On the 11 June 2019, it was announced that The Competition and Markets Authority (CMA) had formally launched an investigation to find out whether people are being treated fairly when buying their home – – and initial submissions were asked for by the 12 July 2019.

The CMA announced its investigation will examine 2 key areas:

    1. Potential mis-selling: whether people who have bought a leasehold property are given the information they need to fully understand the obligations they are taking on, for example the requirement to pay ground rent over a certain period of time, or whether they have an accurate understanding of their ability to buy their freehold.
    2. Potential unfair terms: whether people are having to pay excessive fees due to unfair contract terms. This will include administration, service, and ‘permission’ charges – where homeowners must pay freeholders and managing agents before making home improvements – and ground rents, which in some cases can double every 10 years.

What follows is my submission to the CMA. Readers of this blog will note that there is some re-working of themes I have already covered, so I apologise for any repetition.

The CMA’s investigation has been prompted by concern surrounding the sale of New Build Leaseholds (“NBLs”) by many of the major national housebuilders.

Although there is a superficial measure of agreement that the main issues affecting NBLs are:

      1. Escalating ground rents and
      2. Clauses permitting freeholders to charge significant sums for what are, essentially, administrative actions which do not typically involve the freeholder in significant expense or effort*.
      3. The way:
        (i) NBLs subject to (1) and (2) were marketed and
        (ii) buyers of such properties were advised

it is not necessary to drill very far down into the detail to discover that there is very little agreement about whether these issues are real or illusory, how many people have been affected by them, and what the substance of each issue actually is (in large measure, for example, there is not even agreement about what an “onerous” lease term is). The purpose of this briefing note is therefore to cover some key points that have proved most problematic, for example, during the CHLG Select Committee enquiry into leasehold. The best place to start because it is key, is with escalating ground rents.

I am going to avoid, for the moment use of the word “onerous” because it clouds discussion, and focus, rather, on the effect of escalating ground rents which, when they exceed a particular level, £1,000 in London, £250 in the rest of England & Wales, change and change fundamentally the nature of the tenure; this is because of the operation of the ‘Housing Act Trap’

The Housing Act Trap
One of the consequences of escalating ground rent clauses, described as ‘The Ground 8 trap’, was noted in the government’s consultation paper Tackling Unfair Practices in The Leasehold Market (December 2017), at para 75:

‘ The government is aware that, where ground rents exceed £250 per year or £1,000 per year in London, a leaseholder is classed as an assured tenant. This means, for even small sums of arrears, leaseholders could be subject to a mandatory possession order if they were to default on payment of ground rent.

The Ground 8 trap’ is something of a misnomer and ‘The Housing Act 1988 Trap’ is the more accurate description because The Ground 8 Trap is only the most obvious consequence of a wider problem.

The trap arises from interplay of s 1(1) and (2) and Sch 1 of the Housing Act 1988, which, respectively, define assured tenancies and list those tenancies which cannot be assured tenancies. The basic definition provides that any tenancy under which a dwelling is let as a separate dwelling ‘is for the purposes of this Act an assured tenancy’, and a long lease could always, theoretically, have been caught, but the historically low levels of ground rent associated with long leases meant that most did not exceed the £250 per year or £1,000 per year in London used to define ‘Tenancies at a low rent’ under Sch 1, para 3A. The idea that many long leases would be outside the exception was dismissed when the then Housing Bill was debated in the House of Lords—Hansard (Lords) 24 October 1988, Volume 500, Col 1461-2.

I should add that as a sting in the tail Section 96 of the Housing Act 1996 operates to make assured tenancies entered into on or after 28 February 1997 an assured shorthold tenancy unless it falls within one of the exceptions.

A long lease and an assured or assured shorthold tenancy cannot co-exist, Richardson v Midland Heart Ltd [2008] L & T.R. 31; not only is relief against forfeiture inapplicable but, because of ss 5, 8 & 45 of the Housing Act 1988 the mechanisms for termination are mutually exclusive; an assured tenancy can only be determined by the landlord by serving a s.8 notice and using the Housing Act 1988.

