The Human Rights Acts - Essay Example

IN THE HIGH COURT OF JUSTICE CLAIM No. QUEENS BENCH DIVISION ADMINISTRATIVE COURT VERONICAH PEPPER (MINOR SUING THROUGH HER MOTHER AND GUARDIAN AD IDEM MRS. ANTONIA PEPPER) CLAIMANT -VERSUS- THE SECRETARY OF STATE FOR EDUCATION 1ST DEFENDANT THE INDEPENDENT REVIEW PANEL OF THE EDUCATION DEPARTMENT, GLADBURY DISTRICT COUNCIL 2ND DEFENDANT AND THE BOARD OF GOVERNORS, GRADBURY GRANGE SCHOOL 1ST INTERESTED PARTY THE HEAD MASTER, GRADBURY GRANGE SCHOOL 2ND INTERESTED PARTY FACTUAL BACKGROUND 1. The claimant on and before 22nd December 2014 was a bonafide pupil at The Gladbury Grange School of address Gladbury Grange GD15 5BX. She had attended the said school until the said 22nd December, 2014 when the head teacher decided to permanently expel her on the grounds of indiscipline. 2. The claimant herein was suspended through the decision of the head teacher, The Gladbury Grange School, Mr. D J Carey via a letter dated 22nd December 2014 and under Section 51A of The Education Act, 2002. The said Head Master expelled her on the grounds that the claimant herein had on 19th December 2014 been ‘seen contaminating Mrs. Kovac’s tea with sleeping pills’. The drug alleged to have spiked into the teacher’s hot beverage was diphendyramine citrate. The head teacher, in reaching his decision, relied on statements recorded by Ms. P, the claimant’s fellow student and Mrs. Kovac, the alleged victim. 3. According to the complainant’s main witness, one Ms. P who recordeda statementstating that during the morning break, she had been curious of what the claimant was up to and had followed her to classwhere the claimant was alone and seen “Veronica (the claimant herein)openherbag,takeoutasmallpacketofwhatlookedlike medicine(Icouldn’tseeexactlywhatitwasasitwas smallandIwastoofar away).Shethen wentovertoMrs.Kovac’s desk.IcouldclearlyseethemugMrs.Kovacusesonherdesk.Itisverylargeandhas“world’sbestteacher”written on it.Veronica thendroppedsomething intothemug.Sheput thepacketbackin herbagandturnedtowardsthedoorIranawayimmediatelyasIdidn’twant her toknowthat I’dseen her. Idon’t think she saw me.”Witness P further records that while in her French class there ensured some commotion in the hallway outside when Mrs. Kovac had passed out and an ambulance had to be called. However, she does not state the exact time when she had attended the said French class. Neither Mr. Carey nor Mrs. Kovaccorroborates Witness P’s allegations. 4. The claimant states that the Head teacher, Board and Panel erred by not taking notice of the fact that Witness P, whom the claimant believed to be Ms. Pauline and the claimant herein were not in good terms. The claimant further states that Pauline and the claimant have had disagreements after the claimant started dating Paulina’s former boyfriend, Steven. The claimant’s mother aptly puts it: “Pauline was devastated when he (Steven) dumped her and got together with my daughter. She has hated Veronica ever since. I know that they havehadverbalfightsinclass,sotheteachers mustknow.Ihave advisedVeronicatoriseaboveit.” 5. Mrs. Kovac in her statement records that she started feeling unwell after the end of the lesson after the morning break. She notes: “Isuddenlyfeltvery dizzyandasifIcouldn’tspeakclearly.MyarmsandlegsweretinglingandIfeltsick.Ifelt likeI wasunderwaterandeverythingaroundmewasquiteunreal.I startedtopanicasI thoughtI mightbehavingastroke.Itsuddenlyfeltdifficulttobreathe.I hadtositdownand musthaveslumpedoveronmy desk.”She further records that she was hospitalized that day and informed by her doctor that she had “an over doseof diphendyraminecitratewhichisaningredientinsleeping pills.”Mrs. Kovac blames the claimant herein because she is one of her difficult students with whom they have had disagreements and the allegations of sexual harassment the claimant made against her former teacher, Mr. Fernley. 6. The Head Teacher, Gradbury Grange School dismissed the claimant’s side of the story without much consideration and adopts Ms. P’s statements. He perceives her to be unreliable. He further writes, in his statement, that “In my experience “P” is a reliable, truthful student. In contrast, Veronica is, I believe, an habitual liar.”He further refers to an incident in which the claimant had made sexual assault allegations against her teacher, Mr. Fernley who later had to be transferred from the said school. Mrs. Kovac too, in her statement refers to the sexual assault allegations incident and notes that the claimant “is a trouble maker we can do without”. 7. The claimant urges that the reference to this earlier incident involving sexual allegations against her teacher was unnecessary, unacceptable and prejudicial to the claimant’s case and chances to be readmitted into the school. 