completely paralysed, while preserving intellectual function. Mr Karsai maintains that “he will be “imprisoned in his own body without any prospect of release apart from death” and his existence will consist almost exclusively of pain and suffering” (§14). Mr Karsai applied to the ECtHR arguing that the prohibition on assisted dying under Hungarian law violated his right to private life (art. 8 ECHR); the applicant also complained the violation of his right to private life in conjunction of his right not to be discriminated against (art. 14 ECHR) because the Hungarian law offers the option of withdrawal of invasive medical treatments (and, hence, hasten their death) only to terminally ill patients who are dependent on them.
Article 8
Regarding the potential violation of the applicant’s right to privacy, his primary argument centres on his desire to control the timing of his death. Due to his medical condition, he is condemned to a life of physical incapacity, pain, and existential dread. The applicant dismisses palliative care as a viable option: “While palliative care could provide relief with respect to certain aspects of his physical suffering, it could not provide relief from the experience of existential dread” (§91). Instead, he focuses on the fact that he cannot avail himself of assisted suicide provisions either in Hungary or abroad. Hungarian law prohibits assisting a patient in procuring their death, and even those aiding with arrangements for this purpose can face prosecution (§§135; 159).
The Court observed that, due to the lack of a uniform consensus among member states on assisted dying practices, each state is granted a considerable margin of appreciation in implementing policies on such sensitive issues. The court also noted, as the recent case of Mortier v. Belgium held, that the right to life (art. 2 ECHR) does not inherently exclude the decriminalisation of assisted dying. However, this decriminalisation must be accompanied by safeguards to prevent abuses of the right to life (§§126-128; 145).
The Court, finding no violation of art. 8, held that Mr Kasai’s suffering could not dismissed lightly. It noted that the applicant’s complaint mainly focused on “existential suffering” that “although it amounts to genuine and severe anguish, existential suffering relates essentially to a personal experience, which may be susceptible to change and does not lend itself to a straightforward objective assessment” (§158). Furthermore, the Court acknowledged that “existential suffering may be refractory to medical treatment […] and that the use of sedation to alleviate it might be contested or unwarranted in certain situations […]” (§157). Professor Aubry, one of the experts consulted by the Court, emphasised two key points. First, he noted that patients suffering from the same condition as the applicant often exhibit ambivalence about their desire to die as the disease progresses. Second, he underscored the importance of palliative care for individuals affected by ALS, particularly in advanced stages, when they are typically permitted to receive palliative deep sedation and can die peacefully (§46).
Article 14
Regarding the violation of art. 8 ECHR and art. 14 ECHR the Mr Karsai argued that “Hungarian law accorded different treatment to those terminally ill persons with mental capacity who suffered from refractory symptoms but could hasten their death only by means of PAD [physician assisted dying], and those who could do so by having recourse to RWI [refusal or withdrawal of life-sustaining interventions” (§170).
In this case the Court held that the applicant’s clinical picture could not be compared to that of terminally ill patients who depend on life-sustaining medical treatments (§174). In fact, Mr Kasai’s diagnosis might lead to invasive life-sustaining interventions only towards the latest stages of his degenerative illness. Furthermore, the withholding or withdrawing of unwanted medical treatments falls within the right to informed medical consent and it is subjected to specific guidelines and safeguards in order to protect the patient’s autonomy (§175).
According to Professor Sandor, who produced an expert opinion for the Court, the right to informed consent is paramount in bioethics. On the other hand, “patients could refuse care, but could not ask for something specific” (§56). For these reasons the Court held that there has been no violation of art. 14 in conjunction with art. 8 of the Convention.
Separate opinions
Two judges’ separate opinions provide an opportunity to delve deeper into the reasoning of the Court’s majority, as they both address the fundamental principles underlying the final decision. Judge Wojtyczek in his separate concurring opinion disagreed with the majority that the applicant’s request to have access to physician assisted dying would fall under his right to respect his private life. The judge emphasised how the right to life – as the practical and effective basis for the enjoyment of all other rights – may hardly “encompass decisions about one’s own life and death” and for this reason, the right to private life, should not extend to the choice of death (§4, Judge Wojtyczek partly concurring, partly dissenting opinion). He noted that the suffering stemming from a personal feeling in relation to the absence of meaning of life may be exacerbated (or not properly tackled) if people can choose their own death.
Judge Felici, dissenting on both accounts with the Court’s majority, firstly emphasised his impression that “the applicant’s legitimate concerns were not taken into account, and that his legitimate request for help fell on deaf ears” (§7, Judge Felici dissenting opinion). In fact, according to Judge Felici, palliative care could not be considered a feasible option to ease the applicant’s suffering since “the expert consulted have indicated that there is currently no medical treatment capable of alleviating existential suffering” (§9, Judge Felici dissenting opinion, my emphasis). In other words, the dissenting Judge stressed an evident reality: so far medicine has not been able to offer a cure to the sentiment that life has lost its meaning. And, for this reason, assisted dying is envisaged as the only possible answer to the applicant existential cry for help. Consequently, the dissenting judge finds that the impossibility for the applicant to avail himself of assisted dying provisions both in his country and abroad would breach his right to privacy enshrined by art. 8 of the Convention.
