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<h1><b>Seizing Travellers’ Homes, Neutering Protest: Priti Patel’S PCSC
Bill Should Be Called ‘The Police State
Bill’</b></h1>
<a href="https://tlio.gn.apc.org/policing-crime-sentencing-and-courts-pcsc-bill-should-really-be-called-priti-patels-police-state-bill/" eudora="autourl">
https://tlio.gn.apc.org/policing-crime-sentencing-and-courts-pcsc-bill-should-really-be-called-priti-patels-police-state-bill/<br>
<br>
</a>
<a href="https://tlio.gn.apc.org/policing-crime-sentencing-and-courts-pcsc-bill-should-really-be-called-priti-patels-police-state-bill/">
14 JULY 2021</a> <a href="https://tlio.gn.apc.org/author/tony/">TONY
GOSLING</a>
<a href="https://tlio.gn.apc.org/policing-crime-sentencing-and-courts-pcsc-bill-should-really-be-called-priti-patels-police-state-bill/#respond">
LEAVE A COMMENT</a><br><br>
Since Margaret Thatchers introduction of paramilitary policing in the
Miners Strike (1984), Battle of the Beanfield (1985) and Wapping print
workers dispute (1986) the number of UK ‘Bobbys on the beat’ has fallen
to virtually zero.<br><br>
Policing has become more arbitrary during the Coronavirus Act (2020-21)
period where unprecedented intrusion into peoples homes on the rumour
there may be an unauthorised visitor, and violent police action against
certain types of demonstration, while facilitating others, has led many
to point out that the British police have become a political
force.<br><br>
<a href="https://thebristolcable.org/2021/03/bristol-protest-police-violently-shut-down-peaceful-sit-down-occupation-college-green-police-crime-bill/">
<img src="cid:.0" width=474 height=418 alt="[]"></a><br><br>
<i>
<a href="https://thebristolcable.org/2021/03/bristol-protest-police-violently-shut-down-peaceful-sit-down-occupation-college-green-police-crime-bill/">
24Mar21, BRISTOL: Police violently shut down peaceful sit down occupation
of College Green</a><br><br>
</i>Now in July 2021 the Police Crime Sentencing and Courts Bill is about
to receive the royal assent. The Home Secretary Priti Patel, whose bill
it is, was previously
<a href="https://www.theguardian.com/politics/2017/nov/08/priti-patels-meetings-cancelled-as-pm-considers-sacking-her">
sacked as a likely Israeli agent for 14 undeclared meetings with top
Israeli government officials when Secretary of State for Overseas
Development (DFID) in 2017</a>.<br><br>
So here is a selection of the lawyer and traveller groups’ responses to,
and briefings on, the bill.<br><br>
<h1><b>The Good Law Project has summed the failings of the bill up as
follows.</b></h1>• The police already have a wide range of powers to deal
with protests.<br>
• The Bill marks a “significant departure” from the historic approach to
the policing of protests under the Public Order Act 1986.<br>
• The advice shares our concern that the Secretary of State has the power
to effectively prohibit “entire classes or types of protests” and has the
power to set a low bar for what constitutes ‘significant disruption’ to
the community or organisation – although how that power will be exercised
remains to be seen. This includes defining the phrase in ways that would
cover a picket or trade union demonstrations (even though their very
purpose may be to cause disruption in order to draw attention to concerns
around working conditions).<br>
• The Bill broadens the circumstances in which police can impose
restrictions on public processions and assemblies, including the
introduction of a new “noise” criterion. All of this is likely to have a
chilling effect on protests.<br>
• Whether or not the legislation is incompatible with the European
Convention on Human Rights (ECHR) may well depend on the restrictions
imposed in specific circumstances, but the new provisions increase the
possibility of protests being regulated in ways that could interfere with
the rights under Articles 10 and 11 of the ECHR.<br><br>
<a href="https://www.standard.co.uk/news/london/how-peaceful-vigil-sarah-everard-turned-violence-met-police-clapham-common-b924177.html">
<img src="cid:.1" width=474 height=270 alt="[]"></a><br><br>
<i>
<a href="https://www.standard.co.uk/news/london/how-peaceful-vigil-sarah-everard-turned-violence-met-police-clapham-common-b924177.html">
13Mar21 CLAPHAM COMMON: How the police turned peaceful vigil for Sarah
Everard to violence<br><br>
</a></i><h3><b>Full article: The return of the Policing
Bill</b></h3>
<a href="https://goodlawproject.org/news/return-of-the-policing-bill/">
The Government’s legislative agenda for the next year – set out in
yesterday’s Queen’s Speech – contains a series of deeply troubling
measures, from plans to introduce Voter ID to a piece of legislation to
prevent ‘no platforming’ at universities. They masquerade as confected
solutions to non-existent problems. But in fact, they are worse – they
are transparent attempts to silence opposition. </a><br><br>
But these proposals, deeply concerning as they are, risk overshadowing
the more immediate danger of the controversial Police, Crime, Sentencing
and Courts Bill (the “<b>PCSC Bill</b>”) being pushed through without
robust opposition. The Bill is set to return to the House of Commons in
the next couple of weeks for what is known as the Committee Stage.
