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Legislation
THE LEGAL FRAMEWORK
THE CHILDREN ACT
The legal framework, for the care and
protection of children, is contained
within the Children Act 1989. All persons
likely to be involved in the protection
of children should have a working knowledge
of this piece of legislation.
Whilst the following paragraphs outline
the current legal framework, relating
to the protection of children, they should
not be taken as a complete statement
of all the relevant legal provisions.
Legal advice should always be sought
where legal action is being considered.
The Children Act 1989 should be used
as a source of reference by those working
in child protection.
The Rules of Court which will also be
relevant are the Family Proceedings Courts
(Children Act 1989) Rules 1991/1395 (Magistrates’ Courts)
and the Family Proceedings Rules 1991
(S.1.1991/1247) (County and High Court)
GENERAL PRINCIPLES OF THE CHILDREN ACT
A number of general principles, which
need to be borne in mind when considering
any part of the legal framework are
outlined in the Children Act. These
are:
-
The welfare of the child shall be the
paramount consideration of the court.
(Section 1(1)).
The court shall have regard to the
general principle that any delay in
determining
a question with respect to the upbringing
of a child is likely to prejudice the
welfare of the child. (Section 1(2)).
-
The court shall have regard in particular
to a number of matters set out in
the welfare checklist in Section 1(3),
including the
wishes and feelings of the child,
his/her
age, gender etc. when considering
whether to make, vary or discharge
any section
8 order which is opposed, or any
order under Part 1V.
-
Where a child is
of sufficient understanding, medical
treatment may only be given
with his/her consent (except in
medical emergencies).
It is for the doctor to decide
whether the child is capable of giving
consent.
Children of 16 and over can give
their own consent. Where a child
is not of
sufficient understanding, the consent
of the parent,
including a person with parental
responsibility, is required. This
would include the
local authority where the child
is subject to
a Care Order. Children who are
capable of giving consent cannot be
medically
examined without their consent
when subject to a
Child Assessment Order (Section
43), Emergency Protection Order (Section
44), or Interim
Care or Supervision Order (section
38), or examined or treated in
accordance
with
a full Supervision Order (paragraphs
4(4)(a) and 5(5)(a) of Schedule
3) without their
consent. If there is a dispute
in other circumstances in which a child
refuses consent, the matter should
be put
to the court to resolve.
-
The court
shall not make an order unless it
considers that doing so would be
better
for the child than making no order
at all. (Section 1(5)).
More detailed guidance can be found
in the Children Act Guidance and Regulations,
Volume 1-Court Orders.
PREVENTION
Schedule 2 Children Act 1989
Section 17 Children Act 1989
The Local Authority has a duty to take
reasonable steps to identify the extent
to which there are children in need within
the Local Authority’s area. (Schedule
2, para.1) Every Local Authority has
a duty to take reasonable steps by providing
services, under Part III of the Act,
to prevent children within their area
suffering ill treatment or neglect. There
is a duty to share information about
any child who is likely to suffer harm
between Local Authorities where appropriate.
Paragraph 7 provides that every Local
Authority shall take reasonable steps
to reduce the need to bring proceedings
for Care or Supervision Orders or criminal
proceedings in relation to children.
Similarly there is a duty to encourage
children not to commit criminal offences
and to avoid the need for children in
their area to be placed in secure accommodation.
Section 17 of the Act makes it a general
duty of every Local Authority to:
-
safeguard
and promote the welfare of children
within their area who are in
need; and
-
so far as is consistent
with that duty, to promote the upbringing
of
such children
by their families, by providing a
range and level of services appropriate
to
those children’s needs.
Alternatively, they may arrange for
others to provide the services. Such
assistance may include assistance in
kind or, in exceptional circumstances,
in cash.
PROVISION OF ACCOMMODATION FOR CHILDREN
Section 20 Children Act 1989
Every Local Authority has a duty to
provide accommodation for any child in
need within their area who appears to
them to require accommodation as a result
of:
-
there being no person who has parental
responsibility for him/her;
-
his/her
being lost or abandoned; or
-
the person
who has been caring for him/her being
prevented (whether
or not permanently,
and for whatever reason) from providing
him/her with suitable accommodation
or care.
THE DUTY TO INVESTIGATE
Section 47 Children Act 1989
Section 37 Children Act 1989
The duty of the Local authority to
make enquiries following information
received suggesting that a child may
need protection is contained in Part
V of the Children Act.
