Why the SNP won’t remove the threat of eviction

Why the SNP won’t remove the threat of eviction

Margaret Burgess, Scotland's Housing Minister, has said she will not prevent Bedroom Tax evictions.

The reason: she doesn't believe the cuts will result in evictions.

If that's true then why not just remove the threat of eviction from those affected by them?

The reason why she won't is simple: neither the SNP or Margaret Burgess want the threat of eviction to be taken off the table. They don't want benefit claimants to decide whether they should eat, pay the heating or pay the £12 per week from their other benefits towards their rent.

And that's the brutal truth of these cuts and the SNPs unwillingness to remove the threat of eviction. Some will be faced with evictions, but many instead will voluntarily disconnect their gas or electricity or go hungry and this is in a country where already one in six children go hungry according to Save the Children Scotland.

So in a nutshell, the real reasons why section 16 of the Housing (Scotland) Act 2001 will not be amended as proposed by Govan Law Centre is the threat of eviction is too important.

These cuts may be made in Westminster, but they are going to be enforced in Scotland using Scottish laws and the SNP know this, as does Margaret Burgess, an ex Citizen Advice Bureau Manager of 20 years from East Ayrshire.

Ultimately, this is the true shame of the SNPs inaction to date. They understand exactly what they are doing, or not as the case is, and the Minister has the experience to know exactly what she is doing.

This inaction would be more understandable if other action had been taken, such as proposed by Shelter, like making £50 million available in the next year to compensate social landlords, but none is being taken.

It's certainly possible action could be taken.

Already the SNP have found £40 million to protect Scots from 10% cuts to Council Tax Benefit. Would this money not be better spent protecting the more vulnerable from housing benefit cuts? It may still mean people would accrue debts, but not the type that could leave them on the street.

These are indeed difficult times and difficult decisions have to be made. Unfortunately, the SNP don't appear able to make those decisions, or if they can, they are making the wrong ones.

In the long run people will blame the Tories for the Bedroom Tax, but I suspect they will also blame the SNP and when they are evicted in Scottish courts using Scottish laws, it will be hard not to see their point.

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England’s Charging Orders Could be On Their Way to Scotland

By Alan McIntosh

A recent report has found that four large finance banks have been abusing charging orders in England and Wales, supplying consumers with misleading and oppressive paperwork.

Charging orders are a legal method of debt enforcement which exist in England and Wales and allow unsecured lenders to secure a consumer’s unsecured debts over the customer homes, resulting in some people losing their homes for as little as £600 of debt.

The only similar enforcement methods that exist in Scotland are inhibitions and adjudication for debt. Inhibitions are a type of “diligence”, as legal enforcement is called in Scotland, which allows a bank to secure a debt over a consumers home once they have a court order against the consumer. Unlike, with charging orders, however, lenders cannot use an inhibition to force a borrower to sell their home, but they can refuse to allow them to sell it or secure more debt over it until their debt has been paid. The other type of diligence that can be used in Scotland in Adjudication for Debt, which dates back to the 1661 Diligence Act, a piece of legislation passed by the old Scottish Parliament.

Adjudications for debt are extremely rare in Scotland, although they have become more common since 2004. These allow a creditor to effectively secure the debt over the borrower’s home and then take ownership of the home, if the debtor hasn’t settled the debt, after ten years.

A new enforcement method exists on the Scottish statute books and was introduced by the Bankruptcy and Diligence Etc (Scotland) Act 2007. This is Land Attachments. Unlike with inhibitions, lenders will be able to use land attachments to force the sale of a debtor’s home and unlike with adjudication for debt, which will be abolished when land attachments are introduced, the creditor will not have to wait ten years before they sell the home.

Creditors will be able to use land attachments for debts as little as £3,000 and after six months will be able to apply to the court for the power to sell the borrowers home. Unlike with charging orders in England and Wales, which give debtors there a number of different protections and allow the courts a lot of discretion in deciding whether or not to allow a sale to go ahead, land attachments will not. Providing the debtor has a court order for £3,000 or more and providing they have served a legal document on the debtor called a charge for payment, they will be able to attach someone’s home. After six months they will be able to apply to the court for a warrant to sell the home. The only defences open to the debtor will be either they have paid off the debt or it is unduly harsh on the debtor or their family to sell their home. Considering losing your home for a credit card debt is likely to be deemed harsh anyway by its nature, being able to prove it is unduly harsh is likely to be a hard defence to prove.