<br><br>
We commissioned advice from Phillippa Kaufmann QC and Anita Davies at
Matrix Chambers on the part of the Bill that deals with protest rights,
and we promised we would publish that advice. It can now be
<a href="https://glplive.org/PPCS-advice">accessed here</a>.<br><br>
The advice confirms some of our deep worries about the protest provisions
in the Bill, but also highlights that the defining battle will be around
how the Home Secretary exercises her powers under the Bill to define
certain key phrases such as ‘<i>significant disruption</i>’. The
definitions of these key terms will effectively set the tone for how
protests are policed from now on. <br><br>
Below are some of the key findings from the advice.
<ul>
<li>The police already have a wide range of powers to deal with
protests.
<li>The Bill marks a <i>“significant departure”</i>from the historic
approach to the policing of protests under the Public Order Act 1986.
<li>The advice shares our concern that the Secretary of State has the
power to effectively prohibit <i>“entire classes or types of protests”
</i>and has the power to set a low bar for what constitutes
<i>‘significant disruption’</i>to the community or organisation –
although how that power will be exercised remains to be seen. This
includes defining the phrase in ways that would cover a picket or trade
union demonstrations (even though their very purpose may be to cause
disruption in order to draw attention to concerns around working
conditions).
<li>The Bill broadens the circumstances in which police can impose
restrictions on public processions and assemblies, including the
introduction of a new <i>“noise” </i> All of this is likely to have a
chilling effect on protests.
<li>Whether or not the legislation is incompatible with the European
Convention on Human Rights (ECHR) may well depend on the restrictions
imposed in specific circumstances, but the new provisions increase the
possibility of protests being regulated in ways that could interfere with
the rights under Articles 10 and 11 of the ECHR.
</ul><br>
And that’s just the protest provisions. There are, of course, other
aspects of the Bill that should concern all of us – including the
proposed criminalisation of trespass in a way that
<a href="https://www.gypsy-traveller.org/wp-content/uploads/2021/03/Briefing-on-new-police-powers-PCSCBill-and-CJPOA-002.pdf">
disproportionately impacts</a> Gypsy, Roma and Traveller (GRT)
communities, and the fact that the plans for policing and sentencing are
likely to further entrench
<a href="https://www.criminaljusticealliance.org/blog/coalition-warns-new-policing-and-sentencing-bill-will-deepen-racial-inequality/">
racial inequality</a> in the criminal justice system.<br><br>
We are continuing to speak to MPs on both sides of the aisle to highlight
our concerns. But if the Home Secretary, Priti Patel, introduces
regulations of the sort anticipated, Good Law Project will bring or
support legal action, alongside other civil society watchdogs, to try to
stem our alarming slide towards authoritarianism.<br><br>
It is only with your support that we can continue to hold Government to
account. If you would like to make a donation, you can do so
<a href="https://goodlawproject.org/donate">here</a>.<br><br>
<h1><b>THE CRIMINALISATION OF TRESPASS</b></h1>Community Law
Project<br><br>
<a href="http://www.communitylawpartnership.co.uk/news/the-criminalisation-of-trespass">
http://www.communitylawpartnership.co.uk/news/the-criminalisation-of-trespass</a>
<br>
Posted by clp-admin 17th March, 2021 News<br>
<b>Legal Briefing on Proposals to Criminalise Trespass<br>
</b>By The Community Law Partnership<br>
<a href="http://www.communitylawpartnership.co.uk/news/the-criminalisation-of-trespass">
Thanks to Marc Willers QC and Tessa Buchanan of Garden Court Chambers and
to Abbie Kirkby of Friends, Families and Travellers for their comments on
this paper.</a><br>
The Travellers Advice Team at Community Law Partnership are very
interested in hearing from any Gypsies and Travellers who may be
adversely affected by the proposed new criminal offence. We would
encourage people to phone us on our Advice Line which is 0121 685 8677
Monday to Friday 9am to 1pm.<br><br>
<b>1. THE PROPOSALS<br>
</b>In November 2019 the Home Office launched a consultation entitled
‘Strengthening police powers to tackle unauthorised encampments’. On 8th
March 2021, the Government finally produced their response to that
consultation and you can find that response here:
<a href="https://www.gov.uk/government/consultations/strengthening-police-powers-to-tackle-unauthorised-encampments/outcome/government-response-to-the-consultation-strengthening-police-powers-to-tackle-unauthorised-encampments-accessible-version">