Ground 8
Ground 8 is one of the mandatory grounds for possession under the Housing Act 1988, Sch 2 and it applies when—at the date of the service of the notice under s.8 of the Act and at the date of the hearing:

      •  if rent is payable weekly or fortnightly, at least eight weeks’ rent is unpaid;
      •  if rent is payable monthly, at least two months’ rent is unpaid;
      •  if rent is payable quarterly, at least one quarter’s rent is more than three months in arrears; and
      •  if rent is payable yearly, at least three months’ rent is more than three months in arrears;

Its effect is not just that small amounts of arrears of ground rent can result in leaseholders being subject to a mandatory possession order if they default on payment but that there is no ability to apply for relief from forfeiture. While it is right that the arrears must still be outstanding at the date of the hearing, not every defaulting leaseholder will be in a position to pay, notwithstanding that they may have considerable equity locked up in their leasehold property. That equity is lost when the possession order is made. Moreover it is not always the leaseholder who loses; a possession order determines the leasehold interest and any mortgagee loses their security as well—also without any possibility of rectifying the matter by applying for relief against forfeiture.

Ground 8 is not the only trap
Ground 8 is not the only mandatory ground which could potentially apply to a long lease not at a low rent, the other mandatory grounds are:

      • Ground 7A, conviction for certain offences or antisocial behaviour;
      • Ground 7B, immigration status; and
      • Ground 6, if the lease gives the freeholder the right under certain circumstances to carry out work on the leasehold property and the works are such that the leaseholder cannot remain in occupation while the works are carried out.

Additionally, while a court may be unlikely to exercise its discretion under any of the discretionary Grounds 9 to 17 in Sch 2, that they may apply at least gives rise to a risk that a leaseholder may end up facing proceedings from an aggressive freeholder (it is not as if history suggests that aggressive freeholders do not exist).

Other rights can also be ousted, for example, the right of first refusal on a sale of the freehold for leaseholders of flats under the Landlord & Tenant Act 1987 is also ousted because a tenant under an assured tenancy is not a “qualifying tenant” under s.3 of the 1987 Act.

Escalating Ground Rents and NBLs
With higher initial levels of ground rent and escalator clauses, a long lease of an NBL can either be outside the tenancy at a low rent from exception from the outset or cease to be a tenancy at a low rent within a relatively short time thereafter. Thus while the most egregious escalator clauses which double the ground rent, say, every ten years have attracted the most publicity any escalator clause (unless it is capped at the £1,000/£250) can trigger the Housing Act Trap. This leads back to what “onerous” means in the context of Ground Rents.

The lack of agreement about what “onerous” means is highlighted by three pieces of evidence given in the course observations of the HCLG Select Committee’s enquiry:

” The problem is that there is no real definition of what an onerous ground rent is.

– David Jenkinson, Group Managing Director and Main Board Director, Persimmon in oral evidence to the HCLG Select Committee, 19th November 2018.

“ As Bellway, we do not have any onerous leases. Our standard lease is based upon a rent review based on RPI, which is acceptable to all the main lenders.

– Jason Honeyman; Chief Executive, Bellway – ibid.

“ Ultimately the market will decide what constitutes an “onerous” ground rent.

– John Tutte, Group Chief Executive, Redrow plc in a letter to Clive Betts MP 10th January 2019

The term “onerous” is derived from case law and the debate about what it means as a matter of English is largely sterile because a competent conveyancer will not look at a term and ask: “Is it onerous?” but “Is this something which materially affects what the buyer is buying?” and, because of the Housing Act Trap, because when an escalating ground rent provision takes the ground rent over the £1,000/£250 limit, the system of tenure and the leaseholder’s rights will be changed fundamentally, an escalating ground rent clause is something about which a potential buyer must be warned, so as a matter of law, unless subject to a £1,000/£250 cap, all escalating ground rent clauses are “onerous”.

Determinedly working with the definition of “onerous” as being a ground rent which doubles every 10 or 15 years, research carried out by Long Harbour and Winkworth Sherwood LLP came up with a figure of 12,000 for such leases while separate research by Landmark Investments Group suggested there were 11,700 leases that double every 10 years.

Because the Select Committee, I have been told by one of the members, did not fully appreciate the legal effect of the Housing Act Trap (although they came up with the right definition at paragraph 91* of their report) they did not press witnesses on how many properties, say, Bellway has sold with escalating ground rents clauses linked to RPI that will take their leaseholders above the £1,000/£250 limit, or about how many properties had ground rents above that limit initially. Given a base of around 12,000 for the worst type of onerous ground rent provision, the Land Registry data for sales of new leasehold houses which indicates that sales grew between 2010 and 2015, from £616m to £1.79bn, the 100,000 figure for affected leases suggested by campaign groups does not look improbable, although research and solid evidence is needed.

