‘Silk of the Year’ hat-trick for Aidan O’Neill QC
Congratulations to Ampersand’s Aidan O’Neill QC, who has retained his title as Silk of the Year at the Law Awards of Scotland.
Aidan has been in many high profile cases in the past year including successes in the so-called Scottish Brexit case (Wightman v Secretary of State) and proroguing of Parliament case (Cherry and others v Advocate General for Scotland).
While an outright winner in 2017, Aidan shared the award in 2018 with solicitor-advocate, John Scott, QC. This year, as the outright winner, makes it 3 out of 3 for Aidan.
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Inner House confirms Serco’s actions were lawful in seeking to recover possession of property provided to failed asylum seekers and concluded that Serco was not acting as a hybrid public authority
Ali (Iraq) v Serco Ltd [2019] CSIH 54
Facts
The reclaimer is a failed asylum seeker, whose appeal rights became exhausted in November 2017. The reclaimer was provided with accommodation while her asylum claim was being determined. Nearly 6 months after the asylum claim was refused. the Secretary of State served notice that asylum support and accommodation would be withdrawn. The reclaimer was to quit her accommodation by 13 June 2018. Persons provided with asylum support accommodation are excluded from the protection against eviction without court order in terms of s.23 of the Rent (Scotland) Act 1984 (“1984 Act”). A form of support is available to failed asylum seekers in terms of s.4(2) of the Immigration and Asylum Act 1999 (“1999 Act”) if they meet certain criteria. The reclaimer argued that notwithstanding (i) her asylum claim had been refused, (ii) persons provided with asylum support accommodation were excluded from the terms of s.23 of the 1984 Act, and (iii) the availability of support in terms of s.4(2) of the 1999, it was unlawful for Serco to seek to recover possession of property without a court order.
Issues
The Court identified 4 key issues:
- Did the reclaimer have a right under common law preventing eviction without court order?
- Did the reclaimer have a right akin to a lease created by virtue of a jus quaesitum tertio preventing eviction without court order?
- Would eviction without a court order breach the reclaimer’s rights under Articles 3 or 8 of the ECHR?
- Was the Lord Ordinary correct to find that Serco were a ‘hybrid public authority’ for the purpose of the Human Rights Act 1998?
Decision
Issue 1 – A common law right?
The first issue had not been argued in front of the Lord Ordinary, but the Inner House considered its substance. The reclaimer accepted that she was excluded from the statutory protection against eviction without court order. However, the statute expressly preserved any existing common law rights. The reclaimer argued that there was a right at Scots common law that prevented eviction without court order. In Conway v Glasgow City Council, however, the only preserved common law right was said to be reasonable notice. There was a weight of Inner House authority against the contention that eviction of contractual occupiers (rather than leaseholders) without court order was per se unlawful at common law. The reclaimer’s occupancy was precarious from the outset. No court process was required at common law. Accordingly, the reclaimer’s argument was rejected (at [43] – [46]).
Issue 2 – A jus quaesitum tertio?
This argument was not advanced to the Lord Ordinary, but sought to argue that Home Secretary and Serco had agreed a contract to benefit the reclaimer, and the reclaimer could enforce this agreement. The effect was said to be that a right akin to a lease was created and thus eviction without court order would be unlawful. The Court decisively rejected this argument (at [47]). Crucially, the reclaimer was averred to be in a contractual relationship directly with Serco, and the reclaimer’s argument, if correct, would have directly contradicted the specific terms of that agreement.
Issue 3 – Article 3 or 8 breach?
The Court dismissed the case under Articles 3 and 8 as having no merit (at [48]). The threat of lawful eviction could not reach the minimum severity threshold of Article 3. The Court noted that support is available under s.4 of the 1999 Act for failed asylum seekers in certain situations. The refusal or withdrawal of s.4 support carries a right of appeal. The Court raised the possibility of challenging the Secretary of State’s decision to issue a statutory notice to quit by way of judicial review, combined with interim interdict. In respect of Article 8, there were various ways in which a failed asylum seeker could raise the question of proportionality without the necessity of an eviction action having to be raised against them. Lord Hodge’s observations in R(N) v Lewisham LBC were approved as being applicable to this context.
