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Prout de Jure in 2013

As 2013 draws to a close; here are the top ten blog posts published on this blog during 2013:

1. ECHR, International Law and Abu Qatada (published: 10 March 2013)
2. Police Scotland and Freedom of Information (published: 25 March 2013)
3. Changes to FOI in Scotland from 31 May 2013 (published: 23 May 2013)
4. Changes to FOI in Scotland approved (published: 17 January 2013)
5. Prison, prisoners and Prison Conditions (published: 3 February 2013)
6. Is it the case that the Complainer clearly lied? (published: 11 September 2013)
7. ‘Thinking time’ and Freedom of Information (published: 25 January 2013)
8. Abolition of corroboration: where is the case? (published: 14 November 2013)
9. Transparency in the Reporting of FOI requests (published: 19 August 2013)
10. FOI and requests for documents (published: 13 April 2013)

A mixed bunch of articles there.  In early 2014 (January 13th to be precise) this blog will enter into its seventh year (!) and I look forward to putting out onto the internet more of my thoughts and opinions on whatever takes my fancy.  Thanks to all who come and read this blog (although I don’t know why), and have done over the years.

Wishing you all the very best for 2014!

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Some tweeters to follow in 2013

I have had the great pleasure of following so many amazing and interesting people on Twitter and below are some of my recommendations of who you should follow in 2013 if you don’t already follow them:

The Prison Lawyer (@theprisonlawyer) – a regular tweeter who more often than not has interesting things to say.  He tweets about a wide range of things and is passionate about justice.  He has taken to the internet this year and been to ‘Twitter Jail’ over his support for #protestforjustice.  His tweets are informative.  He took a few small steps into the world of blogging in 2012 and I hope we’ll see more blogs from him in 2013!

Adam Wagner (@Adamwagner1) – a tweeting and blogging Barrister with a focus on Human Rights.  Tweets are always interesting and informative.  He’s very good ate challenging the human rights myths told by the mainstream media.  If you want a true understanding of Human Rights in the UK then Adam’s definitely a good person to follow.

Paul Gibbons (@FOIManUK) – Paul works for a University dealing with Freedom of Information.  His blogs and tweets from the practitioner’s point of view are interesting and informative.  He has done a lot to help try

Claire Mitchell (@madisonmitchel1) – tweeting Scottish Advocate who specialises in Criminal law.  Interesting and insightful tweets

The Firm (@TheFirmOnline) – Account operated by Steven Raeburn, Editor of the Firm Magazine and Social Media trainer.  An excellent sources for news about what is happening in the world of law.  The Firm is always the first place I check for the latest legal news

The Custody Sergeant (@TheCustodySgt) – An anonymous custody sergeant working somewhere in England who tweets and blogs about policing.  His tweets and blogs often present an interesting and informative alternative to what is presented in the news.  It’s clear from his tweets and blogs that he is passionate about policing and has a great deal of compassion.

Love and Garbage (@loveandgarbage) – interesting and often amusing tweets and blogs.  He is also an expert on the pronunciation of scone.

Tina McGreevy (@tinamcgreevy) – always interesting tweets.  Passionate about justice and very vocal on twitter about #Protestforjustice

Waqqas Ashraf (@DefenceAgentWA) – first year trainee solicitor in Scotland.  Passionate about justice and another active and vocal person in the #protestforjustice.  Great guy to tweet.

Jon Baines (@bainesy1969) – Another FOI and Data Protection tweeter.  He writes great blogs on information rights and vocal about the protection of FOI rights.

Prison Chaplain (@hmp_chaplain) – Interesting tweets about life on the inside from the point of view of a prison chaplain.  They’re important people inside our prisons and the Prison Chaplain’s tweets often get me thinking about things that I might not otherwise have considered.

Ollie (@dietjustice) – blogs and tweets about law, policing and politics.  His tweets and blogs are interesting and informative and can get a good discussion going.

Brian Inkster (@BrianInkster) – another Scottish legal tweeter.  He was the first Scottish solicitor to use twitter.  Tweets and blogs about interesting things and is a decent guy.  Uses twitter and social media in innovative ways.  Can’t wait to see what he and his firm @Inksters will come up with in 2013!

Tim Turner (@tim2040) – another FOI and DPA tweeter who is worth following if you have an interest in FOI or Data Protection.  He knows his stuff!

