DOCSLIB.ORG

IN the COUNTY COURT at CENTRAL LONDON Claim No. E40CL216 in the MATTER of the POLITICAL PARTIES, ELECTIONS and REFERENDUMS ACT 2

Total Page：16

File Type：pdf, Size：1020Kb

Download full-text PDF Read full-text
IN the COUNTY COURT at CENTRAL LONDON Claim No. E40CL216 in the MATTER of the POLITICAL PARTIES, ELECTIONS and REFERENDUMS ACT 2 IN THE COUNTY COURT AT CENTRAL LONDON Claim No. E40CL216 IN THE MATTER OF THE POLITICAL PARTIES, ELECTIONS AND REFERENDUMS ACT 2000; AND THE POLITICAL PARTIES, ELECTIONS AND REFERENDUMS (CIVIL SANCTIONS) ORDER 2010 BEFORE HHJ DIGHT CBE B E T W E E N: DARREN GRIMES Appellant -and- THE ELECTORAL COMMISSION Respondent _____________________________ NOTICE OF RESPONSE _____________________________ INTRODUCTION 1. The Commission is the independent body which oversees elections and regulates political finance in the UK. It is a body corporate established by statute which consists of nine or ten members, known as Electoral Commissioners and appointed by the Queen, who also appoints one of the Commissioners to be the chairman of the Commission: see ss.1(1)-(5) PPERA. Mr Grimes is an individual who registered as a permitted participant in the 2016 EU referendum. 2. This appeal concerns the decision contained in the Commission’s Statutory Notice dated 16 July 2018 and issued on 17 July 2018 (“the Notice”). In the Notice, the Commission concluded that Mr Grimes had committed offences in connection with four payments made in June 2016 to a Canadian data analytics firm called Aggregate IQ (“AIQ”) for services provided to campaigners in the EU referendum; and had thereby acted in breach of the Political Parties, Elections and Referendums Act 2000 (“PPERA”). The Commission concluded that the offences were serious and imposed civil sanctions accordingly. On the same date, the Commission published a report of its investigation into the Appellant (amongst others) concerning campaign funding and spending for the EU referendum (the “Report”). The Appellant now appeals against the Notice pursuant to §6(6) of Schedule 19C PPERA. 3. The Commission was satisfied beyond reasonable doubt that Mr Grimes had committed an offence under s.117(3) PPERA by incurring referendum spending, in excess of the statutory £10,000 limit applicable, on behalf of an unincorporated association (“BeLeave”) that was not a permitted participant, in circumstances where Mr Grimes 1 knew or ought reasonably to have known that he was doing this. The Commission found that these expenses came to over £675,000 and were incurred by BeLeave in a common plan with Vote Leave Limited (“Vote Leave”). Vote Leave is a limited company established for the purpose of the EU referendum in June 2016. It was the designated lead campaigner for a “leave” outcome in the referendum. 4. The Commission found (amongst other things) as follows: 4.1. Mr Grimes had registered as a permitted participant in his individual capacity, even though from May 2016 BeLeave existed as an unincorporated association and could have so registered. Nevertheless, Mr Grimes chose to campaign using BeLeave as the vehicle for accepting donations and for incurring referendum spending in excess of £10,000, to a total of £675,908.32 (Notice §47); 4.2. BeLeave’s overall spending was “substantially above the threshold of £10,000 at which a campaigner must become a permitted participant”. The Commission concluded that “[t]hat is a very significant failure and warrants a significant sanction” (Notice §48). 4.3. The Commission weighed the mitigating factors raised by Mr Grimes against the aggravating factor of the seriousness of the offence. However, it stressed that “an unprecedented sum of money was involved here and the referendum was a highly significant political event (Notice §88). 4.4. Having considered Mr Grimes’ representations, the Commission was nevertheless satisfied beyond reasonable doubt that he had committed the following offences; under s.122(4)(b) PPERA that Mr Grimes, as a permitted participant without reasonable excuse delivered a return that did not meet the requirements of section 120(2) or (3) PPERA; under s.117(3) PPERA that he incurred referendum spending in excess of £10,000 on behalf of a body that was not a permitted participant (Notice §98). 4.5. In the circumstances of the case, the Commission was satisfied that it was appropriate to impose a sanction in respect only the second of these offences and that it was proportionate and in the public interest to impose the sanction of £20,000 in relation to that offence (Notice §99). 