Issue 4 – Hybrid public authority
The Lord Ordinary had concluded that Serco were exercising “functions of a public nature” and were thus would have to comply with Convention rights. The Inner House disagreed (at [52]). Fundamentally, the Court held that the exercise of the public law function remains with the Secretary of State; Serco were exercising private law functions. The Secretary of State remains answerable for the public law duty to arrange for the provision of accommodation to asylum seekers. Serco were simply performing a service under contract. Accordingly the cross appeal was allowed (at [58]).
Analysis
The Inner House rejected each of the reclaimer’s arguments. Neither Serco, nor the Home Secretary, acted unlawfully in any of the ways alleged. Moreover, Serco was not acting as a ‘hybrid public authority’.
Contrary to some commentary in the aftermath of the decision, the effect of this ruling was not that the Home Secretary can ‘outsource its statutory and international legal obligations’. Quite the reverse. As noted at [56], “the state cannot absolve itself of responsibility for such public law duties as the provision of accommodation to asylum seekers by delegating its responsibility to private bodies”.
Nor is it the case that the government can simply ‘contract out of the Human Rights Act’. Instead, as the Court noted, “responsibility for the exercise of the public law duty is not delegated, but remains with the Home Secretary”. What this means is that in this context a public law challenge is properly made against the Home Secretary, who decides whether support should be provided, and not against a private contractor.
The reality is, as the Court noted at [48], that when an asylum claim is refused the person is expected to leave the UK. If there are good reasons why a person simply cannot leave, then statutory support is available. Parliament decided to exclude those in asylum support accommodation from the statutory protection against eviction without court order that other “residential occupiers” have. In the circumstances, the Court was left with little option but to refuse the reclaiming motion.
Opinion of Inner House can be viewed here.
Representation
Ampersand’s Michael Way was instructed on behalf of the 1st and 2nd Respondent at Note of Argument stage in the reclaiming motion and in related interdict proceedings.
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Ali (Iraq) v Serco Ltd [2019] CSIH 54
Inner House confirms Serco’s actions were lawful in seeking to recover possession of property provided to failed asylum seekers and concluded that Serco was not acting as a hybrid public authority
Facts
The reclaimer is a failed asylum seeker, whose appeal rights became exhausted in November 2017. The reclaimer was provided with accommodation while her asylum claim was being determined. Nearly 6 months after the asylum claim was refused. the Secretary of State served notice that asylum support and accommodation would be withdrawn. The reclaimer was to quit her accommodation by 13 June 2018. Persons provided with asylum support accommodation are excluded from the protection against eviction without court order in terms of s.23 of the Rent (Scotland) Act 1984 (“1984 Act”). A form of support is available to failed asylum seekers in terms of s.4(2) of the Immigration and Asylum Act 1999 (“1999 Act”) if they meet certain criteria. The reclaimer argued that notwithstanding (i) her asylum claim had been refused, (ii) persons provided with asylum support accommodation were excluded from the terms of s.23 of the 1984 Act, and (iii) the availability of support in terms of s.4(2) of the 1999, it was unlawful for Serco to seek to recover possession of property without a court order.
Issues
The Court identified 4 key issues:
- Did the reclaimer have a right under common law preventing eviction without court order?
- Did the reclaimer have a right akin to a lease created by virtue of a jus quaesitum tertio preventing eviction without court order?
- Would eviction without a court order breach the reclaimer’s rights under Articles 3 or 8 of the ECHR?
- Was the Lord Ordinary correct to find that Serco were a ‘hybrid public authority’ for the purpose of the Human Rights Act 1998?
Decision
Issue 1 – A common law right?
The first issue had not been argued in front of the Lord Ordinary, but the Inner House considered its substance. The reclaimer accepted that she was excluded from the statutory protection against eviction without court order. However, the statute expressly preserved any existing common law rights. The reclaimer argued that there was a right at Scots common law that prevented eviction without court order. In Conway v Glasgow City Council, however, the only preserved common law right was said to be reasonable notice. There was a weight of Inner House authority against the contention that eviction of contractual occupiers (rather than leaseholders) without court order was per se unlawful at common law. The reclaimer’s occupancy was precarious from the outset. No court process was required at common law. Accordingly, the reclaimer’s argument was rejected (at [43] – [46]).
Issue 2 – A jus quaesitum tertio?
