ࡱ> {}z7 LbjbjUU c7|7|Hl,z z z z 4,I   TIVIVIVIVIVIVI$J L*zI "   zI; #I;;; R  TI; TI; ;GDTI }ˣ,N z ]H&TII0I IJN;NTI;,,Response to the consultation on the Power to Close Premises: Part One of the Anti Social Behaviour Bill, and associated Notes of Guidance. 1 About the respondent: 1.1 This response has been prepared by Kevin Flemen. Mr. Flemen has worked extensively with drugs and housing providers over the past five years, trying to develop legal policy and practice that allowed the safe and effective housing and support of people who use drugs. 1.2 In this time, Mr. Flemen has delivered work through the national drugs and legal charity, Release, where he was Acting Director until November 2003. He was the author of the widely-read document Room for Drugs, and co-authored the document Managing Drug Use in Rented Accommodation, for the DTLR. In November, he established an independent organisation KFx and has since worked with several hundred organisations and individuals to take forward drugs and housing work. 2 The scope of this response: 2.1 While this response is primarily concerned with the Notes of Guidance, it also makes some wider observations about the framing of the legislation itself. This is essential as, unfortunately, no consultation with the field took place when the proposed legislation was being drafted or put before Parliament and, as such, this consultation is the first opportunity to comment formally on the legislation. 2.2 We would note that, with many other changes to drugs legislation, such as the changes to the paraphernalia legislation, extensive consultation took place before legislation was framed, and these changes reflected recommendations made by the ACMD or other bodies. 2.3 We would note that on this occasion, the legislative changes have not emerged from recommendations from the ACMD, the Home Affairs Select Committee, the Police Foundation Review and as such have not emerged from evidence-based reviews of the law. 2.4 We believe that many of the problems and flaws integral to the legislation would have been avoided had the proper process of consultation been undertaken before the legislation was passed, a more acceptable piece of legislation would have emerged. 2.5 We welcome the decision to move away from Section 38 of the Criminal Justice and Police Act 2001 and recognise that there was a need to ensure that other effective measures need to be put in place to address drug related nuisance in society. 2.6 We feel however, that the powers created by Part One of the Anti Social Behaviour Act 2003 are excessive, and that there are insufficient safeguards and checks on these powers. The Notes of Guidance heighten these concerns and leave us unable to endorse either the legislation in its current form or the notes of guidance. 2.7 The powers created under the Act appear to over-ride centuries of property and common law, and do so with an unacceptable level of safeguard or scrutiny. Further, we believe that aspects of the legislation run contrary to the Human Rights Act, especially Article 8, and Article 1 of Protocol 1, relating to the right to peaceful enjoyment of possessions and protection of property. 2.8 We would stress that amongst other powers, this act creates a power to seize a persons home, even if they are the legal owner, seal that property, and deny them access to it for a period of up to six months. This power would be granted on the order of a magistrate, within a period of 48 hours. This is an unprecedented legal power, which overrides many previous legal rights enjoyed by UK citizens, and yet has been passed with little or no comment. We are concerned that this has implications for home-owners, tenants, travellers, squatters and many other groups. The scope for abuse of this power is huge. 3: Terms and Language 3.1: We would note that the short title for Part one of the Anti Social Behaviour Act, i.e. premises where drugs are used unlawfully, is misleading, and gives an inaccurate impression of the contents of the legislation. The scope extends beyond use, but is limited to Class A drugs. As such we would urge that the use of this inaccurate short title be discontinued. 3.2: The Notes of Guidance need to make explicit that the Act relates to unlawful use, production or supply of Class A drugs. This is not explicit in the Guidance notes; for example at 1.1 the notes read these powers are designed to enable police to close premises which Class A drugs are produced, used or supplied This wording would clearly include a pharmacist legally dispensing Methadone. This exceeds the actual scope of the legislation and so it is essential that the word unlawful is inserted and used throughout the guidance document. 3.3: We are aware that the impetus behind the legislation was to shut down properties associated with crack cocaine. In turn, we are aware of the associations between crack and violent crime. However, by far the majority of properties where the use or supply of Class A drugs takes place have no relationship to crack use. We would wish to stress therefore that, in the majority of situations, the powers created by the Act will not be appropriate and other, less draconian responses should be used. 3.4 Throughout the document, terms such as supply and dealer are used. We would note that (a) the Act and the Notes of Guidance relate to properties associated not solely with supply but also use and production and (b) as no criminal charges are required, at most the person may be an alleged user or alleged supplier and (c) the repeat use of the term dealer in this document is both inappropriate and inaccurate. We would especially highlight the following examples: and sometimes dealers may return the tenant/owner , who may be the dealer the dealers will return the help provided to the displaced tenantif they are not the dealer, is crucial. It is all to easy for them to be preyed on again. [our emphasis] 3.5 We are also concerned that at points in the document, language and images have been used which are intentionally inflammatory. While these may be accurate in a small minority of situations, they are not in the vast majority of situations and should be removed from the notes of guidance. We would especially draw attention to the following use of colourful language, notably: 2.5.4 .the testimony of residents who feel terrorised The use of the term terrorised is hugely value-laden, and excessive given the nature and purpose of the document. 