Judge Lower was right not to lift the Sexual RIsk Order on John O’Neill

We must wait until 22nd September to discover exactly what District Judge Adrian Lower has in mind for John O’Neill, the York man who, despite having been acquitted of a charge of rape, is now not allowed to have sex unless he gives the police at least 24 hours notice of his intention.

Mr O’Neill has been subject to a peculiar and, as far as I know, unique interim “Sexual Risk Order” since January. At a hearing yesterday the judge announced that he would be making a final order, although in the same breath he also strongly implied that he would amend its terms, describing the notice provisions as “wholly disproportionate” and “frankly unpoliceable.”

Until some of the allegations against Mr O’Neill started to emerge I had simply assumed that the Sexual Risk Order was both absurd, and an outrageous attack on his human rights. I sympathised with the view expressed by Brendan O’Neill who thundered in January:

… there’s little funny about this case. In fact it speaks to the creeping warping of the values of both justice and liberty. It smashes together the sex-policing instinct of Big Brother in 1984 with the idea of ‘precrime’ from Philip K Dick’s Minority Report, making real the dystopian dread of a society that believes it can interfere in people’s most intimate relationships and treat individuals as criminals-in-the-making….

The Yorkshire case, and Sexual Risk Orders more broadly, demolishes the ideal of due process. If someone can be treated as a criminal, or precriminal, despite not having been convicted of a crime, then the entire, Magna Carta-derived basis of civilised law is called into question.”

Having read some of the reports – Kate Liptrot’s in the Malton Gazette and Herald and the York Press have been particularly good – I’ve changed my mind. Perhaps not for the first time, Brendan O’Neill (he probably is a relation, though no doubt a very distant one) has delivered his characteristically trenchant opinion on the basis of very little knowledge of the facts of the case and even less of the law.

The starting point is that Mr O’Neill (John, that is, not Brendan) was acquitted of rape. We don’t know the details of that allegation, but we do know that at the end of it Judge Simon Bourne-Arton QC said: “Please could you inform the authorities that although this man has been acquitted, it is my judgment that he is a very dangerous individual.” The judge’s words seem to have encouraged the North Yorkshire Police to apply for the Sexual Risk Order, although perhaps they would have done so anyway.

The evidence which has now emerged in court in support of the application is unquestionably disturbing. Mr O’Neill had a consultation with a community psychiatric nurse, Kevin Holmes. Mr Holmes (who had also given evidence at the rape trial) noted that Mr O’Neill said he had feelings of rage and violence. He had had sex with women without being sure that they had consented, and in 2010 he stopped bothering to ask them. The nurse said Mr O’Neill told him “I need them to be scared or I don’t respond.” He also noted that he has “homicidal thoughts” and his sexual tastes include “biting, choking, cutting and burning.” His GP had made similarly worrying notes when he came to consult her about a cold. “Patient thinks he is dangerous and needs to be stopped,” she wrote. She noted that he had had thought about killing his partner a lot and “choked her unconscious several times.” The doctor told the court that she was concerned for her own safety. Mr O’Neill’s answer to this is that the notes are “thematically correct” but also “largely inaccurate” and the “specifics have got lost.”

The District Judge who heard the evidence last Friday was unimpressed:

“I have found him to be a manipulative and grandstanding individual… There is a narcissistic strain to Mr O’Neill which does trouble me as to his future behaviour with others and what he may say and do to them.”

Despite Brendan O’Neill’s harrumphing, I don’t think Magna Carta has a great deal to say about what we should do in these circumstances. Here is a man revealing that he is liable to rape and choke a sexual partner to death. He can’t be imprisoned because he has not committed any crime, but if he is at liberty there is real and identifiable risk that he may choke a woman to death for the sexual thrill. It is a situation which demands careful reflection rather than swashbuckling polemic. Most women would be grateful for being made aware of this risk before accepting an invitation back to the Fulford tent where he is presently living.