Deborah Dillon (@infogovgeek) – A Scottish information governance tweeter.  I’ve enjoyed tweeting her this year.

There are many more tweeters who I have enjoyed tweeting and/or reading their tweets during 2012.  If I listed them all here it would be far too long so these are just some of my favourites!  Watch out for my first #ff of 2013 where even more of my favourite tweeters will get a mention.

That’s all from me on this blog for 2012 and I’ll see you all in 2013 with more blogs on law and politics in the UK!

Legal System, Random

Nonsensical codswallop

There is undoubtedly a growing reliance by some on what can only be described as codswallop in the defence of civil and criminal proceedings as well as in their pursuance of such proceedings against individuals and the state.  I am, of course, referring to the growing Freemen-on-the-Land (FOTL) movement and other similar movements.  Their dangerous pseudolegal arguments are resulting in serious harm to people who are quite often vulnerable.

A lot has been written about the movement on blogs, particularly after the Guardian published one of their incredibly dangerous theories in its “Comment is free” section.  The reaction from lawyers who commented was, unsurprisingly, unanimous in its conclusions that it was dangerous and legally inaccurate information.  It’s not unsurprising because, as a Freeman would suggest, they are part of the fraud that is the system; but rather it is unsurprising because the simple fact is that the arguments deployed by these people are nonsense.

I have been aware of this movement for a couple of years now and have had a great deal of enjoyment listening to the rubbish that their “experts” expel as fact.  I, and others, may laugh at this nonsense, but the truth is that many people up and down the country are being taken in by this fiction and it is having a considerable negative effect on their life.  When one remembers this the laughter soon dries up and it is replaced with a sense of anger that these “experts” are causing so much damage to vulnerable people in our society.

There are many different groups which adhere to the principles of the FOTL movement which go by various different names.  However, in essence all the groups have one major shared characteristic: they all argue that he state (and its instruments) have no authority over them.  The most common things that I have observed about these movements is that they will often adopt a split personality which argues that they (a human-being) are an agent or representative of a legal fiction (a corporation) which shares the same name as they do.  They place arbitrary distinctions between their name written in lower-case and their name written in upper-case.  Associate Chief Justice J.D. Rooke (Court of Queen’s Bench of Alberta, Canada) has issued lengthy judgment dealing with the freeman nonsense that he sees in his court on a fairly regular basis.  The Respondent in the case in question deployed some of the FOTL arguments (or OPCA arguments as Associate Chief Justice Rooke styles them).

The judgment referred to above is lengthy, but is sets out in great detail the various types of arguments deployed by FOTL types and refutes them (using Canadian law, naturally).  However, his excellent explanations of the various types of arguments deployed are an excellent resource for lawyers and judges the world over who are increasingly coming up against this codswallop.  From there it doesn’t take too much to apply the law of England and Wales, Scotland, Australia or wherever necessary to refute the arguments being advanced.

There is, however, a much more serious issue and that is the effect that these things have on people’s lives.  The “experts” from these movements will tell you that it works.  However, it is clear that it does not.  There are examples of where people have deployed these arguments and their desired outcome has been the result.  However, that is not as a result of their arguments (as much as their “experts” might suggest that it is).  Debt recovery is an area where these arguments are frequently deployed and are where a number of “success” stories come from.  However, the more logical (and more likely) explanation for these apparent successes is that the company in question looks at the case and decides that to try and recover the debt through the courts is going to be too costly and it’s probably better just to take the “hit”.  FOTL types have argued in the past that the creditor knows that what they are doing is illegal and they back down because the debtor knows and understands “the truth”.

I have yet to come across a single reported case which shows a court accepting a FOTL argument.  Equally, I cannot find any reported cases in Scotland or England where the arguments have been rejected (although I am sure there are plenty in reality).  However, Associate Chief justice Rooke provides a considerable number of reported cases in Canada where the arguments of the FOTL types have been rejected by the Courts.

The circular nature of the FOTL type arguments is such that even if there was an abundance of reported authority rejected their arguments it would do little to stop the courts facing such arguments.  The FOTL types will simply put this down to part of the big fraud that they think they’ve uncovered and are fighting against.

The real sadness of all this is that vulnerable people in a desperate situation who are willing to try anything to get out of the situation they find themselves in are being duped and are suffering as a result of this nonsense.