Specifically, Hungary – compared to other member states which permit assisted dying or are paying great attention on the matter – would have failed to address the severe suffering of the applicant (§5, Judge Felici dissenting opinion). Therefore, Judge Felici dissented that in this instance the margin of appreciation doctrine (which applies on sensitive matters where there is no uniform agreement) should not be invoked. Giving that, “there are no insurmountable legal obstacles to affirming a positive obligation on the part of the State, having regard to all the characteristics of this case, in relation to the application of Article 8 of the Convention” (§6, Judge Felici dissenting opinion).
Secondly, the Judge disagreed with the Court majority’s decision according to which the applicant’s medical condition should be considered similar to the one endured by terminally-ill patients subjected to invasive life-sustaining medical treatments since Mr Kasai’s condition has made him dependant on others for all his personal needs. Hence Judge Felici argued that “the subordination of the decision to take one’s life to whether one is dependent on life-saving treatment represents an unnecessary reduction of the protection of the right to life and an interference in private life, understood as the individual’s capacity for self-determination” (§13, Judge Felici dissenting opinion).
Dr Ilaria Bertini is a Research Fellow at BIOS Centre
The case of R (TTT) v Michaela Community Schools Trust [2024] EWHC 843 (Admin) in the High Court before Mr Justice Linden concerned a claim brought by a pupil referred to as a TTT (“the Claimant”) against the Michaela Community Schools Trust; (“the School”). The School is a secular secondary free school in the London Borough of Brent, which appeared as an interested party. The School is ethnically and religiously diverse, although over half of the pupils, including the Claimant are Muslims [1].
This post addresses only Ground 1 of the Claimant’s claim – alleged breach of the right to religious freedom under Article 9, ECHR – although the judgment (all 83 pages of it!) includes extensive discussion on Indirect Discrimination [214-232], the Public Sector Equality Duty (“PSED”) [257-273] and school exclusions [294-311], none of which were successful save for Ground 4b which concerned procedural unfairness around exclusions.
The following piece was first published on the UK Constitutional Law Blog on 25 April 2024 and is reproduced here with their permission, for which the editors are grateful
Commentary on the Safety of Rwanda (Asylum and Immigration) Act (“RA”), which is shortly to receive Royal Assent, has concentrated principally on its deeming of Rwanda as a safe country whilst ousting the supervision of courts. This post considers a separate issue – section 4 of the Act as it applies to victims of slavery (“VOS”). Section 4 provides a carve out from the Act’s deeming provisions where the Home Secretary considers Rwanda is unsafe for an individual “based on compelling evidence relating specifically to their particular individual circumstances”. It also providescourts with a power of review of that question.
This post argues that, read in the light of the common law constitutional prohibition of slavery (“POS”), s.4 should prevent all suspected and confirmed victims of slavery from being removed against their will to Rwanda without, at the least, a detailed assessment of their specific risks of re-trafficking there.
Science tells us that animals are social and sentient creatures, that they experience the world much like we do. But the law treats them very differently. Despite some progress, animals remain inadequately protected, and they can suffer in entertainment, research, farming, and conflicts.
The interconnectedness of humans, animals and the environment is recognised by the World Health Organisation, and the body of scientific work into intelligence in the animal kingdom continues to grow: the songs of Humpback whales are passed down through generations; crows and ravens are renowned for their exceptional problem-solving skills; elephants display empathy and emotional sensitivity; chimpanzees and orangutans exhibit complex tool use; dolphins engage in sophisticated vocalisations and coordinated behaviours.
In a significant ruling, the Court of Appeal has quashed the conviction of the appellant for an offence contrary to Section 1 of the Malicious Communications Act 1988 based on an email written to local councillors in a political dispute. In R v Casserly [2024] EWCA Crim 25, The Court gave guidance on – and placed emphasis on the importance of – directing juries on the right to free speech under Article 10 ECHR. The appeal considered the interaction between s 1 of the Malicious Communications Act 1988 and Article 10.
The appeal in Wolverhampton City Council and others v London Gypsies and Travellers and others [2023] UKSC 47 concerned injunctions obtained by over 38 different local authorities between 2015 and 2020 to prevent unauthorised encampments by Gypsies and Travellers. These “newcomer injunctions” as they are known, are a wholly new form of injunction, granted without prior notice, against persons unidentified at time of the grant of the injunction and who have not yet performed, or even threatened to perform the acts which the injunction prohibits. They therefore apply “to potentially anyone in the world” [143(i)].
Local authorities sought to use such injunctions, due to the inefficacy of obtaining an injunction against named Gypsies or Travellers who, by the time proceedings have commenced, have left, and been replaced by another group, against whom the injunction has no effect.