The local authority has a duty to make
enquiries where they:
-
are informed that a child who lives,
or is found, in their area -(a) is
the subject of an Emergency Protection
Order;
or(b) is in police protection; or
-
have
reasonable cause to suspect that
a child who lives or is found in
their
area
is suffering or likely to suffer significant
harm. The Authority shall make, or
cause to make, such enquiries as
they consider
necessary to enable them to decide
whether they should take any action
to safeguard
or promote the child’s welfare
(S.47(1)).
This includes obtaining access to him
or her. Should access be denied, or information
withheld, they must take reasonable steps
to obtain access or information unless
they are satisfied that they already
have sufficient information. They may
call upon other Local Authorities, Health
Authorities, Education Authorities or
others for assistance and it shall be
the duty of such Authorities to assist
unless it would be unreasonable in the
circumstances.
Where, as a result of enquiries, they
conclude that action should be taken,
they must do so, as far as is practicable
(S.47(8)).
“Where, in family proceedings
in which a question arises with respect
to the welfare of any child, it appears
to the court that it may be appropriate
for a Care or Supervision Order to be
made in respect of him, the court may
direct the appropriate Authority to undertake
an investigation of the child’s
circumstances” (S.37(1)).
The Authority must then make enquiries
and consider whether it would be appropriate
to apply for a Care or Supervision Order,
or to provide services to help the child
and his/her family, or to take some other
action. If they decide not to apply for
a Care or Supervision Order, they must
give the court their reasons and tell
them what they are doing instead within
8 weeks unless the court directs otherwise.
EMERGENCY PROCEDURES
Emergency Protection Order (EPO)
Section 44 Children Act 1989
An Emergency Protection Order is a short
term order which enables a child to be
made safe when (s)he might otherwise
suffer harm. Application for an Emergency
Protection Order may be made by any person,
a Local Authority or an authorised person.
Grounds For Emergency Protection Order
Section 44 Children Act 1989
An Emergency Protection Order may only
be made if the court is satisfied that:
-
where the applicant is “any
person”,
there is reasonable cause to believe
that the child is likely to suffer
significant harm if (s)he is not
removed or does
not remain where (s)he is (S.44(1)(a)).
-
where
the applicant is the Local Authority
enquiries are being made with respect
to the child under Section 47(1)(b);
and those
enquiries are being frustrated by access
to the child being unreasonably refused
to a person authorised and access is
required urgently (S.44(1)(c)).
Powers and duties under Emergency
Protection Order Section 44(4) and
(5).
The effect of an EPO is to give parental
responsibility to the Local Authority
in addition to the parents or whoever
had it immediately before. The court
may order that the child be removed or
kept where (s)he is, and may give directions
about medical examinations or assessment.
It may also give directions about contact.
An order to remove the child will only
be made if necessary and (s)he should
be returned when it is safe to do so.
Duration
Section 45 Children Act 1989
An EPO lasts for a maximum of eight days.
On application, the court may extend
this for a maximum of a further 7 days;
the Order may only be extended once.
Application may be made to discharge
an Emergency Protection Order after 72
hours from the making of the Order. Such
application may be made by the child,
his/her parent, anyone with responsibility,
or anyone with whom (s)he was living
immediately before unless they were given
notice (in accordance with the Rules
of Court) of the hearing at which the
Order was made and were present at the
hearing. No application can be made for
discharge once the original period of
the Order has been extended by the court.
Including Exclusion Requirements In
Emergency Protection Orders
Section 44A of the Children Act 1989
(Amended by the Family Law Act 1996)
The Court may include an Exclusion Requirement
where it makes an Emergency Protection
Order with respect to the child and:
-
there is reasonable cause to believe
that, if the relevant person (RP) is
excluded from a dwelling-house in which
the child lives then either the child
will not be likely to suffer significant
harm within the context of S44 (1)(a)
or the enquiries referred to in S44
(1)(b)(c) will cease to be frustrated;
and
-
that another person living in the
dwelling-house
(whether a parent of the child or some
other person) is (a) able and willing
to give to the child the care which
it would
be reasonable to expect a parent to
give him, and (b) that other person
consents
to the inclusion of the Exclusion Requirement.
