LEGAL
Court-authorised deprivation of liberty Richard Griffith
Senior Lecturer in Health Law, College of Health Science, Swansea University
ABSTRACT
The United Kingdom Supreme Court judgment in Cheshire West and Chester Council v P in 2014 introduced a more inclusive ‘acid test’ for determining the objective element of a deprivation of liberty in cases concerning people who lack decision-making capacity. The case made clear that adults and young people who lack capacity could be deprived of their liberty in care settings other than hospitals and care homes, including the person’s own home. A deprivation of liberty that occurs in a setting other than a hospital or care home must be authorised by a Court. This article explains the revised process for applying for Court authorisation of a deprivation of liberty where it occurs in supported living, Shared Lives placements or the incapable person’s own home.
KEY WORDS
w Deprivation of liberty w Court authorisation w Welfare order w Practice direction
38
district nurses will therefore provide care and treatment to a person who lacks capacity that amounts to a deprivation of liberty because that person is subject to continuous supervision and control and is not free to leave that care setting (Griffith, 2014). It is essential that district nurses are able to recognise when such a deprivation of liberty arises and what evidence is required by the Court of Protection to enable the court to authorise that deprivation of liberty in the person’s best interests.
Welfare orders The Court of Protection has the power to make a welfare order in relation to a person who lacks decision-making capacity.That order can include authorisation of the person’s deprivation of liberty where this is necessary in the person’s best interests to protect them from harm (Mental Capacity Act 2005, section 16(2)(a)). The court’s authority to deprive a person of their liberty is limited by section 16A of the Act and a welfare order cannot order a deprivation of a person’s liberty if they would have been ineligible under schedule 1A of the 2005 Act. Some 134 applications for welfare orders that authorised a deprivation of liberty were made to the Court of Protection in 2013–14. The more inclusive ‘acid test’ for determining a deprivation of liberty set out by the Supreme Court in Cheshire West is likely to result in a rise in applications during 2014–15 to some 18 633 (Re X and others (Deprivation of Liberty) [2014]). The head of the Court of Protection, Sir James Munby, recognised that in order to cope with this huge increase in demand for welfare orders authorising a deprivation of liberty, it would be necessary to bring a measure of administrative order and proper process to the applications. In Re X and others (Deprivation of Liberty) [2014], Sir James Munby considered whether it would be possible to devise a standardised streamlined process that was compatible with the requirements of the right to liberty and security of person under Article 5 of the European Convention on Human Rights (Council of Europe, 1950) that would enable the Court of Protection to deal with deprivation of liberty cases in a timely, just and fair way. The aim was to identify the types of cases involving a
© 2015 MA Healthcare Ltd
T
he Supreme Court judgment in Cheshire West and Chester Council v P [2014] introduced a new, more inclusive ‘acid test’ for the determination of the objective element of a deprivation of liberty. Adults and young people who lack capacity—and whose care results in them being subject to continuous supervision and control and not free to leave—will meet that objective element and will be deprived of their liberty (Griffith 2014).The Supreme Court further held that a deprivation of liberty could arise in care settings other than hospitals and care homes such as supported living, shared lives or even a person’s own home. A deprivation of liberty is only lawful if it is authorised in accordance with a procedure set out in law (HL v United Kingdom (45508/99) [2005]). In hospitals and care homes a deprivation of liberty can be authorised using the administrative deprivation of liberty safeguards (DoLS) procedure set out under the Mental Capacity Act 2005, schedule A1. The DoLS procedure does not extend to other care settings and a deprivation of liberty in a care setting other than a hospital or care home must be authorised by the Court of Protection. The Supreme Court held in Cheshire West that a deprivation of liberty could occur in supported living, Shared Lives placements and even a person’s own home. It is likely that
Email: [email protected]
British Journal of Community Nursing January 2015 Vol 20, No 1
h Journal of Community Nursing. Downloaded from magonlinelibrary.com by 138.253.100.121 on December 2, 2015. For personal use only. No other uses without permission. . All rights res
LEGAL