5. Pursuant to §§1 & 7 of the Court’s 2 November 2018 Order, this appeal is being case managed and heard together with a parallel appeal against other financial penalties imposed on Vote Leave arising out of the same investigation. 2 THE APPEAL JURISDICTION Statutory framework 6. The County Court’s appeal jurisdiction is defined by §6(6) of Schedule 19C PPERA: “(6) A person on whom a discretionary requirement is imposed may appeal against the decision to impose the requirement on the ground— (a) that the decision was based on an error of fact, (b) that the decision was wrong in law, (c) in the case of a variable monetary penalty, that the amount of the penalty is unreasonable, (d) in the case of a non-monetary discretionary requirement, that the nature of the requirement is unreasonable, or (e) that the decision is unreasonable for any other reason, or on such other grounds as may be prescribed.” (emphasis added) 7. Schedule 19C PPERA is supplemented by the Political Parties, Elections and Referendums (Civil Sanctions) Order 2010/2860 (the “2010 Order”). Art. 8 of the 2010 Order relevantly provides as follows: “(2) On an appeal under paragraph […] 6(6) […] of Schedule 19C the county court […] may— (a) withdraw, confirm or vary the requirement or notice; (b) take such steps as the Commission could take in relation to the act or omission giving rise to the requirement or notice; (c) remit the decision whether to confirm the requirement or notice, or any matter relating to that decision, to the Commission.” 8. Two particular matters are to be noted regarding the appeal jurisdiction: 8.1. First, the Appellant bears the legal burden of establishing one of the grounds of appeal specified in §6(6) of Schedule 19C. Insofar as the Appellant seeks to make a factual challenge, it is incumbent upon him to identify an “error” of fact upon which the Commission’s decision was based: see §6(6)(a) of Schedule 19C. Accordingly, the Court is not tasked with a de novo rehearing of the facts and matters upon which the Commission’s decision is based. As Mr Grimes accepts, the Court’s jurisdiction is to “review ... the factual and legal basis on which [the] decision is made” and this amounts to “jurisdiction only to review a discretionary decision” (Grounds §20, emphasis added). 8.2. Secondly, the error of fact or law must be material. Thus, as set out in art. 8(2)(a) of the 2010 Order, the powers of the Court on appeal include (amongst other things) to “withdraw, confirm or vary the requirement or notice” (emphasis added). Immaterial matters provide no basis for varying or withdrawing the requirement imposed by the Commission. If the Court is not satisfied as to materiality, the appropriate course is to confirm the requirement. This follows the well-established principle in civil appeals that “(e)rrors of law of which it can be 3 said that they would have made no difference to the outcome do not matter” and an appeal against a finding of fact must identify a “material matter”: see R. (Iran) v Secretary of State for the Home Department [2005] EWCA Civ 982 at §§9-11 per Brooke LJ. 9. Mr Grimes has pleaded a number of grounds which (even on his own case) would make no difference to the correct outcome. To give one example, he advances a ground of appeal based on the statutory eligibility requirement for an unincorporated association to have its “main office” in the UK. He contends that “(t)he Commission made no finding… that BeLeave did or did not have an office in the [UK]”: Grounds §111-112. Yet he does not contend that BeLeave had any office outside the UK. Indeed, his pleaded case as to his own whereabouts is that “(h)e was based in and almost exclusively worked from his home in Brighton” and “(h)is activities were carried out wholly in the [UK]”: Grounds at §114(4)-(5). Accordingly, even if there were anything missing from the Commission’s findings on this point (which there is not), this is not a matter which provides any basis for disturbing the Commission’s decision. The statutory scheme does not require the Court to vary or withdraw a decision based on unmeritorious and immaterial grounds such as this. Article 6 ECHR 10. Mr Grimes contends that the civil sanction imposed on him involves a “criminal charge” for the purposes of Article 6 ECHR: Grounds §§59-60. The Commission submits that: 10.1. A variable monetary penalty imposed as a discretionary requirement under Schedule 19C PPERA is a civil matter for the purposes of Article 6; 10.2. In any event, even if such a monetary penalty were properly to be characterised as a “criminal charge”, the statutory scheme under Schedule 19C for the imposition of such penalties by the Commission and appeal to the County Court is compatible with Article 6. 