Land attachments as yet have still to be implemented, primarily as the current SNP government has refused to implement them. However, they remain on the statute books and there is increasing pressure from banks for them to be commenced. Currently a consultation is being planned by the Accountant in Bankruptcy’s office and is likely to begin after the next Scottish Parliament elections.

Some proposals which are being looked at is increasing the amount a borrower has to be owed before a land attachment can be executed, that is increasing it from £3,000.  However, what is contradictory here is the Scottish Government has recently introduced  legislation in the form of the Home Owner and Debtor Protection (Scotland) Act 2010, which will make it much more difficult for a bank with a mortgage or secured loan over a house to repossess it.  In some circumstances it is likely they won’t be able to, even where there are arrears or it will take between 12-18 months before they can eject the occupiers and sell the home.

It, therefore, seems bizarre that we are seriously considering implementing legislation which would allow lenders like Wonga loans to place a land attachment on someone’s home and then sell it after six months, with little or no protection for the home owner.

Most lenders are saying if they get the power to use land attachments, they won’t use them excessively, but as can be seen in England and Wales, where charging orders have increase over the last few years from 45,000 to 164,000, this is clearly not true. They have also claimed they will not use them to force the sale of properties, but what that means is they will use them instead to threaten home owners with having their homes sold if they do not succumb to their unreasonable demands for lump sum payments and payments that cannot be afforded.

In 2007 when land attachments were passed by the Scottish Parliament, we were all in a completely different place. There was a Lib Lab coalition in power and the economy was still going well, with house prices still booming. Even recently discharged bankrupts could get mortgages. Where we are now however, makes land attachments completely unacceptable. It seems bizarre the Accountant in Bankruptcy and the Scottish Government still feel this legislation should still go out to consultation and that it would ever be acceptable that an unsecured lender, in so many ways, should be in a stronger position than a lender who has bothered to secure his lending over the borrowers home.

It may be necessary to implement land attachments for commercial properties, not used to any extent for residential purposes, but to introduce them now so they can be used against the principal home of a debtor is never going to be acceptable.

Do Those in Debt need Respect?

Do Those in Debt need Respect?

In some way name calling is inherently unequal. By reducing someone to a name we turn a person into a one dimensional character and deny ourselves the wisdom that comes with seeing them as human beings. You only need to think of the ways people have referred to others over the years: the wife, the servant, the child, and that is even without degrading myself and quoting the more offensive racist and sexist names that exist.

This is something I have been thinking about recently and particularly how I have fallen into this trap with regards consumers (which is another name) or as I commonly refer to those who are experiencing financial difficulties, debtors. As someone who trained as a money adviser, my everyday terminology when speaking about clients is that they are debtors. This is something I have gradually become uncomfortable with in my role as a social policy officer and trainer for Money Advice Scotland.

When in the company of other money advisers, such terminology rolls off the tongue with ease, but when I am in the company of others, as I more often find myself now, it has gradually dawned on me I am the only person using such derogatory terminology. I say derogatory as its interesting how in Scottish society when you pay your debts you are viewed as a consumer, which denotes you having certain rights and a certain status and more importantly the right to choose between services; but when you become a debtor you lose the privileged of this status and everything that flows from it. This is the terminology that prevails in all those well-intentioned money advice service across Scotland, whether it’s Citizen Advice Bureaux or local authority money advice services (at best you may be referred, officially at least, as a client).

This in itself would be bad enough if it didn’t have serious implications. As, can be seen in more extreme examples such as Nazi Germany or apartheid South Africa, name calling and the characterisation of people in a negative vein, is part of that initial process which ultimately allows those people and their families to be dehumanised and have their rights infringed.

Cheats, Chancers and Debtors

It is, therefore, not unusual in Scotland to hear politicians, when speaking about debtors and the legislation that relates to them as cheats charters or chancers charter (most famously Donald Dewar called Tommy Sheridan’s Abolition of Poinding and Warrant Sales Bill as a “cheats charter” – which has with the passage of time shown to be completely unjustified). In another context I remember speaking at a Credit Today conference held in Edinburgh and listening to Gillian Thompson, the former Accountant in Bankruptcy, stating how low income debtors applying for bankruptcy were money adviser’s dead who were being brought out. She also controversially labelled the Scottish Parliament as being “debtor friendly”, which in the context of that conference could only be interpreted as a criticism: quite arrogant for a civil servant.