Brendan O’Neill’s indignant assertion that “if someone can be treated as a criminal, or precriminal, despite not having been convicted of a crime, then the entire, Magna Carta-derived basis of civilised law is called into question,” is nonsense, even without the Magna Carta reference. There is certainly a danger, and quite a serious one, with civil orders of this sort being used to criminalise otherwise non-criminal behaviour. ASBOs, or their modern equivalents “Criminal Behaviour Orders” can be used oppressively to criminalise behaviour which is merely irritating or even – as in the case of the Naked Rambler – harmless. But a civilised system of law also has to have some means of protecting the rights of potential victims before they become actual victims. Injunctions – far more than Magna Carta – have long been used to protect potential victims from the threat of harm. Many a wronged wife (and not a few husbands too) have owed their peace of mind to Restraining Orders imposed on unconvicted ex-partners who threaten to harass them. There is nothing intrinsically uncivilised or oppressive about a law that tries to control the danger from a potentially dangerous, if unconvicted man.

To return to Mr O’Neill’s case: one possibility might have been compulsory “sectioning” under the Mental Health Act 1983 (which would incidentally have restricted his liberty a great deal more than a Sexual Risk Order). A person can be sectioned for the protection of others, but only if the strict and complex provisions of the Act are met: he would have to be suffering from a mental disorder, it would have to be appropriate for him to receive treatment in a mental hospital, and there would have to be appropriate treatment actually available. I would guess that this option has been explored and rejected; if it has not been then it probably should be.

But assuming he can’t be sectioned, what does the law say about Sexual Risk Orders?

SROs are a product of the Anti Social Crime and Policing Act 2014, which amended the Sexual Offences Act 2003 The procedure is that an applicant (normally the Chief Police Officer for the relevant area) applies to a Magistrates Court. The Court:

… may make a sexual risk order if it is satisfied that the defendant has, whether before or after the commencement of this [Part of the Act], done an act of a sexual nature as a result of which it is necessary to make such an order for the purpose of—

(a) protecting the public or any particular members of the public from harm from the defendant, or

(b) protecting children or vulnerable adults generally, or any particular children or vulnerable adults, from harm from the defendant outside the United Kingdom.”

There are quite a few points to note here.

First, there is no need for the defendant to have committed a criminal offence. All that is necessary is that he should have “done an act of a sexual nature” which makes such an order “necessary.” A defendant who has been convicted of a sexual offence is more likely to be made the subject of a “Sexual Harm Prevention Order,” discussion of which will have to wait for another day.

Secondly, it does not matter when the “act of a sexual nature” occurred; it makes no difference if it occurred yesterday or 20 years ago before the Anti Social Crime and Policing Act, or even the Sexual Offences Act 2003 were passed. Sharp-witted readers may already have asked themselves whether this breaches the principle that criminal legislation should not be retrospective, and in particular Article 7 of the European Convention on Human Rights:

ARTICLE 7

No punishment without law

No one shall be held guilty of any criminal offence on account of any act or omission which did not constitute a criminal offence under national or international law at the time when it was committed. Nor shall a heavier penalty be imposed than the one that was applicable at the time the criminal offence was committed.

The answer is that it does not, because imposing a Sexual Risk Order does not involve the defendant being held “guilty of a criminal offence.” It is a “civil” not a “criminal” order, even though the consequences of breaching it are criminal, including a maximum sentence of 5 years imprisonment.

Thirdly, the order may only be made if it is “necessary” for protecting any member of the public within the UK, or “children or vulnerable adults” outside the UK from harm. In Mr O’Neill’s case the order has been made to protect adult women in the UK.

The SRO’s predecessor under 2003 Act was called a “Risk of Sexual Harm Order” (“RSHO”). It had many similarities, including the fact that its imposition did not require a conviction, but crucially so far as Mr O’Neill’s case is concerned, it required proof of some form of sexual activity with children and could only be imposed to protect children. In other words, Mr O’Neill could not have been made the subject of a “RSHO”. The Act was amended largely because of the Report of a Committee of wise men and women, under the Chairmanship of Hugh Davies QC, who recommended that the regime should be tightened insofar as it related to the protection of children, although it specifically did “not advocate reform so far as adult victims are concerned” (although this was perhaps because the focus of the Committee was almost entirely on the protection of children).

Fourthly, although the Act does not expressly say so, the applicant for a SRO almost certainly does not need to prove “beyond reasonable doubt” that such an order is necessary.1 In other words, it is in some ways easier to obtain a Sexual Risk Order than it is to obtain a criminal conviction, although the higher courts have repeatedly urged that great care should be taken before imposing orders of this type.