*[NOTE: I should probably have said almost the right definition, the committee did not pick up that ground rent can be up to £1,000 in London before the House Act Trap kicks in, what para 91 says is:

91. Any ground rent is onerous if it becomes disproportionate to the value of a home, such that it materially affects a leaseholder’s ability to sell their property or obtain a mortgage. In practical terms, it is increasingly clear that a ground rent in excess of 0.1% of the value of a property or £250—including rents likely to reach this level in future due to doubling, or other, ground rent review mechanisms—is beginning to affect the saleability and mortgage-ability of leasehold properties.

this note has been added for the purposes of this article]

Fees payable for permissions are more of an ad hoc problem, they can vary wildly between leases but again, insofar as there is an issue about what is “onerous” the legal position is that in order not to be negligent a conveyancer needs to tell a potential buyer about terms that will limit their unfettered right to enjoy their property during the term of the lease.


” The point that I am trying to make is that these onerous clauses, leases and terms do not get there by accident; they are put there by whoever wrote that lease to start with. The developer has set out to do that, and then the management company and the managing agent continue to make these excessive charges. We need to look at sorting that out, so the onerous clauses are not there to be explained to a buyer by either the estate agent or the conveyancer. They should not be there in the first place.

– Beth Rudolf, Director of Delivery, Conveyancing Association giving evidence to the HCLG Select Committee’s Inquiry into Leasehold 10th December 2018.

This is one of the matters that the HCLG Select Committee failed to unpick and it is an important aspect of the NBL problem that conscious decisions were taken about inserting escalating ground rent provisions, for example, but in evidence to the Select Committee, the approach appears to have been taken that these problems “happened” to housebuilders in exactly the same way as they “happened” to house buyers, something well-illustrated by the following evidence given to the Select Committee:

Jennie Daly: … Taylor Wimpey does have a voluntary assistance scheme for our customers who were affected by a specific 10-year doubling ground rent clause. We took the matter extremely seriously when it was brought to our attention around autumn 2016. The reason for that timing is that the leases we created with that specific clause were used on new developments between 2007 and 2011, and they were coming up for their first doubling and were starting to cause concerns to customers.

Jennie Daly was a recent appointee (April 2018) to the Taylor Wimpey board and her knowledge of what happened historically will have had to be derived from what information she will have received from briefings and, possibly what she has established by her own research, and although she joined the company in 2014, it is not even necessarily the case that she was part of the “we” to whom she was referring when she said:

” We took the matter extremely seriously when it was brought to our attention around autumn 2016.

But, having given all those caveats, and making it clear moreover, that nothing which follows suggests Jennie Daly was doing other than her best to give the evidence as she understood it to be, that answer bears rather closer consideration. The “matter” was not a previously undiscovered manufacturing defect in a product, which may well only come to a manufacturer’s attention after a product has been in circulation for some years, it was:

” a specific 10-year doubling ground rent clause

which, as Beth Rudolf rightly observed, is one of those terms which:

 do not get there by accident; they are put there by whoever wrote that lease to start with.

Jennie Daly did go on in her evidence to say of the clause:

” The reason for that timing is that the leases we created with that specific clause were used on new developments between 2007 and 2011, and they were coming up for their first doubling and were starting to cause concerns to customers.

but it follows that “the matter” that was taken “extremely seriously” can only have been that people were starting to notice and complain about the draconian effect of the clause, not any concern on Taylor Wimpey’s part that the clause had been drafted and inserted in these leases in the first place.

The bland reassurance, with its apparent edge of candour, that “the matter” had been “taken extremely seriously when it was brought to our attention” averted a whole raft of other questions that might, reasonably, have been asked about how the clause originated and just how anyone thought it was justifiable in the first place. The question might that equally have been asked was: if the clause was not used after 2011, how had the change been sanctioned without someone, somewhere in the company, having had it brought to their attention?

There is also some evidence about the genesis of the doubling ground rent clause from 2007, when the clause was first introduced.