This argument was not advanced to the Lord Ordinary, but sought to argue that Home Secretary and Serco had agreed a contract to benefit the reclaimer, and the reclaimer could enforce this agreement. The effect was said to be that a right akin to a lease was created and thus eviction without court order would be unlawful. The Court decisively rejected this argument (at [47]). Crucially, the reclaimer was averred to be in a contractual relationship directly with Serco, and the reclaimer’s argument, if correct, would have directly contradicted the specific terms of that agreement.
Issue 3 – Article 3 or 8 breach?
The Court dismissed the case under Articles 3 and 8 as having no merit (at [48]). The threat of lawful eviction could not reach the minimum severity threshold of Article 3. The Court noted that support is available under s.4 of the 1999 Act for failed asylum seekers in certain situations. The refusal or withdrawal of s.4 support carries a right of appeal. The Court raised the possibility of challenging the Secretary of State’s decision to issue a statutory notice to quit by way of judicial review, combined with interim interdict. In respect of Article 8, there were various ways in which a failed asylum seeker could raise the question of proportionality without the necessity of an eviction action having to be raised against them. Lord Hodge’s observations in R(N) v Lewisham LBC were approved as being applicable to this context.
Issue 4 – Hybrid public authority
The Lord Ordinary had concluded that Serco were exercising “functions of a public nature” and were thus would have to comply with Convention rights. The Inner House disagreed (at [52]). Fundamentally, the Court held that the exercise of the public law function remains with the Secretary of State; Serco were exercising private law functions. The Secretary of State remains answerable for the public law duty to arrange for the provision of accommodation to asylum seekers. Serco were simply performing a service under contract. Accordingly the cross appeal was allowed (at [58]).
Analysis
The Inner House rejected each of the reclaimer’s arguments. Neither Serco, nor the Home Secretary, acted unlawfully in any of the ways alleged. Moreover, Serco was not acting as a ‘hybrid public authority’.
Contrary to some commentary in the aftermath of the decision, the effect of this ruling was not that the Home Secretary can ‘outsource its statutory and international legal obligations’. Quite the reverse. As noted at [56], “the state cannot absolve itself of responsibility for such public law duties as the provision of accommodation to asylum seekers by delegating its responsibility to private bodies”.
Nor is it the case that the government can simply ‘contract out of the Human Rights Act’. Instead, as the Court noted, “responsibility for the exercise of the public law duty is not delegated, but remains with the Home Secretary”. What this means is that in this context a public law challenge is properly made against the Home Secretary, who decides whether support should be provided, and not against a private contractor.
The reality is, as the Court noted at [48], that when an asylum claim is refused the person is expected to leave the UK. If there are good reasons why a person simply cannot leave, then statutory support is available. Parliament decided to exclude those in asylum support accommodation from the statutory protection against eviction without court order that other “residential occupiers” have. In the circumstances, the Court was left with little option but to refuse the reclaiming motion.
Opinion of Inner House can be viewed here.
Representation
Ampersand’s Michael Way was instructed on behalf of the 1st and 2nd Respondent at Note of Argument stage in the reclaiming motion and in related interdict proceedings.
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Ampersand Advocates Top Rankings success in latest Chambers and Partners UK Bar Guide
Ampersand has again received top tier rankings across a number of areas of practice in the latest published guide to the legal profession, Chambers and Partners UK Bar Guide 2020.
Ampersand received 60 listings across 16 areas of practice, ranking as top tier (band 1) in Clinical Negligence as a Set, and band 2 in Administrative & Public law, Civil Liberties & Human Rights, Commercial Dispute Resolution, Planning & Environment, Personal Injury, Product Liability and Restructuring/Insolvency as a Set. 5 members are noted as “star individuals”.
Noted as a Band 1 set for Clinical Negligence, Ampersand has 18 rankings in this area, including 2 “Star Individuals”. The guide says “Ampersand dominates the Scottish medical negligence market due to its outstanding reputation and impressive offering of advocates. It has a wide selection of juniors and silks at the stable, who act on behalf of both claimants and defenders. Members have far-reaching expertise, covering all areas of clinical negligence, including the most severe birth injuries, fatal surgical errors and cancer cases, as well as widely publicised group actions concerning medical device liability, such as the pelvic mesh litigation. Instructing solicitors point out that the set “has depth and very strong, specialised practitioners.” The clerks also receive high praise “The service is first class. The clerks are extremely approachable, very helpful and nothing is too much trouble for them.” “Alan Moffat is the lead clerk and is a good point of contact. He is helpful and accommodating, so I can go directly to him if I need something urgently.” The “Star Individuals” are Maria Maguire QC and David Stephenson QC.