Interestingly she did not say the Parliament was consumer friendly (she retired shortly after).

This is important, as it has effects. One of these I touched on in my last blog (Why the poor pay for the poor in modern Scotland) is that debtors will be denied a choice of whose service they use to help manage their debts – despite the fact they will be expected to pay for such services. This would never be acceptable if debtors were considered consumers, which they are.

We Risk De-humanising Ourselves

However, if we stigmatise these consumers and dehumanise them with names, call them cheats and chancers, then we can deny them the choices that the rest of us take for granted. Instead they will be landed with second class state providers of services who can do a good job or a bad one and who can increase their prices year on year, safe in the knowledge their customers cannot walk away.

This is the fate that can befall all of us, for these debtors are us, they are unfortunate consumers. Many of whom have just had the misfortune of suffering illness or bereavement in their families or have been downsized or streamlined in response to the current economic crisis.

Unlike in the past, however, you will no longer find yourself in a debtor’s prison, but you will be stripped of much of the dignity and status of being a consumer and reduced to a debtor, someone who should be treated with suspicion and should be denied the rights and choices the rest of us take for granted. You and your family might even lose your home, a outcome more acceptable if your viewed as a debtor or a cheat, as you can’t be allowed to get away with repaying your debts: even if you don’t feel like your getting away with anything.

Scotland Requires A Respect Agenda

As we work to building a modern Scotland, we need to move away from this culture. In a modern consumer society, if we expect people to go out there and spend and take the risks that we need consumers to take to grow the economy, we must ensure that there are safety nets to protect those who fail. Consumer rights and protections shouldn’t just apply when things are good, but also when they are not.

Consumers deserve to be protected from stigmatisation, especially from those that try to help them and choice shouldn’t disappear when things go wrong.

We need a respect agenda for consumers.

The poor pay for the poor in modern Scotland, so the rest of us don’t have to.

By Alan McIntosh

Be scared, very scared, as Scotland’s Accountant in Bankruptcy seems hell bent, yet again, on trying to spread its tentacles and grow its empire as the de facto godfather of Scotland’s personal debt solutions. Fears are that after receiving a bruising defeat by the personal insolvency industry in relation to its attempts to expand its empire further into bankruptcies and protected trust deeds, it is now focusing its attention on Scotland’s Debt Arrangement Scheme as a means of swelling its coffers and reducing its reliance on public funding.

The Accountant in Bankruptcy is Scotland’s effective official receiver for bankruptcies. It also has a supervisory function in relation to protected trust deeds, a less formal type of bankruptcy. In a different capacity, it is also the Debt Arrangement Scheme Administrator.

One of the success stories of Government Agencies, The AIBs office has year on year been reducing it dependency on public funding and is working towards full cost recovery, so its services come at no expense to the public purse.

However, as admirable an aim as this may be on the face of it, the morality of a government agency pursuing such an objective is morally questionable. Why should one debtor who is financially struggling have to pay more to allow another debtor to access a service? Surely the test should be whether that debtor can pay for their own remedy and where they can they should be allowed to access it. Where another debtor can’t, then society has to decide whether it has a social responsibility to pay for that solution or whether they want to leave that person caught in a debt trap which will not benefit society (see my article on why Scotland needs 200,000 bankrupts). But to disproportionately place the costs of Scotland’s debt remedies on those least able to pay is a morally bankrupt policy.

One of the services the AIB currently provide is to administer Low Income Low Asset bankruptcies. These are bankruptcies where debtors who have more than £1,500 in debt, own no heritable property, have no one asset above £1,000 (or in total £10,000) and are either in receipt of a means tested benefit or effectively earn less than 40 x the hourly national minimum wage rate. All these debtors have to pay a £100 application fee to access the scheme, but the majority of these bankrupts will not pay anything towards their debts, because of their low income and will be discharged from their liability within one year.

