Posts Tagged ‘vicarious liability

25
Apr
17

Crown Office drops third prosecution in two weeks

Two weeks ago, we blogged about how the Crown Office & Procurator Fiscal Service (COPFS – the public prosecutors in Scotland) had dropped a long-running vicarious liability prosecution against landowner Andrew Duncan, who was alleged to have been vicariously liable for the crimes of his gamekeeper, who had killed a buzzard on the Newlands Estate in 2014. When pressed for a reason behind the decision to drop the vicarious liability case, the Crown Office said it was “not in the public interest to continue” but did not provide any further detail of how, or why, that decision had been reached (see here).

Ten days later, we learned that the COPFS had dropped another long-running prosecution, this time against gamekeeper Stanley Gordon who was alleged to have shot a hen harrier on the Cabrach Estate in 2012. No explanation was given for this decision.

And now today, we have learned that the COPFS have dropped another long-running prosecution, this time against Angus Glens gamekeeper Craig Graham who was alleged to have set and re-set an illegal pole trap on the Brewlands Estate in 2015. Again, no explanation has been given for this decision.

That’s three high profile prosecutions for alleged raptor persecution crimes, dropped within a two week period, with no explanation why.

One long-running case being dropped would raise an eyebrow; a second long-running case dropped a few days later would cause concern, but three long-running cases, all dropped within a fortnight, all on the eve of an actual trial? That is highly suspicious, even for the most unassuming observer.

Was it incompetence on the part of the COPFS? That is surely a possibility, especially as each of these cases has been running for months, at huge cost to the public purse. Why did it take so long to decide to abandon each case? Was it an issue with video evidence? We’ve been there before, although we’ve also seen successful prosecutions based on video evidence. If it was an issue with video admissibility (and we don’t yet know if it was, so this is just speculation), why did it take so long to reach that decision and anyway, wouldn’t admissibility be an issue for the court to decide, not the prosecutor? Was there another reason for discontinuing these cases? We don’t know, because the Crown Office is saying nothing.

Whatever it was, the discontinuing of these three cases will cause huge damage to public confidence in the Scottish criminal justice system. What do you have to do to get someone to stand trial for alleged raptor persecution in Scotland? We know how difficult it is to identify a named suspect, and we know that the evidential threshold is set extraordinarily high for this sort of crime, so when you do manage to secure enough evidence to charge and then prosecute somebody, it is massively frustrating to (a) see the cases dropped and (b) not be told why.

What is clear amongst all this murkiness is that the current system is not fit for purpose. This series of discontinued prosecutions just adds more grist to the mill for the introduction of a licensing system, and for basing that system on the civil burden of proof.

Meanwhile, we’re looking forward to the release of the video footage……

24
Apr
17

Evidence session: petition to introduce gamebird hunting licensing

Last week the Scottish Parliament’s Environment, Climate Change & Land Reform (ECCLR) Committee held an evidence session as part of their consideration of the Scottish Raptor Study Group’s petition calling for the introduction of state-regulated licensing for all game bird hunting in Scotland.

The archived video of the session can be viewed here

The official transcript can be read here: ECCLR transcript gamebird shooting licensing 18 April 2017

The evidence session was split in to two parts. The first part comprised evidence from the petitioners (Logan Steele & Andrea Hudspeth from the SRSG) and the second part comprised a panel of ‘stakeholders’ including Logan Steele, Duncan Orr-Ewing (RSPB Scotland), Robbie Kernahan (SNH), Andy Smith (Scottish Gamekeepers’ Assoc) and Lord David Johnstone (Scottish Land & Estates). (Photos from ECCLR webpage).

We’re not going to go through the transcript line by line because that would be tedious, but instead we wanted to comment on a few observations.

Unlike the evidence session held at Westminster last autumn, this was a civilised, unbiased hearing. That may be because, unlike the Westminster Environment Committee, none of the ECCLR Committee have a direct conflict of interest in the subject nor receive payment from any of the organisations represented by the witnesses. The Convenor of the ECCLR Committee (Graeme Dey MSP) was far more professional than his inexplicably rude Westminster counterpart, and although Mr Dey is known to support the propagandist Gift of Grouse campaign, his management of this evidence session was reasonably balanced and fair.