Band 2 listings include Administrative and Public law where Ampersand is noted as a “Highly regarded stable which possesses several standout advocates acting in important constitutional, commercial and human rights cases. The advocates represent petitioners and respondents in judicial reviews, advise public bodies on the interpretation of regulations and legislation, and act for core participants in public inquiries”. In Civil Liberties & Human Rights the Band 2 listing notes Ampersand as a “A highly regarded stable, Ampersand Advocates has members who represent both claimants and defendants in high-profile civil liberties and human rights cases. Advocates regularly appear at the highest courts in Scotland and the UKSC, as well as the ECtHR and CJEU.”.
In Commercial Dispute Resolution it states “Ampersand Advocates is a highly regarded stable, noted for its involvement in a wide range of complex commercial disputes. The stable houses a number of experienced commercial advocates at both silk and junior levels, and attracts instructions from a diverse client base that includes several financial institutions and large corporates. Its advocates offer expertise in professional negligence, construction and commercial contracts disputes, as well as matters involving intellectual property, planning and insolvency.”
Ampersand’s Commercial expertise is further noted in Restructuring and Insolvency, which includes “Star Individual” David Sellar QC, stating Ampersand “Ampersand Advocates is a strong stable, housing some of the most distinguished restructuring and insolvency advocates in Scotland. It is a go-to stable for companies and their directors, banks and various government departments seeking restructuring advice and representation in major insolvency cases. Members are also regularly instructed by insolvency practitioners to assist with asset recovery matters, and offer significant expertise in international asset-tracing.”
Ampersand’s Personal Injury work is again acknowledged with the guide noting “A highly regarded stable in the personal injury market, Ampersand Advocates retains its reputation as a go-to stable for all manner of injury claims. In addition to offering representation to pursuers in complex and high-value catastrophic and fatal injury claims, the stable’s advocates are also regularly instructed by defenders, and have experience acting on behalf of government agencies and several major insurers. Areas of particular strength for the stable include cases arising from RTAs, accidents at work and accidents abroad, and its advocates are noted for their expert handling of complex employers’ and occupiers’ liability claims. The tenants are also frequently called upon to represent a variety of parties, including local authorities, health boards and bereaved families in fatal accident inquests. Instructing solicitors praise Ampersand as “a very professional stable which provides a high level of service,” adding that “you can tell that everyone there really cares about what they’re doing.”. The clerks get a special note for being “very organised and you can rely on the team to get back to you.” “The clerks are very good at dealing with any queries and are very flexible and very friendly – you never have any difficulties getting in touch with them.” “The clerking team is friendly, reliable, quick at responding and always happy to help.” The “very proactive and easy to deal with” Alan Moffat is the head clerk.” The listing includes Maria Maguire QC and Graham Primrose QC as “Star Individuals”.
In Planning and Environment it states “Ampersand Advocates is distinguished for the substantial planning and environmental expertise of its advocates. It acts for local authorities and all kinds of developers in cases heard at all levels of the court system, including the Supreme Court. The environmental aspects of energy developments are a great source of instructions for Ampersand Advocates. Members of the stable are regularly involved in high-profile matters, including the public inquiry into the refusal of planning permission for the development of the Royal High School in Edinburgh, a challenge to the planning consent for Aberdeen FC’s new stadium and a Supreme Court case dealing with the complexities of European law in relation to a wind farm development.” This includes “Star Individual” Malcolm Thomson QC.
Ampersand is also a Band 2 set in Product Liability stating “A respected presence in the product liability field, with a strong track record of representing pursuers and defenders in a broad array of claims. The stable is able to draw on its impressive capabilities in professional liability and personal injury.”
Ampersand’s full listings can be viewed on the Chambers and Partners website here.
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The Prorogation Case: A Panel Discussion
University of Edinburgh event
Chair
Professor Christine Bell (Edinburgh)
Panel
Professor Aileen McHarg (Durham)
Professor Stephen Tierney (Edinburgh)
Mr Paul Reid (Ampersand Advocates)
Time: 2pm – 4pm
This event is free and open to all. No registration necessary.
