PARLIAMENTARY DEBATE
Patrick Finucane Murder - 11 September 2024 (Commons/Commons Chamber)

With permission, Mr Speaker, I would like to make a statement about the death of Patrick Finucane.

Patrick Finucane was a human rights lawyer. On 12 February 1989, he was brutally murdered in his home in north Belfast by loyalist paramilitary group the Ulster Defence Association, in front of his wife, Geraldine, who was wounded, and his three children, one of whom is now the hon. Member for Belfast North (John Finucane). From that day onwards, Mrs Finucane and her family have campaigned tirelessly in search of answers about the killing of their loved one.

In 1990 an inquest was opened and closed on the same day with an open verdict. Subsequently, a number of investigations and reviews were conducted. In 2001, following the collapse of power sharing, the UK and Irish Governments agreed at Weston Park to establish public inquiries into a number of troubles-related cases, if recommended by an international judge. Judge Peter Cory was appointed to conduct a review of each case, and in 2004 he recommended that the UK Government hold public inquiries into four deaths: those of Rosemary Nelson, Robert Hamill, Billy Wright and Patrick Finucane. Judge Cory also recommended that the Irish Government establish a tribunal of inquiry into the deaths of former Royal Ulster Constabulary officers Bob Buchanan and Harry Breen. Inquiries were promptly established in all those cases, with one exception: the death of Mr Finucane.

Meanwhile, in 2003, the third investigation by Sir John Stevens into alleged collusion between the security forces and loyalist paramilitaries had concluded that there had been state collusion in Mr Finucane’s killing. That investigation was followed by the conviction in 2004 of one of those responsible, Ken Barrett. With criminal proceedings concluded, the then Northern Ireland Secretary, Paul Murphy, made a statement to Parliament setting out the Government’s commitment to establishing an inquiry, but despite a number of attempts, the Government were unable to reach agreement with the Finucane family on arrangements for one.

In 2011, the coalition Government decided against an inquiry. Instead, a review of what had happened, led by Sir Desmond de Silva QC, was established. Sir Desmond concluded that he was left

“in no doubt that agents of the state were involved in carrying out serious violations of human rights up to and including murder.”

The publication of his findings in 2012 led the then Prime Minister, David Cameron, to make from this Dispatch Box an unprecedented apology to the Finucane family on behalf of the British Government, citing the

“shocking levels of state collusion”—[Official Report, 12 December 2012; Vol. 555, c. 296.]

in this case.

In 2019, the Supreme Court found that all the previous investigations had been insufficient to enable the state to discharge its obligations under article 2 of the European convention on human rights. The Court identified a number of deficiencies in the state’s compliance with article 2. In particular, Sir Desmond’s review did not have the power to compel the attendance of witnesses; those who met Sir Desmond were not subject to testing as to the accuracy of their evidence; and a potentially critical witness was excused from attendance. In November 2020, the then Secretary of State for Northern Ireland announced that he would not establish a public inquiry at that time, pending the outcome of continuing investigations, but that decision was quashed by the Northern Ireland High Court in December 2022.

This Government take our human rights obligations, and our responsibilities towards victims and survivors of the troubles, extremely seriously. The plain fact is that, two decades on, the commitment made by the Government to establish an inquiry into the death of Mr Finucane—first in the agreement with the Irish Government, and then to this House—remains unfulfilled. It is for that exceptional reason that I have decided to establish an independent inquiry into the death of Patrick Finucane, under the Inquiries Act 2005.

I have, of course, met Mrs Finucane and her family—first on 25 July to hear their views, and again yesterday to inform them of my decision. Mrs Finucane asked the Government to set up a public inquiry under the 2005 Act, and, as I have just told the House, the Government have now agreed to do that, in line with the 2019 Supreme Court ruling and the Court of Appeal judgment of July this year.

In making this decision, I have, as is required, considered the likely costs and impact on the public finances. It is the Government’s expectation that the inquiry will, while doing everything that is required to discharge the state’s human rights obligations, avoid unnecessary costs, given all the previous reviews and investigations and the large amount of information and material that is already in the public domain. Indeed, in the most recent High Court proceedings, the judge suggested that an inquiry could

“build on the significant investigative foundations which are already in place”.