In the first part of the session, Logan and Andrea gave measured, thoughtful evidence about the continuing issue of illegal raptor persecution, supported by decades of scientific monitoring and peer-reviewed science. These two witnesses deserve much kudos. They are ‘ordinary’ members of the public, so exasperated by the failure of successive Governments to sort out this problem that they’ve been moved to exercise their right through the democratic process of petitioning the country’s decision-makers. As a result, they’ve been vilified on social media, exposed to a barrage of personal abuse from certain individuals within the game shooting sector, and yet here they were again, calmly and adeptly stating their case. We all owe them a massive vote of thanks.

The performance of the other witnesses was mixed. Andy Smith (SGA) is doubtless well intentioned but his ability to engage in the actual discussion is limited. He clearly had a list of points he wanted to get across, but blurting them out whenever he had an opportunity to speak, instead of listening to the question that was posed and reacting to that, didn’t help his cause.

Robbie Kernahan (SNH) didn’t say too much, and most of what he said was fairly standard SNH-speak (i.e. fence sitting), although he did make an important opening statement that should add some gravitas to the Committee’s future deliberations:

Generally, in Scotland, we have quite a positive message about the recovery of raptor populations from those all-time lows. It is certainly a national picture. However, that is not to say that there are not issues. Certainly, some of the concerns about the intensification of moorland management prompted our scientific advisory committee to have a review two years ago. Without wanting to go through that chapter and verse, I can say that there is no doubt that the on-going issue of raptor persecution is inhibiting the recovery of populations in some parts of the country“.

The evidence provided by Duncan Orr-Ewing (RSPB) and David Johnstone (SLE) was perhaps the most interesting. Duncan spoke with authority about the extent of illegal raptor persecution, saying the RSPB “thinks the situation is as bad as it has ever been“, while David flatly denied this, pointing to the annual ‘body count’ as his supporting evidence but completely ignoring the long-term population data, as published in peer-reviewed scientific papers. When asked by the Convener whether there was a possibility that culprits might now be better at hiding the evidence, in part pressured by measures such as the threat of vicarious liability, David’s response was “No“. No? Really? No possibility of that happening at all? Come on.

What made David’s response even more incredible (in the literal sense) was that SLE, as members of the PAW Scotland Raptor Group, have been made aware of the recent flow of scientific papers (e.g. on red kite, golden eagle, hen harrier, peregrine), all clearly showing population-level impacts of illegal raptor persecution, and as PAW partners, are supposed to have been advising their members accordingly. So how come the Chairman of SLE hasn’t been informed?

And on the subject of ‘possibilities’, much was made of the possibility of estates being ‘set up’ (i.e. someone planting evidence) if a licensing system was introduced. Both Logan and Duncan accepted that this was a possibility and they were right to do so. Of course it is a possibility, although on previous experience, the probability of it happening seems quite low.

In January 2012, just after the introduction of vicarious liability, David Johnstone was cited as saying there was a risk of estates being set up in response to the new vicarious liability measure. Five years on, there hasn’t, as far as we are aware, been a single case of an estate being ‘set up’.

Similarly, in November 2013, the then Environment Minister Paul Wheelhouse was asked during a Parliamentary Committee whether estates being ‘set up’ was a legitimate concern for landowners and gamekeepers. Wheelhouse responded that yes, it was a possibility, but that there wasn’t currently any evidence to support such claims, although a new study on trap interference was due to assess the issue. The results of that study showed that the illegal tampering of traps was not as widespread as the gameshooting industry had claimed (see here) and when it had happened, the interference mostly related to trap ‘damage’ (rendering the trap inoperable) as opposed to setting an illegal trap to infer a guilty responsibility on the estate.

There was quite a lot of discussion about what a licensing system might look like, and it was argued by Logan and Duncan that it should be based on the civil burden of proof (much like the policy used for General Licence restrictions) and that this should be a tiered approach, so that a number of incidents would be required before a licensing penalty was applied. David Johnstone was totally opposed to this, saying that the use of the civil burden of proof would be too much of a business risk. There was quite an amusing discussion about this between him and Committee member Mark Ruskell MSP, who argued that if the business was already fully compliant with the law, as David claimed, then the risk should be very low.

All in all, it was a useful evidence session and the ECCLR Committee will be hard pressed to justify not taking things further. The Committee now has to consider the evidence presented and decide on its next move. We may well have to wait until after 8 June to find out what that move might be, because thanks to the forthcoming General Election, no political or sensitive announcements or decisions are permitted during election purdah.

