When They Make a Battlefield of Her Choice

This is a guest post from Victoria Ridler, who is a lecturer in law from Birkbeck College, London.  It was originally posted at Critical Legal Thinking.

 

When I first noticed their banner as I walked by Bedford Square, in London,  I didn’t think too much about it. It registered as a depressing example of the public expression of a position I had strong opposition to, not much more. It wasn’t until sometime later that I clocked the unusual location of the small public protest — a quiet spot with relatively little pedestrian or other traffic upon which to make an impact. I googled. It turns out that the ‘impact’ of the protest was directed toward the women who were seeking the services of the clinic across the road, the British Pregnancy Advisory Service. Although the large banner, small signs, a handful of the ‘faithful’ across the street — watching, singing, and praying as the women came and went — was not the full extent of their activities. It also involved up to two individuals stationed on either side of the front entrance of the clinic, handing out (factually incorrect and manipulative) information, and trying to engage both those coming and going to the clinic, and passer-bys, in discussion. There have also been reports of assault and filming. This outraged me. Freedom to protest, freedom of expression, okay. Harassing women during what is often a very difficult and private experience, not okay.

The response to the vigil has been escalating, along with the vigil itself. Most recently we saw a counter-protest (outside of clinic hours) which significantly outnumbered the pro-life campaigners. Whilst the symbolic victory may have been won by those who will defend the right to choose, the fact that the counter protest was held only after clinic hours is indicative of a deeper issue. Those who would defend the right to choose are conscious not to contribute to the distress of women seeking these services.  Unfortunately, vigil keepers do not share this concern, and willingly make a battlefield of the clinic entrance. Even if the slumbering giant of the pro-choice movement has awoken, it does not necessarily address this key issue — that is the issue of tactic, strategy, and what constitutes an acceptable form of protest or political expression. Counter protest (outside clinic hours), polite but clear letters of opposition (I am infamous for this one), or confronting vigil keepers as one walks by may persuade some that their peaceful protest is not as peaceful as they think, but those committed to the campaign remain. The question that I want to raise is what role, if any, do we think the law ought to play in addressing this issue?

The role of the law in relation to forms of direct action or protest is understandably met with suspicion. Examples of disproportionate and violent responses to peaceful protest has ceased to surprise many of us (if it ever did). Perhaps even more fundamentally, the law itself is a form of constituted power that protest may seek to challenge. We have good reason to be hesitant about invoking the law to limit forms of protest: But this hesitation risk subsuming the political to the legal. The right to protest as a legal right is already necessarily limited. It does not define what may be legitimate protest according to political or ethical (or other) criteria. But that does not mean that a legal right to protest is not an important and valuable thing – but it will always be a limited conception of political action. What we should be asking ourselves is what kinds of limits these legal limits should be.

Returning to our case of those who keep vigil outside of abortion clinics, we might want to say that as a form of political action it should not be confined or deterred by the legal form. But then if harassing women is their form of action – my political response is to stop them. Theoretically, a politically ‘legitimate’ response would be for me to send my posse out to stop their posse from harassing women, but not only does the law already constrain such a response, it is not a particularly desirable form of action. If we ask where we believe the limits of legal protest should lie on the other hand – many of us would likely say that those limits should preclude harassing women.

As it turns out, the law already reflects this limit. Harassment is a criminal offence, and the law does not recognize protest as a defence. Significantly, since the introduction of the Serious Organised Crime and Police Act 2005, the law recognises the particular kind of harassment that is the result of a political campaign, campaigns which target a particular person or persons to try to persuade them not to do something they are legally entitled to do. But then, what does the law recognise as harassment? Generally, the answer is a course of conduct that causes someone alarm or distress (or fear of violence). It doesn’t matter whether the person engaged in this conduct thinks they are causing alarm or distress, but what the ‘reasonable person’ would think would cause someone alarm or distress. Are these dangerous lines to be drawing, especially in relation to protest? Absolutely. Most forms of protest probably cause some kind of alarm or distress — in fact wearing a bright colour whilst walking down the street might cause someone alarm or distress. But it is, I would argue, a line that should be drawn.