3.1and informing drug dealers that their activities will no longer be tolerated The term drug dealers is not one that should be used in a serious guidance document. Is a sensationalist and value-laden term. Further, its use here is inaccurate as the legislation relates to production, use or supply. The phrasing here is sensationalist and needs to be revised. 7.2.2This is probably the most sensationalist and provocative section. in others they may also be resistant to leaving. They may also be armedFirearms support may be required. 3.6 Again, we would note that this document relates to any property where class A drugs are being used (or produced or supplied.) The above example is drawing on a smaller number of exceptions but by its inclusion in this settings suggests that it is the norm where people use Class A drugs. Such an approach is not helpful or balanced in the context of the notes of guidance. 3.7 We would want to stress that in a large number of situations people who supply drugs are also users and so can benefit from access to services and treatment. This point is at odds with clause 12.6 of the guidance notes which maintains the stereotype of predatory dealers preying on vulnerable users. We would also note that this illusion is maintained in clause 10.4.1 which discusses when a tenant is prepared to surrender the tenancy immediately and the dealers have disappeared. As we are all aware, people do not disappear, and to suggest that they do so in the guidance is fallacious. 4: Consultation: 4.1 We feel that, overall, the Notes of Guidance do not place sufficient evidence on a process of consultation and alternative routes to resolution. This is especially apparent in Section 2.6.2. This suggests that the process of consultation is to allow the police to discuss with the local authority what they intend to do, whyand to seek their views. 4.2 We would strongly suggest that the process of consultation should also be an opportunity for interested parties to identify other approaches or strategies which may achieve a desired resolution without recourse to these powers. 4.3 At no point in this section, in the bullet points or elsewhere, is the idea of using consultation to achieve alternative resolution explored. We would urge its inclusion here and elsewhere. 4.4 We are concerned that both the wording of the Act and the Notes of Guidance puts too little emphasis on the value of contacting the managers of housing stock especially when this is a voluntary sector housing organisation. While the Act obliges the police to consult the local authority, the only requirement beyond this is to take reasonable steps to establish the identity of other parties. We would like to see more onus placed on the police to consult with RSLs and other social housing providers as an alternative to use of the powers in the Act, not merely to inform them of impending action. 4.5 We disagree that the appropriate point of notification is the Chief Executive or Directorin the RSL.. Given that a number of RSLs operate on a regional or National Basis, and given the miniscule time made available to respondents to prepare for court, it will be more appropriate that contact is made both at a senior level but also where necessary at a local management level. 5: Legal and Policy Issues There are a number of legal and policy issues that need to be considered further. 5.1 Meaning of habitually resident: while the meaning of this term has been established over time in the context of habitually resident in the UK, its meaning here is not clarified. Does it mean tenants, their partners, offspring, friends who stay frequently? As being habitually resident can make the difference between being arrested and not being arrested, it is important that this term is clarified. 5.2 [from 3.3.3 onwards] some persons occupying the property may need alternative accommodation and at 5.4.1 those at a premisesmay well choose to leave voluntarily. We are deeply concerned about the lack of clarity here. We need to see resolution of the following points: would a person who chose to leave voluntarily be classed as intentionally homeless. Would this therefore mean that such a move would deny the person any further housing by the Local Authority. Further, even where a person has been removed by force from a property, what will there status be under housing law. Will local authorities still have an obligation to house them. The lack of clarity here is of great concern. What is the status of the tenancy for the duration of a Closure Order? Is the tenancy ended, surrendered, or still in place? There is an utter lack of clarity here, and as it is an essential aspect of housing law needs to be addressed and resolved. What is the status of Housing Benefit payments for the duration of the Closure Order. Again, this is influenced by the above. The status of the tenancy during a period of closure will probably determine aspects such as Housing Benefit and liability for bills, repairs, etc. But this needs to be clarified. 5.3 Duration of Closure Notices: It does not appear to be clear from the wording of the legislation how long a Closure Notice can remain in force. Is it open-ended or does it lapse after 48 hours? Is there any legal impediment that stops a second closure notice being put in place when a first one lapses? The power to create a closure notice would appear to give the Police an unfettered power to restrict access to a property without due legal process, and without a process of appeal. There is scope for this power to be abused and we strongly feel that there are insufficient checks on this power. Courts: We are concerned that the Act and the Notes of Guidance seeks to substantially constrain the power of the Courts and puts undue weight on the decisions of the Police. This is especially apparent at paras 6.1.7 and 6.2.3 and at G6.1 and G6.2. We would argue that it is up to the courts at this time to hear other evidence that may be relevant, and not up to