11. The established case-law of the ECtHR sets out three criteria to be considered in the assessment of the applicability of the criminal aspect of Article 6. These criteria are sometimes referred to as the “Engel criteria” following the decision of the ECtHR in Engel and others v The Netherlands (No 1) (1976) 1 E.H.R.R. 647. The Engel criteria, in summary, require the following to taken into account in considering characterisation: (a) the classification of the penalty in domestic law; (b) the nature of the offence; and (c) the nature and degree of severity of the penalty that the person concerned had risked incurring.
Load more

Recommended publications
  • Expert Says Brexit Campaign Used Data Mined from Facebook 27 March 2018, by Danica Kirka
    Expert says Brexit campaign used data mined from Facebook 27 March 2018, by Danica Kirka persuade voters. "It was everywhere." Among the companies that had access to the data was AggregateIQ, a Canadian political consultant that did work for Vote Leave, the official campaign backing Britain's withdrawal from the EU, Wylie said. Wylie described Cambridge Analytica as just one arm of a global company, SCL Group, that gets most of its income from military contracts but is also a political gun-for-hire, often in countries where democratic institutions are weak. He suggested the company combines computer algorithms and dirty tricks to help candidates win regardless of the cost. Whistleblower Christopher Wylie who alleges that the The 28-year-old Canadian with a swath of pink hair campaign for Britain to leave the EU cheated in the referendum in 2016, speaking at a lawyers office to the says he helped set up Cambridge Analytica in media in London, Monday, March 26, 2018. Chris 2013. He left the next year. Wylie's claims center around the official Vote Leave campaign and its links to a group called BeLeave, which Wylie has previously alleged that Cambridge it helped fund. The links allegedly allowed the campaign Analytica used personal data improperly collected to bypass spending rules. (AP Photo/Alastair Grant) from Facebook users to help Trump's 2016 presidential campaign. Cambridge Analytica says none of the Facebook The computer expert who alleges a trove of data was used in its work on the Trump campaign. Facebook data was improperly used to help It denies any wrongdoing.
    [Show full text]
  • Report of an Investigation in Respect Of
    Report of an investigation in respect of - Vote Leave Limited - Mr Darren Grimes - BeLeave - Veterans for Britain Concerning campaign funding and spending for the 2016 referendum on the UK’s membership of the EU 17 July 2018 1 Other formats For information on obtaining this publication in a large-print or Braille version, please contact the Electoral Commission. Tel: 020 7271 0500 Email: [email protected] The Electoral Commission is the independent body which oversees elections and regulates political finance in the UK. We work to promote public confidence in the democratic process and ensure its integrity. 2 Contents 1 Introduction..................................................................................................... 4 2 The decision to investigate ............................................................................. 9 3 The investigation .......................................................................................... 12 4 The investigation findings ............................................................................. 16 Joint spending by Vote Leave and BeLeave ................................................... 16 Vote Leave’s spending limit ............................................................................. 21 Other issues with Vote Leave’s spending return ............................................. 24 BeLeave’s spending ........................................................................................ 25 Mr Grimes’ spending return ............................................................................