In this case the nature of the conduct is distinguishable as harassment by the nature of the target. These are not any member of the public going about their daily business — the targets of the vigil keeper’s conduct are women who are actively seeking abortion related services. They are identified as such and confronted because they enter the door of a clinic. In what is perhaps one of the more difficult and deeply private moments of their lives, they are subjected to an ordeal by those who assume moral and spiritual superiority — and who would seek to stop them from exercising their choice. Would the law find this to be harassment? I suspect so. Should we look to the law in such a case? Yes.

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Online Survey: Sexual Violence, Substance Use and Capacity to Consent

This is a guest post from Nick Beard of AVA’s Stella Project.  Nick says ” We’re conducting a survey into the views of both survivors and professionals as to how the law deals with intoxication and the relationship with sexual consent.  We’re particularly eager to get the opinion of legal professionals who have worked either defending or prosecuting rape cases.”

 

AVA’s Stella Project is the leading UK agency addressing the intersecting issues of domestic and sexual violence, drug and alcohol use and mental health. As part of its current work, the Stella Project is conducting a small research project on alcohol, drugs and sexual assault.
The project will critically review the law and the criminal justice system in England and Wales on the issue of “capacity to consent” in order to develop guidance and work with service providers, the police and the criminal justice system to improve responses to survivors of sexual violence.
To ensure that the views and experiences of survivors are at the centre of this work, we are looking for people in England and Wales who have experienced sexual assault when either they, or the perpetrator, were affected by drugs and/or alcohol to complete a short online survey. We would also like to consult with professionals whose work is in any way connected to these issues about their understanding of how drugs and/or alcohol affect a person’s “capacity to consent”.
To find out further information about the project and links to both surveys please click here.
There is a standalone link to our survey for professionals available here and our online survey for survivors can be found here.

If you are able to display a poster which requests participation from survivors in this project or you would like further information about the work please email lucy.hayton@avaproject.org.uk or nick.beard@avaproject.org.uk. Any time which can be spared would be greatly appreciated.

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Forced marriage: why criminalisation isn’t the cure

This is a guest post by Dr Aisha K. Gill (@AishaGill), Reader in Criminology at University of Roehampton and co-editor of Forced Marriage: Introducing a social justice and human rights perspective, and Khatun Sapnara, a barrister at Coram Chambers specialising in criminal and family law cases, and Chair of the Ashiana Network.

At the end of March 2012, the Home Office concluded its consultation on criminalising forced marriage. Proponents of criminalisation argue that the creation of a specific criminal law against forced marriage would allow the police and courts to combat the practice more effectively. However, many of those who work directly with victims believe that criminalisation would create more problems than it would solve.

Currently, the Forced Marriage (Civil Protection) Act allows family courts to issue forced marriage protection orders to prevent individuals from being forced into marriage. The ever increasing number of applications for these protection orders is a strong indication that the legislation is effective. Moreover, while no official statistics are currently available, published evidence indicates that only five breaches of forced marriage protection orders occurred between November 2008 and May 2011.

The Ashiana Network (the only dedicated forced marriage refuge in the country) asked all twenty current residents in its three refuges what they thought of the proposals. Seven said that criminalisation might help raise awareness of the issue within affected communities, potentially deterring families from engaging in the practice. However, nineteen agreed that if forced marriage were a criminal offence they would not have gone to the authorities for help because they would not want to see their parents being prosecuted in a criminal court or imprisoned. Several also worried that criminalisation would lead victims who reported their plight to be ostracised or even disowned, not only by their family but the wider community. Some even feared violent reprisals against women who seek help from the authorities would increase.

Many victims of forced marriage need to be reassured that the protection they seek can be obtained in the family courts and that their families will not be prosecuted before they will agree to make a formal statement. This would not be possible if plans to criminalise FM go ahead: as crimes are prosecuted in the public interest rather than by the victim, victims’ wishes are rarely prioritised.

This is critical as under-reporting is already recognised as a major problem in relation to both forced marriage and other forms of abuse that occur within the family; although the Government estimates that 5000-8000 cases of forced marriage take place in theUKevery year, only around 1500 are currently reported to the Forced Marriage Unit. The fact that criminalisation may deter even more victims from seeking help should be a major concern to the Government.

Moreover, the Crown Prosecution Service can already prosecute cases of forced marriage under existing criminal offences including rape, kidnap and assault. It would be simpler and far less controversial to introduce forced marriage as an aggravating factor with regard to sentencing as opposed to creating a new, specific offence.