w Draft of the precise order sought, including the duration of the authorisation, and appropriate directions for automatic review and liberty to seek a redetermination of the order w Proof the person is 16 years old or more and is not ineligible to be deprived of liberty under section 16A of the Mental Capacity Act 2005 w The basis upon which it is said that the person suffers from an unsound mind, together with the relevant medical evidence w The nature of the person’s care arrangements with a copy of the care and why they amount to a deprivation of liberty w The basis upon which it is said that the person lacks the capacity to consent to their care arrangements together with the relevant medical evidence w The basis upon which it is said that the arrangements are or may be imputable to the state w The basis upon which it is said that the arrangements are necessary in the person’s best interests and why there is no less restrictive option, including details of any investigation into less restrictive options and confirmation that a best interests assessment, which should be attached, has been carried out w The steps taken to notify the person and relevant people in the person’s life, who should be identified for the court, of the application and to canvass their wishes, feelings and views w The relevant wishes and feelings expressed by the person and any views expressed by any relevant person w Details of any relevant advance decision by the person and any relevant decisions under a lasting power of attorney or by a court appointed deputy who should be identified w The person’s eligibility for public funding w The identification of anyone who might act as the person’s litigation friend w Reasons for particular urgency in determining the application w Any factors that ought to be brought specifically to the court’s attention Source: adapted from Re X and others (Deprivation of Liberty) [2014] (Munby P at para 35)
deprivation of liberty that could be dealt with on the papers without the need for an oral hearing, and those that require an oral hearing before the court. A hearing on the papers can be dealt with more quickly by the court than one that requires an oral hearing. The difference in costs for a case decided on the papers and one requiring an oral hearing are considerable. A case on the papers is likely to cost around £900 in application and hearing fees, while a case requiring an oral hearing is likely to run to tens of thousands of pounds in additional costs and legal fees. In Re X and others (Deprivation of Liberty) [2014], Sir James Munby held that it was possible to introduce a streamlined application process that allowed for a hearing on the papers and complied with article 5 of the European Convention
40
on Human Rights (Council of Europe, 1950), as long as it clearly set out the documents the court must have in order to decide on a deprivation of liberty case. A 14-point process was set out for an application on the papers as set out in Box 1.
Triggers for an oral hearing Not all cases will be suitable for a hearing on the papers and the court identified trigger situations to assist district nurses in identifying cases that will require an oral hearing. It would be inappropriate to deal with an application on the papers where: w The relevant person or anyone else contested any of the evidence submitted to support the application for a deprivation of liberty set out in Box 1 w The health body, such as a health board or clinical commissioning group, failed to inform the person and the relevant people in that person’s life of the court application w There are concerns arising from information supplied relating to the person’s or their family’s wishes and feelings, the urgency of a particular case or due to the fact that the health body has not made a full and frank disclosure in their evidence. w The person objects to being deprived of their liberty w The request for authorisation would conflict with an advance decision to refuse treatment or a decision made by a health and welfare deputy appointed by the court or attorney acting under a lasting power of attorney for health and welfare w There is some other reason the court thinks that an oral hearing is necessary or appropriate.
Full and frank disclosure District nurses are under a duty to make a full and frank disclosure when providing the information required by the Court of Protection to authorise a deprivation of liberty. In their written evidence to the court under the streamlined process, district nurses must ensure they provide a rounded, unbiased account of the patient’s circumstances. All facts and matters that might have an impact upon the court’s decision must be disclosed. This would include those facts that: w Need particular scrutiny by the judge w Suggest that the arrangements may not in the person’s best interests or be the least restrictive option w Might indicate that the order sought should not be made.
Making an application to the court To facilitate applications under the streamlined process, the Court of Protection has issued a new application form, COPDOL 10, and practice direction for a welfare order authorising a deprivation of liberty. The court does not require that one individual completes the form and provides the supporting evidence verified by a statement of truth when different people are best placed to provide evidence on different matters (Court of Protection,
© 2015 MA Healthcare Ltd
Box 1. Requirements for the streamlined application process to decide a deprivation of liberty case on the papers
British Journal of Community Nursing January 2015 Vol 20, No 1
h Journal of Community Nursing. Downloaded from magonlinelibrary.com by 138.253.100.121 on December 2, 2015. For personal use only. No other uses without permission. . All rights res
LEGAL 2014). The litigation manager of a clinical commissioning group or trust might complete the form but may ask the district nurses involved in the care of the person to supply the documents necessary to support the application.