8. Additionally, the claimant states that the sexual harassment incident caused the said school, Gradbury Grange School ill reputation and as a consequence, Mr. Fernley had to leave the school. The claimant further notes that the Head Teacher has been under criticism on the manner in which he handled said incident as the same was quite casual and unsatisfactory. As a consequence, no stern action was taken against Mr. Fernley even though the claimant had reported the matter to the appropriate authorities which included the school management. 9. On receiving the head teacher’s letter referred in Paragraph 2 above informing her of her right to review the decision to the Board of governors (herein after referred to as the Board), Mrs. Antonia Pepper filed her application for review and the same conducted on 5th January, 2015. In the said meeting, the Board held that the head teacher had justifiably expelled the claimant herein from the school in its decision dated 5th January, 2015. 10. In the currency of the said meeting, the Board took oral statements of various witnesses including Mr. Carey and Mrs. Kovac and read out statements of other witnesses. Even though the Board requested the claimant’s mother to present her oral presentations, which she declined, they refused and or declined to allow the claimant herein from making her oral presentations as they thought that such endeavors were unnecessary. The claimant asserts that the Board defied the rule of natural justice that requires the board to hear and consider the claimant oral and written statements. 11. The claimant cannot be said to have waived her right to be heard by the board since her solicitor, who represented her in the said hearing, demanded that the board not only reads the claimant’s statement but also hears and considers her oral presentations. The Board buffed off the solicitor’s request and held that it was not necessary to have the claimant testify. In addition, the meeting was surprisingly short. The meeting was conducted in only one and a half hours, precisely between 3:30pm and 5:00pm, and as a result the Board could not listen to the claimant’s oral presentations. 12. In view of the Board’s decision, Mrs. Antonia Pepper further appealed to the Independent Review Panel, Gladbury District Council (herein after referred to as the Panel) for a review of the decision of the Board. The Panel through its decision dated 30th January, 2015 held upheld the head master’s and the Board’s decisions of permanently excluding the student as being “not illegal, irrational and procedurally improper”. 13. The claimant, as a consequence of her permanent exclusion, has been out of the said school since 22nd December, 2014 to date. She attends a pupil referral unit in Gladbury whose pupils have had negative influence on the claimant. The claimant’s mother has been forced to engage the services of tutor outside school hours to ensure that the claimant’s education does not suffer. The said tutor charges £250 a week and the tutor has been teaching the claimant since the date of schooling opening, following the permanent exclusion from school approximately 14 weeks. Therefore, the claimant’s mother has incurred a sum of £3,500i.e, 14*£250=£3500. 14. The claimant hereby applies to this court for a review of the decisions of the Head teacher, The Board and The Panel through an order of Certiorari. GROUNDS FOR REVIEW Legal frame work (i)STATUTORY FRAMEWORK a) THE HUMAN RIGHTS ACT, 1998 15. The claimant asserts that her right to a fair trial under Article 6 of The Part I of The Second Schedule to The Human Rights Act, 1998. Article 6 requires that in the determination of the civil rights andobligations or any criminal charges against the claimant, she was entitled to a fair and public hearing within a reasonable time and by an independent and impartial tribunal established by law. The Board and the Panel failed or refused to consider the oral presentations by the claimant after the board considered that her representations were unnecessary. The Board in its decision noted that: “While in general it is desirable for the Board of Governors to hear oral evidence from the pupil concerned, this is not a strict requirement.” 16. The claimant asserts that the decisions of the Head teacher, Board and Panel have violated her right to education assured under Article 2 of Part II of The First Protocol of The Human Rights Act, 1998 by excluding her from school permanently since 14th December, 2014 and upholding the decisions of the Head teacher and the Board respectively. The claimant has, by actions of the above parties, been denied opportunity to study in a school of her choice. Instead she has been forced to join another school that has characters that may ruin her persona. b) THE SCHOOL DISCIPLINE (PUPILS EXCLUSIONS AND REVIEWS) (ENGLAND) REGULATIONS, 2012 17. The claimant asserts that the decisions of the Board upholding the permanent expulsion of the claimant from the said school were contrary to Section 51A of The Education, 2002 and Rules 6 (1) (a) and 6 (3) (a), (b), (c) and (d) of The School Discipline (Pupils Exclusions and Reviews) (England) Regulations, 2012 (herein after referred to as the Rules). Rule 6 (1) (a) provides that paragraphs (2) to (6) apply where the Board is