However, the simplest solution of all would be to ensure that existing criminal sanctions and civil remedies are used effectively. At present, statutory agencies (including education, health, police and social services) are insufficiently versed in the Government’s own best practice guidelines. There is a far more urgent need for better training for professionals dealing with forced marriage cases than there is for new legislation.

In addition, the Government could follow Scotland’s example and criminalise breaches of forced marriage protection orders. It is significant that breaches of civil non-molestation orders relating to domestic violence are already treated as criminal offences inEnglandandWales, even though there are no proposals to create a specific criminal offence concerned with domestic violence. It would make more sense for the Government to apply the same principles to both forms of abuse to ensure that these similar problems are treated as equal under the law. Criminalising breaches of protection orders for both would rectify the current disparity. Introducing a criminal offence for forced marriage would only deepen it.

While the proposal to criminalise forced marriage is well-intentioned and would likely have some positive effects, it ultimately represents a ‘quick fix’ solution to a complex and longstanding problem. The Coalition Government needs to step back and review how well current legislation is working, and how it can be improved, before adopting new legislation that is likely to make it harder, rather than easier, to protect victims and prosecute perpetrators.

Categories: crime, family | 1 Comment

Families need fathers… unless they’re foreign

Theresa May has pledged to change the Immigration Rules to end the ability of deportees to appeal on the basis of Article 8 ECHR.

Deportation is very different to administrative removal, although the tabloids often use ‘deportation’ to mean removal.  Removal is what happens to someone whose paperwork is not in order, and it is possible (in most circumstances) for that person to reapply to enter the UK, although they would have to have a good explanation for being previously removed.  Deportation is banishment: get out, and never darken our white cliffs again.  Anybody bar a British citizen can be deported, even if they are a permanent resident, or have lived in the UK from early childhood, if they commit a criminal offence.

This marks a final shift in favour of the state against the individual when it comes to deportation.  When I began practising immigration law, in 2002, a person with a deportation notice could appeal on the basis that their deportation was unnecessary.  A judge (Adjudicator) would consider the evidence in the round, and it was only if deportation was deemed conducive to the public good that the order would be upheld.  This meant that a person who had no previous convictions, or who had acted uncharacteristically, or who had good probation reports, would often avoid deportation.

This changed substantively with  the UK Borders Act 2007, which swung the pendulum the other way.  Any person receiving a prison sentence of twelve months or more (including cumulative shorter sentences over five years) will automatically be deported, subject to s.33 of the Act which includes:

(2)Exception 1 is where removal of the foreign criminal in pursuance of the deportation order would breach—
(a)a person’s Convention rights, or
(b)the United Kingdom’s obligations under the Refugee Convention.

(3)Exception 2 is where the Secretary of State thinks that the foreign criminal was under the age of 18 on the date of conviction.

(4)Exception 3 is where the removal of the foreign criminal from the United Kingdom in pursuance of a deportation order would breach rights of the foreign criminal under the Community treaties.

There are also exceptions for a person who is in custody awaiting extradition, or for a person hospitalised under the Mental Health Act.

It is s.33(2) which is most commonly used.  If a person gets a sentence which triggers deportation, they will be deported unless they can prove that deportation would breach their rights under the European Convention on Human Rights, or the Refugee Convention.  For example, a recognised refugee would appeal on the basis that the circumstances pertaining when they were granted refugee status still apply.  Even Theresa May has not yet suggested that sending someone to a likely brutal death in Evin Prison would be acceptable if they did a naughty in the UK, although it’s probably a matter of time.

The ECHR is more complex.  Articles 2 and 3 (right to life; freedom from torture) are usually swallowed up within the Refugee Convention.  The most commonly argued Article is Article 8, the  right to family life. Well, you could ask bullishly, why should criminals have rights?  You could go further; the Telegraph did.  And the answer is found in Beoku-Betts, an enormously useful little case which confirms that when it comes to Article 8, “each affected family member is to be treated as a victim.”  That is to say, if F is deported, and that affects his wife W, and his children S and D, then it is not just an assessment of F’s rights which must be carried out, but also an assessment of W, S and D who are innocent parties.

It wasn’t purely out of sympathy for family members of foreign prisoners that the Lords came to such a decision.  As they pointed out,

“What could be less convenient than to have the appellant’s article 8 rights taken into account in one proceeding (the section 65 appeal), other family members’ rights in another (a separate claim under section 7 of the Human Rights Act)?”