Links
The law is not the enemy of protest but an essential tool of impartiality, Carl Gardner
We are the change: welfare, education and law at the Occupy camp, Comment is Free
The freeman-on-the-land strategy is no magic bullet for debt problems, LegalBizzle
Occupy Woo Street, LegalBizzle
Comment is free, but woo is sacred, LegalBizzle
Further adventures in woo, LegalBizzle
Meads v Meads, 2012 ABQB 571 (Associate Cheif Justice Rooke’s judgment)

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What happened in 2011?

As we enter the final week of 2011 it’s a time for reflection and to look back on what’s happened over the last 12 months.  There’s certainly been a lot to talk about and some interesting blogging opportunities were created as a result.

In January the media were still somewhat pre-occupied with Christopher Jeffries who had been arrested on suspicion of murdering Joanna Yates.  Of course, later another man was convicted for that murder that took place in December 2010.  However, the treatment of Jeffries by the media raised some important questions over the way in which the media reported ongoing police investigations and their obligations under Contempt of Court laws.

January also saw the first former Member of Parliament to be sentenced over the 20009 expenses scandal which had been trundelling along causing huge damage to the reputation of Parliament and many who sat within it.  The first former MP to be sentenced was David Chaytor, a former Labour MP, who was given an 18 months custodial sentence for his part in the expenses scandal.

January also brought us the end of the Tommy Sheridan Perjury saga.  This had been running since 2006 when Tommy Sheridan, a former MSP, won a defamation action against the News of the World at the Court of Session.  It later transpired that he had perjured himself during that trial and having been convicted in December by a jury at the High Court in Glasgow following the longest ever perjury trial in the history of Scots law, Sheridan was sentenced to 3 years in custody.

February saw an impassioned debate in the House of Commons on the issue of Prisoners’ votes.  This issue has been brushed aside for a number of years and follows the decision in the European Court of Human Rights in the Hirst case.  The House of Commons overwhelmingly rejected giving votes to convicted prisoners.  However, with the Hirst judgment from the European Court and pressure from the Council of Europe 2012 could see legislation extending the franchise to some prisoners being brought forward.  In any event, the current Government will need to deal with it before the demit office in 2015.

In March the outgoing Lord Advocate, Dame Elish Angiolini QC, put on record her thoughts on the requirement for Corroboration in rape cases.  Dame Elish’s argument centred on the fact that, in her view, the Corroboration requirement in rape cases could be open to challenge on the grounds that it breaches the victim’s rights under the European Convention on Human Rights.

In April Lord Carloway issued his consultative document on criminal procedure and evidence in Scots law.  Lord Carloway was asked to conduct the review by Cabinet Secretary for Justice, Kenny MacAskill MSP, in November 2010 following the October 2010 UK Supreme Court decision in the Cadder case.  The decision caused chaos in Scotland as the UK Supreme Court held that the practice in Scotland of allowing the police to detain someone and question them for a period of up to six hours without access to a Solicitor was a breach of the suspect’s Article 6 rights.

May was quite a busy month in terms of blogging on this site.  The verdict of the jury at the Inquest into the death of Ian Tomlinson at the 2009 London G20 protests was that Mr Tomlinson had been unlawfully killed by PC Simon Harwood.  Some people in the Police were not too happy with this verdict and appeared to be of the view that they should be beyond challenge because taking decisions in these situations was difficult.  Not something that I agreed with and I made that clear when I wrote about the Inquest’s verdict.

On Thursday 5 May 2011 Scotland went to the polls to elect the fourth session of the Scottish Parliament.  The result of that election was something that many thought to be quite impossible: a single party securing an overall majority in the Scottish Parliament.  The SNP became the first party to secure an overall majority in Parliament.  Following that result came analysis of what it now meant for the SNP and also an examination of what happened to the Scottish Labour Party in that election as they had lost a number of seats in their traditional Glasgow heartland.

May also saw Sky News beginning to show live streaming of cases before the UK Supreme Court on the Sky News website, this represented a big milestone in legal history.  The UK Supreme Court is the first UK Court to have its proceedings routinely filmed and broadcast live.  Other UK Courts are likely to follow the UK Supreme Court’s lead and we could see cases routinely being shown on TV in the years to come.