informed that the proceedings would lead to the permanent exclusion or exclusion for a total number of 15 school days in a term or where the student would lose an opportunity to take a public examination or a National Curriculum Test. 18. Paragraph 6 (3)provides that in considering whether the pupil should be reinstated or not, the Board is must: (a) consider the interests and circumstances of the excluded pupil, including the circumstances in which the pupil was excluded and have regard to the interests of other pupils and persons working at the school (including persons working at the school voluntarily); and (b) consider any representations about the exclusion made to the governing body by or on behalf of the relevant person, the head teacher or the local authority;and (c) take reasonable steps to arrange a meeting at which the exclusion is to be considered for a time and date when each of the following persons is able to attend- (i) the head teacher, (ii) the relevant person (and, where requested by the relevant person, a representative or friend of the relevant person) and a representative of the local authority; and (d) allow each of the persons described in the sub-paragraph (c) to attend the meeting and to make representations about the exclusion. 19. The claimant asserts that the Head teacher and the Board did not consider the interests of the pupil when excluding her from the school as required under Rules 6 (a) of The Rules. Neither did the head teacher consider the interests of other students and other persons employed in or by the school. He took into consideration an incident in which the claimant had made allegations against her teacher, one Mr. Fernley in which teacher had sent her a message addressing her as ‘babe’ and signed off ‘from GAV xxx’. This incident was said to occasion the school harmful reputation and as a consequence no conclusive investigations and actions were to be taken. The head teacher fell under intense criticism for his failure to act on the said teacher for the accusations of sexual harassment against the claimant. 20. The claimant argues that the Board failed and refused to consider her oral submissions as required by Rule 6 (3) (b), (c) and (d) of The Rules referred to in Paragraph 17 above. The Board considered the representations of the Mrs. Kavoc and Mr. D J Carey but declined to have the claimant testify and be cross examined. Paragraphs (c) and (d) of Rule 6 expressly requires that representations including those of the relevant person (in this case the claimant) be heard and considered. No regard was therefore given to accord claimant fairness that would have lead to reinstatement. 21. The panel further went ahead and affirmed the decision of board that had erred in law as already indicated and that perpetuated unfairness that meant claimant did not opportunity to be reinstated. 22. It is important to interrogate the provision set out in Rule 10 in relation to this case; it reads in part “…the head teacher, in exercise of the power conferred by section 51A(1) of the Act; to establish any fact, any question as to whether that fact is established is to be decided on a balance of probabilities”. It follows that the school authority including the school head and the board should have adhered to those provisions. However given that the claimant had stated the blurred relationship that existed between her and witness P and given that the exclusion took place based on testimony of that witness whose accounts were not corroborated, the test of “balance of probability was not met for the simple reason that the teacher relied on P’s accounts and not the claimants. 23. The school board that was equally bound by the same threshold of balance of probability went ahead to depend on the accounts offered by P as well as the head teacher and Mrs Kovac the alleged victim. The test of balance of probability is questionable given that the board relied on Mrs Kovac’s testimony without any medical proof availed as well as P assertions and not claimant’s sides over the sour relationship between P and claimant. 24. The same balance of proof threshold was not met by the decision of the independent panel. The panel, in making its determination affirmed the position of the school’s board of governors without due regard to the questionable account of witness P on which he case was founded as well as other matters such as lack of medical evidence for Mrs Kovacs case (C) EDUCATION ACT 2002 25. Whereas section 51A (1) of this Act provides that head teachers have the power to temporarily or permanently exclude students from schools, section 51A (e) provides that, “Regulations must make provision about the procedure to be followed on a review”. The spirit and letter of this Act was founded on the common law of procedural fairness means that those procedures must give parties equal treatment in course of deliberations and equal opportunity to give their side. Evidently from the process used, this was not achieved. The claimant was not given time to give her side of the story in front of the panel. On the same note, despite the claimants plea on the possibility of bias of witness “P” as well as the likely bias on the part of the head teacher given the earlier incident( sexual harassment that the head teacher had not satisfactorily handled) the board did not give procedural considerations to those genuine pleas. 