There is now talk the AIB office, in its Debt Arrangement Scheme  role will aim to take over much of the administration of Debt Payment Programmes under the Debt Arrangement Scheme. These are repayment programmes, which are not types of bankruptcies, which allow debtors to repay their debts in full, whilst protecting them from their creditors. At recent conferences the AIB office has  indicated they now want to monopolise this type of work and it is likely if they do they will start charging for the service. Asking debtors to pay is in itself not completely objectionable, as one of the reasons the AIB office has indicated it wishes to take over this role is because public and voluntary money advice services have stated they lack the capacity to do so. Also if debtors who have little or no disposable income, such as those that apply for low income low asset bankruptcies have to pay, then why should those that apply for a Debt Payment Programmes and who by definition have some disposable income not pay? In addition to this for those who enter into DPPs, as the interest and charges on their debts are frozen, many benefit up to the tune of hundreds of pounds each months.

However, the concern is that as the AIB move to full cost recovery, the poor will be used to pay for the poor, with some services being used to cross subsidise other services. It has to be noted that when the AIB talk of full cost recovery, there is no suggestion that the fees they charge debtors are only to pay the cost of providing those services to those debtors. It is likely some are paying more to pay for the services of those that can’t afford to pay.  There are also indications that as the AIB continue their journey towards full cost recovery, the temptation will be, with an effective monopoly, to year on year increase the cost and charges to debtors. There is a basis for stating this: in 2008 the AIB began charging trustees in protected trust deeds a one office supervisory fee of £200 per case. Last year this will have raised the AIB’s office close to £2 million. This year that fee was increased to £234 per case, despite the fact the number of protected trust deeds are now likely to begin falling. Also it is extremely unlikely that the supervisory function the AIB performs for protected trust deeds, costs anywhere near the approx £2 million they raised: so effectively this is a profit making service this Government agency is now running.  It is clear to many, however,  that this is an effective tax on the insolvency industry, with the costs in reality being passed onto those least likely to afford it: the debtor.

This is concerning as there is an alternative and that is to allow the private sector to take over the administration of DAS cases and allow the public and voluntary sector to refer those cases onto them. Although they will also charge and some of those that currently provide it do (with one charging up to £1,800), with more involvement by firms, there will be pressure on them to compete and this should be a force for good driving down the cost of the DAS to debtors. There are already some large UK private firms that already provide fee charging services, with the best of them charging only nominal amounts. It is not inconceivable that in the future, if the private sector were allowed to compete for this work that the service may eventually be free to debtors in Scotland, with the most successful of firms only relying on the 10% that the legislation allows them to charge creditors for providing the service.

It will also be providing the Scottish Government with a means of beginning to regulate the private debt management industry in Scotland, which is currently a role reserved to Westminster, as if they wish to provide access to the scheme, they will need to comply with Scottish Parliament regulations. This will help drive out the rogues and cowboys in the industry.

However, there is currently little indication the AIB, which is responsible for developing  government policy in this area are prepared to have open discussions on the future of the scheme. Clearly there is a conflict of interest with them more than likely wanting to choose a path or consider options that will benefit them as an agency and add to their coffers. This is even if the alternative could produce a more accessible, cheaper and more professionally run service for debtors and the voluntary and public sector money advice services to refer on to.

The truth is, however, the only reason the AIB’s office wish to monopolise the DAS (which in itself is probably a breach of European competition law), is to allow it as means to raise more revenue to cross-subsidise other services.

That is to ensure Scotland’s poor pay for the poor , so the rest of us don’t have to.

Coalition’s Attack on Benefits Will Leave Thousands Worse Off

By far one of the policies of New Labour which made a huge difference to the lives of some of Britain’s lowest paid families, was tax credits. It is, therefore, disgraceful that the coalition will now be removing one of the key features of that benefit which prevented thousands of the lowest income claimants in the UK from incurring huge overpayments and ultimately debts.

Working as an income adviser, the difference was palpable over a short space of time between 2003 and 2004, when client’s who previously couldn’t afford to work, suddenly taking up part-time jobs. The biggest beneficiaries were single parents, who suddenly could afford child care.

The tax credit system, however, wasn’t perfect. It required people to predict their income a year ahead and with many of the jobs people took up being casual, this led to people wrongly estimating their incomes, which resulted  huge overpayments of  thousands of pounds for many.

Often these overpayments were repaid by direct deductions from claimant’s future tax credits, meaning they lost the benefit of the credits and thousands of claimants either stopped going to work or worse still stopped claiming the benefits, avoiding future overpayments which they couldn’t afford.