    [Show full text]
  • 17 July 2018 - - Page 1 of 38 - (I) Causing Or Permitting a Derogatory Article to Be Written in Brexit Central; And
    IN THE EMPLOYMENT TRIBUNAL CASE NUMBER: [TBC] B E T W E E N: SHAHMIR SANNI (Claimant) -and- THE TAX PAYERS ALLIANCE LIMITED (Respondent) PARTICULARS OF CLAIM Parties (1) The Claimant was employed by the Respondent from 13 March 2017 to 13 April 2018. He was employed as a Digital Campaign Manager. His responsibilities included running the Respondent’s social media accounts, YouTube channel, and producing website content and video content. (2) The Respondent is a self-declared “grassroots campaigning group dedicated to reforming taxes, cutting spending and protecting taxpayers”. It is a lobbying group pursuing a right-wing political ideology. It operates from 55 Tufton Street, Westminster, an office block where seven other similar right-wing political organisations are based. (3) The Claimant was summarily dismissed by the Respondent on 13 April 2018. Legal Claims (4) The Claimant advances claims of: (a) Automatically Unfair Dismissal by reason of having made a protected disclosure (s.103A Employment Rights Act 1996 (“ERA”)); (b) Directly discriminatory dismissal (s.13 and s.39(2)(c) Equality Act 2010 (“EqA 2010”) because of his belief that protecting the integrity and sanctity of British democracy from taint and corruption was paramount, which is a philosophical belief protected by s.10 EqA 2010 and in accordance with the characteristics set out in Grainger v Nicholson [2010] ICR 360; (c) Protected Disclosure detriment (s.47B ERA), namely:- _________________________ - Particulars of Claim - - 17 July 2018 - - Page 1 of 38 - (i) Causing or permitting a derogatory article to be written in Brexit Central; and (ii) Instructing Wilsons LLP to write the letter wrongly threatening defamation proceedings; and (iii) Permitting or causing the making of derogatory statements in public and the media on 4 July 2018.
    [Show full text]
  • Post Layout 1
    Friday 15 International Friday, July 26, 2019 Britain new leader rejects ‘unacceptable’ Brexit deal Johnson urged EU leaders to rethink their opposition LONDON: Britain’s new Prime Minister Boris ing the EU after 46 years without an agreement will Johnson yesterday called the current Brexit deal be less painful than economists warn. The markets negotiated with the EU “unacceptable” and set were relieved by the appointment of former preparations for leaving the bloc without an agree- Deutsche Bank Sajid Javid as finance chief. The ment as a “top priority” for the government. In a pound held steady against the dollar and euro as pugnacious debut in parliament, the former London traders waited for Johnson’s first policy moves. mayor urged EU leaders to rethink their opposition Other appointments were more divisive. Brexit to renegotiating the deal. hardliner Dominic Raab became foreign secretary After installing a right-wing government follow- and Jacob Rees-Mogg - leader of a right-wing ing a radical overhaul, Johnson doubled down on faction of Conservatives who helped bring about his promise to lead Britain out of the EU by Octo- May’s demise - as the government’s parliament ber 31 at any cost. In case of a no-deal exit, he also representative. New interior minister Priti Patel threatened to withhold the £39 billion ($49 billion) has previously expressed support for the death divorce bill that Britain has previously said it owes penalty and voted against same-sex marriage. The the EU and instead spend the money for prepara- Labor opposition-backing Mirror newspaper tions for leaving with no agreement.