https://www.gov.uk/government/consultations/strengthening-police-powers-to-tackle-unauthorised-encampments/outcome/government-response-to-the-consultation-strengthening-police-powers-to-tackle-unauthorised-encampments-accessible-version</a>
. After publishing the response, the following day the Government
included the new criminal offence of trespass in the Police, Crime,
Sentencing and Courts Bill (PCSCB) which has already had its Second
Reading on 15th and 16th March 2021. You can find the Bill here:
<a href="https://publications.parliament.uk/pa/bills/cbill/58-01/0268/200268.pdf">
https://publications.parliament.uk/pa/bills/cbill/58-01/0268/200268.pdf</a>
.<br>
This new criminal offence, and the other proposed changes to the existing
provisions of the Criminal Justice and Public Order Act (CJPOA) 1994,
cover both England and Wales.<br>
In summary, the PCSCB will make it a criminal offence for someone with a
vehicle residing or intending to reside on land without the consent of
the occupier of the land to fail to comply with a request to leave the
land in a case where that person’s residence or intended residence has
caused or is likely to cause significant disruption, damage, or distress.
If the person fails to leave the land or, having left, re-enters it, he
or she can be arrested and his or her vehicle (i.e. his or her home) can
be impounded.<br><br>
<b>2. WOULD THE CRIMINALISATION OF TRESPASS BE LAWFUL?<br>
</b>It seems to us that the proposed criminalisation amounts to an
unlawful breach of Articles 8 and 14 ECHR. Article 8 enshrines the right
to respect for a person’s private and family life and home. This includes
his or her traditional way of life. Article 14 contains the right not to
be discriminated against in the enjoyment of other Convention rights. The
measure is an obvious interference with the nomadic way of life of
Gypsies and Travellers and is also obviously discriminatory against these
minorities. It is difficult to see how the measure is proportionate in
light of the concerns set out below and especially the following
factors:<br>
(i) Alternative Sites<br>
Many Gypsies and Travellers still have to resort to unauthorised
encampments because of the continuing lack of permanent and transit site
provision (including emergency stopping places) in England and Wales and
a collective failure by national and local government over many years to
develop arrangements such as ‘negotiated stopping agreements’ which would
ensure that lawful stopping sites were provided.<br>
(ii) The Government’s positive obligation to protect Gypsies and
Travellers’ traditional way of life<br>
In Chapman v UK [2001] 33 EHRR 399, the European Court of Human Rights
stated:<br>
…the vulnerable position of gypsies as a minority means that some special
consideration should be given to their needs and their different
lifestyle both in the relevant regulatory planning framework and in
reaching decisions in particular cases…To this extent, there is thus a
positive obligation imposed on the Contracting States by virtue of
Article 8 to facilitate the gypsy way of life… (para 96)<br>
In the case of London Borough of Bromley v Persons Unknown, London
Gypsies and Travellers and Others [2020] EWCA Civ 12, the Court of
Appeal, in upholding the refusal of the High Court Judge to grant Bromley
a wide injunction against Gypsies and Travellers, stated:<br>
Finally, it must be recognised that the cases…make plain that the Gypsy
and Traveller community have an enshrined freedom not to stay in one
place but to move from one place to another. An injunction which prevents
them from stopping at all in a defined part of the UK comprises a
potential breach of both the Convention and the Equality Act… (para
109).<br>
(iii) The lack of public support for the measure<br>
It is clear from the Government’s response to the consultation the
majority of respondents disagreed or strongly disagreed with the proposed
measures.<br>
(iv) The lack of Police support for the measure<br>
It is particularly significant that the majority of Police forces that
responded to the Government’s consultation exercise did not want greater
powers.<br>
(v) Chilling effect<br>
The Government suggest that the legislation is only designed to address
encampments that cause ‘disruption or distress’.<br>
First, we find their explanation somewhat disingenuous. In their
Frequently Asked Questions factsheet it is stated at page 4:<br>
The Government’s view is that criminalisation of intentional residence on
land without consent and the extension of existing powers in 1994 Act
will provide Police with sufficient powers to effectively and efficiently
enforce against a range of harms caused by some unauthorised encampments.