Care plan The crucial evidence that district nurses will be required to provide under the streamlined process set out in Box 1 is the person’s care and treatment plan. The care plan will be carefully scrutinised by the court and it is essential that district nurses ensure that it clearly and accurately reflects the actual care and treatment being provided to the patient. The court has to be satisfied that the care plan results in the person being deprived of their liberty and that the deprivation of liberty is necessary and proportionate in the patient’s best interests.
Further evidence An application for a court-authorised deprivation of liberty must be in relation to a person who lacks capacity to make decisions about their care and treatment and who is additionally of unsound mind (HL v United Kingdom (45508/99) [2005]). The streamlined application process that evidence of a lack of capacity and unsound mind is provided by a doctor. District nurses cannot provide this evidence, even though they are generally entitled to do so for other types of Mental Capacity Act 2005 cases before the Court of Protection. In deprivation of liberty cases, however, the European Court of Human Rights requires medical evidence establishing unsoundness of mind (Winterwerp v The Netherlands [1979]): w Of a kind warranting the proposed measures w Persisting at the time when the decision is taken. An application for a court-authorised deprivation of liberty can be made in respect of an adult or young person (i.e. a person aged 16 or older) who lacks decision-making capacity. This differs from the DoLS process used in hospitals and care homes that requires the relevant person to be an adult. It will generally be sufficient to state the person’s date of birth, verified by a statement of truth, as evidence of the person’s age.
© 2015 MA Healthcare Ltd
Applications under the streamline process The streamline process for court-authorised deprivations of liberty came into effect on 17 November 2014. District nurses and their employing health body must now ensure that the applications comply with the requirements of form COPDOL 10 that is available to download from http:// tinyurl.com/po86o3c now. Practice direction 10AA and an example of a completed form are available from the Court of Protection and can be found at http://tinyurl.com/lsaw5o2.
Conclusion The more inclusive ‘acid test’ for determining when a person who lacks capacity is deprived of their liberty applies to
British Journal of Community Nursing January 2015 Vol 20, No 1
people in a broad range of care settings, such as supported living, ‘Shared Lives’ placements and even the person’s own home as well as hospitals and care homes. District nurses must be able to identify the people in their care who are deprived of their liberty and ensure that the deprivation of liberty is authorised where it is necessary in the person’s best interests. Deprivations of liberty in care settings other than hospitals and care homes can only be authorised by a court. The Court of Protection has introduced a new streamlined process that will allow the court to decide on the papers whether it should authorise a deprivation of liberty.This will speed up the authorisation process and keep costs to a minimum while respecting the human rights of the person. It is essential that district nurses are familiar with the streamlined process and are able to provide clear accurate documentation in support of an application for a deprivation of liberty authorisation made to the court. District nurses must also be able to identify trigger situations where the streamline process should not apply and an oral hearing before the court would be necessary. BJCN If you are interested in finding out more about the legal cases noted in this feature, please email the editor at [email protected] Cheshire West and Chester Council v P [2014] UKSC 19 HL v United Kingdom (45508/99) [2005] 40 EHRR 32 Re X and others (Deprivation of Liberty) [2014] EWCOP 25 Winterwerp v The Netherlands [1979] 6301/73 ECHR 4 Council of Europe (1950) European Convention on Fundamental Human Rights and Freedoms. Council of Europe, Rome Court of Protection (2014) Practice direction: deprivation of liberty. Practice direction A—deprivation of liberty applications. http://tinyurl.com/p8qqfyy (accessed 19 December 2014) Griffith R (2014) The impact of the Supreme Court judgment in Cheshire West v P on the human rights of vulnerable patients. Br J Community Nurs 19(12) 612–15
KEY POINTS
w A deprivation of liberty can arise in care settings other than hospitals and care homes such as supported living, ‘Shared Lives’ placements or even a person’s own home w Where a district nurses provides care and treatment to a person who lacks capacity that amounts to a deprivation of liberty, it must be authorised by a court w The Court of Protection has introduced a streamlined process allowing for some applications to made on the papers without an oral hearing w Not all cases will be suitable for a hearing on the papers and the court has identified trigger situations to assist district nurses in identifying cases that will require an oral hearing w To facilitate applications under the streamlined process, the Court of Protection has issued a new application form (COPDOL 10) and practice direction for a welfare order authorising a deprivation of liberty
41
h Journal of Community Nursing. Downloaded from magonlinelibrary.com by 138.253.100.121 on December 2, 2015. For personal use only. No other uses without permission. . All rights res
Court-authorised deprivation of liberty Richard Griffith
Senior Lecturer in Health Law, College of Health Science, Swansea University
ABSTRACT
The United Kingdom Supreme Court judgment in Cheshire West and Chester Council v P in 2014 introduced a more inclusive ‘acid test’ for determining the objective element of a deprivation of liberty in cases concerning people who lack decision-making capacity. The case made clear that adults and young people who lack capacity could be deprived of their liberty in care settings other than hospitals and care homes, including the person’s own home. A deprivation of liberty that occurs in a setting other than a hospital or care home must be authorised by a Court. This article explains the revised process for applying for Court authorisation of a deprivation of liberty where it occurs in supported living, Shared Lives placements or the incapable person’s own home.