That is to say, separating the claims would not prevent W, S and D from having their own claims heard, it would merely require further court time and expenditure as they would be forced to litigate separately.  The conclusion for F may well remain the same.

It is not all that uncommon for a person subject to deportation to have a British or settled wife / girlfriend and child(ren).  Some prisoners with more chaotic lives may have contact with more than one child by different mothers.  The reason that foreign prisoners are able to rely on Article 8 is not because the judges are holding a pity-party for them, but because it can be destructive for children to have a parent whisked away. A parent going into prison for a predetermined length of time can be traumatic, but for that parent to be taken off to a foreign country and never seen again can have a devastating effect on a child.  This is not to say that procreation is a get-out-of-deportation-free card – a parent who has little or no contact with their child will be in a very different position to one who is a joint or primary carer – but that the child’s needs must be at the forefront of the decision.  Even if their parent has committed an offence.

At best, all that is suggested is the restoration of the old “truly exceptional” test, whereby it had to be shown that the case was truly exceptional.  At present, it is a “reasonableness” test: is it reasonable for the entire family to relocate with the deportee?  The old test would demand that it were impossible that they could do so.  At worst, and from what May has said the more likely option, is that a deportee and their family would be unable to rely on Article 8 at all.  That would mean forcible separation of parent and child in some cases.  To deny a child the right to a relationship with a parent is an unconscionable breach of the child’s Article 8 rights.

And there’s another sneaky little part in these plans.  According to the Guardian,

“May will make clear in the new rules that a right to family life will not prevent the deportation of a foreign national who has been convicted of a criminal offence, has breached immigration rules or cannot maintain themselves or their family.”

Did you notice that?  Hang on; one minute we’re talking about people who have committed an offence meriting 12 months in prison, and the next we’re talking about a parent who’s lost their job.  In conjunction with the new minimum income proposals, that’s quite frankly terrifying.  Also, incompatible with s.55: if we’re talking about children settled in the UK and again, innocent parties where a parent has been made redundant and fallen below the income threshold, then May is talking about denying not just the parent but also the children the right to appeal on the basis of Article 8.

Back in opposition in 2005, Theresa May was quoted by the Sun and by the organisation Families Need Fathers as saying:

“Parental rights have been steadily eroded by New Labour, from the right of parents to discipline their children, to the ability of separated fathers to have an involvement in their upbringing.”

Her own proposals are not so much an erosion as a landslide.

Categories: immigration | Tags: , , | 4 Comments

Time to review Nutting?

An interesting lump of caselaw for today’s blog:  the 2004 case of Nutting v Southern Housing Group.  I wrote about this a few years ago, but there doesn’t seem to have been any change since; indeed, it is cited with approval in Baynes v Hedger (2008) and Lindop v Agus (2009).

Where a person in social housing dies, their partner (same sex or otherwise) is entitled to inherit their tenancy.  So far, so good.

However, the local authority who provide the housing need to be satisfied that the relationship really did exist.  I guess that’s fair enough, before they assign over the tenancy, when there are so many people waiting for social housing.

But to show that you were in a relationship, it’s not enough just to *tell* them.  You have to show that you had “openly” set up home together, that “the relationship was one which had been presented to the world openly and unequivocally” and basically that everyone, including the local authority, knew about it.  (This is, at least, how the local authority are interpreting the ‘open and unequivocal’ requirement.)

This is actually more problematic than it might first seem.  I came to this case via an elderly man of Jamaican origin whose same-sex partner had died, and who was trying to inherit the tenancy in an area not best known for its friendliness to Dorothy.

Where does Nutting leave people who aren’t out?  How about people who live in areas where they don’t want it known that they’re gay, because of the threat of abuse?  Or those who have a homophobic housing officer?  Or people who are from cultures where it’s shameful to be gay and they don’t want to shout it from the rooftops?

Apparently the local authority gets to demand that older people ( 70+) who still suffer shame and stigma about their sexuality, and who may want to keep their private lives private, and who because of being older are also more vulnerable to abuse in the community, just start waving the rainbow flag for all to see – or they can make the grieving partner homeless when one partner dies.