    [Show full text]
  • Disinformation and 'Fake News': Interim Report
    House of Commons Digital, Culture, Media and Sport Committee Disinformation and ‘fake news’: Interim Report Fifth Report of Session 2017–19 Report, together with formal minutes relating to the report Ordered by the House of Commons to be printed 24 July 2018 HC 363 Published on 29 July 2018 by authority of the House of Commons The Digital, Culture, Media and Sport Committee The Digital, Culture, Media and Sport Committee is appointed by the House of Commons to examine the expenditure, administration and policy of the Department for Digital, Culture, Media and Sport and its associated public bodies. Current membership Damian Collins MP (Conservative, Folkestone and Hythe) (Chair) Clive Efford MP (Labour, Eltham) Julie Elliott MP (Labour, Sunderland Central) Paul Farrelly MP (Labour, Newcastle-under-Lyme) Simon Hart MP (Conservative, Carmarthen West and South Pembrokeshire) Julian Knight MP (Conservative, Solihull) Ian C. Lucas MP (Labour, Wrexham) Brendan O’Hara MP (Scottish National Party, Argyll and Bute) Rebecca Pow MP (Conservative, Taunton Deane) Jo Stevens MP (Labour, Cardiff Central) Giles Watling MP (Conservative, Clacton) The following Members were also members of the Committee during the inquiry Christian Matheson MP (Labour, City of Chester) Powers The Committee is one of the departmental select committees, the powers of which are set out in House of Commons Standing Orders, principally in SO No 152. These are available on the internet via www.parliament.uk. Publication Committee reports are published on the Committee’s website at www.parliament.uk/dcmscom and in print by Order of the House. Evidence relating to this report is published on the inquiry publications page of the Committee’s website.
    [Show full text]
  • Standing Committee on Access to Information, Privacy and Ethics
    Standing Committee on Access to Information, Privacy and Ethics ETHI Ï NUMBER 113 Ï 1st SESSION Ï 42nd PARLIAMENT EVIDENCE Tuesday, June 12, 2018 Chair Mr. Bob Zimmer 1 Standing Committee on Access to Information, Privacy and Ethics Tuesday, June 12, 2018 As the chief operating officer, I can assure you, though, that I can speak for AggregateIQ on all matters. Ï (0850) [English] The Vice-Chair (Mr. Nathaniel Erskine-Smith (Beaches—East We've been entirely co-operative with this committee. After our York, Lib.)): Let's begin. last appearance on April 24, we immediately followed up and provided many documents related to the questions you asked. Your Thank you, Mr. Silvester, for attending today. Before we begin chair also asked us to preserve documents in a letter dated May 3. In with your opening statement, I do want to make it known that this our response on the 10th, we told the committee that we had already committee issued a summons to your colleague, Mr. Massingham, preserved the documents in the context of our cooperation with the and he has clearly refused to attend in the face of that summons. Information and Privacy Commissioner of British Columbia and the federal Privacy Commissioner. We respect the important work being Mr. Angus. done by the privacy commissioners and this committee, and wish to Mr. Charlie Angus (Timmins—James Bay, NDP): Thank you, continue a constructive dialogue in support of that work. Mr. Chair. I am very concerned that Mr. Massingham has refused a summons With respect to our discussion with you on the 24th, we were by our committee.
    [Show full text]
  • Populism Or Embedded Plutocracy? the Emerging World Order
    City University of New York (CUNY) CUNY Academic Works Publications and Research Hunter College 2019 Populism or Embedded Plutocracy? The Emerging World Order Michael Lee CUNY Hunter College How does access to this work benefit ou?y Let us know! More information about this work at: https://academicworks.cuny.edu/hc_pubs/603 Discover additional works at: https://academicworks.cuny.edu This work is made publicly available by the City University of New York (CUNY). Contact: [email protected] Draft: Populism or Embedded Plutocracy? Envisioning the Emerging World Order Introduction The liberal world order is in dire straits. The world of moderately open migration, free trade, and free flows of capital that has existed since the 1970s is under attack. Liberal democracies around the world have seen the rise of far-right political parties trading in xenophobia, while attacking traditional liberal institutions. Many political scientists, increasingly committed to country-specific studies, or mid-level theories of small phenomenon are picking up many of these developments, while missing common threads between them. We are bearing witness to systemic changes. After the collapse of the Bretton Woods system in 1971, the United States and its allies in the G-7 constructed a new neo-liberal world order characterized by relatively open migration, free trade, and free flows of capital.1 Today, that order is collapsing in the face of its internal contradictions. Free flows of capital, combined with the privileged position of the American dollar, saddled the global economy with recurrent financial crises. Internally, the implementation of many neoliberal policies (and creation of transnational workarounds) undermined many of the civil society groups vital for broad-based democracy.