KEY WORDS
w Deprivation of liberty w Court authorisation w Welfare order w Practice direction
38
district nurses will therefore provide care and treatment to a person who lacks capacity that amounts to a deprivation of liberty because that person is subject to continuous supervision and control and is not free to leave that care setting (Griffith, 2014). It is essential that district nurses are able to recognise when such a deprivation of liberty arises and what evidence is required by the Court of Protection to enable the court to authorise that deprivation of liberty in the person’s best interests.
Welfare orders The Court of Protection has the power to make a welfare order in relation to a person who lacks decision-making capacity.That order can include authorisation of the person’s deprivation of liberty where this is necessary in the person’s best interests to protect them from harm (Mental Capacity Act 2005, section 16(2)(a)). The court’s authority to deprive a person of their liberty is limited by section 16A of the Act and a welfare order cannot order a deprivation of a person’s liberty if they would have been ineligible under schedule 1A of the 2005 Act. Some 134 applications for welfare orders that authorised a deprivation of liberty were made to the Court of Protection in 2013–14. The more inclusive ‘acid test’ for determining a deprivation of liberty set out by the Supreme Court in Cheshire West is likely to result in a rise in applications during 2014–15 to some 18 633 (Re X and others (Deprivation of Liberty) [2014]). The head of the Court of Protection, Sir James Munby, recognised that in order to cope with this huge increase in demand for welfare orders authorising a deprivation of liberty, it would be necessary to bring a measure of administrative order and proper process to the applications. In Re X and others (Deprivation of Liberty) [2014], Sir James Munby considered whether it would be possible to devise a standardised streamlined process that was compatible with the requirements of the right to liberty and security of person under Article 5 of the European Convention on Human Rights (Council of Europe, 1950) that would enable the Court of Protection to deal with deprivation of liberty cases in a timely, just and fair way. The aim was to identify the types of cases involving a
© 2015 MA Healthcare Ltd
T
he Supreme Court judgment in Cheshire West and Chester Council v P [2014] introduced a new, more inclusive ‘acid test’ for the determination of the objective element of a deprivation of liberty. Adults and young people who lack capacity—and whose care results in them being subject to continuous supervision and control and not free to leave—will meet that objective element and will be deprived of their liberty (Griffith 2014).The Supreme Court further held that a deprivation of liberty could arise in care settings other than hospitals and care homes such as supported living, shared lives or even a person’s own home. A deprivation of liberty is only lawful if it is authorised in accordance with a procedure set out in law (HL v United Kingdom (45508/99) [2005]). In hospitals and care homes a deprivation of liberty can be authorised using the administrative deprivation of liberty safeguards (DoLS) procedure set out under the Mental Capacity Act 2005, schedule A1. The DoLS procedure does not extend to other care settings and a deprivation of liberty in a care setting other than a hospital or care home must be authorised by the Court of Protection. The Supreme Court held in Cheshire West that a deprivation of liberty could occur in supported living, Shared Lives placements and even a person’s own home. It is likely that
Email: [email protected]
British Journal of Community Nursing January 2015 Vol 20, No 1
h Journal of Community Nursing. Downloaded from magonlinelibrary.com by 138.253.100.121 on December 2, 2015. For personal use only. No other uses without permission. . All rights res
LEGAL
w Draft of the precise order sought, including the duration of the authorisation, and appropriate directions for automatic review and liberty to seek a redetermination of the order w Proof the person is 16 years old or more and is not ineligible to be deprived of liberty under section 16A of the Mental Capacity Act 2005 w The basis upon which it is said that the person suffers from an unsound mind, together with the relevant medical evidence w The nature of the person’s care arrangements with a copy of the care and why they amount to a deprivation of liberty w The basis upon which it is said that the person lacks the capacity to consent to their care arrangements together with the relevant medical evidence w The basis upon which it is said that the arrangements are or may be imputable to the state w The basis upon which it is said that the arrangements are necessary in the person’s best interests and why there is no less restrictive option, including details of any investigation into less restrictive options and confirmation that a