Last month marked one year since the startling repeal of Roe v Wade on the 24th June 2022 – the day the US Supreme Court rowed back the right of American women to obtain an abortion. Almost exactly a year later, back in the UK, last month saw the conviction of Carla Foster for the late abortion of her 32-week-old foetus. The case has brought abortion law back into the public conscience this year and reignited the fears around the safety of women’s rights to abortion in the UK. Thousands of protestors descended on the steps of the Royal Courts of Justice days after the conviction was announced, fighting for a woman’s right to abortion to be enshrined in UK law and opposing the fact that, legally, abortion remains a crime in the UK.
On 29 November 2019 Usman Khan attended a rehabilitation event at Fishmongers’ Hall and stabbed five people, two fatally. On 2 February 2020 Sudesh Amman attacked two passers-by in Streatham High Road with a knife before being shot dead by police. Both men had previously been convicted of terrorism offences. Both men had been automatically released on licence halfway through their custodial sentences.
Following these attacks, on 3 February 2020, the Secretary of State for Justice made a statement to the House of Commons highlighting that in the interests of public protection immediate action needed to be taken to prevent automatic early release halfway through an offender’s sentence without oversight by the Parole Board. He announced that terrorist offenders would now only be considered for release once they had served two-thirds of their sentence and would not be released before the end of the full custodial term without Parole Board approval. This proposal was passed in England and Wales with the enactment of the Terrorist Offenders (Restriction of Early Release) Act 2020. It was extended to Northern Ireland by the Counter Terrorism and Sentencing Act 2021 (“the Act”).
2023 has already been a landmark year for nuisance, with the Supreme Court handing down its controversial decision in Fearn v Tate Gallery (as discussed on this blog).
The good news for those with a particular interest in the bothersome behaviour of neighbours is that Fearn is only the start.
This post focuses on one of the many fascinating points raised by these cases – namely, the slippery concept at the heart of both Davies and Jalla: continuing nuisance.
The pumping of raw, untreated sewage into Britain’s waterways is one of the defining political issues of the day. Its potency as a legal issue, however, is limited. That, at least, is the outcome of R (Wild Justice) v OFWAT [2023] EWCA Civ 28.
Sewage polluting the River Coln, at Fairford, Gloucestershire, this January. Photograph: Graeme Robertson/Guardian
The Claimant, a not-for-profit organisation which advocates for the protection of wildlife and nature, asked the Court of Appeal for permission to apply for judicial review of the Respondent’s alleged failure to perform its duties to regulate the discharge of raw sewage.
Permission had already been refused twice below – on the papers by Ellenbogen J, and at an oral hearing by Bourne J. This appeal was heard by Bean LJ.
We are pleased to welcome this guest post from Prof Brice Dickson, Emeritus Professor of International and Comparative Law at Queen’s University Belfast, in which he sets out the international human rights monitoring mechanisms applicable to the UK and considers the UK’s engagement with the relevant monitoring processes (Eds).
On 10 November 2022 the UN Human Rights Council conducted its fourth Universal Periodic Review of the UK’s compliance with international human rights standards. The Council’s report was adopted just six days later and contained no fewer than 302 recommendations from other States on how the UK could improve its human rights record. That figure is up from 227 in 2017. For early accounts of the review meeting see the pieces by Marcial Boo and Robert Booth.
The UPR, of course, is just one of many international mechanisms for monitoring human rights in the UK. In a book published this month, International Human Rights Monitoring Mechanisms: A Study of their Impact in the UK, I examine the full range of monitoring mechanisms to which the UK is subject and attempt to evaluate how they have operated to date, especially since 2000. In particular, I try to determine what difference they have made to the protection of human rights in practice. The analysis extends to monitoring conducted by a committee of the International Labour Organisation and by the Council of Europe’s Group of States against Corruption (GRECO), two bodies which do not usually attract the attention of human rights lawyers.
In this guest post, Dr Ilaria Bertini, Research Fellow at Bios Centre, examines the recent decision of a Chamber of the Third Section of the European Court of Human Rights in Mortier v. Belgium, which examined Belgian law relating to euthanasia.
Introduction
The European Court of Human Rights recently delivered a landmark judgment, Mortier v. Belgium (78017/17), on a case of euthanasia.
The case concerns an adult Belgian citizen who underwent a euthanasia procedure at a time when she was suffering from severe depression, without her son or daughter being properly informed. Hence her son, Tom Mortier, claimed that the government failed to protect both her right to life (art. 2 ECHR) and her right to respect for private and family life (art. 8 ECHR).
According to the Belgian Act on Euthanasia (28th May 2002) it is legal for a physician to perform euthanasia if the following three criteria are met: the patient is legally competent and conscious at the time of the request, the request is made autonomously without external pressure, and the patient is suffering from a “medically futile condition of constant and unbearable physical or mental suffering that cannot be alleviated, resulting from a serious and incurable disorder caused by illness or accident.” An independent second opinion might be needed to assess the patient’s willingness to die. Once the euthanasia is approved, there is a cooling off period of one month before the act takes place. Afterwards a Commission of 16 persons seeks to check all the reports to make sure that the procedure has complied with the law.
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