17
Apr
17

Vicarious liability prosecution abandoned as ‘not in public interest to continue’

Last week we blogged about the Crown Office dropping all proceedings against landowner Andrew Walter Bryce Duncan, who was alleged to be vicariously liable for the criminal actions of his gamekeeper, William (Billy) Dick in April 2014.

Gamekeeper Dick was convicted in August 2015 of killing a buzzard on the Newlands Estate, Dumfriesshire by striking it with rocks and repeatedly stamping on it (see here). Mr Dick was sentenced in September 2015 and was given a £2000 fine (see here). Mr Dick appealed his conviction but this appeal was rejected on 15 July 2016 (see here).

The Crown Office & Procurator Fiscal Service (COPFS) began vicarious liability proceedings against Mr Duncan in August 2015 but the case was repeatedly adjourned (a total of 13 court hearings) with two trial dates assigned but then later dropped (see here). These repeated delays were due in part to gamekeeper Dick’s appeal against his conviction but in part for other reasons which have not been explained.

As the third trial date (24 April 2017) approached, we were somewhat surprised to learn last week that the case had been abandoned. We asked COPFS why this had happened and this is their response:

All cases are continually kept under review, and after taking consideration of the full circumstances of this case, and all of the available evidence, Crown Counsel concluded that it was not in the public interest to continue the case to trial.

COPFS remain committed to tackling raptor persecution and there is a strong presumption in favour of prosecution of the cases reported to us where there is sufficient evidence and it is in the public interest to do so“.

There is no detail about why proceeding to trial ‘was not in the public interest’ and indeed, the COPFS does not have to disclose this information. We do know that the COPFS Prosecution Code outlines a large number of factors that are to be considered for a public interest test, including:

  • The nature and gravity of the offence
  • The impact of the offence on the victim and other witnesses
  • The age, background and personal circumstances of the accused
  • The age and personal circumstances of the victim and other witnesses
  • The attitude of the victim
  • The motive for the crime
  • The age of the offence
  • Mitigating circumstances
  • The effect of prosecution on the accused
  • The risk of further offending
  • The availability of a more appropriate civil remedy
  • The Powers of the court
  • Public concern

Without knowing the specific details of the evidence in this case it is pointless to speculate about why the case was abandoned (and for anyone commenting on this post, please be careful not to libel Mr Duncan). We just have to accept that it was abandoned, as frustrating as that is, but we do hope that the COPFS will share some detail with the reporting agencies so that lessons can be learned for future cases.

Journalist Rob Edwards has written an interesting piece about the case, published today on The Ferret website (here), which includes some news about the Newland Estate’s membership of Scottish Land & Estates and its accredited membership of the SLE-administered Wildlife Estates Scotland initiative.

In a wider context, this abandoned case is highly significant. Contrary to the COPFS’ decision, there is huge and legitimate public concern and interest about wildlife crime enforcement, particularly in respect to raptor persecution crimes. The Scottish Government is keenly aware of this and has come under increasing pressure in recent years to introduce new measures to tackle the problem. Vicarious liability was one of those new measures (introduced on 1 January 2012) but to date, only two cases have resulted in a conviction: one in December 2014 (see here) and one in December 2015 (see here). Both related to raptor persecution on low ground shoots, not on intensively managed driven grouse moors where raptor persecution is known to still be a common occurrence. One further case in October 2015 did not reach the prosecution stage due, we believe, to the difficulties associated with identifying the management structure on the estate where the crimes were committed (see here).

Given the low success rate of vicarious liability, alongside the continued illegal persecution of raptors on game-shooting estates, it is clear that the Scottish Government needs to do more.

Tomorrow, the Scottish Parliament’s Environment Committee will hear evidence from the Scottish Raptor Study Group (Logan Steele & Andrea Hudspeth) in support of their petition to introduce a state-regulated licensing scheme for all game bird shooting in Scotland. Part of this licensing scheme would include provisions for sanctions against estates where raptor persecution takes place. Evidence will also be heard from various stakeholders including RSPB Scotland (Duncan Orr-Ewing), Scottish Gamekeepers’ Association (Andy Smith), SNH (Robbie Kernahan) and Scottish Land & Estates (David Johnstone). The evidence session begins at 10am and can be watched live on Scottish Parliament TV (here) and we’ll post the transcript when it becomes available later in the week.