The offence and strengthened Police powers could also deter unauthorised
encampments from being set up in the first instance (our emphasis).<br>
Secondly, not only can the offence be committed by someone who is said to
be ‘likely to cause significant damage or significant disruption’ but it
can be committed once they have been given a notice to leave not just by
a Police Constable but also by the occupier of the land or a
representative of the occupier. Thus the occupier of the land ( who could
be the landowner or a leaseholder or licensee) or their representative
can effectively turn a Gypsy or Traveller into a criminal by the giving
of this notice. Moreover they risk being arrested and losing their homes
without any Court having to conclude that they are guilty of the
offence.<br>
Thirdly, it may be said that the Gypsy or Traveller in question could
simply challenge the assumption or declaration that they are likely to
cause significant disruption or significant damage at the time that the
request to leave is made but the reality is that if they were to do so
they would then put themselves at risk of being arrested and having their
vehicles (their homes) impounded. In those circumstances the vast
majority of Gypsies and Travellers will feel obliged to leave the land
without delay.<br>
Finally, whereas the Police currently have a discretion as to whether to
use their existing powers under CJPOA 1994 s61 or s62 A to E (in the
latter case where there is a suitable alternative pitch available), they
may feel obliged to make arrests and impound vehicles if they are
informed that a criminal offence has taken place.<br><br>
<b>3. EXISTING POLICE POWERS<br>
</b>It is important to note that (1) the Police already have extensive
powers to move on unauthorised encampments and (2) the Police do not
support the strengthening of their powers of eviction which are currently
contained in the CJPOA 1994.<br>
CJPOA s61(1) states:<br>
If the senior police officer present at the scene reasonably believes
that two or more persons are trespassing on land and are present there
with the common purpose of residing there for any period, that reasonable
steps have been taken by or on behalf of the occupier to ask them to
leave and –<br>
(a) that any of those persons has caused damage to the land or to
property on the land or used threatening, abusive or insulting words or
behaviour towards the occupier, a member of his family or an employee or
agent of his, or<br>
(b) that those persons have between them six or more vehicles on the
land,<br>
he may direct those persons, or any of them, to leave the land and to
remove any vehicles or other property they have with them on the
land.<br>
This existing provision is already draconian since it enables the Police
to evict an encampment at very short notice. Even where the Police are
arguably exercising their powers unlawfully, it can be difficult to bring
a challenge due to how swiftly the eviction can take place.<br>
However, this power is somewhat ameliorated both by Government guidance
on the question of managing unauthorised encampments (which stresses the
need for the assessment of welfare considerations and alternative
locations) and by very important guidance from the Police themselves,
namely Operational Advice on Unauthorised Encampments (National Police
Chiefs Council, 2018). This guidance stresses that the Police have a
discretion as to whether or not to use their powers. Therefore, they may
use their powers if an encampment is causing significant anti-social
behaviour or if there are crimes occurring but, in other circumstances,
may decide not to use their powers.<br>
CJPOA 1994 s62 A – E relate to circumstances where there is a suitable
alternative pitch available. Given the continuing lack of transit site
provision (albeit that there has been a small increase in such provision
over recent times), these provisions are of limited practical relevance
and we will not discuss them further here.<br>
It can certainly be concluded, at the very least, that the existing
Police powers of eviction are sufficient. There is absolutely no need for
them to be increased as the Police themselves accept.<br><br>
<b>4. THE PROPOSAL TO CRIMINALISE TRESPASS<br>
</b>Clause 61 of the PCSCB introduces a new offence into the CJPOA 1994
as follows:<br>
60C Offence relating to residing on land without consent in or with a
vehicle.<br>
(1) Subsection(2) applies where –<br>
(a) A person aged 18 or over (“P”) is residing, or intending to reside,
on land without the consent of the occupier of the land,<br>
(b) P has, or intends to have, at least one vehicle with them on the
land,<br>
(c) One or more of the conditions mentioned in subsection (4) is