On Tuesday 25 September 2007 in an article entitled ‘New warning on small print’ with the sub-heading “We unearth a disturbing new trend in leases – a buried clause that that means ground rent can double in 10 years” The Evening Standard’s Homes & Property Newsletter told the tale of an intending purchaser in of a flat in a Taylor Wimpey development in Mill Hill; the report quotes the intending purchaser, who had demanded the return of his £2,000 deposit as saying:

 Even first-time buyers know about ground rent, but they expect it to be a small and fixed amount, as it has always been, … But in my case, when I looked through the 19-page draft lease from Taylor Wimpey for a modest flat in Mill Hill, I discovered that the initial ground rent may be only £300 a year — but by 2057 it would be £9,600.”

Taylor Wimpey did return the deposit as a gesture of “goodwill” but their response, also quoted in the report, is enlightening:

” [the rent review is] George Wimpey UK policy and is in place on all leasehold developments … Historically, most ground rent review clauses were tied to the Retail Price Index (RPI). But house price inflation has significantly outstripped RPI, and developers are looking at terms and conditions that better reflect this.

The quotation indicates that the clause had been inserted as a matter of considered policy and it was attributed to David Bridges, who, from his biography on LinkedIn, served with Taylor Wimpey:

” April 2007 – June 2008
Headed up Sales & Marketing, Strategy & Partnerships, Sustainability and Start-ups. Sat on the Board of Taylor Wimpey UK, a £4b turnover business which delivered over £600m profit in the year to the end of December 2007.

which also shows that the handling of the buyer’s complaint in 2007 had reached up to board level.

Although I have not researched this closely, from my experience, the reference to ground rents “historically” being linked to RPI would require quite an extended meaning of “historically” to include the relatively recent. My experience would accord more closely with what was said to Homes & Property Newsletter by the intending buyer (who, my researches suggest, was a chartered surveyor):

” Even first-time buyers know about ground rent, but they expect it to be a small and fixed amount, as it has always been …I have since spoken to several solicitors who confirmed that, like me, they had never heard of this, and described it as outrageous … ”

Much of what is in this post was covered by a piece by LKP at the end of 2016, and Jennie Daly’s reference to the matter having been brought to Taylor Wimpey’s attention in 2016 may be a reference to the LKP’s having raised the issue of doubling ground rents with Taylor Wimpey then. Be that as it may, the recent evidence to the Select Committee adds a new topicality to the story and certainly justifies revisiting it.

It is submitted that an essential part of an investigation into mis-selling is establishing what was known about the effect, in particular, of escalating ground rent clauses and how the detail of the decision-making process by which they came about.

From the perspective of the housebuilders, the role of solicitors has been painted as a distinct issue, unconnected with the selling of NBLs and that is not an uncommon view among the legal profession and politicians. The widespread use of recommended solicitors, that is, solicitors recommended by the housebuilders to potential buyers, blurs the line somewhat, particularly where in some cases recommended solicitors paid a referral fee to the housebuilders, meaning that there was a contractual relationship between them, even if it was not one of solicitor and client.

The role of recommended solicitors has been much commented upon and has generated a fair amount of fury on the part of buyers who felt themselves inadequately advised about escalating ground rents. A survey by the Leasehold Knowledge Partnership found 71% of leasehold house buyers used developer recommended solicitors.

There are two obvious concerns, which ought not to be dismissed:

      1. that the downward costs pressure created by the use of recommended solicitors has been contrary to consumers’ best interests because it puts costs pressures on all solicitors and leasehold conveyancing, in particular, can be complex and time-consuming (when done properly).
      2. that where there are also allegations of high pressure selling techniques, recommended solicitors are less likely to be open to the possibility that housebuilder’s sales staff have engaged in such techniques. Some of the evidence to the Select Committee suggested that the high-pressure selling had extended to encouraging the use of recommended solicitors. What happened and how this came about, if it happened, has not been the subject of scrutiny.

This part of the submission deals with some of the less-obvious points.

The possibility of claims against recommended solicitors has been widely canvassed in the media, as another article on the LKP website illustrates, but beyond that and a general expression of outrage, the “recommended solicitor problem” has not been forensically analysed, hence the submission below, which asks in effect “How did recommended solicitors get recommended by developers of new-build leaseholds with escalating ground rents?

When NBLs with escalating ground rents started to come on to the market (from about 2007), it is a matter of record that many solicitors were not alive to the pitfalls with which such properties came but it is unlikely that they were all unaware. Notwithstanding this, the lack of awareness seems to have been particularly widespread among recommended solicitors.

