A. INTRODUCTION

6.1 In this chapter we make a number of recommendations in relation to the regulation of specialisation amongst solicitors. We do so under the following headings:

• Our General Approach;
• Advertising about Willingness to Accept Work in Particular Fields of Practice;
• Other Advertising about Fields of Practice;
• Associations of Practitioners in Particular Fields of Practice (“Special Interest Associations”).

In Chapter 7 we make recommendations in relation to regulation of specialisation amongst barristers. We also consider in Chapter 7 the implications in this area of the recommendation in our First Report that the present division in the profession between barristers and solicitors should be abolished.

6.2 We mentioned in chapter 3 the Law Society’s proposal to relax the present restrictions on advertising by solicitors so as to allow certain types of information to be advertised in Newspapers and periodicals. ¹ We discuss the general question of advertising in Parts III and IV of this Report and we recommend there that a wide range of information should be able to be advertised by solicitors in newspapers, periodicals and printed publications generally, subject to certain restrictions such as that it must not be false, misleading or disreputable. ² We also favour permitting advertisements on radio and television although we do not expect them to become common, at least in the short term. ³ It is against this background that we consider here whether special restrictions should apply to advertisements about fields of practice.

B. OUR GENERAL APPROACH

6.3 We described in our Discussion Paper, and in earlier chapters of this Report, a wide range of considerations relevant to the regulation of specialisation amongst solicitors. ⁴ In the light of those considerations we have arrived at the following general conclusions.

The Principal Issue

6.4 The principal question of present relevance in relation to the regulation of specialisation is whether solicitors should continue to be prohibited from advertising about their fields of practice, either in terms of “specialisation” or otherwise.

Advertisements about Willingness to Accept Work

6.5 Generally speaking, wealthy or sophisticated users of legal services, such as many business corporations, are able to find their way to practitioners who have appropriate skills for their problems, even in narrow fields of practice. On the other hand, there is a pressing need to assist less sophisticated users, or would-be users, to locate appropriate practitioners. For these people, it would be a significant advance if they could more readily obtain information about the broad fields of practice in which particular solicitors are willing to accept work. However, if solicitors were permitted to advertise their willingness or unwillingness to accept work in particular fields, there would need to be some controls to reduce the dangers of misleading or ambiguous advertising.

Other Advertisements about Fields of Practice

6.6 Many clients would benefit from greater assistance in seeking a solicitor who is competent or expert in the field of practice relevant to their problem. One possibility is to permit solicitors to advertise themselves in terms such as “specialising in”, or “experienced it”, particular fields, provided that they meet certain medium or high level qualifications such as a specified degree of concentration in a field or the completion of formal examinations in it. Another possibility is to allow such advertising subject only to low level requirements such as that it must not be “false or misleading”.

6.7 We do not favour adoption of either of these possibilities. For reasons mentioned in the previous chapter, we consider that medium or high level schemes can have gravely adverse consequences on the cost and accessibility of legal services, and even on the quality and speed of service. They can have an unfair and undesirable impact on some sectors of the profession especially general practitioners and young practitioners. On the other hand, low level schemes can lead to a high incidence of advertising which is consciously or unconsciously misleading, and which it is difficult to police effectively. Moreover, the incidence of misleading advertising under such schemes is likely to lead to compelling demands for the introduction of a medium or high level scheme, with the consequential disadvantages to which we have referred.

6.8 It may be possible, however to devise a low-medium level scheme which encourages practitioners to develop and maintain competence in particular fields, and which gives the public some assistance in identifying practitioners who do so, without having the serious weaknesses of the higher or lower level schemes to which we have referred.

Special Interest Associations

6.9 The growth of associations of practitioners having a special interest in particular fields (“special interest associations”) can provide advantages for the profession and the public. But it is of the greatest importance that solicitors who are members of these associations should remain subject, in practice as well as in theory, to the general regulatory body for all solicitors. The introduction of a medium or high level fields of practice scheme would increase the danger of fragmentation of the profession into largely autonomous groups which then use their dominant position in a field to restrict competition, and increase fees, to an unjustifiable extent.

C. ADVERTISING ABOUT WILLINGNESS TO ACCEPT WORK IN PARTICULAR FIELDS

I. Introduction

6.10 We turn now to specific recommendations, beginning with a low level scheme in relation to advertisements about willingness to accept work in particular fields of practice.

II. The Basic Scheme

6.11 At present solicitors are permitted to advertise in the Legal Services Directory but not elsewhere, their willingness or unwillingness to accept work in particular fields. We see no sufficient reason why advertisements of such a kind should continue to be confined to that directory. We note that in the United States and several Canadian provinces lawyers are now permitted to insert such advertisements in a wide range of printed publications. ⁵ And recent changes in England and Scotland have enabled such advertisements to be displayed on office signs and, in some circumstances, in newspapers. ⁶

6.12 It can be argued that willingness to accept work may be misinterpreted as connoting expertise. The Law Society has put this view in two submissions to us. ⁷ We recommend below certain controls on terminology which would reduce the likelihood of misleading claims being made. ⁸ A danger of occasional misinterpretation would remain, but in our view it is greatly outweighed by the advantages of providing the public with basic information about lawyers fields of practice. At present, many members of the public are severely hampered by lack of such information. In many circumstances, clients do not need lawyers with special expertise in the relevant field, or, although such lawyers would be preferable, their use is not feasible for particular clients because they are too costly, geographically remote, or taken up with other commitments.

6.13 Accordingly, we recommend that advertisements about solicitors willingness or unwillingness to accept work in particular fields should be permissible in newspapers, periodicals and any other media in which solicitors will become entitled to advertise information about themselves if our recommendations in Part III are implemented.