satisfied, and<br>
(d) The occupier, a representative of the occupier or a constable request
P to –<br>
(i) Leave the land;<br>
(ii) Remove from the land property that is in P’s possession or under P’s
control.<br>
(2) P commits an offence if –<br>
(a) P fails to comply with the request as soon as reasonably practicable,
or<br>
(b) P –<br>
(i) Enters (or having left, re-enters) the land within the prohibited
period with the intention of residing there without the consent of the
occupier of the land, and<br>
(ii) Has, or intends to have, at least one vehicle with them on the
land.<br>
(3) The prohibited period is the period of 12 months beginning with the
day on which the request was made.<br>
(4) The conditions are –<br>
(a) In a case where P is residing on the land, significant damage or
significant disruption has been caused or is likely to be caused as a
result of P’s residence;<br>
(b) In a case where P is not yet residing on the land, it is likely that
significant damage or significant disruption would be caused as a result
of P’s residence if P were to reside on the land;<br>
(c) That significant damage or significant disruption has been caused or
is likely to be caused as a result of conduct carried on, or likely to be
carried on, by P while P is on the land;<br>
(d) That significant distress has been caused or is likely to be caused
as a result of offensive conduct carried on, or likely to be carried on,
by P while P is on the land (our emphasis).<br>
Someone who commits the offence can be arrested and their vehicles (i.e.
their homes) can be impounded.<br><br>
<b>5. CONCERNS ABOUT THE NEW OFFENCE<br>
</b>The new offence is deeply troubling, for several reasons:<br>
(A) Even a single Gypsy or Traveller travelling in a single vehicle will
be caught by this offence. When the powers in CJPOA 1994 were first being
debated in Parliament, it was stated that the powers were intended to
deal with ‘mass trespass’. We have now come to a stage where even a
single Gypsy or Traveller will be caught by these draconian
provisions.<br>
(B) As mentioned above the ‘request’ to leave the land can be made by the
occupier of the land or a representative of the occupier. This is a very
important difference as compared to the current powers under CJPOA 1994
s61. The existing powers can only be exercised by the Police, which means
that a person only faces criminalisation once they have disobeyed the
instruction of a law enforcement official. Under the new offence, a
person can be criminalised for disobeying the instruction of a private
citizen. Moreover, whilst the Police are – or should be – motivated by
concerns such as protection of the public and preservation of public
order, the private citizen will be motivated by the protection of his or
her personal interests as an ‘occupier’ of land. To criminalise what has
previously always been a civil dispute between private citizens is
alarming in the extreme.<br>
(C) As currently drafted (and unless any guidance changes this) this
request does not appear to have to be in writing. This is extraordinarily
casual given the draconian results that may follow.<br>
(D) The period during which the Gypsy or Traveller is effectively banned
from the land in question is extended from 3 months (as it is currently
under the 1994 Act) to 12 months. For those Gypsies and Travellers who
have no alternative but to resort to unauthorised encampments, there are,
in effect, very few potential stopping places in any one area. The
extension of the time limit to 12 months effectively creates a kind of
wide injunction covering the relevant areas where a Gypsy and Traveller
might be able to stop in other circumstances.<br>
(E) The interpretation section defines ‘damage’ to include<br>
(a) Damage to the land;<br>
(b) Damage to any property on the land not belonging to P;<br>
(c) Damage to the environment (including excessive noise, smells, litter
or deposits of waste)<br>
‘Disruption’ is defined to include interference with:<br>
(a) A person’s ability to access any services or facilities located on
the land or otherwise make lawful use of the land, or<br>
(b) A supply of water, energy or fuel.<br>
These definitions are vague and could potentially include a very wide
range of issues. Moreover, it is unlikely that judicial clarification
will be forthcoming soon, because Gypsies and Travellers will not want to
risk potentially being arrested and getting their vehicles impounded in
order for them to go to Court and find out what the Court decides is
meant by ‘damage’ or ‘disruption’. Moreover, the offence can be
committed, as discussed above, if damage or disruption is only ‘likely to
be caused’.<br>