Fifthly, although it may be obvious, the precise terms of a SRO are for the Court to decide. Judge Lower has said that the terms of the interim order – I assume that he was referring to the 24 hour notice of sexual intent – is both “unpoliceable” and “disproportionate.” I’m not so sure about “disproportionate,” but it does seem somewhat unrealistic to think that if Mr O’Neill had choking, burning or homicide in mind, he would be dissuaded by the fact that this might also breach his SRO.

We must wait and see what order Judge Lower comes up with. He has reserved his judgment and obviously recognises that the decision is far from straightforward. It seems very likely that whatever order he imposes will be appealed, certainly to the Crown Court and very probably to the Administrative Court which will be able to give full consideration to the very difficult issues that it raises. I don’t know what the right answer is but I think Judge Lower is probably thinking along the right lines and Brendan O’Neill is wrong.

One other footnote to the case: Mr O’Neill was legally unrepresented at the hearing of this application.  It may be that that was his choice.  If, however, he was refused legal aid that was a disgraceful decision. If ever there was a case which demanded skilful and knowledgeable legal representation on both sides, this was it.

1See DPP v Bulmer [2015] EWHC 2323 (Admin) (DC) a decision on Criminal Behaviour Orders.

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Author: Matthew

I have been a barrister for over 25 years, specialising in crime. You may also have come across some of my articles I have written on legal issues for The Times, Standpoint, Daily Telegraph or Criminal Law & Justice Weekly

31 thoughts on “Judge Lower was right not to lift the Sexual RIsk Order on John O’Neill”

  1. Interesting. So much for the 50 Shades of Grey mentality.

    I’m interested in this as effects those who go outside of the UK. How it can be policed elsewhere? Would an alleged breach enable the courts/Government to have the individual extradited back to Britain?

    1. “So much for the 50 Shades of Grey mentality. ”

      Not entirely seeing the relevance of this comment. I’m not aware of any evidence whatever that BDSM afficionados are any more likely to commit offences as compared to the general (‘vanilla’) population – all responsible ones are fully aware of the long tried and tested rule of thumb: ‘Safe, Sane and Consensual’.

      Recently in the UK, new legislation for which as far as I can see, there was no public demand for, was introduced, effectively banning the production of certain types of ‘kink’ adult material in the UK. I speak of the 2014 ‘ATVOD’ regulations.

      A brave lawyer named Myles Jackman defends cases brought under ‘sexual liberties and obscenity law’:

      http://www.independent.co.uk/voices/comment/the-uks-sexist-new-pornography-restrictions-arent-just-an-act-of-state-censorship-but-could-be-the-9903830.html

      An equally brave feminist BDSM blogger, Pandora Blake, who was the first to be targeted under the 2014 ATVOD legislation, recently won the right to reinstate her website and continue to have it registered in the UK:

      http://www.independent.co.uk/life-style/love-sex/feminist-porn-director-pandora-blake-wins-right-to-reinstate-fetish-website-in-landmark-ruling-anti-a7067006.html

  2. If all the sexual references were removed from this article, could this “manipulative and grandstanding individual… pre-criminal” be subject to an order requiring him to notify the police before engaging in any social intercourse?

    In case he decides to claim he choked, or even THOUGHT about killing, his new friends?!

    If not, why not?!

    And is this right or wrong?!

    Incidentally, should I be subjected to a similar order?

    After all, I can’t be “sure” I’ve EVER had consent for intercourse. I’ve certainly never had formal, or even informal, documented permission to proceed, and I can’t recall ever having asked permission, never mind received verbal consent!

    But, then again, I’m a dinosaur from the wrong side of history when going clubbing involved animal skins, short, stout, heavy lumps of wood, long hair, and caves!

    1. No, and that’s why we need judges, to ensure (as Judge Lower is trying to do) that these & similar orders are reasonable & proportionate. Law is very rarely a matter of cold logic.

      1. My point was, if such an order can’t be applied for any other kind of non crime, which you appear to be confirming is the case, why does one apply to sex crimes?!

        The point isn’t, if we are going to apply them to sex crimes (only), we need to apply them carefully:

        It’s, if we aren’t going to apply it to any other kind of crime, why are we going to apply it, however carefully, to sex crimes!