The caselaw doesn’t take into account that being “open and unequivocal” about a same-sex relationship is still something of a privilege.  It will be easier to be “open and unequivocal” if you live in a Guardian-reading yoghurt-knitting liberal area than if you live on an inner-city estate.  Similarly, you might be more open if you’re young.  If you’re not from a traditionalist background.  If you’re confident you can outrun anyone with an issue over it.  I’m quite interested in whether there’s an argument here that this caselaw falls foul of Article 8 (right to private & family life) conjoined with Article 14 (freedom from discrimination) because it clearly discriminates against those who, for whatever reason, find themselves unable or unwilling to be out, and that is more likely to be older people and those from traditionalist backgrounds.

But there’s another issue, too, confined solely to expectations of privacy.  Because what the caselaw seems to be saying is this:  if you own your own home, you can enjoy as much privacy over your sexuality as you like.  If you rent from the local authority, then they will feel entitled to know exactly who you’re sleeping with, in the name of “openness.”  Privacy?  Too good for the poor.

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Would you x-ray Anne Frank?

Yet another gem from the Ministry of Silly Ideas – sorry, UKBA – on how to identify unaccompanied asylum seeking children (UASCs) as children.

This has caused something of a headache to the authorities in the past, because children under 18 get a preferential deal to adults – as they should be.  UASCs can expect to be granted Discretionary Leave to Remain until they are rising eighteen, placed either in foster care or in teen hostels, and given access to education, purely on the strength of their age and regardless of the strength of their claim.  It is possible – even probable – that a few “UASCs” are in fact over eighteen, and it’s jolly difficult to tell the difference between a young person aged seventeen and a half and a young person aged eighteen and two months, especially since UASCs don’t tend to bring their passports with them.

The current way to deal with this is for a child to present as a child, and the local authority to assess them based on what they look like and how they interact with adults.  Hillingdon and Croydon are in my experience the most disbelieving, no doubt because they have the most referrals (Heathrow arrivals come under Hillingdon; in-country arrivals go to Croydon).

This is obviously an inexact science, and there are continual tussles through the courts as to whether a child is a child.  If the social services report is “Merton compliant” then even a later paediatric report may carry little weight, but an Immigration Judge has superpowers and can do an on-sight assessment at the Tribunal.  Confused?  Not nearly as much as the kids are.

It would obviously be preferable that the age assessment is made as quickly as possible so that the child can either be settled, or, if they are deemed to be an adult, can have a decision made on their claim.

However, the means of assessment are inexact.  A sixteen year old Afghan boy who has never attended school and has worked outdoors from the age of ten is unlikely to interact in the same way, or look as childish, as a sixteen year old UK boy who is still in mainstream education.  A sixteen year old Congolese girl who has been imprisoned and raped may well come across as significantly more world-weary than her Islington-based counterpart.  A teenage victim of trafficking who has been given a false backstory to learn under physical or emotional duress could give a confused and incoherent chronology.  Few UASCs will present as the picture of rosy-cheeked, Blytonesque adolescence.

However, the proposals for dental x-rays (implemented without formal approval) are unlikely to be a great improvement.  Not only are there serious doubts over the ethical and legal principles, but there is no evidence that they will give an answer; according to the document linked by Free Movement, the only dataset comes from UK Caucasians and Afro-Trinidadians.  Since by far the largest group of UASCs is from Afghanistan, dental x-raying is unlikely to provide a definitive age assessment.

This is not the first time that UKBA has come up with dubious pseudo-science in the field of asylum.  They continue to implement linguistic analysis tests without any recognition of the function of code-switching (or the use of qualified linguists!), and a couple of years ago there was a proposal to take tissue samples from asylum seekers in order to “prove” their nationality.  This was based on the optimistic theory that the Torso in the Thames science would be applied to living asylum seekers.

What they had failed to recognise is a) the Torso in the Thames analysis involved testing the bones, not mitochondrial DNA, which might still be forensic science but is Not The Same Thing, and b) testing mitochondrial DNA might, possibly, at a stretch, tell you if someone is ethnically Somali but not whether their grandparents moved to Kenya fifty years previous.  It could only work if UKBA were under the delusion that your DNA changes as you cross a border.