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Ampersand Advocates ‘goes above and beyond at all times’ in latest Legal 500 UK Bar listings
Ampersand is delighted to be once again be recommended as a top-tier set by The Legal 500 UK Bar Directory in their latest listings for 2019 published today.
The guide says “‘From a user’s perspective’, Ampersand Advocates ‘goes above and beyond at all times to assist wherever possible’. Like the other Scottish stables, a diverse range of work comes through its doors, however, tort, real estate, and commercial matters are key strengths, and arbitration is a growing area of focus. ‘All the clerks are friendly, accommodating and very professional’, however at the most senior level Alan Moffat ‘will go out of his way to make sure you get the right counsel for the job’, and his deputy Sheena Hume is ‘particularly efficient and easy to deal with’. Vinit Khurana QC and Una Doherty QC took silk in 2018.”
Ampersand has 36 listings across 10 areas of practice in the Legal 500 UK 2019 guide. The Scottish bar section can be viewed here.
Civil liberties, human rights, public inquiries, and public and administrative law (including local government)
Key areas of work at Ampersand Advocates include EU law, judicial review, and procurement matters. Aidan O’Neill QC recently lead on behalf of the petitioners in Wightman v Secretary of State for Exiting the European Union, an Court of Justice of the European Union case concerning if it was possible for a member state to revoke its notification of intent to leave the European Union under Article 50.
Leading Seniors
Aidan O’Neill QC – Ampersand Advocates ‘ Intellectually impressive and creative in his approach to dealing with issues of public law. ’
Douglas Ross QC – Ampersand Advocates ‘ Highly intelligent and tenacious, with good common sense ’
Dorothy Bain QC – Ampersand Advocates ‘ Highly recommended for civil liberties work. ’
Leading Juniors
Laura-Anne van der Westhuizen – Ampersand Advocates ‘ A first-class legal mind who deals well with complicated cases. ’
Timothy Young – Ampersand Advocates ‘ Technically excellent in public procurement matters. ’
Commercial litigation
Ampersand Advocates is home to a strong contingent of commercial litigators, with experience in a wide range of commercial cases. Notable recent highlights include Take-Two Interactive Software Inc and Rockstar Games Inc v Aaron Renicks, in which Usman Tariq acts, as junior to Roddy Dunlop QC for the developers of Grand Theft Auto who are pursuing a claim against the developer of a modification for the game. Giles Reid recently acted for the borrower in a case concerning the oral variation of a loan agreement, as well as interim orders preventing the lender from commencing bankruptcy.
Leading Seniors
Alan Dewar QC – Ampersand Advocates ‘ Hugely experienced, completely unflappable and always fights his client’s corner. ’
Robert Howie QC – Ampersand Advocates ‘ His depth of knowledge in commercial matters is unparalleled. ’
Leading Juniors
Ross Anderson – Ampersand Advocates ‘ Never afraid to take on even the largest of legal challenges. ’
Giles Reid – Ampersand Advocates ‘ A legal encyclopaedia. ’
Usman Tariq – Ampersand Advocates ‘ His advice and knowledge is consistently of the highest standard. ’
Company and insolvency
Members of Ampersand Advocates are particularly experienced in insolvency matters, acting for all parties in such cases. Of recent note, Timothy Young recently acted for the liquidators in Rowallan Asset Management Limited v Morris & Co, which involved a claim for gratuitous alienation (a transfer under value to dissipate assets) relating to a large agricultural property holding company.
Leading Seniors
David Sellar QC – Ampersand Advocates ‘ His technical knowledge of company and insolvency law makes him a go-to. ’
Leading Juniors
Timothy Young – Ampersand Advocates ‘ Clients appreciate his confident yet approachable demeanour. ’
Employment
Russell Bradley of Ampersand Advocates acts for employers in a wide range of first instance matters, with particular expertise of defending whistle-blowing and unfair dismissal claims.
Russell Bradley – Ampersand Advocates ‘ Extremely tenacious when needed and great with clients. ’
Intellectual property, information technology and media
Usman Tariq at Ampersand Advocates is highly recommended for contentious intellectual property matters, as well as maintaining a substantial presence in the IT sector, particularly in matters concerning gaming and digital applications. Recent instructions include a substantial trade mark infringement and passing off dispute between two manufacturers of electronic cigarettes, where Tariq acted for the pursuers, as well as conducting breach of interdict cases on behalf of large rights-holders such as Sky and the Performing Right Society.