The Exclusion Requirement may include
one or more of the following:
-
a provision requiring the RP to
leave a dwelling-house in which he
is living
with the child;
-
a provision prohibiting
the RP from entering a dwelling-house
in which the child lives;
-
a provision
excluding the RP from a defined area
in which a dwelling-house
in which
the child lives is situated.
Duration of the Exclusion Requirement:
The Court may provide that the Exclusion
Requirement is to have effect for a
shorter period than the provisions
of the Emergency Protection Order.
Attaching a Power of Arrest:
The Court may attach a Power of Arrest
to the Exclusion Requirement provision
within an Emergency Protection Order.
Police Protection
Section 46 Children Act 1989
A police constable, having reasonable
cause to believe that a child would otherwise
be likely to suffer significant harm,
may either remove the child to suitable
accommodation or prevent his/her removal
from a hospital or other safe place.
No child may be kept in police protection
for more than 72 hours.
The police must take steps as soon as
reasonably practicable to inform the
child’s parents of what has been
done and the reasons for that action
being taken. If the child appears capable
of understanding (s)he must also be so
informed.
The police, where they have reasonable
cause to believe that a child is likely
to suffer significant harm, can apply
for an Emergency Protection Order on
behalf of the Local Authority. They can
do this whether or not the Local Authority
know or agree (S.46(8)).
The police can obtain a warrant under
Section 102 of the Children Act to enter
premises and search for children.
Life Or Limb
Section 17(1)(e) Police and Criminal
Evidence Act 1984
Where speed is essential to protect a
child and a warrant would take too long
to obtain, the police can enter premises
without a warrant, to save life or limb.
Powers To Assist In Discovery Of A Child
Who May Need Emergency Protection
Section 48 Children Act 1989
The court may require a person to disclose
the whereabouts of a child and may issue
a warrant for entry into premises where
entry has been refused.
Recovery Of Abducted Children
Section 50 Children Act 1989
The court may make a Recovery Order where
there is reason to believe that children
in care have been abducted, have run
away or are missing, or being kept away.
CHILD ASSESSMENT ORDERS
Section 43 Children Act 1989
Grounds For Child Assessment Order
Section 43(1) Children Act 1989
A Child Assessment Order may be made
if the court is satisfied that:
-
the applicant has reasonable cause
to suspect that the child is suffering,
or likely to suffer, significant harm;
and
-
an assessment of the state of the
child’s
health or development, or the way in
which (s)he has been treated, is
required to
determine whether or not the child
is suffering, or is likely to suffer,
significant harm;
and
-
it is unlikely that such an assessment
will be made, or be satisfactory, if
an order is not made.
Notice
Section 43(11) Children Act 1989
Notice of the hearing must be given
to the persons specified in this Section.
Powers And Duties Under Child Assessment
Order
Section 43(6) Children Act 1989
The order requires that any person who
is able to produce the child does so
to the person named in the order, and
that court directions regarding assessment
be complied with.
The order may contain directions, including
one to keep the child away from home,
and in that case, what contact (s)he
is to be allowed with parents, etc. while
away from home.
A court may make an Emergency Protection
Order if it is satisfied that there are
grounds for doing so.
Duration
Section 43(5) Children Act 1989
Section 91(15) Children Act 1989
Section 43(12) Children Act 1989
Section 94(1) Children Act 1989
The order must specify the date by which
the assessment is to begin and have effect
for no longer than 7 days from that date
(S.43 (5)).
There can be no further application
for a Child Assessment Order within six
months without leave of the court (S.91(15)).
Application for variation or discharge
may be made by anyone entitled to notice
(S.94(1)).
CARE PROCEEDINGS
Section 31 Children Act 1989
Grounds For Care/Supervision Order
Section 31(2) Children Act 1989
A Care Order may only be made by a court
if it is satisfied:
-
that the child concerned is suffering,
or likely to suffer, significant harm
and
-
that the harm, or likelihood of
harm, is attributable to:
(a) the care
given
to the
child, or likely to be given to him;
or
(b) the child’s being beyond
parental control.(S.31(2))
CARE ORDERS
Powers And Duties Under Care Order
Section 33(1)(3) and (4) Children Act
1989
Section 23(10) Children Act 1989
The Local Authority is under a duty
to receive the child into its care and
keep him/her in care while the order
remains in force. This includes providing
accommodation and maintaining the child
(S.33(1) and 23(1)).