As part of my decision-making process, I also considered whether to refer the case to the Independent Commission for Reconciliation and Information Recovery. The commission has powers comparable to those provided by the 2005 Act to compel witnesses and to secure the disclosure of relevant documents by state bodies—powers identified by the Supreme Court as being crucial for the Government to discharge their human rights obligations.

The commission was found, in separate proceedings in February this year, by the High Court to be sufficiently independent and capable of conducting article 2-compliant investigations, and while I am committed to considering measures to further strengthen the commission, I have every confidence in its ability, under the leadership of Sir Declan Morgan, to find answers for survivors and families. However, given the unique circumstances of the case, and the solemn commitment made by the Government in 2001 and again in 2004, the only appropriate way forward is to establish a public inquiry.

Many of us in this House remember the savage brutality of the troubles—a truly terrible time in our history—and we must never forget that most of the deaths and injuries were the responsibility of paramilitaries, including the Ulster Defence Association, the Provisional IRA and others. We should also always pay tribute to the work during that time of the armed forces, police and security services, the vast majority of whom served with distinction and honour, and so many of whom sacrificed their lives in protecting others.

It is very hard for any of us to understand fully the trauma of those who lost loved ones—sons and daughters, spouses and partners, fathers and mothers—and what they have been through. There is of course nothing that any of us can do to bring them back or erase the deep pain that was caused, but what we can do is seek transparency to help provide answers to families and work together for a better future for Northern Ireland, which has made so much progress since these terrible events. I hope that the inquiry will finally provide the information that the Finucane family has sought for so long.

The Government will seek to appoint a chair of the inquiry and establish its terms of reference as soon as possible, and I will update the House further. I commend this statement to the House.

I call the shadow Secretary of State.

I thank the Secretary of State for his statement, and for advance sight of it and his courtesy call this morning. I am particularly grateful to him for bringing it forward before recess. I know the deadline that the Court gave him was 27 September, so it was important that we had the chance to hear the Government’s position and ask questions before we rose for conference recess.

The murder of Patrick Finucane, like so many murders during the troubles, was a dreadful act of violence that must not be forgotten. The Opposition stand by the findings of the 2012 de Silva report that while there was no evidence of an overarching state conspiracy in the case of his murder, there were shocking levels of collusion—something for which the then Prime Minister, now Lord Cameron, rightly apologised to the House in that year. I fully appreciate the Secretary of State’s desire to bring the matter to a close after a very long period, and I know that a full public inquiry will do it, but I wish to ask serious questions about the decision to choose a full public inquiry over one of the alternatives that he mentioned.

It is clear that the Finucane family, who have suffered so much, are owed a further and deeper investigation. That much was made clear by the Supreme Court’s finding in February 2019, when it noted that the de Silva report had not been able to compel witnesses or take its evidence in public. In other words, it had not been article 2 compliant. However, as the Secretary of State said, this year the Belfast High Court concluded that the ICRIR was capable of conducting an article 2-compliant investigation and was sufficiently independent to do so.

My first question to the Secretary of State is: given that the ICRIR has powers to compel witnesses and take evidence in public, what is it that a full public inquiry will be able to do that the ICRIR cannot? This is important because the ICRIR is already fully staffed and active and could begin work quickly, whereas the establishment of a full public inquiry and the building of that team will inevitably take time. Given the opportunity for further delay, I ask him to set out for the House what steps he is taking to ensure that the public inquiry is conducted as quickly as possible. Can he give an undertaking to have appointed a chair and agreed terms of reference before the end of the year, say? In his statement, he referred to the High Court proceedings, where the judge suggested that an inquiry could

“build on the significant investigative foundations which are already in place”.

I hope that will mean that we can have terms of reference relatively fast.

Similarly, in the Secretary of State’s conversations with his right hon. Friend the Chancellor, has the Secretary of State set an expectation of time and costs? We know from previous public inquiries that unless these things are considered early on, the inquiries can take a long time and cost a great deal.

On the issue of the ICRIR itself, I am pleased to hear that the commission has the Secretary of State’s confidence. We agree that it is showing itself to be an excellent and effective body with a highly capable chair. I note that it was also the creation of the previous Government. It was created, as he knows, by the Northern Ireland Troubles (Legacy and Reconciliation) Act 2023, which his Government have committed to repeal. Indeed, the House will appreciate that a large part of that legislation is given over to the creation of the ICRIR. I ask him to reassure us that he has no intention of repealing that part of the Act.