the notes of guidance to preclude such evidence being offered. The notes of Guidance vacillate on this point; on the one hand they say at G 6.1, quite correctly, that ultimately it is for the court to decide whether the closure of any specific premises on a specific occasion is justified But at G.6.2 the Guidance Notes attempt to restrict the power of the court by saying the court is not asked to decide whether it is in the public good whether such premises are closed, simply whether the criteria for closure are met We deplore this approach to decision making and argue that this untrammelled power in the hands of the police, without a balancing power in the courts is unprecedented and dangerous. We would argue that in this instance, the legislation should be revised so as not to curtail the powers of the courts. In lieu of this we would urge that the Notes of Guidance do not place such an imposition on the courts. At 6.1.5 the Notes of Guidance state the simple presence of controlled drugs, rather than the proven possession by any named individual, is all that is required that this criteria [supply or production] is met. This again is a decision for the courts to reach, not one that should be imposed by the Notes of Guidance. 6 Discharge of a closure order: The Guidance seems to focus mainly or exclusively on situations where the tenant surrenders the tenancy (and becomes homeless) or where the tenant has been evicted (and become homeless). The Guidance places undue weight on requiring the courts to assess the potential for reoccurrence of the nuisance and disorder and measures in place to prevent this (s.10.4.2). Based on the text of the Act, the court is may discharge the order when it is satisfied that the order is no longer necessary to prevent the occurrence of disorder or serious nuisance(S.8). No reference is made in the Act to potential new nuisance by potential new tenants (or the previous tenant) and as such the guidance appears to suggest requirements not imposed by the legislation. 7 Safeguards, appeals and exemptions: 7.1 Both the Act and the Notes of Guidance make reference to Exemptions that can be granted by the Secretary of State; we would welcome an illustration within the notes of guidance as to how organisations can apply for such an exemption and under what circumstances they would be granted. 7.2 We are concerned that, notwithstanding existing criminal and civil constraints, there is little safeguard against abuse of the extensive powers created under the Act. Comparable legislation (e.g. the Criminal Justice and Public Order Act 1994,) created statutory offences where individuals made false statements for the purpose of securing Interim Possession Orders for the purpose of removing squatters from properties. 7.3 Similarly, individuals seeking IPOs were required to give the court undertakings relating to safeguarding the tenancy, the individuals possessions and to pay damages should the IPO be contested. No such safeguards have been put in place relating to Closure Orders and this would appear to be an essential safeguard. At present, the process detailed in the Act and the Guidance Notes is biased towards swift closure of properties rather than ensuring that other measures have been explored and that all parties have access to justice. While in a small minority of situations, such a process will be required, in other situations, such an approach would risk denying individuals time to secure legal aid to approach the courts, prepare a case and make representations. Without adequate safeguards written in to the legislation, we cannot condone such an approach, and believe that it is at odds with both the Human Rights legislation and natural justice. 8 Errors in text: We would note the following errors in the text which we feel may contribute to confusion or misinterpretation: Para 2.1: Table: Class B Drugs: no power under this act As Class B drugs prepared for injection are classed as Class A drugs, premises used for the preparation of Class B drugs for injection would fall under the scope of this Act, technically. Para 2.2: Ecstasycommonly produced in the UK in houses: simply not borne out by evidence; clandestine labs for Ecstasy production are not typically located in domestic dwellings. Para 10.2.3 in the case of buildings not occupied which have been taken over illegally Such occupation of unoccupied premises is not illegal, until and unless a court has determined otherwise. Para G.1.1 Wording related to sections 8(b) and (d) of the MDA are the wrong way round. 9 Conclusions and Recommendations: 9.1 The legislation and associated guidance is certainly a step in the right direction away from the absolute offences created by Section 8 of the Misuse of Drugs Act 1971. 9.2 However, given the far-reaching powers created by the Act, the lack of robust legal protection, and the potential for abuse of these powers, we feel that they cannot and should not be brought in to force at this time. 9.3 We believe that essential considerations, including the duration of effect of a closure notice, the housing status of individuals removed from properties by and order and the status of tenancies thus affected has not been adequately addressed. 9.4 We feel that the tone of the guidance notes has been primarily drafted in relation to crack houses, and, as the guidance should relate to the Act in all its potential uses, it should be redrafted to reflect this wider application. We find the language and tone of the document, and its repeated reference to dealers to be prejudicial and inflammatory. 9.5 The powers that the Act creates are substantial, and should be viewed as a last resort; the Guidance does not seem to place sufficient emphasis on collaboration and planning to avoid or resolve problems. Kevin Flemen KFx 21.12.03 www.ixion.demon.co.uk  {OWEDe~*yGX""##4#0$$W'^'''Q(\(()2*N*Y,,,,*1-1/1M13356t6 78W9n9v999:: ;;;2<<"=CCSDlD4EcEE9FKKLLjCJUmHnHsH u 56\]6]5\>*TK L W T U Q R H I @A{|L+,"#Hatu$%JKh^h8^8 & F ^ & F ^ & F ^ & F ^K "###4#5#$$%%M&N&((1*2*N***>,?,,,X-Y-. & F^ ^`h^h./)1*1M133394:4758566 7 788w9x9999::::^ & F h^h & F:<<!="=C>D>??0A1ACCCC1D2D)E*EEEFFFF G!GGGHHIIKKKKKKKKKL 1F. 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