best interests assessment, which should be attached, has been carried out w The steps taken to notify the person and relevant people in the person’s life, who should be identified for the court, of the application and to canvass their wishes, feelings and views w The relevant wishes and feelings expressed by the person and any views expressed by any relevant person w Details of any relevant advance decision by the person and any relevant decisions under a lasting power of attorney or by a court appointed deputy who should be identified w The person’s eligibility for public funding w The identification of anyone who might act as the person’s litigation friend w Reasons for particular urgency in determining the application w Any factors that ought to be brought specifically to the court’s attention Source: adapted from Re X and others (Deprivation of Liberty) [2014] (Munby P at para 35)
deprivation of liberty that could be dealt with on the papers without the need for an oral hearing, and those that require an oral hearing before the court. A hearing on the papers can be dealt with more quickly by the court than one that requires an oral hearing. The difference in costs for a case decided on the papers and one requiring an oral hearing are considerable. A case on the papers is likely to cost around £900 in application and hearing fees, while a case requiring an oral hearing is likely to run to tens of thousands of pounds in additional costs and legal fees. In Re X and others (Deprivation of Liberty) [2014], Sir James Munby held that it was possible to introduce a streamlined application process that allowed for a hearing on the papers and complied with article 5 of the European Convention
40
on Human Rights (Council of Europe, 1950), as long as it clearly set out the documents the court must have in order to decide on a deprivation of liberty case. A 14-point process was set out for an application on the papers as set out in Box 1.
Triggers for an oral hearing Not all cases will be suitable for a hearing on the papers and the court identified trigger situations to assist district nurses in identifying cases that will require an oral hearing. It would be inappropriate to deal with an application on the papers where: w The relevant person or anyone else contested any of the evidence submitted to support the application for a deprivation of liberty set out in Box 1 w The health body, such as a health board or clinical commissioning group, failed to inform the person and the relevant people in that person’s life of the court application w There are concerns arising from information supplied relating to the person’s or their family’s wishes and feelings, the urgency of a particular case or due to the fact that the health body has not made a full and frank disclosure in their evidence. w The person objects to being deprived of their liberty w The request for authorisation would conflict with an advance decision to refuse treatment or a decision made by a health and welfare deputy appointed by the court or attorney acting under a lasting power of attorney for health and welfare w There is some other reason the court thinks that an oral hearing is necessary or appropriate.
Full and frank disclosure District nurses are under a duty to make a full and frank disclosure when providing the information required by the Court of Protection to authorise a deprivation of liberty. In their written evidence to the court under the streamlined process, district nurses must ensure they provide a rounded, unbiased account of the patient’s circumstances. All facts and matters that might have an impact upon the court’s decision must be disclosed. This would include those facts that: w Need particular scrutiny by the judge w Suggest that the arrangements may not in the person’s best interests or be the least restrictive option w Might indicate that the order sought should not be made.
Making an application to the court To facilitate applications under the streamlined process, the Court of Protection has issued a new application form, COPDOL 10, and practice direction for a welfare order authorising a deprivation of liberty. The court does not require that one individual completes the form and provides the supporting evidence verified by a statement of truth when different people are best placed to provide evidence on different matters (Court of Protection,
© 2015 MA Healthcare Ltd
Box 1. Requirements for the streamlined application process to decide a deprivation of liberty case on the papers
British Journal of Community Nursing January 2015 Vol 20, No 1
h Journal of Community Nursing. Downloaded from magonlinelibrary.com by 138.253.100.121 on December 2, 2015. For personal use only. No other uses without permission. . All rights res
LEGAL 2014). The litigation manager of a clinical commissioning group or trust might complete the form but may ask the district nurses involved in the care of the person to supply the documents necessary to support the application.