The proposals to x-ray UASCs are almost as scientifically dubious and could well mean that children who desperately need our protection will be classified as adults and refused permission to stay.  It is too easy for desk-drivers in Whitehall to lose the reality of the situation amidst the statistics.  But had Margot and Anne Frank managed, in 1942, to travel to London, would they have been received as the children they were?  Or disbelieved, x-rayed and slung into detention?  Family law tries to keep the welfare of the child at the forefront of decision making.  This should carry over into asylum cases.  My own view is that it is far preferable for the tiny number of dubious teens to be treated as children than for children to be wrongly treated as adults.

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Response from MoJ re women in the CJS

In February, we wrote to the Justice Secretary in support of Clive Chatterton’s call for reforms for women in the criminal justice system.

Click here to read the response.

Broadly, this looks very positive; I hope that here, policy will translate into action.  We’d be interested to hear views from anybody working in the field; do feel free to leave your thoughts in comments.

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Family Migration: Too Good For the Poor?

There were rumours last November that the minimum income threshold for spouse migration was about to increase dramatically, following a recommendation from the Migration Advisory Committee announced by UKBA.

At present, a non-EEA national wishing to join a British or settled spouse (or civil partner or unmarried partner) must show that the relationship is genuine; that the parties have met; that they intend to remain together and that they will be maintained and accommodated “adequately” in the UK.

“Adequate” could mean almost anything, and until 2006 it was a fairly subjective test.  That changed with KA & Ors (Adequacy of Maintenance) Pakistan [2006] UKAIT 00065, where the Tribunal held that the household income must amount to at least as much as it could expect to receive if it were dependent on benefits.

There was good reason behind this:  the Tribunal commented that

“It is extremely undesirable that the Rules should be interpreted in such a way as to envisage immigrant families existing (and hence being required to exist, because social security benefits are not available to them) on resources less than those which would be available through the social security system to citizen families. To do so is to encourage the view that immigrant families need less, or can be expected to live on less, and in certain areas of the country would be prone to create whole communities living at a lower standard than even the poorest of British citizens.”

(That leaves open of course the question of whether it is acceptable for NASS and s.4 payments to be made at only two thirds of the income support level, but that is a separate issue.)

A spouse applying to enter the UK therefore needs to show that they have an income which equals rent plus council tax plus approximately £105 per week (the income support level for a couple over the age of 21).  The exact amount will depend on the rent that is paid, but it is in the region of £13,700.

However, this covers only the cost to the couple themselves.  The MAC calculated that with an income of £13,700, the hypothetical couple would be entitled to some tax credits.  They would not lose that entitlement until they had a household income of £18,600, and would not be contributing to defence, schools and the NHS until it was at £25,700.  Their calculations are in this report; it is unclear how they came to the latter figure given that a household on £18,600 will be paying income tax as well as VAT.

The MAC therefore recommended that the minimum income threshold be raised to somewhere between £18,600 and £25,700, with corresponding increases for every accompanying child.

A letter leaked at the weekend to the Telegraph now shows that the government are intending to adopt the higher figure.  The figures will now look like this:

Family entering Household income needed
Spouse only £25,700
Spouse + 1 child £37,000
Spouse + 2 children £49,300
Spouse + 3 children £62,600

 

That is quite a serious departure from the current rules, and the MAC estimate that it will reduce net spouse migration by 63%.

It is unlikely that this will disturb the government: they have pledged to reduce net migration, and are currently struggling to do so.  If this is merely a transparent ploy to reduce net migration without a ‘necessary purpose,’ it will go the way of the Quila judgment and be overturned.  If however the government are able to point to the straitened economy as a necessary purpose, it would, like the English language requirement in Chapti, remain.

The effect of this would inevitably be greatest on women, people from the Indian subcontinent, younger people, people with disabilities and those outside London and the south-east.

It has been clear for some time that UKBA want to limit family migration from the Indian subcontinent.  According to the Migrants Rights Network, over 40% of people in the Bangladeshi and Pakistani communities in the UK earn less than £14,500 per year compared to the white British rate of 25%.  Age is also an issue here:  Asian and British Asian people tend to marry earlier than white British people.  Even a promising student is unlikely to be earning £26,000 straight out of university as compared to the same person in their early 30s.

The ongoing gender pay gap means that women continue to be paid around 15% less than men, and women are also more likely to take part-time or low-paid employment.   Work done predominantly by women (such as caring assistant work) tends to pay less than work done predominantly by men.  There is no doubt that the new income requirements would be more strenuous for women seeking to bring a partner to the UK than for men trying to do the same.