The innovative solution to this introduced by the Labour Government was to introduce a buffer, which meant if someone miscalculated their income by up to £25,000 they would not have to repay their overpayments. The difference was immediate with people suddenly having the confidence to claim and the lowest income families not being burdened by debts they did not realise they were incurring.

The  coalition’s decision to reduce that buffer to £10,000 by next year and £5,000 the following year ,  will result in  the lowest income families, with young children, incurring overpayment  they cannot afford.

What worries me is that for  many this will mean the risk of claiming working tax credits will be too high and uncertain and going back into the workplace will no longer be  worth while.

Watch for the child poverty rates beginning to increase again.

English Bailiffs Threaten BBC With Legal Action 

????Although this blog normally deals only with issues of debt, I thought in this case I would make an exception as it relates to the conduct of Shergroup, an English High Court Enforcement Officer’s conduct.

Recently at the Democracy Village camped outside the House’s of Parliament, High Court Enforcement Officers were brought into evict the protestors, after Tory Mayor, Boris Johnstone obtained a court order to evict them. In one piece of video footage by the BBC, a bailiff appears to be kicking a protestor.

However Shergroup, the private bailiff firm employed to carry out the eviction, have now hit back and threatened to take legal action against the BBC. They have posted their own footage on YouTube, showing what they say was their employee only trying to free his feet from the protestor.

Although, I need to ask if stamping on the protestor was really necessary to free the bailiffs foot. Possibly it doesn’t show them in the good light they hoped.

It  raises an important point, however, and that is court officers, north and south of the border are representatives of the court and its authority, so when their conduct is unacceptable, they bring not only themselves, but the court into disrepute. In Scotland a complaint can be made to the Sheriff Principal when it concerns a sheriff officer or the Lord President of the Court of Session when it concerns messenger at arms.

You decide:

BBC footage can be seen here.

Shergroup footage can be seen here.

NOTE: Bailiffs do not operate in Scotland to enforce court orders, instead we have Sheriff Officers and Messenger at Arms. What is often not realised, however, is that although most people associate  bailiffs and sheriff officers with enforcement of debt, they can be required to enforce any court order, such as evicting people. One of the more stranger aspects of the court regulations which relate to sheriff officer  in Scotland is that there is actually a price for them to arrange and take possession of a child: a bargain at only £124.30.

Enforcement of Debt (Scotland) Bill Required

By Alan McIntosh

John Wilson, MSP, Enforcement of Local Tax Arrears Bill proposal has opened up an important issue in Scotland regarding the enforcement and extinguishing of the obligations of debtors to repay their debts.

Scottish Debtors are currently at a disadvantage to debtors in other parts of the UK, in that debts can be pursued in Scotland for longer than they can in England, up to twenty years or more, once a court order or its equivalent has been obtained. In England, there is no automatic right to enforce a debt using legal enforcement (or distress) after 6 years. This encourages bad practice in Scotland, meaning bad debts can be held over people for an extraordinary long period of time. This encourages debt purchasers who buy debts, sometimes for pennies in the pound to then use the full force of the law to harass and persecute debtors who have reasonably assumed the original creditor has abandoned their right to pursue the debt.

John Wilson’s draft proposal concerned only local tax arrears and the pursuit of them using the summary warrant procedure, which only local authorities and Her Majesty’s Revenue and Customs can use. The debate, however, should be wider and look at the enforcement and extinguishing of a debtor’s obligations to repay all debts.

I would call for:

  • The prescriptive period for enforcing local tax arrears being reduced to five years;
  • Debtors having a statutory right of recall when served by a summary warrant by local authorities or Her Majesty’s Revenue and Customs Department;
  • That no court decree for payment of money, or summary warrant, should automatically be enforceable after five years, unless the creditor can show exceptional circumstances for not enforcing the debt earlier; and
  • That local authorities and HMRC,  who use summary warrant procedure, being allowed to enforce debts constituted by summary warrant  by executing and registering inhibitions on the property of debtors.

My full paper, The Enforcement and Extinguishing of Debtor Obligations in Scotland can be read here.

It’s Premature To Say Repossessions Risk Has Gone

The recent announcement by the Council of Mortgage Lenders that their prediction of 53,000 repossessions in 2010 is now pessimistic, should not be taken as a sign that the worst is over. This failure to get predictions correct could create a culture of complacency amongst politicians, especially, as it follows on another inaccurate prediction by the CML in 2008 that there would be 75,000 repossessions in 2009.