Usman Tariq – Ampersand Advocates ‘ The best all-round IP junior in Scotland. ’
Personal injury and medical negligence
Ampersand Advocates is home to one of the key teams in personal injury and clinical negligence within Scotland, and has ‘real strength in depth’ across all levels of call. Members have significant expertise in all areas of such work, with recent cases including fatal accidents, medical device litigation, catastrophic injury and birth injury. A notable recent case for the set is Gibson v Babcock International, a leading case on the issue of secondary exposure to asbestos, in which Simon Di Rollo QC led for the pursuers.
Leading Seniors
Lisa Henderson QC – Ampersand Advocates ‘ Highly numerate, excellent at drafting complex schedules of loss and very personable. ’
Geoffrey Mitchell QC – Ampersand Advocates ‘ Highly respected by both health boards and claimant solicitors ’
Douglas Ross QC – Ampersand Advocates ‘ A relatively new silk who already posesses all the qualities of an experienced one. ’
Simon Bowie QC – Ampersand Advocates ‘ Recommended for significant clinical negligence cases. ’
Una Doherty QC – Ampersand Advocates ‘ Extremely reliable, quick-witted and efficient. ’
Maria Maguire QC – Ampersand Advocates ‘ Combines superb advocacy skills and a forensic attention for detail. ’
Simon Di Rollo QC – Ampersand Advocates ‘ Highly experienced in industrial disease claims. ’
Lauren Sutherland QC – Ampersand Advocates ‘ Leaves no stone unturned to find a path to a successful outcome. ’
Leading Juniors
Jamie Dawson – Ampersand Advocates ‘ Fantastic at dealing with complex medical evidence and technical details. ’
Fiona Drysdale – Ampersand Advocates ‘ Well-prepared, good with clients and has an eye for detail. ’
Chris Marney – Ampersand Advocates ‘ A very safe pair of hands with good commercial sense. ’
Jennifer Nicholson – Ampersand Advocates ‘
A strong negotiator who has achieved fantastic results for clients. ’
Planning, environmental and licensing
Ampersand Advocates is home to planning law specialists Marcus McKay QC and Laura-Anne van der Westhuizen, who are often instructed in complex or high-profile inquiries and appeals. Notable recent highlights include McKay’s representation of The Viking Wind Farm in a consent application under crofting legislation, and Westhuizen’s work on behalf of the Scottish ministers in an appeal lodged by a dairy farm following the refusal of planning permission for a large greenbelt development.
Leading Seniors
Marcus McKay QC – Ampersand Advocates ‘ Highly experienced in energy-related planning work. ’
Leading Juniors
Professional Negligence
Members of Ampersand Advocates are instructed by both pursuers and defenders in professional negligence cases, across the full range of industry sectors. Recent highlights include Midlothian Council v Bracewell Stirling, where Paul Reid acted as a junior to Alastair Duncan QC on behalf of the defenders, an architectural firm alleged to be liable for negligent ground investigations carried out by another company.
Paul Reid – Ampersand Advocates ‘ One to watch for professional negligence matters. ’
Property, construction and agriculture
Members of Ampersand Advocates are instructed in a wide range of commercial development and property disputes, as well as agricultural issues and nuisance claims. Timothy Young recently advised the defenders on several potential cases concerning property damage caused by incorrectly constituted mortar in the development of a large residential estate.
Leading Seniors
Leading Juniors
Ross Anderson – Ampersand Advocates ‘ Definitely one to watch for property litigation. ’
Timothy Young – Ampersand Advocates ‘ Exceptionally intelligent with a gift for honing in on the points that matter. ’
Tax, trusts and pensions
Ross Anderson at Ampersand Advocates has significant experience acting for HM Revenue and Customs in both the First-Tier and Upper Tribunals. He also appeared as appearing as a junior to Kieron Beal QC of Blackstone Chambers in London, again on behalf of the Revenue, in the Supreme Court case Frank A Smart & Sons v HMRC, which concerned the deductability of VAT incurred when purchasing entitlements to the Single Farm Payment, a European Union farming subsidy.
Ross Anderson – Ampersand Advocates ‘ He has made a sure-footed transition from academia to the Bar. ’
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