More research is needed and I am not suggesting that all recommended solicitors failed buyers, let alone making any comment on individual cases, but, if it is right that the unawareness was particularly prevalent among recommended solicitors, it is a legitimate area of enquiry to ask how that might have come about?

It is a matter of record that many buyers of NBLs with escalating ground rents complain they were not properly advised by recommended solicitors. It does not seem to me that the process of how solicitors came to be recommended has been considered.

Did developers, for example, select solicitors to recommend on the basis of draft reports on title?

If so did developers effectively make their recommendations based on the advice they knew in advance such solicitors would provide?

If so there is a case for saying that, even if the solicitors acted in good faith, the developers had assumed a duty of care towards the buyers and ought to be liable for the advice buyers received.

Ibraheem Dulmeer of the Leasehold Advisory Service and I wrote about the chequered history of recommended solicitors and the potential ethical difficulties of acting as a recommended solicitor in the Law Society’s ‘Property in Practice’, Issue 59, June 2017 in an article reproduced on Lease’s website . On the back of that I was invited to supply the leasehold module for the Law Society’s Conveyancing Quality Scheme 2018 update, which I did with an experienced conveyancer, Suzanne Broughton of Wolferstans solicitors (in fact we ended up contributing 3 of the course modules). The specification for the leasehold module specifically asked that we should cover:

      1. Understanding the potential dangers of buying or lending on leasehold properties with leases containing provisions for escalating ground rents and other excessive charges
      2. Advising clients of the risks of proceeding with such transactions.
      3. Understanding the potential for claims against conveyancers if clients are not properly advised.

This is something, I take as an implicit endorsement of the original article, and its cautions about the position of recommended solicitors. Those cautions were expressed in amplified form in the CQS 2018 leasehold module.

This is why it would be interesting to know how recommended solicitors were selected. Not only about the mechanics of the selection process, but the criteria the developers applied. It would be interesting to know too, what solicitors were rejected and why?

Most of all it would be interesting to know how aware of the pitfalls the developers were and how consciously they pursued a strategy to ensure sales of what many buyers would now describe as “toxic leaseholds” were not impeded by properly cogent legal advice.

If there was a pattern in the appointment and rejection of recommended solicitors which meant that recommended solicitors, as a group, were likely not to warn buyers about the risks associated with escalating ground rents, or at least not in terms which buyers would readily understand, to what extent can the buyers be said to truly have had independent legal advice?

In this scenario, those who acted as recommended solicitors and who did not give adequate warnings about escalating ground rents, may have been entirely innocent of any collusive behaviour with developers but, in their selection, the advice given to buyers may, nonetheless, have been pre-determined by the developer.

Unless and until the role of recommended solicitors has been investigated and in a thorough and forensic way, the suspicion will remain that something did not simply go wrong but was caused to go wrong and, if the advice given to buyers was controlled by developers, it would be very much harder to justify letting what happened in the past go by uncorrected.

How might it be established whether there was a pattern in the appointment and rejection of recommended solicitors by developers, which meant that their recommended solicitors, as a group, were likely not to warn buyers about the risks associated with escalating ground rents?

Recommended solicitors did not appear from thin air; in evidence to the Housing Communities & Local Government Select Committee on the 18th November 2018, Jennie Daly, who sits on the board of Taylor Wimpey, said this:

 To assist customers, Taylor Wimpey does, as do many of our competitors, identify solicitors who are familiar with the development, operate locally and are familiar with new home sales.

and, also in evidence the same day, Jason Honeyman, Chief Executive of Bellway, said:

” We provide a local list of solicitors on each development and often get asked by purchasers for assistance, whether it is flooring contractors, solicitors, curtains and carpets, those types of things. We have a list of solicitors that are local to that development. We would put on that list where we have previously had experience that they are providing a good service to our customers. There are no commercial relationships between Bellway and any solicitor. We have never received any referral fees. That list will change from region to region across the country.
“If I could just explain the purpose, some conveyancing solicitors are set up to work with new builds, to run volume through their business because they have a lot of conveyancers. Those types of solicitors are used to working on developments such as ours or Taylor Wimpey’s. Some conveyancers are more boutique, or there are just one or two partners in that practice, and would be slower and less helpful. We always find the repetition and the volume guys provide a better price to the purchaser and are more used to that type of land.