That last prediction led directly to the current Scottish Government facing attacks last year that they weren’t doing enough to prevent rising repossessions and even calls for new legislation to be brought forward and passed in a day. New legislation has since been brought forward in the form of the Home Owner and Debtor Protection (Scotland) Act 2010, which arguably will ensure Scotland, come October, will have the highest level of legal protection in the UK for home owners facing repossession.

Part of the problem is that many of the protections that were introduced for home owners at the height of the credit crunch were arguably a knee jerk reaction and too much too soon. First of these was the UK Government’s Home Owner Mortgage Support Scheme introduced in January 2009, which allowed home owners struggling to pay their mortgages to enter into agreements with their lender and avoid repossession, providing they could pay at lest 30% of the interest on their mortgages. Then in England and Wales the Home Owners Support Fund introduced variations of Scotland’s own mortgage to rent and mortgage to shared equity schemes. Even the Department of Works and Pensions Support for Mortgage Interest Scheme was extended to allow more people to apply quicker.

The problem is the Home Owner Mortgage Support Scheme was intended to operate only for two years and the length of time applicants would be able to benefit from the DWPs Support for Mortgage Interest Scheme was reduced to two years, as part of the changes extending access. It has now also been revealed in England and Wales the amount available to home owners applying for the Home Owner Support Fund will be cut, although the total budget will remain the same, with the LibCon coalition arguing that reducing the deficit and keeping interest rates low will do more good. The problem is, however, if you reduce the amount available to  local authorities and housing associations to buy homes, so home owners can remain in them as tenants, less social landlords will participate.

There is also the problem that one of the reasons repossession levels have not materialised at the level predicted is with the bursting of the housing bubble, many homes were thrown into negative equity, meaning many lenders were happy to provide customers with more time to pay,  as even if homes were repossessed, the full amounts owed to the banks would not be repaid.

The danger is now with the Home Owner Mortgage Support Scheme possibly due to end in 2011, cuts to to the English and Wales Home Owner Support Fund and many of those who claimed Support for Mortgage Interest nearly exhausting their two years of assistance, repossession levels could begin rising. Add into this the LibCon Coalition deficit cuts, the prospect of increased unemployment and rising housing prices (with lenders possibly being less willing to show forebearance to customers) and it is clear we are no where near out of the woods yet. There is also no guarantee at present that we will not see an early return to increases in interest rates (although increasingly unlikely).

Even in Scotland our own Mortgage to Rent and Shared Equity Schemes are not without their faults, with increasing number of advisers complaining it is harder to find landlords willing to purchase homes and that the valuation figures used to decide which home owners can participate are too low.

It is vital that with the worst predictions of the Council of Mortgage Lenders failing to materialise and increasing budget cuts, we do not become complacent and think  there is no more that can be done. It is telling that although the number of repossession actions in Scottish courts fell  last year by 20% , they are expected to increase by 11% this year.

Repossessions, like unemployment, as an effect of a recession generally lags behind other effects. Scotland may be out of recession, but the worse social effects could be with us for some time.

MSP John Wilson’s Draft Bill Proposal Before Its Time

It is with disappointment today I discovered John Wilson (Central Scotland MSP) has decided not to submit a final proposal for his private member bill the Proposed Enforcement of Local Tax Arrears (Scotland) Bill. The proposal was ahead of its time as it now transpires many local authorities are dusting off old poll tax bills from over 19 years ago  to  raise cash for their cash strapped budgets.

The bill, which related to council tax arrears proposed:

  • that local authorities should only be able to pursue council tax debts for five years, as opposed to the 20 years they are currently able to; and
  • that the summary warrant procedure used to constitute council tax debts, denying debtors a right to be a fair hearing,  should be abolished

The fact the bill will not be going forward in this session is a loss after being supported by Citizen Advice Scotland and Consumer Focus.

However, I would support its reintroduction in the next parliamentary session, but believe it should be strengthened to  ensure

  • that no debts, even once constituted by decree or its equivalent, including summary warrant, should be automatically enforceable after five years, without the permission of the court; and
  • that the summary warrant procedure should not be abolished, but a right of recall introduced.

I am hoping to write a paper on these proposals in the coming week and will post them on here.