If these proposals go through, there is likely to be a slew of cases arguing Article 8 (the right to family life), in particular where family life cannot be exercised elsewhere, for example where the parties are in a same-sex relationship and the non-settled party is from a country where homosexuality is illegal.  It is also likely to take the courts to settle the question of future earnings:  if, say, a woman works as a part time teaching assistant on a salary of £14,500, and has one son from a previous relationship, is she allowed to bring a spouse if he is a qualified doctor likely to earn far more than she does?   Then Article 8 again, with the question of what a person would do if they cannot meet the income threshold but equally cannot move to another country as it would disrupt their children’s contact with their fathers?  It would be unconscionable to force a British woman to choose between life with her husband in another country and life with her children in the UK, if those children have their own ties here.

Gross LJ described the SSHD’s reliance on a blanket policy in Quila as “an unpersuasive counsel of despair” – one of my favourite judicial quotations – and it is possible that this blanket income requirement would meet with the same assessment.  If not, then it would seem that the ECHR, and in particular Article 8, will be increasingly needed to repair the ruts left in the UK’s family migration policy by the coach and horses driven through it by Parliament.

Categories: immigration | Tags: , , | 1 Comment

Lesbian families: the role of the donor

An interesting judgment handed down in the case of A v B & C, adding to the growing list of caselaw dealing with the position of a donor father to a lesbian family.

The situation in this case was that the two women – B and C – had started a family using sperm from a male friend, A.  They had agreed that B and C would be the parents of the child, and that A would have a more avuncular role.  A however saw his role more as that of a father who had divorced the mother (“the divorce model”) and wished to have increased contact with the child as would be the case if he had been the male parent in a heterosexual family.

The court below had made an order for a set amount of contact between A and the child.  The challenge brought by A was not to the terms of the order, which were accepted, but to the judgment.  The judge had gone on to say that he did not see the basis for staying contact as being likely to change for the next two years or so, which the Court of Appeal held amounted to a prohibition on A seeking to increase staying contact during that time.

It was clear that the intentions of the parties pre-conception were now radically changed.  B and C had anticipated setting up a nuclear lesbian family, without interference from A, as had been agreed at the outset.  Could A then change his mind about his role in parenting?

The court held that he can, and as ever, it is only the child’s welfare which is to be taken into account, not any agreements made between the adults.  Giving the leading judgment, Thorpe LJ said that:

“I am cautious in reaction to Mr Howard’s repeated submissions that great weight should be attached to adult autonomy and the plans that adults make for future relationships between the child and the relevant adults. Human emotions are powerful and inconstant. What the adults look forward to before undertaking the hazards of conception, birth and the first experience of parenting may prove to be illusion or fantasy. B and C may have had the desire to create a two parent lesbian nuclear family completely intact and free from fracture resulting from contact with the third parent. But such desires may be essentially selfish and may later insufficiently weigh the welfare and developing rights of the child that they have created.”

An agreement is not to be taken as gospel, and can be overriden if the child’s interests demand it.

Black LJ – a lady who knows her onions in these cases – said that she had hoped that it would be possible for this case to lay down some generalised guidance, but that “I have concluded that this is an area of family law in which generalised guidance is not possible.” It looks as though practitioners hoping for a nice clear rule to cite will be disappointed for the immediate future.

She, like Thorpe LJ, specifically rejected the idea that a pre-conception agreement would be determinative of the case:

“The adults’ pre-conception intentions were relevant factors in this case but they neither could nor should be determinative. What happened here shows graphically how plans change over time. Plainly it is sensible for people who are intending to enter into an arrangement such as this one to consider and spell out in as much detail as they can what they contemplate will be the arrangements for the care and upbringing of their child. But no matter how detailed their agreement, no matter what formalities they adopt, this is not a dry legal contract. Biology, human nature and the hand of fate are liable to undermine it and to confound their expectations. Circumstances change and adjustments must be made. And above all, what must dictate is the welfare of the child and not the interests of the adults.”

Where does that leave those wishing to conceive a child in a lesbian relationship with donor sperm, or those advising them?  Is a pre-conception agreement worth the paper it’s written on?  It is still worth creating one, if only to commit to paper the intentions of the parties, as a means to ensure that all parties at least start off on the same page, and that issues have been thought through.  However, such an agreement cannot be used to force each party to adhere to the terms of it if they later decide they wish to change something, and the courts will not treat it as an enduring contract.