Returning to the public inquiry that has just been announced, there is one other issue on which we should seek clarity today. In his statement, the Secretary of State referred to the “unique circumstances” of the case. It is important that we understand exactly what those unique circumstances are, because it is important that the Government do not unwittingly set a precedent for many more public inquiries. As a veteran of the Cabinet Office, I became acutely aware of a danger that public inquiries could cease to be the exception and become the rule. Given that there are thought to be thousands of murders from the troubles still unsolved, there is a risk of setting a precedent that would make inquiries the rule. There will be those who ask that if there is to be a full public inquiry in one murder case, why not in another, or in many others? To avoid that happening if this case is, as the Secretary of State says, genuinely unique, the Government have a responsibility to set out why that is. We must not risk turning the system of public inquiries into a more routine process. I am sure that he will feel the same way, and I ask him to make that commitment. I thank him for his statement.

I am grateful to the Opposition spokesperson for his opening remarks, and I will respond directly to his very legitimate questions.

What is unique about this case—I apologise for the length of the opening statement but I thought it was really important to take the House through the history—is the commitment given on two previous occasions by the Government of our country that there would be a public inquiry. To come to his last question, it sets no precedent, but there were exceptional circumstances relating to this case that led me to take this decision.

I will of course, especially as the Finucane family have been waiting 35 years, seek to establish the inquiry as quickly as possible. We have to appoint a judge. The judge then has to be consulted by myself about the terms of reference. The time it takes will depend on how the inquiry unfolds. I am acutely conscious of cost—the hon. Gentleman’s point was extremely fair—which is why it seems to me that, given all the material and information that is already out there, what the inquiry can most usefully do is not seek to go over all of that, but interrogate the information, material and witnesses as necessary. As the Supreme Court made clear, that is what has been missing that led it to conclude that this was not article 2 compliant.

We have a commitment to repeal and replace the legacy Act, and we will begin that process shortly, finally laying to rest the conditional immunity. The hon. Gentleman will have heard what the Government have said about civil cases and inquests. On the independent commission, while I shadowed this role in Opposition and since taking up the office of Secretary of State, I have been very clear that while we want to return to the principles of the Stormont House agreement, there needs to be information recovery and there needs to be continuing investigation. It is true that the agreement envisaged two separate bodies, but those functions are combined in the ICRIR. As I have been very frank in saying, now that body has been established and all its staff appointed, I really do not see the point in abolishing it only to recreate something that looks very much like what we have today. It is a pragmatic decision that I have taken. I also made clear in my statement that I am committed to considering further steps to strengthen the ICRIR’s independence and its powers as necessary. I hope that provides the hon. Gentleman with the reassurance he was looking for.

On 17 January 1989, Conservative Minister Douglas Hogg claimed in Parliament that solicitors in Northern Ireland were

“unduly sympathetic to the cause of the IRA.”—[Official Report, Standing Committee B, 17 January 1989; c. 508.]

Seamus Mallon MP responded that he had

“no doubt that there are lawyers walking the streets or driving on the roads of the North of Ireland who have become targets for assassins’ bullets as a result of the statement that has been made tonight.”—[Official Report, Standing Committee B, 17 January 1989; c. 519.]

Three weeks later, lawyer Pat Finucane was shot 14 times and murdered in his own house in front of his wife and three children.

I commend Geraldine Finucane and the Finucane family, including of course the hon. Member for Belfast North (John Finucane), on their tireless campaigning to get to this point, and I thank the Secretary of State for finally doing the right thing on behalf of the British Government in announcing this inquiry. When does he envisage the inquiry beginning?

I thank the hon. Gentleman for his appreciative words. He alludes to a very, very unhappy history in this and many other cases. I do take the point made by the hon. Member for Brentwood and Ongar (Alex Burghart) about all the pain and suffering that all families have experienced, but in this particular case, I have decided that this inquiry is the right thing to do.

I am grateful to the hon. Gentleman for welcoming the inquiry, and I am very happy to give him and all Members of the House an assurance that as we develop our proposals, I am in the process of talking to lots of people about how to give effect to the “repeal and replace” commitment that was in the Gracious Speech. I will, of course, come back to the House with proposals in due course and keep it informed. The honest answer to the question he and other Members have put is that I want to get on with this inquiry as soon as possible, but I have certain duties that I have to undertake in order to give effect to it. However, after this long period of time, let us get going with this inquiry as soon as we possibly can.