By the End of May the Privacy debate was well and truly underway as Super-injunctions and anonymised injunctions came in for sustained attack and criticism.  One of the big cases that was involved was of the footballer known only as CTB who was widely known and named frequently on Twitter but who could not (and indeed still cannot) be named in the traditional press.  The UK Parliament began looking at this issue and the usual desperately poor reporting of legal matters confused the debate with all injunctions quickly becoming known as, quite incorrectly, super-injunctions.

My look at Super-injunctions on this website got interrupted by the outrageous attacks made by Alex Salmond and Kenny MacAskill, no doubt bolstered by their recent historic electoral success, against the UK Supreme Court and its involvement in Scottish criminal cases.  Some of the comments made by Salmond and MacAskill were deeply personal and highly inappropriate for senior Government officials to be making about the Judiciary.

Finally May saw the new SNP Government publish its first piece of proposed legislation.  This was the controversial anti-sectarian Bill that would later pass into law with almost no meaningful changes having been made to it.

June brought the sad news of the death of Lord Rodger, one of Scotland’s two justices on the UK Supreme Court.  Lord Rodger’s death was a big loss for that Court and for the Scottish legal profession.

In July the Crown Office instructed Strathclyde Police to carry out an investigation into phone-hacking in Scotland.  This followed revelations that phone-hacking, once thought to have been confined only to the News of the World might have been happening at its Scottish edition.  The Crown Office instructed Strathclyde Police to look at four things while it conducted this investigation including police corruption in Scotland and perjury allegations arising out of the trial of Tommy Sheridan for Perjury the previous year.

July also saw the last ever edition of the News of the World.  The paper ceased to be published following the revelations that illegal and unethical practices were not confined to a rogue few but were commonplace at the newspaper.

In August the Metropolitan Police shot and Killed Mark Duggan and what followed was days of mass public disorder, violence and looting in towns and cities around England.  Courts sat all night in the days that followed the riots and soon people were beginning to question the sentences being handed won by the Courts.  People who had never before been convicted of a crime or had come to the attention of the police were being sentenced to lengthy period of custody for low values thefts carried out during the disorder.  Most of the sentences were later upheld by the Court of Appeal.

October and November saw the debate around the SNP’s anti-sectarian Bill intensify but it was becoming clear that the SNP were not for dropping the Bill.  Minor revisions were eventually made to the Bill, but the Bill largely remained in its original format and the huge number of criticisms levelled against the Bill were left unaddressed as the Bill passed at Stage 3.  It was the first example of the SNP using its overall majority to force through poor legislation.

In November Lord Justice Leveson began his inquiry into the Culture, Ethics and Practice of the Media.  Lord Justice Leveson was appointed by the Prime Minister in July to conduct an inquiry and to make recommendations in light of the wide-scale corrupt and illegal practices uncovered at the News of the World and which are also considered to extend beyond the News of the World into other tabloid newspapers.

In December it was announced that Lord Reed, an inner-house judge of the Court of Session, had been appointed as a Justice of the Supreme Court.  His appointment filled the vacancy left by the passing of Lord Rodger earlier in the year.

So, that’s a quick round-up of some of what has happened in 2011 in the UK legal and political world.  Much, much more has happened over the course of 2011.  What were your highlights of 2011?

Random

ScotRail fares increase by 6%

ScotRail have announced that regulated fares will increase by 6% from January 2012.  Currently a one month season ticket between Glasgow Queen Street and Edinburgh Waverly would set a person back £306.10.  From January this will rise to £324.50 each month.

At a time when salaries are being frozen or cut and other household expenses such as electricity and gas and food are increasing this represents a further pressure on already tight household expenses.  ScotRail argues that this price rise will help them to “continue to invest in service improvements while ensuring that rail travel remains value for money.”

This will not be welcomed by most regular users of the ScotRail network who will see it as an addition expense which they can probably ill afford in the current economic climate.

When asked about people feeling as though they were being priced off the rail network in Scotland ScotRail had nothing further to add.

Criminal Justice, Criminal Law, English Law, Legal System, Random, Scots Law

Life Sentences

There is often a lot of criticism of the life sentence system in the UK in that it doesn’t mean life.  The way in which these sentences are reported is not conducive to helping people to understand the sentence and that can damage public confidence in the system.  When a member of the public reads in the newspaper or hears about a life sentence on the TV or radio they will often hear phrases like “must serve 16 years”.  I’ve often heard people talk about how the latest big murder case to hit the news the accused is only handed a sentence of 18 years (as an example).