26. The laws also provides that(The law(Section 550ZA of the Education Act 1996; which now stands amended in 2011 ) the person carrying on the search must be authorized by the head teacher and must be of the same gender as the person who is being searched . further it provides that there should be a witnesses. From the statement of the head teacher which reads, “I pulled Veronica out of class and asked to search her school bag and her locker. She agreed. In her bag I found a packet of „Sleep-Eeze‟ sleeping pills. Half the packet was empty”. From that statement it is clear that the head teacher was not only alone without witness but also is male. Those actions show procedural in accuracy which amount to illegality. D. The Education (Provision of Full-Time Education for Excluded Pupils) (England) Regulations 2007 27. Section 4(1) provides that, “Except in a case prescribed by regulation ,in relation to the duty of a local education authority under section 19(1) and (3A) of the 1996 Act to make arrangements for the provision of suitable full-time education for a pupil of compulsory school age who is permanently excluded from a relevant school or pupil referral unit, or excluded from a pupil referral unit for a fixed period, on disciplinary grounds, the day from which the education must be provided is the relevant day”. Despite the existence of this piece of regulation, there no attempt whatsoever from the head teacher of from any other authority in the school to offer any kind of arrangement or liaison with the claimant in order to ensure the welfare of the child with regard to education was protected. The actions of the head teacher as well as the school management amounted to actions in bad faith. PROCEDURAL UNFAIRNESS 28. The claimant herein asserts that the Board’s and the Panel’s decision was illegal, irrational and procedurally improper. First, the claimant notes the Board and the Panel refused, neglected and or failed to hear and consider the claimant’s side of the story. The two bodies, above, only heard and considered the oral statements of the schools witnesses namely, Mr. D J Carey and Mrs. Kavoc. The two bodies denied the claimant an opportunity to present her case via oral presentations even after the claimant’s counsel demanded that the claimant give oral presentations. 29. The Board and the Panel, by virtue of exercising quasi-judicial functions is mandated to have accorded the claimant a fair hearing. The fair hearing includes an opportunity to allow the claimant to satisfactorily present her case before the said board. The Lord Loreburn in the acclaimed case of Board of Education v Rice (1911) AC 179 observed that in discharging its quasi-judicial duties just as in this case, “the board of education will have to ascertain the law and also to ascertain the facts. I need not add that in doing either they must act in good faith and listen fairly to both sides, for that is the duty laying upon everyone who decides anything.” BREACH OF LEGITIMATE EXPECTATION 30. Rule 6 of The Rules create a legitimate expectation that the claimant would have her representations considered. The Board and the Panel, by declining to consider the claimant’s oral representations breached this expectation. The Court in Republic v Indian Steamship Co. Ltd (No. 2) (1998) AC 878 it was acknowledged that where the law provides for a certain state of facts or law, there exists a legitimate expectation that the state of facts or law exists. IRRATIONALITY 31. The claimant urges that respective decisions of the Head teacher, Board and Panel fell short of the wednesbury reasonableness test or the principle of rationality as set out by Lord Greene in Associated Provincial Picture Houses v Wednesbury Corporation (1947) 1 KB 223. The head teacher, the Board and Panel relied on the statement by witness P. Witness Ms. P wrote to have seen the claimant add the drug into the beverage. The inclusion of the evidence was detrimental as there existed grudges between P and the claimant. None of the three authorities considered or decided on the credibility of the witness P whom the plaintiff stated to be Paulina. Therefore the Head teacher, Board and Panel reached decisions that no reasonable body could have reached. 32. Both Paulina and the claimant have a history of grudges and or spats amongst themselves and this fact was not denied by the school. None of the three offices considered the import of the spats between the claimant and P in this case. Given their history of disagreements, it was irrational for the Head teacher, Board and Panel not to require P’s evidence be corroborated. There was also no consideration of whether P could be Paulina or a student other than Paulina. 