The Local Authority acquires parental
responsibility for the child and, although
this is shared with the parents, it can
decide the extent to which a parent may
meet his/her parental responsibility
in order to safeguard the child’s
welfare (SS.33(3)(b)and(4);2(7)).
More specific duties are contained in
Section 23(6)-(9) and Schedule 2 part
II.
Contact
Section 34 Children Act 1989
There is a presumption of reasonable
contact between the child and his/her
parent, guardian, any person who held
a Residence Order in respect of the child
or any person who had care under inherent
jurisdiction of High Court (S.34(11)).
Before making a Care Order the court
must consider the Local Authorities’ arrangements
for contact.
The court may make an order defining
contact where agreement cannot be reached
without this.
Refusal of contact requires an order
from the court, except in exceptional
circumstances, where the Local Authority
can refuse contact without an order if
they need to do so to safeguard the child’s
welfare.
The Local Authority may only refuse
contact for 7 days without an order from
the court.
Duration Of Care Order
Section 91(12)
A Care Order expires at child’s
18th birthday unless it is discharged
by the court at an earlier date.
Discharge of a Care Order may be through
the making of an Adoption or Freeing
Order (Adoption Act 1976 SS.12 and 18),
the making of a Residence Order (S.91(1),
the making of a Supervision Order (Schedule
3 para 10), or application for discharge
or variation of the order by Local Authority,
child or person with parental responsibility.
Appeals are made to the High Court if
the decision is made in the Magistrates
Court. If the decision is made in the
County Court or the High Court the appeal
lies to the Court of Appeal. An appeal
against a decision of a District Judge
in the County Court is made to a Care
Judge within the County Court.
SUPERVISION ORDERS
Section 31 Children Act 1989
Powers And Duties Under Supervision
Order
Section 35(1)
The supervisor is under a duty to advise,
assist and befriend the child, to take
such steps as are reasonable to give
effect to the order and to apply to the
court for variation/discharge when the
order is no longer appropriate (S.35(1)).
Duration Of Supervision Order
Section 91(3) and (13) Children Act 1989
Schedule 3 Paras 6(1) and (4)
Section 39 Children Act 1989
The order lasts for a year but may be
extended; the maximum duration is three
years (Schedule 3 paras 6(1) and (4)).
The order cannot continue after the child’s
18th birthday (S.91(13)).
Application for discharge/variation of
the order may be made by Local Authority,
child or person with parental responsibility
(S.39).
Appeals are made to the High Court if
the decision is made in the Magistrates
Court. If the decision is made in the
County Court or the High Court then appeal
lies to the Court of Appeal. An appeal
against a decision of a District Judge
in the County Court is made to a Care
Judge within the County Court.
INTERIM ORDERS
Section 38 Children Act 1989
The court may make an Interim Care or
Supervision Order provided that it is
satisfied that the grounds, laid down
in S.31(2), for a Care or Supervision
Order are met.
An Interim Order can be made where an
application for a Care or Supervision
Order is adjourned or where it has given
directions to investigate, under Section
37(1) or Section 38(1).
Powers And Duties Under Interim Orders
Under an Interim Care Order reasonable
contact is to be arranged, as for a
full Care Order.
When making an Interim Order the court
has the power to make directions about
medical or psychiatric examination or
assessment of the child. The child can
refuse to undergo such examination (S.38(6)
and Schedule 3).
Section 38a Of The Children Act 1989
(Amended By The Family Law Act 1996)
The Court may include an Exclusion Requirement
where it makes an Interim Care Order
and
-
There is reasonable cause to believe
that if the relevant person is excluded
from a dwelling house in which the
child lives, the child will cease to
suffer
or cease to be likely to suffer, significant
harm; and
-
That another person living
in the dwelling house (a parent of
the child or some other
person) is (a) able and willing to
give to the child the care which it
will be
reasonable to expect a parent to give
to him/her; and (b) that other person
consents
to the inclusion of the Exclusion Requirement.
The same provisions may be included
as those included when an Emergency
Protection
Order is made.
Duration of the Exclusion Requirement:
This is the same as for an Exclusion
Requirement included in an Emergency
Protection Order.
Attaching a power of arrest:
The Court may also attach a power of
arrest to the exclusion requirement
provision within an Interim Care Order.