    [Show full text]
  • 5. Advertising and Persuasion: a Literature Review
    Masaryk University Faculty of Arts Department of English and American Studies English Language and Literature Bc. Natália Belicová Advertising Brexit: Elements of Persuasion in the Facebook Campaign Master’s Diploma Thesis Supervisor: Mgr. Jana Pelclová, Ph. D. 2020 I declare that I have worked on this thesis independently, using only the primary and secondary sources listed in the bibliography. …………………………………………….. Natália Belicová I would like to thank my supervisor Mgr. Jana Pelclová, Ph. D., for her invaluable advice, guidance, and willingness to meet regularly online whenever I felt the need to discuss a problem. I genuinely appreciate it. I also thank everybody who helped me and supported me when writing this thesis, especially Jakub G.. Table of Contents 1. Introduction ............................................................................................................... 5 2. Aim and data ............................................................................................................. 7 3. Methodology of research ........................................................................................... 9 4. Historical background of Brexit ................................................................................ 10 5. Advertising and persuasion: A literature review ....................................................... 13 6. Analysis of the persuasive elements ......................................................................... 19 6.1. Linguistic modes of persuasion ............................................................................
    [Show full text]
  • Information on Cases
    Casework and Investigations Decision on offence or Decision on Name and type of regulated Potential offence or contravention contravention sanction (imposed Brief summary of reason for Outcome or current Status last Further information entity investigated (by regulated on regulated entity decision status updated entity or or officer) officer) Published on 21 May 2019 The Commission considered, in Liberal Democrats (Kensington Late delivery of 2017 statement of £200 (fixed monetary accordance with the enforcement policy, Paid on initial notice on Offence 21 May 2019 and Chelsea accounting unit) accounts penalty) that sanctions were appropriate in this 25 April 2019 case. The Commission considered, in Liberal Democrats (Camborne, Late delivery of 2017 statement of £200 (fixed monetary accordance with the enforcement policy, Paid on initial notice on Redruth and Hayle accounting Offence 21 May 2019 accounts penalty) that sanctions were appropriate in this 25 April 2019 unit) case. The Commission considered, in Scottish Democratic Alliance Late delivery of 2017 statement of £200 (fixed monetary accordance with the enforcement policy, Due for payment by 12 Offence 21 May 2019 (registered political party) accounts penalty) that sanctions were appropriate in this June 2019 case. Published on 16 April 2019 The Commission considered, in British Resistance (registered Late delivery of 2017 statement of £300 (variable accordance with the enforcement policy, Offence Paid on 23 April 2019 21 May 2019 political party) accounts monetary penalty) that sanctions were appropriate in this case. The Commission considered, in Due for payment by 3 The Entertainment Party Late delivery of 2017 statement of £200 (fixed monetary accordance with the enforcement policy, May 2019.