33. The claimant urges that by considering the sexual harassment accusations which the claimant made against Mr. Fernley made the decisions of the head teacher, the Board and The Panel irrational. 34. The claimant asserts that the decisions of the Head teacher, Board and Panel were erroneous, irrational and detrimental to the interests of the claimant as they failed to consider Mrs. Antonia Pepper and the claimant’s assertion that the sleeping pills found in the claimant’s bag belonged to the claimant. 35. The claimant asserts that no medical reports for Mrs. Kavoc for the days she was hospitalized were produced as evidence to prove the contents of the said drug. In the alternative, a chemical analysis report of the drug alleged to have been added to Mrs. Kavoc’s beverage were not produced in evidence. ILLEGALITY 36. The claimant argues that the decisions of the Head teacher, Board and Panel are null and void as they are illegal and made as a result of an illegal process. The three bodies failed to take into consideration of the interests of the claimant as they are required under 6 (3) (a) of The School Discipline (Pupils Exclusions and Reviews) (England) Regulations, 2012. 37. Additionally, the claimant urges that these decisions fail on the grounds of illegality due to the failure to grant the claimant a fair hearing as under 6 (3) (c) and (d) of The School Discipline (Pupils Exclusions and Reviews) (England) Regulations, 2012 by failing and or refusing to hear the oral presentations of the claimant. 38. The claimant avers that there was no procedural fairness given that, the witness accounts of ‘P” was not corroborated as is expected in any proceeding of this magnitude. The rulings that deprived the claimant the right to education were founded on those uncorroborated assertions and this comes in the backdrop of feud (as indicated in paragraph 4) between that witness and the claimant. That in itself makes it illegal BREACH OF NATURAL JUSTICE 39. The claimant urges that the Board and the Panel breached the fundamental rule of fair hearing by not affording the claimant the right to be heard. The Panel breached this rule when it ordered that only the claimant’s statement would be read and that she would not be heard and instead chose to hear oral presentations from the school’s witnesses, D J Carey and Mrs.Kovac. BIAS 40. The claimant urges the Board and the Panel were biased against and to her detriment. The claimant avers that the Panel by denying her an opportunity to present her oral presentations was an act of biasness in favor of the school. The Board and the Panel ought to have heard the oral representations from both the school and the claimant’s sides. Further, while making the determination, the school head teacher out rightly stated that witness “P” would was trustworthy while the claimant was perpetual liar. LEGAL FRAMEWORK (ii) CASE LAW 41. In Ali v UK no. 40385/06 [2011] ECHR while court agreed that exclusion may be justified, it laid down rules that must be followed for justice to prevail. The court held that In assessing the proportionality of an exclusion, The Court will consider a number of factors: (i) extent of applicable procedural safe guards; (ii) duration of the exclusion; (iii) extent of applicants’ co-operation with any re-integration efforts; (iv) steps taken to minimise the effect of the exclusion; (v) adequacy of any alternative education provided; and (vi) extent to which the rights of third parties are engaged. 42. The court further held in case of LEYLA ŞAHİN v. TURKEY (Application no. 44774/98) that, “ the principle of equality of treatment of all citizens in the exercise of their right to education must be upheld” 43. As Justice Harman expressed himself in Bryne v Kinematograph Renters Society Ltd (1958) 2 ALL ER 579 that the requirements of natural justice are that: first the person accused should know the nature of the accusation made; secondly, he should be given an opportunity to state his case; and lastly, the tribunal should act in good faith. 44. Board of Education v Rice (1911) AC 179 in discharging its duty, “theboard of education will have to ascertain the law and also to ascertain the facts. I need not add that in doing either they must act in good faith and listen fairly to both sides, for that is the duty laying upon everyone who decides anything” 45. A person against whom allegations have been made has the right to an effective opportunity to meet and contradict the allegations brought against him-see James v National Coal Board (1957) 2 QB 55 46. A person before being condemned is entitled to a right to defend himself and to do so he needs to be informed of the charge against him-see Ridge v Baldwin (1964) AC 40. 47. A tribunal hearing a dispute should not base its decision on the hearing of one side. It should grant both parties an opportunity to present their cases or divergent view points and should hold the scales fairly between them.