SECTION 8 ORDERS
Section 8 Children Act 1989
Courts are not limited, in care proceedings,
to Care and Supervision Orders, they
are also empowered to make a range of
other orders under Section 8.
There are four orders under Section 8,
which can be made in any family or care
proceedings and at any stage in such
proceedings. These orders will not be
made in respect of children over 16 years
old, except in exceptional circumstances.
Contact Order
This is an order requiring the person
with whom the child lives, or is to
live, to allow the child to visit or
stay with the person named in the order,
or for that person and the child to
have contact with each other (S.8(1)).
The Local Authority may not apply for
this order (S.9(2)).
Prohibited Steps Order
This order means that no step, specified
in the order which could normally be
taken by a parent in meeting his/her
parental responsibility for a child,
can be taken without the consent of
the court. A Prohibited Steps Order
is not available if the child is on
a Care/Interim Care Order.
Residence Order
This is an order settling the arrangements
to be made as to the person with whom
a child is to live. Where a child is
in care and the court makes a Residence
Order this has the effect of discharging
the Care Order. (S.91(1)) The Local
Authority may not apply for a Residence
Order (S.9(2)).
Specific Issue Order
This is an order giving directions for
the purpose of determining a specific
question which has arisen, or which
may arise, in connection with any aspect
of parental responsibility for a child.
The court may make any of these orders
of its own motion.
FAMILY ASSISTANCE ORDERS
Section 16 Children Act 1989
The court may, in exceptional circumstances,
make an order in any family proceedings
requiring an officer to be made available
to advise, assist and befriend a person
named in the order. This order may not
last more than 6 months and requires
the consent of all parties (S.16(3)).
LOCAL AUTHORITIES AND CHILDREN THEY
LOOK AFTER
Section 22 Children Act 1989
It is the duty of a Local Authority
looking after any child, to safeguard
and promote his/her welfare and to make
such use of services available for children
cared for by their own parents as appears
reasonable to the authority (S.22(3)).
The Local Authority should, as far as
is reasonably practicable, ascertain
the wishes of the child, his/her parents,
any person who has parental responsibility
for him/her and any other person whose
wishes and feelings the authority consider
to be relevant, regarding the matter
to be decided (S.22(4)).
When making decisions, the Local Authority
must give due consideration to the child’s
age, understanding and wishes, and the
child’s religious persuasion, racial
origin and cultural and linguistic background
(S.22(5)).
The Local Authority must accommodate
(as most appropriate) and maintain
such children (S.23).
It is also the Local Authority’s
duty to provide after care for young
persons over 16 who have been looked
after by them up to the age of 21 (Section
24(1).
REVIEW OF CASES
Section 26 Children Act 1989
Review of Children’s Cases Regulations
1991
The Local Authority is required to review
the cases of children who are being looked
after, at regular specified intervals.
Reviews form part of the continuous planning
process for all children being looked
after by the Local Authority, whether
or not there are issues of child protection
to be addressed.
Reviews are normally multi-agency meetings
which include both the young person and
the parent/carer and this review process
may take place alongside the child protection
process for children being looked after
by the Local Authority.
OTHER RELEVANT LEGISLATION
THE CRIMINAL JUSTICE ACT (as amended
by the 1991 Act)
This piece of legislation makes substantial
changes to the way in which children’s
evidence may be received by the courts
in criminal proceedings. The Act also
allows a video recording of an interview
with a child to be used as the child’s
main evidence in criminal proceedings
subject to certain conditions. These
are explained in detail in the Memorandum
of Good Practice issued by Home Office
and Department of Health (HMSO 1992)
THE POLICE AND CRIMINAL EVIDENCE ACT
(PACE) 1984
This legislation sets out the main
powers of the police to investigate
criminal offences. It also makes provision
for the protection of the suspect’s
rights. The Act is wide-ranging and
covers such areas as police powers
to stop, search, arrest and detain.
Five statutory codes of practice make
more detailed provision for the observance
of the Act and the most relevant of
these is Code C, which deals with the
detention, treatment and questioning
of persons in police custody. It includes
guidance on the treatment of juvenile
suspects and the administration of
caution.