(F) There is no specific attempt to define what ‘significant’ means. This
is a word which, in another context, has caused confusion and
necessitated a definition by the Court of Appeal (Panayiotou v Waltham
Forest London Borough Council [2017] EWCA Civ 1624). The lack of clarity
here is concerning.<br>
(G) Additionally there will be amendments to other powers in the CJPOA
1994 including adding on to ‘damage’ under s61(1) (see above) the words
‘disruption or distress’. The period of time during which you must not
return to the land following a notice under CJPOA 1994 s61 is also
extended to 12 months. Section 61 will also be extended to cover the
highway.<br><br>
<b>6. LOBBYING AND CAMPAIGNING<br>
</b>It will be very important, of course, for Gypsies and Travellers,
Gypsy and Traveller national and local groups and those others supporting
Gypsies and Travellers in this vital matter to take forward the strongest
possible campaign and now to lobby Parliamentarians as the PCSCB passes
through Parliament. It is noted that the Government seem intent on
rushing this Bill through.<br>
Friends, Families and Travellers (FFT) have already put together an
impressive array of materials on this matter which you can find on their
website at:
<a href="https://www.gypsy-traveller.org/news/government-announces-plans-to-introduce-harsh-laws-for-roadside-camps/" eudora="autourl">
https://www.gypsy-traveller.org/news/government-announces-plans-to-introduce-harsh-laws-for-roadside-camps/<br>
</a>FFT have produced an excellent briefing paper and, in summary, they
state:<br>
• The measures outlined in the PCSCB will further compound the
inequalities experienced by Gypsies and Travellers, needlessly pushing
people into the criminal justice system.<br>
• The powers will disproportionately affect specific minority and ethnic
communities and are likely to be in conflict with equality and human
rights legislation.<br>
• The case for action is flawed. An enforcement approach to addressing
the number of unauthorised encampments overlooks the issue of the lack of
site provision – there is an absence of places where Gypsies and
Travellers are permitted to stop or reside.<br>
• There are other solutions to managing unauthorised encampments, such as
negotiated stopping, whereby arrangements are made on agreed permitted
times on stopping and to ensure the provision of basic amenities such as
water, sanitation and refuse collection.<br>
• The definition of a Gypsy or Traveller in planning terms requires proof
of travelling – without which you are not assessed as needing a pitch or
get planning permission, but will essentially be prohibited from
travelling by law.<br>
• Police bodies do not support the criminalisation of trespass.<br>
• The majority of respondents to the HO consultation opposed more police
powers.<br>
• There are very little in the way of measures to mitigate harm from the
proposals.<br><br>
<b>7. WALES<br>
</b>We note that these provisions will apply in Wales too. The Welsh
Government has taken a much more positive approach to Gypsies and
Travellers than the Westminster Government in recent years, and
especially since the duty to meet the assessed need for Gypsy and
Traveller sites was enacted in the Housing (Wales) Act 2014 s103. That
being so we hope that the Welsh Government will support the call for this
proposed new offence and the amendments to the CJPOA 1994 to be
withdrawn.<br><br>
<b>8. CONCLUSION<br>
</b>In conclusion, this new offence (leaving aside the other amendments
to the existing powers in CJPOA 1994) would be sufficient to make life on
the road for Gypsies and Travellers impossible and, thus, drive them from
the roadside in England and Wales for the first time since Gypsies
appeared in Britain in the early 16th century.<br>
We hope that the campaigning and lobbying from Gypsies and Travellers and
their supporters will lead to the relevant clauses being removed
completely from the Bill. If these clauses and especially if the new
criminal offence is brought into force, then we think it is clear that a
legal challenge will come forward immediately to these draconian and
inhumane provisions. Once again we would urge Gypsies and Travellers
potentially affected by these provisions to contact us. We would urge all
those who object to these provisions to join with the Gypsy and Traveller
national and local organisations in their campaign against this awful
piece of legislation.<br><br>
<b>Community Law Partnership<br>
</b>23rd March 2021<br>
For full details about the current state of the law please see Willers
and Johnson eds. Gypsy and Traveller Law (Legal Action 2019).<br>
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