    2. If a heroin addict were to be acquitted of a theft or burglary charge, he/she is still a heroin addict and so likely to steal in the future to fund their habit – unless perhaps treatment is available. I do not see how we can generate a new class of people, who are not convicted, but are subject to orders because they are deemed nasty or risky in general. Of course, it is different if there is a particular potential victim.
      Matthew makes many a fair point, but so far this seems like a fudge and like Matthew, I await clarity. Is the man prevented from overseas travel? If not, are we not simply exporting a problem to another jurisdiction? For once an autumnal chill takes hold, living in a UK wood will seem unattractive compared to (perhaps an equally feral) life in warmer climes, especially that the man is identified and completely unemployable in the UK.

      1. Iknow this isn’t much of an answer to your interesting comment Mark, but I’m pretty sure he’s not banned from overseas travel. He seems pretty much confined to York, in fact.

  3. Suggest readers should really have a closer look at the report from the committee chaired by Hugh Davies QC and which has a link to it above. This is a very weak document indeed.

    The Davies Review is very anecdotal and lacking in real research as well as being written with an emphasis on everything being ‘common sense’ and ‘self-evident’; the term ‘self-evident’ crops up at regular intervals and presumable means the authors do not have to explain anything (see paragraphs 2.4; 4.19i; 4.40; 6.6.2; 11.2.4 and 11.2.5).

    The following are further examples from the report of its lack of rigour:

    … preventable sexual abuse of children is occurring on a significant (if unquantifiable) scale (para.2.1)

    No informed party would dispute either (i) that the sexual exploitation of children is an endemic problem internationally; or (ii) that there is a combination of factors that is promoting an expansion, rather than reduction, in such abuse being conducted extra-territorially by UK (and other) Nationals (para.3.1)

    Whilst there is a wealth of literature and data available (originating from international organisations such as United Nations; individual countries; and the NGO community) the intrinsic nature of the offending (covert; much under-reported; in jurisdictions with highly variable systems of policing and criminal enforcement and/or different cultural norms as to child protection) is such that hard quantitative data is, and will remain, elusive (para3.2).

    It is, and remains, a well-documented problem. The scale of it is intrinsically difficult to quantify but on any view the figures are both staggering and appalling (para. 3.10).

    None of this documentation is actually cited. Elsewhere statistics (or the lack of them) are treated in cavalier fashion:

    It begs the obvious question: what proportion of this offending could have been prevented by a different prevention order regime? The fact the data is so intrinsically unsatisfactory does not avoid the inevitable conclusions (i) that it is a high proportion (in any event, in this context, any proportion is a significant proportion); and (ii) that the figures outlined are likely to represent a very small fraction of the whole (para.4.43)

    A survey was conducted of individual forces across the UK. Not every such force responded, which may of itself tend to illustrate the lack of a specialist capacity in these forces in terms of civil prevention orders. We are satisfied that the responses we received provide a sufficient empirical basis to draw wider conclusions (para 1.3).

    The numbers – inadequate as they are in terms of data collection – do not lie (para.8.3.1).

    The Review does not tell us how many forces responded or on what basis they drew their ‘satisfaction’ that their responses provided them with ‘a sufficient empirical base’. We do know that if they disagreed with a response they were quite capable of just dismissing it:

    a significant number of local forces were resistant to a national, and nationally resourced, police unit directed at international offending against children on the purported basis that it would “remove developmental opportunities” from local forces. We reject this approach as insular and myopic.

    The whole tenor of the report is that this is all about protecting children and therefore it is mostly ‘self-evident’ what has to be done. Simplify the means to get new orders on sex offenders:

    The simplification we propose removes arbitrary pre-requisites that have no logic within the reality of the criminality involved (Davies Report para12.2.2)

    Some would say these ‘arbitrary’ pre-requisites represent earlier attempts for more caution, a degree of checks and balances and reasoned debate in the making of these orders.

    Elsewhere the Review sloppily picks up on the spelling of ‘pedophiles’ presumably not realising they are taking a quote from an American journal where the spelling is correct (para.3.6), and makes reference to the Criminal Records Bureau presumably not realising it had been replaced a year earlier by the Disclosure and Barring Service (para3.16). On the sex offender register they appear not to know that police cautions have also lead to registration from the start of the register on 1 September 1997 (para.4.4).