The brutal murder of Pat Finucane in front of his wife and children was mired in collusion before the killing, as it has been in the many long years since. Today is about the tenacity of the Finucane family, including my constituency neighbour the hon. Member for Belfast North (John Finucane), but it will have resonance for many other victims of the troubles whose needs have, for many years, been put behind the needs of the victim-makers who want the truth to remain covered up. I am so glad that the truth may now finally out for this family.

As the Secretary of State knows, many other families have faced obstruction from state and non-state actors in their quest for truth and a reconciled future. I am thinking of families such as those of the victims of Freddie Scappaticci, the family of Sean Brown, and many others. Will the Secretary of State commit to the same swiftness and determination in removing the barriers that have been placed in front of those families in their quest for truth?

The hon. Member has alluded to a number of cases. Of course, we are awaiting the final report on Operation Kenova, the interim report having been published early this year. I undertake and make a commitment, as any holder of this office would do, to carefully consider each individual case and reach what I think is a sensible way forward. Collectively, there is a huge task for all of us in playing our part in enabling families to find out answers that they have not yet had.

In that context, I welcome the ICRIR’s announcement on Monday this week that it has had 85 inquiries and has already agreed to start looking into eight cases. That is significant, because there are those who say that no one should go anywhere near the ICRIR because of its origins and parentage, if I may use that phrase. However, having taken the decision that the ICRIR will remain in place, it does have powers. It has the ability to get information and to question people, and it has said that it wants to develop what it calls a system of “enhanced inquisitorial proceedings”, which is public hearings. Of course, hearings in public are really important to many families, because they want the truth to come out and to be able to ask questions, but, crucially, for justice to be seen to be done.

Can I press the Secretary of State further on the issue of other families? Months ago, under the previous Government, those families saw a Bill—which I did not support—repressing and restricting their ability to have inquests. Today, they see a full public inquiry being announced for another family. Will the Secretary of State update the House on what personal engagement he will have with those families? Inevitably, they are going to say, “We have got a public inquiry in this case, but we are being asked to wait in the queue for this legacy Bill inquest body.” They will think something is not right about that.

I am very grateful to the right hon. Gentleman, who was such a distinguished holder of the office I now hold, for raising that point. Over the past three weeks, I have met a number of those families whose inquests were brought to an end—some because of the 1 May portcullis that came down and brought an end to the inquests; others because the coroners had said, “We don’t think we can take this any further because of issues to do with confidential material.” I undertake to the House to reach a decision in those cases and inform the families as quickly as possible.

As I have said before, one of the reasons why we made our commitment in relation to the legacy Act is this: what is it about this part of our United Kingdom that means citizens should be denied the right to bring a civil case—which is what the Act did—and to have an inquest? That cannot be right and proper, which is why this Government have made that commitment.

I welcome the Secretary of State’s statement, and I am sure all colleagues give thanks that Northern Ireland and its people now live in peace. Can the Secretary of State tell us how he thinks this announcement will help contribute to continued and meaningful reconciliation in Northern Ireland?

For one family, this now provides a process, but I am very conscious that many other families will say, “What about us?” That is why we need to find the most effective means to get to the truth, and that is part of the reason, as I have explained, why I decided that we would not get rid of the commission. I have met Sir Declan Morgan a number of times, and I have confidence in his ability to do his work. We have to find practical means of providing answers to all of those families, so that they feel their story can be told and they can get what they have been looking for. The point I wish to emphasise again to the House is that this particular case is exceptional for the reasons I set out in my statement.

One of the things the Secretary of State did not outline in his statement was that the Supreme Court considered whether it was appropriate not to proceed with a public inquiry, and that the Supreme Court agreed, provided that an investigation could satisfy article 2 compliance. He has said today that the ICRIR not only has his trust and confidence, but has the ability to perform such tasks for other families. So when he rightly says that families across Northern Ireland will ask the question, “What about us?”, so too do I, because the most exceptional circumstance about this is the exceptionality of treatment. Over 1,200 families still have neither truth nor justice, and if the plans enacted last year continue, they will never get justice. I would ask him, in repudiating the ICRIR and suggesting today that it is not an appropriate mechanism for the Finucane family—and I do not besmirch their grief or their quest for truth and justice—but it is appropriate for every other, how can he honestly look victims in the eye and say that there is not a hierarchy?