Categories: family | Leave a comment

Sarah’s Case

This is a guest post by Milly, who blogs at Beneath The Wig.  You can find her on Twitter as @_millymoo.  Here she explains the legal limitations to the Court of Appeal’s powers in “Sarah’s case” and details the changes made to the law as a result of the prosecution.

 

The desperately sad Sarah’s case was in the Court of Appeal today.

Sarah was raped by her husband, and taken by him to massage parlours to provide sexual services for other men, actions which her husband then emotionally abused her about*. Sarah eventually found the courage to make a complaint to the police about her husband, and rape proceedings commenced. He spent sometime on remand, before being released on conditional bail. While on conditional bail, the relationship between Sarah and her husband resumed.

Sarah subsequently withdrew her complaint of rape, and proceedings were then taken against her for making a false complaint. After taking legal advice, Sarah admitted that the retraction was false, and that she had been telling the truth in her original complaint.

On 15th October 2010, the Crown Prosecution Service (CPS) offered no evidence to a charge of perverting the course of justice relating to her making a false complaint of rape. Sarah pleaded guilty however, to a charge of perverting the course of justice by making a false retraction.

Of course, there is a lot of background to the retraction and the retraction of the retraction, which is helpfully set out in today’s judgment, which can be found here.

At the beginning of November 2010, Sarah was sentenced to 8 months imprisonment. On 23rd November 2010, the Court of Appeal reduced that sentence to a non-custodial one. In direct response to this case, Keir Starmer, the Director of Public Prosecutions, changed the CPS guidelines for prosecuting false retractions, putting them in the band of cases that need approval of the DPP to proceed, and acknowledged that Sarah’s case fell into the category where he did not consider justice was done or was seen to be done.

However, the conviction for perverting the course of justice remained. Today’s hearing was the appeal against conviction, which failed.

An appeal against conviction can only succeed if the court is persuaded a conviction is unsafe – a deliberately broad test, but nonetheless, a test which has to be passed. Although Alison Levitt QC, on behalf of the CPS, accepted that under the very guidelines Sarah’s case brought about she would not have been prosecuted, unfortunately she had been, and the Court of Appeal were bound by the fact that not only had she been prosecuted, she pleaded guilty, and therefore there was a conviction that must pass the ‘unsafe’ test for the appeal to succeed.

As may be expected, Sarah’s case was put forward on the basis at the original trial, Sarah ought to have been advised to plead not guilty, on the basis she made the retraction due to duress. Using the remarks of the Court of Appeal made in the appeal against sentence, it was put forward on Sarah’s behalf that she was clearly vulnerable having been subjected to substantial sustained abuse, and that new reports demonstrated she was at all material times suffering from post traumatic stress disorder.

Duress in a legal context bears little relation to the meaning of duress in everyday language – it is not ‘pressure’ as we think of the word in its everyday meaning, but in a legal context, it means pressure of magnitude in extreme circumstances, such as an imminent threat of death or serious injury, which cannot be easily evaded. The court found, while having real sympathy with the pressures that were no doubt placed upon Sarah, that those pressures did not amount to a legal defence of duress, and that no reasonable counsel would advise her that such a defence was available to her at the time of the initial trial.

It was also put forward on Sarah’s behalf that the decision to prosecute her was in itself flawed, and therefore the resulting conviction was. The court went step by step through the process, starting with the police, moving on to Sarah’s legal representatives, and finally, the CPS. In respect of all, the court could find no flaw in the decision making process.

Finally, it was put forward that the conviction was simply unfair. The court rejected that submission, on the basis that when due process had been followed and a conviction determined safe, they had no scope to quash a conviction on such a basis. Overall, they came to the conclusion that there was no basis at all for them to interfere in the conviction, and therefore had no basis to allow the appeal.

Sarah has without doubt or question paid a regrettably high price after making a decision in a very vulnerable state. Her legacy, which undoubtedly she wishes she hadn’t been in a position to create, is that she has also brought about changes that we should all be grateful for.

*All the hearings in Sarah’s case have proceeded on the basis her complaints are true, however, it has to be noted that Sarah’s husband has not been prosecuted for the offences and does deny them.

Categories: crime | Tags: , , | 13 Comments

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