    The working party has subsequently often been referred to as ‘independent’. In the House of Commons Nicola Blackwood MP described the Review as ‘written independently by Hugh Davies QC and a team of experts’ (Hansard House of Commons 14 October 2013 col.482 emphasis added). In a later interview Davies himself called the Review ‘a well-researched (multi-agency) independent report’ (Hugh Davies cited on PACE website http://www.paceuk.info/changes-sexual-risk-order-system-opportunity-empower-parents-part-1/ accessed 26 October 2015).

    But just how independent is this report? The working party is clearly heavily biased toward a police view of civil orders. Of its six members four have policing backgrounds (see report Appendix 1) and the chair has done work for ACPO. We might also question the description of the Review as ‘multi-agency’, when there are no magistrates, probation officers, social workers, doctors or health visitors on the working party.

  4. And if he gives notice that he intends to have intercourse with June, surname unknown, but he thinks she’ll be up for it next time they mett? What are the police going to do about it? They can’t arrest him because he will be compliant with the terms of the order!

    Similarly if he tells the police that he is going to Grance on the 12th of the month; and he will be touring so he cannot give them his address. That too will constitute compliance with the order.

    It’s all a well-intentioned bridge too far.

    As for legal aid: no such order should be made unless the subject of it has legal aid or has had the chance to apply: and if applied for it should be granted regardless of means and merits.

  5. It is a “civil” not a “criminal” order, even though the consequences of breaching it are criminal

    Hmm. Remember what happened to ASBOs after the McCann ruling!

    Thanks for a useful post (always nice to see Brendan O’Neill confuted). I’ve been dismayed by the standard of reporting on this case, even from the BBC; we’ve seen a weird combination of prurience, complaisance as to the civil liberties issues (B. O’Neill does have half a point there) and carelessness as to the details. Every story I’ve seen on this has headlined it as if if the order had been upheld, rather than stressing that the existing order only applies pro tem.

    The point about the mental health system having to have the capacity to deal with a potential offender like this in order for him to be sectioned is interesting, and may help explain why some people may be thinking “the police and the courts never poked their noses in like this in my day”. In my day there was an estate of big, Victorian-era psychiatric hospital dotted around the outskirts of London (and probably other cities); if any man confided in his doctor that he was having fantasies and urges like O’Neill’s, a bed could be made up for him for the next night. All long gone now, and the ‘care in the community’ infrastructure that purported to replace it isn’t looking too clever at the moment either.

        1. Also on Phil’s point, the preponderance of ‘big, Victorian-era psychiatric hospitals’ dotted around the landscape was, if anything, higher in Ireland than in Britain.

          I have even read statistics indicating that the rate of committal to ‘lunatic asylums’ was at one point higher in the Republic of Ireland, on a per capita basis, than in the former Soviet Union.

  6. “Having read some of the reports – Kate Liptrot’s in the Malton Gazette and Herald and the York Press have been particularly good – I’ve changed my mind.”

    Just got round to reading those “reports” and the more I read the more disturbing I find this case.

    The only significant points I’ve spotted are that accused’s GP. community psychiatric nurse and the judge all “felt” the accused was dangerous in their “judgement”.

    “I have found him to be a manipulative and grandstanding individual… There is a narcissistic strain…”.

    How is he “revealing that he is liable to rape and choke a sexual partner to death”, surely he must be grandstanding?

    Where are the guilty charges for these crimes if he’s committed them? If he hasn’t then he can’t actually know he’s “liable” to do any such thing, and neither can anyone else (or is he an extremely manipulative and narcissistically grandstanding sexual serial killer who has so far managed to escape detection and is just toying with the police?!)? Is his claim enough to criminalise him?!

    Where is the “real and identifiable risk that he may choke a woman to death for the sexual thrill…. if he is at liberty”?

    Have I missed something, or is the only “evidence” a failed rape case and some “manipulative and grandstanding” narcissism?

    While “Many [how many?] a wronged wife have owed their peace of mind to Restraining Orders imposed on unconvicted ex-partners who threaten to harass them… (and not a few husbands too)” how many husbands have been threatened, wronged, harassed, and accused of everything from harassment, through assault, to rape and/or paedophilia by their exes?!

    And what, exactly, is the “act” in “… may make a sexual risk order if it is satisfied that the defendant has, whether before or after the commencement of this [Part of the Act], done an act of a sexual nature”? Is it the act he was found innocent of? Or is it his “narcissistic…..grandstanding” to his GP and community psychiatric nurse, whose notes were referred to in the application for the order?