11
Apr
17

Vicarious liability prosecution: case dropped (Andrew Duncan, Newlands Estate)

Regular blog readers will know that we’ve been tracking the vicarious liability prosecution of landowner Andrew Walter Bryce Duncan, who was alleged to be vicariously liable for the crimes committed by gamekeeper William (Billy) Dick in April 2014.

Gamekeeper Dick was convicted in August 2015 of killing a buzzard on the Newlands Estate, Dumfriesshire by striking it with rocks and repeatedly stamping on it (see here). Mr Dick was sentenced in September 2015 and was given a £2000 fine (see here). Mr Dick appealed his conviction but this appeal was rejected on 15 July 2016 (see here).

Vicarious liability proceedings against Mr Duncan began in August 2015 and the case has been repeatedly adjourned since then (a total of 13 court hearings) with two trial dates assigned but then later dropped (see here). These repeated delays were due in part to Mr Dick’s appeal against his conviction but in part for other reasons which have not been explained.

The third trial date (24 April 2017) looked set to go ahead but today we’ve learned that the Crown Office & Procurator Fiscal Service has dropped all proceedings. We do not yet know why the prosecution has been dropped.

Whatever the reason for dropping the prosecution, this result does not reflect well on the efficiency of wildlife crime enforcement measures in Scotland.

Vicarious liability in relation to the persecution of raptors in Scotland (where one person may potentially be legally responsible for the criminal actions of another person working under their supervision) came in to effect over five years ago on 1st January 2012 as a provision in the Wildlife and Natural Environment (Scotland) Act 2011. It was introduced as an amendment to the draft WANE Bill in November 2010 by the then Scottish Environment Minister, Roseanna Cunningham. It was a direct response to the unrelenting problem of illegal raptor persecution and the apparent inability/unwillingness of the game shooting lobby to get their own house (grouse moors) in order.

To date there have only been two successful prosecutions/convictions: one in December 2014 (see here) and one in December 2015 (see here). Both related to raptor persecution on low ground shoots, not on intensively managed driven grouse moors. One further case in October 2015 did not reach the prosecution stage due, we believe, to the difficulties associated with identifying the management structure on the estate where the crimes were committed (see here). And now this latest case has failed, for reasons as yet unknown.

Two successful prosecutions in five years is not very impressive, and won’t be much of a deterrent for those who continue to kill raptors safe in the knowledge that the probability of being caught, prosecuted and convicted is still virtually nil.

25
Jan
17

Vicarious liability prosecution: Andrew Duncan (Newlands Estate), part 13

Criminal proceedings continued yesterday (24 January 2017) against landowner Andrew Walter Bryce Duncan, who is alleged to be vicariously liable for the crimes committed by gamekeeper William (Billy) Dick in April 2014.

Gamekeeper Dick was convicted in August 2015 of killing a buzzard on the Newlands Estate, Dumfriesshire by striking it with rocks and repeatedly stamping on it (see here). Mr Dick was sentenced in September 2015 and was given a £2000 fine (see here). Mr Dick attempted to appeal his conviction but this appeal was rejected on 15 July 2016 (see here).

Here’s a quick review of the proceedings against Andrew Duncan so far:

Hearing #1 (18th August 2015): Trial date set for 23rd Nov 2015, with an intermediate diet scheduled for 20th Oct 2015.

Hearing #2 (20th October 2015): Case adjourned. November trial date dumped. Notional diet hearing (where a trial date may be set) scheduled for 18th January 2016.

Hearing #3 (18th January 2016): Case adjourned. Another notional diet & debate scheduled for 11th March 2016.

Hearing #4 (11th March 2016): Case adjourned, pending the result of gamekeeper Billy Dick’s appeal. Another notional diet scheduled for 4th April 2016.

Hearing #5 (4th April 2016): Case adjourned, pending the result of gamekeeper Billy Dick’s appeal. Another notional diet scheduled for 3rd June 2016.

Hearing #6 (3rd June 2016): Case adjourned, pending the result of gamekeeper Billy Dick’s appeal. Another notional diet scheduled for 17th June 2016.

Hearing #7 (17th June 2016): Case adjourned, pending the result of gamekeeper Billy Dick’s appeal. Another notional diet scheduled for 15th July 2016.