There should not be a hierarchy, and the right hon. Gentleman and I shared reservations with—indeed opposition to—the legacy Act because it did cut off lots of routes to justice. In the end, I think families should have the opportunity to avail themselves of inquests and civil cases, but the commission is now in existence. The honest answer to his question is that in this particular case, and this does not apply to any of the others, the Government of our country made a commitment twice—once at Weston Park, and secondly by the then Secretary of State—to establish a public inquiry. I think it is right and proper, the Government in the past having made that commitment, that we honour it, and that is the answer I would give him.

The state collusion in the murder of a human rights lawyer in front of his wife and children is an incredibly serious matter that chills us all, so I very much welcome the decision by my right hon. Friend the Secretary of State for Northern Ireland on a public inquiry into the murder of Pat Finucane. It is a decision to be welcomed, and it is a good signal from our new Government that they are meeting their commitments and obligations. However, this very welcome announcement must of course be followed by the action that the Secretary of State has rightly outlined. Will my right hon. Friend therefore give further reassurance to this House that all necessary resources will be provided, so that there can be truth and justice in this incredibly important matter?

I am grateful to my hon. Friend and constituency neighbour for what he has said. Having made this decision, I think all of us would recognise the need to get on with it as swiftly as possible.

This is a bad decision today. It will cause anger and further hurt for the many hundreds of families who have not had justice for the murder of their loved ones, including the mass murder of Protestant workmen at Kingsmill, the blowing up of Protestant workmen at Teebane and the horrendous murder of worshippers at Tullyvallen, among others. I think the Secretary of State has to explain to the House why, after tens of millions of pounds have been spent on inquiries and reviews of this case, he still believes it is necessary to acquiesce in the demands of the family by having another inquiry. How does he justify it to those hundreds of families that no such resources will be put in place to seek out the truth about the murders of their family members? Given the record of inquiries of this nature being a golden goose for barristers and solicitors in Northern Ireland, how is he going to ensure that the costs are capped?

The right hon. Member recounts some of the terrible murders, and I have myself met, as I am sure others have, the only survivor of the Kingsmill massacre and heard at first hand the truly chilling story of what happened on that day. First, considerable resources are now being given to the independent commission, and it is important to recognise that, because it has a huge task on its hands. I hope others will come forward to the commission to avail themselves of what it can offer.

Secondly, and I have said this to other Members in answering their questions, in this particular case a commitment was made twice, and I think it is important that we honour it. We also have to recognise in this particular case that the Court held in 2019 that all of the investigations—I accept what the right hon. Member said about them and their extent, and of course they involved the expenditure of public moneys—did not meet the requirements of article 2. Faced with that, and faced with the quashing at the end of 2022 of the decision of a previous Secretary of State not to call an inquiry pending further investigations, it has fallen to me to look at this and to decide how we are going to go forward. I have set out my reasons as clearly as I can hope to do.

Will the Secretary of State clarify that he has now ended any opportunity for the families and loved ones who still held out hope that there would be an inquiry into the death and murder of their loved ones at the hands of terrorists across Northern Ireland? Is he saying that the only opportunity for them is to go to the Independent Commission for Reconciliation and Information Recovery—an organisation that does not have the full support of the communities of Northern Ireland and does not have the support of and has been queried by many of the families who have lost loved ones? Can I just seek clarity from the Secretary of State that he is saying to those families that their only opportunity for truth, recovery and justice is to go through this organisation, and that he will not engage with them about a further inquiry?

I say to the hon. Gentleman that the independent commission should not be the only opportunity open to them. That is why I have indicated that this Government will restore civil cases, and we will restore inquests in the first instance in those cases where they had been brought to an end by the legacy Act. I agree with him that it would be quite wrong if one was to say that there was only one route, denying people—the families—the rights to inquests and civil cases that apply in all other parts of the United Kingdom. That was one of the things about the legacy Act that was so profoundly wrong. It did not say that we were going to establish a new body and people could use that route, but could also use the other two—inquests and civil cases—that had been available to them thus far; it shut those other routes down. That is part of the reason why the legacy Act was so widely opposed in Northern Ireland. I must be honest that it will take time, because it will obviously require primary legislation to deal with the bit of the legacy Act that stopped the inquests and the civil cases, and that will flow from the consultation I am currently undertaking.