The main problem is unlikely to have been any deliberate collusion between solicitor and developer but whether the selection of “recommended” or “panel” solicitors, skewed the advice intending purchasers were likely to receive.

Jennie Daly’s reference to “identify[ing] solicitors who are familiar with the development” suggests that recommended solicitors must have had a level of pre-selection contact with developers because, short some improbable recourse to physic powers, a solicitor could have no familiarity “the development” unless the developer had provided sufficient information to have brought about the necessary familiarity.

The question which follows naturally from that is:
To what extent did interaction go both ways?

For example:

• Did the potential panel solicitor provide a sample report on title and/or a letter of advice or give some prior indication of their likely content?
• If so to what extent was the selection of recommended solicitors dependent upon what went back to the developer?
• To what extent were there warning signs about onerous terms which were overlooked or which resulted in solicitors providing a cautionary report on title/letter of advice being rejected?
• Might the very fact of establishing a panel have impacted on the advice potential purchasers were likely to receive?

To illustrate the last point consider this hypothetical example:

A firm of solicitors is approached to see if it might be interested in becoming a recommended solicitor for a developer, there will be a quantity of work involved (note Jason Honeyman’s reference to the “repetition and volume guys”) and if problems with a particular lease are picked up and the firm’s advice is likely to be:

” this lease has onerous terms and you ought to think very, very carefully before proceeding any further with this purchase

The firm may well anticipate that the volume of conveyancing work it is likely to receive will dry up very quickly and judge that this is not the development on which to be a recommended solicitor.

The firm which fails to see the problem, on the other hand, will not be put off and may well in due course become a recommended solicitor.

Another issue is that every client of a solicitor is entitled to expect that the advice they receive has been considered on their behalf, or, if it is not to be considered individually, at least to be told that the benefits of a lower cost may be at the expense of individual scrutiny. The indications are that there was no individual scrutiny, in this regard, not only may the already cited reference to the “repetition and volume guys” be pertinent, but also this later exchange between the Chair of the Committee and David Jenkinson of Persimmon Homes:

David Jenkinson: Can I just explain? The real reason Persimmon uses a panel of solicitors is to save the customer money because they only need to review the title once. If you go each individual time, the biggest part of actual cost from a sale is to review the title.

Chair: You are saying, “That is the solicitor to go to because they will do it more cheaply for you”.

David Jenkinson: No, they will save them the cost of doing the title.

The saving of costs was also mentioned in the latest evidence given to the select committee but the potential difficulty is that, if reviewing title (which would include the terms of the lease) is only done once, by one individual, and an onerous term is overlooked, there will be no mechanism for correction; later purchasers will all fall with the first, like a chain of dominoes.

Establishing the mechanics of the process of selection is potentially important because it may go to whether the advice received by purchasers could properly be characterised as truly “independent” or whether the overall circumstances are such that a duty of care could be imposed in relation to the selection of recommended solicitors under the principles enunciated by the House of Lords in Caparo Industries Plc v Dickman [1990] 2 A.C. 605.

Questions about recommended solicitors:

• What were the mechanics of the selection process?
• Who approached whom and what were the terms of that approach?
• What criteria did the developers apply in selecting solicitors?
• Did developers either ask for examples of reports on title and letters of advice from potential recommended solicitors or were the developers otherwise aware of the solicitors’ general practice?
• Which solicitors were rejected and why?
• Which solicitors declined to act as recommended solicitors and were their reasons for declining ever established or followed up?
• Was there a discernible pattern in the acceptance and rejection of recommended solicitors?
• To what extent were developers aware of the pitfalls of escalating ground rents?
• How consciously did developers pursue a strategy to ensure sales of what many buyers would now describe as “toxic leaseholds” were not impeded by properly cogent legal advice?

Some people already suspect there was deliberate collusion between recommended solicitors and the developers, I am sceptical that there was deliberate collusion but, in the light of what has happened, those suspicions are understandable and deserve proper investigation.

12th July 2019

(c) Rawdon Crozier 2019, attributed and not-for-profit transmission, reproduction and usage licensed. Otherwise all rights reserved.

This is not legal advice. The application of the law can vary according to individual circumstances and no duty of care is assumed towards any reader of this article.

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