The problem does not lie with the Judges, in my view.  The sentencing judge spells out the sentence in quite explicit terms to the accused and to anyone else who happens to be in the court room at the time sentence is passed.  The following is an extract from a published sentencing statement by Lord Turnbull in the case of HM Advocate v William David McLean:

“I must stress though that this is not the sentence. Given your record you may well never be released at all. That question will be for the parole board. The sentence of the Court is that you should be imprisoned for life”.

Sentencing judges are required to set what is known as the “punishment part” of the sentence.  Essentially this means that this is the minimum period of time that the accused must serve in prison before being eligible for consideration for release on life licence.  In the above noted case this tariff was 17 years.

Is it the case that the prisoner is simply released after this period has expired? Well, the impression I get from people that I speak to is that the public believe that this is the case.  In a recent Freedom of Information request made to the Scottish Prison Service I discovered that in Scotland there are currently 191 life sentenced prisoners currently being detained in custody beyond the punishment part of their sentence.  None of these 191 “lifers” has been released by the parole board on licence since their punishment part had expired.  Clearly the Parole Board are of the view that these 191 prisoners still pose a danger to the public and are not suitable for release on licence.

Under an almost exactly similar Freedom of Information request to the Ministry of Justice I was informed that on 17 November 2010 (the date the latest figures were available for) there were 7,656 life sentence prisoners in custody.  Of these, 2,874 had passed their minimum tariff date.  Again, recalled prisoners are excluded.  Once again, it would seem that the Parole Board is not very quick in releasing people serving a life sentence who have served their minimum tariff.  These 2,874 people clearly, in the eyes of the Parole Board, still represent a danger to the public.

There is the existence of whole life tariffs in which a offender knows from the day they are sentenced that they will never be released from prison and with those serving life sentences with minimum tariff periods there is the very real possibility that they will spend the rest of their life in prison.  I am a firm believer in that everyone deserves a second chance and that the vast majority of people can be rehabilitated (the ability to rehabilitate an offender largely comes down to the offenders willingness of the offender to be rehabilitated).  Not every person who commits a murder will forever more be a danger to the public.  Take, for instance, your man or woman who kills their partner after suffering years of domestic abuse.  Often such cases will be prosecuted as murder as the killing does not occur alongside the abuse they have been suffering.  These individuals do not deserve to spend the rest of their lives in prison, but as they have been convicted of murder the only sentence available to the Court is life imprisonment.

The justice system, especially sentencing, cannot be based upon a one size fits all approach.  The system does have its flaws, but let’s be clear on one thing, the minimum tariff imposed in court on a person sentenced to life is rarely what they serve before being released, and often it is much longer.  The Parole Board are clearly doing their job.

Random

UK Supreme Court Live!

Today Sky News began a live stream on their website of proceedings before the Supreme Court.  For the first time in British legal history court proceedings are being broadcast live to the wider public.  The UK has a long history of public justice by having its courts open to the public in all but the most sensitive of matters.  One would assume that live streams will not take place in matters where the court would be closed to the public because of matters of national security or where other sensitive matters are taking place.

I was able to watch about an hour of today’s proceedings and it didn’t appear that the fact the proceedings were being streamed on the internet live got in the way of the normal business of the court.  What I witnessed was counsel as I would expect to see them in any other court, the Supreme Court judges acting in the way one would expect to see judges act.  They seemed oblivious to the fact the proceedings were being streamed live – they were far too engrossed in section 83(2)(b) of the Finance Act 1989 to be worried about being streamed around the world on the internet.

One does wonder though just who will venture onto the Sky News website to watch the proceedings.  One wouldn’t expect to see a particularly large rush of members of the public to the website and as such the most likely audience will be journalists, law students, lawyers and academics – people who one would generally expect to see sitting on the public benches in court.

This is an exciting development in the UK’s justice system and it will be interesting to see how it develops.  Concerns will undoubtedly remain for sometime as to whether things that ought not to be broadcast get streamed live to the world and one would expect the court to be scrutinising carefully what is getting broadcast to ensure that there are no issues around contempt of court etc.  With no witnesses appearing in the Supreme Court issues that face the lower courts in relation to broadcasting live do not exist.  It will be interesting to observe how potentially sensitive matters in Criminal Appeals and Devolution minutes arise, especially when this requires the naming of witnesses as part of the case before the Supreme Court.