-see Errington v Minister of Health (1935) 1 KB 249 48. A legitimate expectation may arise where the appellant has been given some benefit in the past which is sought to be withdrawn or from policy statements and statutory enactments or individual undertakings-see Council for Civil Service Union v Minister for Civil Service (1984) 3 All ER 935 49. Where the law provides that there exists a certain state of facts or law, then there exists a legitimate expectation that the said state of facts or law exists- seeRepublic v Indian Steamship Co. Ltd (No. 2) (1998) AC 878. 50. With regard to corroboration of witness accounts, it was held in DPP v Kilbourne 91973) 1 ALL ER 440; (1973) AC 720 that “Any risk of conviction of an innocent person is lessened if conviction is based upon the test of more than one acceptable witness”. It was further held that, “Evidence in corroboration must be independent testimony which affects the accused by connecting or tending to connect him with the crime” 51. Above case law is supported in the ruling made in R v Beck [1982] 1 WLR 461 where it wa started that, “judge was obliged to advice the jury…when there is material to suggest that the evidence of such witness was tainted by improper motive”. This case law comes in the backdrop of the relatiohsip that “P’ had with claimant . 52. In support of the provision as set out in rule 10 of the school the deal with standard of proof,THE SCHOOL DISCIPLINE (PUPILS EXCLUSIONS AND REVIEWS) (ENGLAND) REGULATIONS, 2012 , the case of Miller v Minister of Pensions [1947] 2 All ER 372is relevant. It was held that “ The…[standard of proof]…is well settled. It must carry a reasonable degree of probability...if the evidence is such that the tribunal can say: ‘we think it more probable than not’ the burden is discharged, but, if the probabilities are equal, it is not”. Given claimant’s words against witness P, there could be equality. 53. The court through the case of R. (on the application of CR) v Independent Review Panel of Lambeth LBC [2014] EWHC 2461 (Admin); [2014] E.L.R. 359 affirmed that Independent review panels must exercise due diligence while carrying their duties and that means that in course doing their tasks, they must uphold the similar principles held by courts in judicial reviews is. On this basis, it has the full discretion to set aside the evidence set out in the initial stages and could even allow new evidence. In this regard, the independent Review ought to have heed to Claimant prayers for setting aside of evidence of witness P which formed the fulcrum of the ruling against the claimant. TIME LIMITS 54. The claimant urges this court that the application herein has not been filed in compliance with thePart 54 Rule 54 (5) of The Civil Procedure Rules and Practice Directions, 1998as read with Part2 Rule 2 (8) of The Civil Procedure Rules and Practice Directions, 1998.Part 54 Rule 54 (5) requires that a claim be filed within three months of the cause of action, which in this case is 30th January, 2015 and is thus filed out of time. 55. The claimant argues that the delay in filing the claim is not of her making. Firstly, theBoard delayed preparing and sending a copy of its proceedings to the claimant through her mother; and secondly, the claimant’s mother has been preoccupied with having the claimant attend the pupil referral unit and the extra tuition by the tutor. AVAILABILTY OF REMEDIES 56. The claimant was permanently excluded from The Gladbury Grange School by dint of Section 51A of The Education, 2002. 57. The claimant through her mother has exhausted the internal dispute resolution mechanisms provided under The Rules which include The Board and the Independent Review Panel of the District, Education Department. Therefore, an application for review before this court is most expedient. 58. In view of the grounds of review set out herein, the claimant seeks orders of a) Admission of the application herein albeit out of time b) Certiorari quashing the respective decisions of the Head teacher, The Board and the Panel underPart 54 Rule 54 (2) (c) of The Supreme Court Practise Rules & Directions of England. c) Mandamus requiring the 2nd and 3rd defendants to readmit the claimant with immediate effectunder Part 54 Rule 54 (2)(a) of The Supreme Court Practise Rules & Directions of England. d) Declaration that theclaimant’s rights to education under Article 2 of Part II of The First Protocol of The Human Rights Act and right to a fair hearing were violated underArticle 6 of The Part I of The Second Schedule to The Human Rights Act and Part 54 Rule 54 (3)(1) (a) of The Supreme Court Practise Rules & Directions of England. e) Compensation of damages incurred of a sum amounting to £3,500(i.e. 14 weeks ˟£250); amounting the money spent in private tuition under Part 54 Rule 54 (3) (2) of The Supreme Court Practise Rules & Directions of England. f) Any other remedy that this court may deem fit including the cost of this suit. Drawn and Filed by: Sloe, Deer & Goode LLP Advocates, 40 Cathedral Close, Gladbury, RD56S Read More