Hearing #8 (15 July 2016): Case adjourned. Another notional diet scheduled for 2 August 2016.

Hearing #9 (2 August 2016): Proceedings moved to trial. Intermediate diet scheduled for 15 November 2016 and provisional trial date set for 7/8 December 2016.

Hearing #10 (15 November 2016): The case was adjourned for another intermediate diet scheduled for 22 November 2016. Trial date of 7/8 December 2016 is dumped.

Hearing #11 (22 November 2016): The case was adjourned for yet another intermediate diet, scheduled for 6 December 2016.

Hearing #12 (6 December 2016): The case was adjourned for yet another intermediate diet, scheduled for 24 January 2017. A provisional trial date (this will be the third time a trial date has been assigned) is scheduled for 24 April 2017.

Hearing #13 (24 January 2017): Guess what? The case was adjourned for another intermediate diet, scheduled for 11 April 2017. As far as we know, the provisional trial date of 24 April still stands although this could change depending on what happens at the intermediate diet on 11 April.

Vicarious liability in relation to the persecution of raptors in Scotland (where one person may potentially be legally responsible for the criminal actions of another person working under their supervision) came in to force five years ago on 1st January 2012. To date there have been two successful prosecutions/convictions: one in December 2014 (see here) and one in December 2015 (see here).  One further case did not reach the prosecution stage due, we believe, to the difficulties associated with identifying the management structure on the estate where the crimes were committed (see here).

UPDATE 11 April 2017: The Crown Office has dropped all proceedings (see here).

16
Jan
17

ECCLR review of wildlife crime report: session 1

Last week the Scottish Parliament’s Environment, Climate Change & Land Reform (ECCLR) Committee held an evidence session in which to review the Scottish Government’s 2015 Annual Wildlife Crime Report.

The archived video can be watched here

The official transcript can be read here: ecclr-transcript-wildlife-crime-10-jan-2017

The evidence session took place in two parts: the first session involved witnesses from Police Scotland and the Crown Office, and the second session heard evidence from RSPB Scotland, Scottish Badgers, Scottish Gamekeepers’ Association and the Bat Conservation Trust.

This blog focuses on session 1 (we’ll blog about session 2 in another blog).

ecclr1

The witnesses in session 1 were Gary Aitken (Crown Office), ACC Steve Johnson and DCS Sean Scott (Police Scotland). DCS Scott has appeared in front of this committee in previous years (when it was the RACCE committee) but this was a first time appearance for ACC Johnson and Gary Aitken.

Session 1 lasted for about two hours and it’s fair to say these witnesses were given quite a grilling. The ECCLR Committee was extremely well informed and in some cases there was some pretty persistent (but respectful) questioning, notably by Mark Ruskell MSP and Claudia Beamish MSP.

We’ve already blogged about part of this session (see here) in relation to Police Scotland’s inability to answer Mark Ruskell’s question about why some confirmed raptor crimes had been withheld from the Government’s 2015 report. We await Police Scotland’s written explanation to the Committee in due course. A similar problem was raised in this session re: the huge discrepancy between the number of crimes against badgers recorded by Scottish Badgers ( n = 42) and those recorded by Police Scotland (n = 5). Again, Police Scotland has been asked to provide a written explanation to the Committee, which will be important because this appears to be a recurring issue. It was good to hear  though, that Police Scotland has recently set up some new reporting mechanisms with Scottish Badgers, as well as training days for officers. Hopefully this will improve communication and understanding between them.

There was good discussion about increased powers for the SSPCA (Police Scotland appears to have softened its stance on this a bit, although we’re all STILL waiting for the Environment Cabinet Secretary to announce the Government’s position on these increased powers), agreement that increased penalties for wildlife crime would be very welcome, and also agreement on the importance of being able to identify accountable individuals for potential vicarious liability prosecutions. All good.

On the whole, Police Scotland and the Crown Office were far more circumspect at this hearing than in previous appearances. We were very pleased to hear ACC Johnson acknowledge that the full extent of wildlife crime in Scotland is an ‘unknown’, in complete contrast to his predecessor’s (ACC Malcolm Graham) ludicrous claims that Police Scotland ‘wasn’t missing much of it’ (see here).