I thank the Secretary of State for his statement. We should all put on record our thanks to the hon. Member for Belfast North (John Finucane), his mother Geraldine and all the Finucane family, who have campaigned for so long, as have so many others, for this inquiry. I recognise the difficulties in prescribing what an inquiry should do, the cost of it and the length of time it should take, but can the Secretary of State tell us roughly when we can expect to establish the inquiry in its formal setting? Can he give some kind of outline timetable for how long it will take to hopefully bring about a resolution, after the disgraceful murder of Pat Finucane all those years ago?

As I have already indicated, I will seek to establish the inquiry as quickly as possible. How long it will take is ultimately in the hands of the judge when he or she is appointed.

I thank the Secretary of State for his statement. As he understands, the Democratic Unionist party stood against the legacy legislation, in the interests of pursuing justice for victims. What he says today will give hope to families such as those affected by Kingsmill. I had an Adjournment debate on the Kingsmill massacre in the last Session. On 5 January 1976—48 years ago—10 innocent men who just happened to be Protestants were murdered with weapons that were linked to 40 other serious Republican terrorist crimes over a 15-year period. Information has indicated that the perpetrators were helped by the Garda Síochán. Clearly some of the Garda Síochán had IRA sympathies. It could be said that by their very position, they were agents of the state of the Republic of Ireland. Will the families of those 10 innocent Protestant men be granted the same path to justice as the Finucane family? If no inquiry is granted on Kingsmill, it will be perceived—and indeed will be proven by the Secretary of State himself—that a two-tier system of justice for victims has been clearly enshrined by this Government. How disappointing, how disgusting, and how angry that makes me.

I am sorry to have disappointed the hon. Member. As I indicated, having met the one survivor of the Kingsmill massacre, I have some appreciation of just what an appalling and brutal event that was, at a time of many appalling and brutal murders. There has been an inquest, which concluded recently. As I recall, it held the Provisional IRA responsible for that murder. I am sure that the families want to proceed further, and one of the options open to them is to go to the independent commission, but at the risk of repeating myself, I need to point out that I came to my conclusion because the Finucane case is exceptional, for the reasons that I have tried to explain.

May I begin by apologising to the Secretary of State and the House for being absent at the beginning of the statement? Secretary of State, has there ever been a family given more preferential handling by Government than the Finucane family? They have had a prime ministerial apology, multiple investigations, inquiries and now an uncapped public inquiry, after the family rejected previous Government offers of inquiries. Is not the tragic takeaway from the statement that the ICRIR is good enough for innocent victims of the IRA, the Ulster Volunteer Force and others, but not good enough for the Finucane family? Why is the Secretary of State perpetuating that odious hierarchy of victims?

I am not, is the answer. I know that the hon. Member was slightly late in coming to the Chamber, and from the beginning I set out my thought process. He will have an opportunity to read my statement subsequently. I clearly set out the reasons why I reached this decision. It is a fact that when the then Prime Minister David Cameron apologised from this Dispatch Box, it was unprecedented, because he referred to shocking collusion in this case. We Members of this House should take that extremely seriously, all of us who are committed to upholding our obligations. We were faced with two promises to establish public inquiries. I accept what the hon. Member says about that not happening after 2004 because of the then stance of the Finucane family, but that has now changed. There is also the Supreme Court decision of 2019; it said, I am afraid, that for all that had gone before, the state had not complied with its article 2 obligations. We will now do so.

Bill Presented

Renters’ Rights Bill

Presentation and First Reading (Standing Order No. 57)

Secretary Angela Rayner, supported by the Prime Minister, the Chancellor of the Exchequer, Secretary Shabana Mahmood, Secretary Bridget Phillipson, Secretary Liz Kendall, Secretary Jonathan Reynolds, Secretary Ian Murray and Secretary Jo Stevens, presented a Bill to make provision changing the law about rented homes, including provision abolishing fixed-term assured tenancies and assured shorthold tenancies; imposing obligations on landlords and others in relation to rented homes and temporary and supported accommodation; and for connected purposes.

Bill read the First time; to be read a Second time tomorrow, and to be printed (Bill 8) with explanatory notes (Bill 8-EN).