    [Show full text]
  • Electoral Law Forum
    Electoral Law Forum Caselaw update Gethin Thomas 17 September 2019 Copyright remains with the authors set out above. This document is not and does not purport to be legal advice. Neither the authors nor any party associated with 39 Essex Chambers assumes any responsibility to any party as a result of their reliance upon any of its contents. A. INTRODUCTION 1. This paper summarises recent caselaw concerning the electoral process. The first three cases considered below have each addressed three discrete and disparate issues: a. candidate selection protocols and positive discrimination (Dhamija v Liberal Democrats in England [2019] EWHC 1398 (QB) (24 April 2019), b. the voter identification pilot scheme in local government elections this year (R. (on the application of Coughlan) v Minister for the Cabinet Office [2019] EWHC 641 (Admin) (20 March 2019)), and; c. whether the tactile voting device for blind and partially-sighted voters is fit for its legislative purpose (R. (on the application of Andrews) v Minister for the Cabinet Office [2019] EWHC 1126 (Admin) (3 May 2019)). 2. The fourth and final case considered below, R. (on the application of Wilson) v Prime Minister [2019] EWCA Civ 304 (4 March 2019), the Applicants brought a judicial contending that the Prime Minister’s decision to notify the EU of the UK’s intention to withdraw, and the notification itself, were unlawful because they were based upon the result of a referendum that was itself unlawful as a result of corrupt and illegal electoral practices. B. CANDIDATE SELECTION Dhamija v Liberal Democrats in England [2019] EWHC 1398 (QB) (24 April 2019) Introduction 3.
    [Show full text]
  • Microsoft Outlook
    From: FOI Sent: 13 July 2017 16:17 To: Subject: FOI 59/17 Vote Leave and BeLeave EC Correspondence Response Attachments: 20160428 Vote Leave and Labour Leave ATTACHMENT REDACTED.pdf; 20160428 Vote Leave and Labour Leave REDACTED.pdf; 20160429 RE Vote Leave and Labour Leave (1) REDACTED.pdf; 20160429 RE Vote Leave and Labour Leave (2) REDACTED.pdf; 20160602 RE Material from other campaigners REDACTED.pdf Dear Our Ref: FOI 59/17 Thank you for your email to the Electoral Commission dated 12 May 2017. The Commission aims to respond to requests for information promptly within the statutory twenty working days and regrets that on this occasion we have not done so. Your request is in bold below followed by our response. You have requested: Please provide me with any document exchanged between either Vote Leave or BeLeave and the Electoral Commission, during the regulated period right before the Brexit referendum, and concerning 3rd party or joint funding of campaigns. Our response is as follows: We hold some of the information you have requested. We hold documents exchanged between Vote Leave and the Commission but we do not hold any information on the campaigner BeLeave. The Regulated Period for the UK General Election 2017 was from 15 April to 23 June 2017 and this has been reflected in the documents returned. Please find attached 5 emails attached, redaction has been applied to remove signatures and contact information where the individuals would not have reasonably expected their released to the public. Section 40(2) and (3)(a)(i) of the FOI Act In the information we are releasing, we have redacted some of the information in the documents.
    [Show full text]
  • Good-Law-Project-Witness-Statement
    Statement for the Claimant Witness: Statement: Exhibits: P/bundle Date: IN THE HIGH COURT OF JUSTICE QUEEN’S BENCH DIVISION ADMINISTRATIVE COURT BETWEEN: THE QUEEN on the application of The Good Law Project Claimant and The Electoral Commission Defendant WITNESS STATEMENT OF JOLYON MAUGHAM I, Jolyon Maugham QC, director of the Good Law Project, will say as follows: Overview 1. The facts within this witness statement are from matters within my own knowledge except where otherwise stated. The numbers in bold and in square brackets refer to the page numbers of the hearing bundles. Reasons behind the challenge: 2. The Good Law Project is an organisation I set up with the aim of using the law to deliver a progressive society. The three areas the project presently concentrates on are Brexit, tax, and workers’ rights. I campaigned, independently, for Remain in the Referendum. And I continue to believe that the country’s interests would be better served by us remaining in the EU. It is right that I say this. However, it is also true to say that I have a long running and active interest – predating the Referendum – in the proper functioning of ‘institutions’ of Government. My focus was initially on HMRC that being the institution most closely connected to the work I do in my professional life. However, I also wrote, prior to the Referendum, about my attempts to put pressure on the Electoral Commission to discharge what I see as its statutory 2-1 responsibilities in spheres unconnected with the Referendum. And I have written about the functioning of other public institutions, for example, the Office for Budget Responsibility.
    [Show full text]