Care plan The crucial evidence that district nurses will be required to provide under the streamlined process set out in Box 1 is the person’s care and treatment plan. The care plan will be carefully scrutinised by the court and it is essential that district nurses ensure that it clearly and accurately reflects the actual care and treatment being provided to the patient. The court has to be satisfied that the care plan results in the person being deprived of their liberty and that the deprivation of liberty is necessary and proportionate in the patient’s best interests.
Further evidence An application for a court-authorised deprivation of liberty must be in relation to a person who lacks capacity to make decisions about their care and treatment and who is additionally of unsound mind (HL v United Kingdom (45508/99) [2005]). The streamlined application process that evidence of a lack of capacity and unsound mind is provided by a doctor. District nurses cannot provide this evidence, even though they are generally entitled to do so for other types of Mental Capacity Act 2005 cases before the Court of Protection. In deprivation of liberty cases, however, the European Court of Human Rights requires medical evidence establishing unsoundness of mind (Winterwerp v The Netherlands [1979]): w Of a kind warranting the proposed measures w Persisting at the time when the decision is taken. An application for a court-authorised deprivation of liberty can be made in respect of an adult or young person (i.e. a person aged 16 or older) who lacks decision-making capacity. This differs from the DoLS process used in hospitals and care homes that requires the relevant person to be an adult. It will generally be sufficient to state the person’s date of birth, verified by a statement of truth, as evidence of the person’s age.
© 2015 MA Healthcare Ltd
Applications under the streamline process The streamline process for court-authorised deprivations of liberty came into effect on 17 November 2014. District nurses and their employing health body must now ensure that the applications comply with the requirements of form COPDOL 10 that is available to download from http:// tinyurl.com/po86o3c now. Practice direction 10AA and an example of a completed form are available from the Court of Protection and can be found at http://tinyurl.com/lsaw5o2.
Conclusion The more inclusive ‘acid test’ for determining when a person who lacks capacity is deprived of their liberty applies to
British Journal of Community Nursing January 2015 Vol 20, No 1
people in a broad range of care settings, such as supported living, ‘Shared Lives’ placements and even the person’s own home as well as hospitals and care homes. District nurses must be able to identify the people in their care who are deprived of their liberty and ensure that the deprivation of liberty is authorised where it is necessary in the person’s best interests. Deprivations of liberty in care settings other than hospitals and care homes can only be authorised by a court. The Court of Protection has introduced a new streamlined process that will allow the court to decide on the papers whether it should authorise a deprivation of liberty.This will speed up the authorisation process and keep costs to a minimum while respecting the human rights of the person. It is essential that district nurses are familiar with the streamlined process and are able to provide clear accurate documentation in support of an application for a deprivation of liberty authorisation made to the court. District nurses must also be able to identify trigger situations where the streamline process should not apply and an oral hearing before the court would be necessary. BJCN If you are interested in finding out more about the legal cases noted in this feature, please email the editor at [email protected] Cheshire West and Chester Council v P [2014] UKSC 19 HL v United Kingdom (45508/99) [2005] 40 EHRR 32 Re X and others (Deprivation of Liberty) [2014] EWCOP 25 Winterwerp v The Netherlands [1979] 6301/73 ECHR 4 Council of Europe (1950) European Convention on Fundamental Human Rights and Freedoms. Council of Europe, Rome Court of Protection (2014) Practice direction: deprivation of liberty. Practice direction A—deprivation of liberty applications. http://tinyurl.com/p8qqfyy (accessed 19 December 2014) Griffith R (2014) The impact of the Supreme Court judgment in Cheshire West v P on the human rights of vulnerable patients. Br J Community Nurs 19(12) 612–15
KEY POINTS
w A deprivation of liberty can arise in care settings other than hospitals and care homes such as supported living, ‘Shared Lives’ placements or even a person’s own home w Where a district nurses provides care and treatment to a person who lacks capacity that amounts to a deprivation of liberty, it must be authorised by a court w The Court of Protection has introduced a streamlined process allowing for some applications to made on the papers without an oral hearing w Not all cases will be suitable for a hearing on the papers and the court has identified trigger situations to assist district nurses in identifying cases that will require an oral hearing w To facilitate applications under the streamlined process, the Court of Protection has issued a new application form (COPDOL 10) and practice direction for a welfare order authorising a deprivation of liberty
41
h Journal of Community Nursing. Downloaded from magonlinelibrary.com by 138.253.100.121 on December 2, 2015. For personal use only. No other uses without permission. . All rights res