We were also very pleased to hear ACC Johnson’s acknowledgement that the scientific / academic evidence [of the effect of persecution on the distribution and abundance of raptor populations] was a “strong part” of the evidence of wildlife crime.  However, none of this scientific evidence had appeared in the Government’s 2015 annual report and Mark Ruskell MSP asked what progress had been made in assessing this evidence; something ACC Graham had committed to doing last year. The responses from ACC Johnson and DCS Scott were utterly astounding. They both said they’d be happy to look at the scientific evidence ‘if it was brought to their attention’.

What? Are they for real? Are they seriously suggesting they’re unaware of the massive body of scientific evidence? They’re having a laugh, aren’t they?

How many peer-reviewed scientific reports and papers have been published on this issue in the last 20 years? Bloody loads of them! Here’s a list of some of them and hereherehere are some more that have been published in the last year alone and here, here are some preliminary scientific results, all widely reported in the media, that are due to be written up as scientific papers in the immediate future.

Sorry, ACC Johnson and DCS Scott, your claimed ignorance of the scientific evidence just doesn’t wash. Especially DCS Scott, who chairs the PAW Raptor Group, where some of these scientific results have been frequently discussed.

So why claim ignorance? Was it to cover up Police Scotland’s inaction on this issue? If so, that’s not nearly good enough. For two years in a row now Police Scotland has committed to assessing the scientific evidence and incorporating it in to its ‘intelligence-led’ investigations. We, and no doubt the ECCLR Committee, will expect to see progress on this when the Government’s 2016 annual report is published later this year.

14
Jan
17

Public funds to promote wildlife criminals in Scotland?

In December 2016 we blogged about the ‘Game for Growth’ strategy, which is a plan to promote Scottish country sports and boost its value to the economy. The strategy, which was launched at a parliamentary reception on 20th December 2016 (here) is being led by the Scottish Country Sports Tourism Group (SCSTG) and is being part-funded by VisitScotland using tax payers’ money (see here).

You may recall that Scottish Greens MSP Andy Wightman lodged a parliamentary question about the use of these public funds, as follows:

Question S5W-05930: Andy Wightman (Lothian, Scottish Green Party). Date lodged: 22/12/2016

To ask the Scottish Government whether it will provide a breakdown of the recipients of financial contributions from VisitScotland to the strategy, Game for Growth Strategy – Country Sports Tourism in Scotland 2016; what information it has regarding how each recipient will use this; what action it has taken to ensure that no money was provided to the owners or managers of landholdings on which crimes against wildlife have been committed; whether it will publish the strategy on its website, and what aspects of this it is supporting or plans to support with public money.

This question has now been answered:

Answered by Fiona Hyslop MSP (Cabinet Secretary for Culture, Tourism & External Affairs) on 11/1/2017:

VisitScotland has approved a grant of £17,925 to the Scottish Country Sports Tourism Group to promote Scotland as the destination of choice for all country sports. The Group will use this to develop content and supporting digital activity to attract visitors from across the UK and Scandinavia. As this money is for a specific project, no funding will be provided to individual estates or land owners. There is no intention to publish the strategy on VisitScotland’s website and so there will be no funding support for this.

It’s an interesting response. It does clarify that public funds (at least these public funds) will not be given directly to individual estates or landowners, but it is also clear that individual estates will still benefit from this public funding, albeit indirectly, because the SCSTG will use the funds to promote these individual estates as part of an online PR campaign.

In our December blog, we noted that the SCSTG website was promoting the Dunmhor Sporting Agency as a provider of country sports activities in Scotland:

We were surprised to see Dunmhor Sporting being promoted on the SCSTG website because Graham Christie of Dunmhor Sporting was convicted in December 2015 of being vicariously liable for the criminal actions of his gamekeeper, who had used an illegal gin trap to catch and injure a buzzard on the Cardross Estate. We just looked at the SCSTG’s website again and Dunmhor Sporting is still being promoted as a country sports provider.

So much for the game shooting industry ousting its criminal members.

We wonder whether the Cabinet Secretary for Culture, Tourism & External Affairs, Fiona Hyslop, is aware that a now (part) publicly funded organisation (the Scottish Country Sports Tourism Group) is promoting a convicted wildlife criminal and if so, whether she thinks this is an appropriate use of public funds?

Emails to: scottish.ministers@gov.scot and mark it FAO Fiona Hyslop




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