    And while “The evidence which has now emerged in court in support of the application is unquestionably disturbing”, was it ever questioned? The police appear to have been quoting notes, so, unquestionably, the GP and nurse weren’t cross-examined.

    According to those local press reports “Confirming that the order should be made permanent, Judge Lower said there were inconsistencies in Mr O’Neill’s evidence”.

    “He said: ‘I have become increasingly concerned with Mr O’Neill’s evidence’. ‘I have found him to be a manipulative and grandstanding individual… There is a narcissistic strain to Mr O’Neill which does trouble me as to his future behaviour with others and what he may say and do to them’……..”

    “Representing himself in court, Mr O’Neill said the notes made by the health professionals were largely inaccurate and said they were ‘thematically correct’ but the ‘specifics have got lost’.”

    “Judge Lower said he disagreed the notes were inaccurate.”

    So, basically a judge believed him to be unbeleivable, but believed what he’s told the medics, but not his retraction!

    And how can it be “a ‘civil’ not a ‘criminal’ order, even though the consequences of breaching it are criminal, including a maximum sentence of 5 years imprisonment”?

  7. I’m pretty shocked you think this order is OK. Someone expressing certain thoughts to psychiatrists/GPs should be PRIVATE. If you allow the word of psychiatrists/GPs to be used in a court of law then people will simply stop going to psychiatrists/GPs for help. So instead, they’ll just go crazy in their own head and then maybe commit a terrorist attack.

    Also important here is the AGENDA at play. Sexual Risk Orders were created by feminists. The idea is to make men afraid to form relationships with women by creating a puritanical anti-sex climate where any man knows he can be arbitrarily arrested at the will of the feminist police state. These sexual risk orders can and will be used on other men for a variety of reasons. Heck, the previous sexual harm prevention orders have already been used to great extent and entirely wrongly – yet sexual risk orders are broader! For example, Jeremy Forrest, the man who committed a completely victimless crime of running off with a teenage girl to France was handed a sexual harm prevention order to stop him from EVER having unsupervised access to children or working with them. That was entirely WRONG and the sadist knew it. Personally I think the judge who made that sexual harm prevention order should be handed the death penalty.

        1. Imagine the 21 in your username is your age, though you’ve given me a chuckle. Terrorists AND feminists. Spoilt for choice.

    1. Another point is how and why he could be arrested in and extradited from France when nothing he had done was against the law.

      And even more to the point, if the sexes had been reversed, would we have asked for the arrest and return of a female teacher (and would the French have complied?!)?!

    2. Have you been prevented from forming relationships with women? If so who by? (It deosn’t count if the woman with whom you were seeking to form a relationship said no… )

  8. “Perhaps not for the first time, Brendan O’Neill (he probably is a relation, though no doubt a very distant one)”

    ^ Unlikely even a distant one, O’Neill is about as common a surname as Ireland as Smith in England or Jones in Wales.

    To be fair to O’Neill (Brendan, that is) I doubt if he would have been influenced either way by the co-incidence of surnames. Us Irish are a rather fractious race, as you might have heard.

    “has delivered his characteristically trenchant opinion on the basis of very little knowledge of the facts of the case and even less of the law. ”

    ^ Er, yeah, agreed.

  9. As someone who has been branded not only dangerous but a terrorist (by Jeremy Corbyn in Parliament) I have to say so what?

    If these orders are used to forbid a man from approaching a particular individual or a convicted paedophile from being alone with kids, fair enough, but this is garbage.

  10. I have a question as a law student I have chosen this article as part of my portfolio. In the government guidelines
    https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/442151/2015-07-03_FINAL_Guidance_Part_2_SOA_2003.pdf
    It says:
    “An order, whether full, or interim, can only contain restrictions on the behaviour of the defendant, i.e. it can only require them not to do something. It cannot require them to comply with conditions requiring positive action.”
    Is making a phone call before having sex, not a positive action?

    1. hi
      i think you will find that the order restrictions are worded so as to comply with the law.so like my order instead of stating i must wear a gps tag,not allowed under the rules as that implies a positive action,it stated i must not leave home without a tag fitted. subtle difference but makes the restriction legal.

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