It’s a welcome move, but it is far too early to decide whether it has been one which enhances justice or hinders it; only time will allow an answer to that to be determined.

Legal System, Random

Justice on BBC Four

BBC Four broadcast an excellent and really quite fascinating documentary yesterday evening on the United Kingdom Supreme Court.  Justice in the United Kingdom is a public affair.  Up and down the country, with few exceptions, the public can wonder into any court room while the court is sitting and watch proceedings.  It has been a foundation of our judicial system for many years.

When the Supreme Court opened for business the Court has always been of the view that it wanted to be as open and as accessible as possible.  It is fitted with permanent cameras that record proceedings and one would imagine these proceedings are capable of being shown on live television should the need ever arise.  The presence of these cameras in court meant that during this documentary we were able to see scenes of the Supreme Court in action.  In our other courts filming is generally banned.  I can only think of a handful of examples of television cameras being allowed inside Court rooms in Scotland.

The documentary itself was a huge step forward in judicial openness.  It was really quite fascinating to find out more about four of the Justices of the Supreme Court and hearing them  talk candidly about the decision making process.

To hear the Justices describe their frustrations over some of the judgments they have been forced to arrive at given the framing of Statutes as passed by Parliament was really quite remarkable.  It has always been something I have admired about our Judiciary.  The way they arrive at judgments is quite remarkable.  The level of detachment from personal feelings required is quite significant and they cannot always, as much as they would often like to, arrive at a conclusion that they personally feel is fair, but rather have to arrive at one which is as fair as it possibly can be given the statutory provisions they are being asked to interpret.

This programme is just one in a brilliant season on BBC Four just now looking at Justice.  The programming continues next week with many programmes which look fascinating and probably intellectually challenging.

I am looking forward to the remainder of the season on BBC Four and would welcome more of this programming on the BBC, especially the main terrestrial BBC Channels.

The Open University has an interesting experiment called “What’s your verdict?” running.  The experiment can be reached by following The Open University link on the BBC Four Justice website.  I would highly recommend both websites.  All the programmes shown to date as part of the Justice season can be watched on BBC iPlayer and I would recommend watching any you haven’t already seen.

 

BBC Four showed an excellent and really quite fascinating documentary yesterday evening on the United Kingdom Supreme Court.  Justice in the United Kingdom is a public affair.  Up and down the country, with few exceptions, the public can wonder into any court room while the court is sitting and watch proceedings.  It has been a foundation of our judicial system for many years.

When the Supreme Court opened for business the Court has always been of the view that it wanted to be as open and as accessible as possible.  It is fitted with permanent cameras that record proceedings and one would imagine these proceedings are capable of being shown on live television should the need ever arise.  The presence of these cameras in court meant that during this documentary we were able to see scenes of the Supreme Court in action.  In our other courts filming is generally banned.  I can only think of a handful of examples of television cameras being allowed inside Court rooms in Scotland.

The documentary itself was a huge step forward in judicial openness.  It was really quite fascinating to find out more about four of the Justices of the Supreme Court and hearing them  talk candidly about the decision making process.

To hear the Justices describe their frustrations over some of the judgments they have been forced to arrive at given the framing of Statutes as passed by Parliament was really quite remarkable.  It has always been something I have admired about our Judiciary.  The way they arrive at judgments is quite remarkable.  The level of detachment from personal feelings required is quite significant and they cannot always, as much as they would often like to, arrive at a conclusion that they personally feel is fair, but rather have to arrive at one which is as fair as it possibly can be given the statutory provisions they are being asked to interpret.

This programme is just one in a brilliant season on BBC Four just now looking at Justice.  The programming continues next week with many programmes which look fascinating and probably intellectually challenging.

I am looking forward to the remainder of the season on BBC Four and would welcome more of this programming on the BBC, especially the main terrestrial BBC Channels.

The Open University has an interesting experiment called “What’s your verdict?” running.  The experiment can be reached by following The Open University link on the BBC Four Justice website.  I would highly recommend both websites.  All the programmes shown to date as part of the Justice season can be watched on BBC iPlayer and I would recommend watching any you haven’t already seen.