THE PROHIBITION OF FEMALE CIRCUMCISION
ACT 1985
The Act makes female circumcision, excision
and infibulation (“Female Genital
Mutilation”) an offence. Concerns
about Female Genital Mutilation in respect
of a child need to be reported to the
Local Authority, who have a duty to investigate
under Section 47 of the Children Act
1989. An Inter-Agency Procedure exists
to facilitate this (See Appendix 13 of
Leeds ACPC Procedures).
SEX OFFENDERS ACT 1997
This places a requirement upon a sex
offender to notify the police of his/her
name and home address. The Police have
no right to notify others but may well
do so if they consider that in the
particular circumstances there is specific
justification for doing so.
PROTECTION OF CHILDREN ACT 1999
Under Section 7 of the Act, if a child
care organisation is proposing to offer
employment in a child care position,
it needs to check whether the individual
concerned is included in the Department
of Health’s (Consultancy Service)
Index. If the name of the individual
is included in that list, then the
child care organisation is not to offer
him or her employment.
For the purposes of the Act, a child
care organisation is defined under Section
12:
“An organisation -
-
which is concerned with the provision
of accommodation, social services
or health services to children or the
supervision
of children,
-
whose activities are
regulated by or by virtue of any prescribed
enactment,
-
which will fulfil such other
conditions as may be prescribed.”
All of these organisations will be required
to check the Department of Health’s
list in relation to prospective employees
(voluntary or otherwise) if their work
is going to involve contact with children.
THE HUMAN RIGHTS ACT 1998
In October 2000, the Human Rights Act
1998 comes into effect.
This will oblige all Courts to consider
the effect of European Human Rights Law
and in particular the European Convention
for the Protection of Human Rights.
This Convention has many articles all
of which the Courts will need to take
into account. There are, however, some
which are considered to be particularly
relevant to children’s issues:
1 Article 6 - Fair Trials
“ In
the determination of a Civil Rights
and obligations or of any criminal
charge
against him, everyone is entitled to
a fair and public hearing within a
reasonable time by an independent and
impartial
Tribunal established by law ...”The
interpretation of this Article has
been extended in a Netherland’s
case to imply that every party must
be given
a reasonable opportunity to present
his/her case - including his/her evidence
- under
conditions that do not place him/her
at a considerable disadvantage to his/her
opponent.
2 Article 8 - Family Life -
-
“Everyone
has the right to respect for his private
and family life, his home and his correspondence”.
-
“There
should be no interference by a
Public Authority with the exercise
of this
right except such as in accordance
with the
law and is necessary in a democratic
society in the interest of national
security, public safety or the
economic well-being
of the country, for the prevention
of disorder or crime, for the protection
of health or morals, or for the
protection of the rights and freedoms
of others”.
3 Article
14 - Discrimination
The
enjoyment of the rights and
freedom set forth in
the Convention shall be secured
without discrimination on any
grounds which
effects, race, colour, language,
religion, political
or other opinion, national
or social origin, association
with a national
minority, property, birth or status.
All the above Articles are likely
to influence the Court in
enforcing notice
periods for applications
such as Interim Care Orders and
Emergency
Protection
Orders in order to ensure
that the
parents have equal opportunity
to defend the
application to remove their
child.
Also relevant are Article 3 - Prohibition
on torture, inhuman or degrading treatment
or punishment - and Article 5 - The right
to liberty and security of persons.
THE DATA PROTECTION ACT 1998
This Act contains certain requirements:
-
any personal information is obtained
and processed fairly and lawfully,
-
that
it is only disclosed in appropriate
circumstances,
-
that it is accurate,
-
that it is relevant,
-
that it is not
held for any longer than necessary,
-
it
is kept securely.
The Act enables
disclosure without the consent of
the subject
in certain conditions
which have particular relevance
in child protection cases,
including the purposes
of the prevention or detection
of
crime, or the apprehension
or prosecution of offenders, and
where
failure
to disclose would be
likely to prejudice those
objectives in a particular case.
Individuals have the right of access
to recorded information about themselves.
There are some cases where access may
not be granted, including:
-
it would be likely to cause serious
harm to the physical or mental health
or condition of the patient/client
or any other person;
-
the notes contain
information relating
to and identifying another person unless
that person has consented to the release
of the information. This does not apply
where the other person is another professional
from the same agency involved in the
care of that patient/client;
-
the clinician
responsible for the clinical care
of a patient/client
should always
be consulted about applications for
access and his/her views sought
in writing.
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