6.14 We make a similar recommendation in relation to advertisements about willingness or unwillingness to accept work directly from clients in particular fields. In our view, this would facilitate referrals between solicitors, because some solicitors may be more willing to refer a matter to another solicitor if they know that the client will not be lost as a result. This reassurance could be given in a number of ways, including advertising that one does not accept work directly from clients. A further consideration is that if some solicitors do not accept work directly from clients it is desirable, of course, for their would-be clients to be apprised of that fact.

III. Controls on Terminology

Willingness or Unwillingness to Accept Work

6.15 We do not recommend that solicitors should be required to use a standard form of words to indicate willingness to accept work. Satisfactory terminology would include, for example, “willing to handle family law work”, “accepting family law work”, “family law work welcome” or simply “family law work”. Any words should be regarded as acceptable provided that they indicate willingness or unwillingness to accept work; do not claim experience, expertise or specialisation, and do not contravene the general restrictions which we recommend in Part III concerning, for example, false, misleading or disreputable advertising, and claims of superiority over other practices. We make similar recommendations in relation to advertisements about willingness or unwillingness to accept work directly from clients.

6.16 These recommendations reflect our view that appropriate terminology may vary considerably according to circumstances, such as the likely readership of the advertisement, and that prescription of a standard form of words would be unnecessarily restrictive. We recommend, however, that

• the general regulatory body for solicitors should publish examples of terminology which it considers suitable, or unsuitable, for expressing willingness or unwillingness to accept work, and willingness or unwillingness to accept work directly from clients; and
• if solicitors wish to use terms which are not on the regulatory body’s suggested list, they should be required to notify the regulatory body a specified period in advance.

We do not recommend that the regulatory body’s prior approval should be required, nor that its interpretation of the relevant restrictions should be binding on solicitors. Binding interpretation would be the responsibility of disciplinary tribunals and the courts. However, most solicitors wishing to advertise certain terminology are likely to decide not to do so if it is explicitly disapproved by the regulatory body. If a solicitor were found by a disciplinary tribunal or court to have contravened the restrictions, his or her disregard of explicit disapproval by the regulatory body might be taken into account in determining the appropriate disciplinary sanction. In cases of great importance, the regulatory body, having been given prior notice of an intended advertisement, could amend the restrictions, whether to permit the advertisement or to prohibit it.

6.17 The dangers of confusing or deceptive terminology are reduced when the advertisement is in a publication which circulates principally or solely amongst lawyers. We do not recommend that prior notification to the regulatory body should be required in such circumstances. But the regulatory body should be given power to specify with binding effect which publications fall within the requisite category. ⁹

Fields of Practice

6.18 We recommend that the controls described above should apply also to terminology used to describe particular fields of practice. When drawing up a list of suggested descriptions of fields, tie regulatory body should obtain the advice of non- lawyers in order to ensure that the descriptions are useful, and readily comprehensible, to unsophisticated users of legal services. In some instances it may be desirable to use broad descriptions in order to assist the public and to provide the profession with detailed definitions of these descriptions in order to promote uniformity of usage. ¹⁰ If solicitors wish to use a description which the regulatory body has defined, they should be required to use it in accordance with that definition and to supply a copy of that definition to any client, or would-be client, who requests it.

6.19 Where a practitioner is willing to accept work in a wide range of fields, considerations of space or expense might preclude him or her from listing all of them, and an abbreviated list might be misinterpreted as exhaustive. Accordingly, we recommend that practitioners should be permitted to indicate General Practice as a field in which they are willing to accept work. The prohibition of such a description would increase the dangers of excessive specialisation and fragmentation within the profession, especially those relating to general practitioners and small or outlying practices, to which we referred in Chapter 5.

IV. Directories

Legal Services Directory

6.20 As we have mentioned, solicitors are presently permitted to advertise in the Legal Services Directory their willingness or unwillingness to accept work in the 14 fields listed in the Directory. ¹¹ In our view, the Directory is potentially of great value, provided that it is made widely and readily available to the public. We make two recommendations in relation to its further development First, we recommend that solicitors should be permitted to indicate in it those fields, if any, in which they accept work only on referral from another solicitor. This information is important for both clients and lawyers, and it could be included without significantly changing the Director’s present form or detracting from its clear presentation. Secondly, we recommend that the list of fields in the Directory should be kept under review with the assistance of lay people who are familiar with the needs and perspectives of users or would-be users of legal services. For example, a present description in the Directory which may not be comprehensible to many members of the public is “administrative law”. ¹²

Referrals Directory

6.21 Our inquiries indicate that many solicitors would benefit from readier access to the names of solicitors who are willing to handle work in particular fields, especially fields of a somewhat unusual nature. As we mentioned earlier, ¹³ the Law Society has decided to compile a list of solicitors who indicate their willingness to accept work in particular fields, in addition to the fields in the Legal Services Directory. The list will not be published but will be used to answer inquiries to the Society for the names of solicitors handling work in particular fields. This is a valuable scheme, provided that its existence is publicised widely. We recommend, however, that the list should not be used solely to answer inquiries of the Society, but should be made available generally to members of the profession in the form of a Referrals Directory.

D. OTHER ADVERTISING ABOUT FIELDS OF PRACTICE

I. Introduction

6.22 For reasons explained earlier, ¹⁴ we do not favour the introduction of schemes enabling solicitors to advertise themselves in terms such as “specialists” or “experts” in particular fields, whether subject to meeting specified qualifications or otherwise.

6.23 We are not necessarily opposed, however, to a scheme which permits solicitors to advertise themselves as, for example, “preferring”, or being “specially interested in”, particular fields. If solicitors are to be permitted to advertise in such a way they should be required to meet certain qualifications. But in our view the qualifications should be modest and, for example, should not involve substantial levels of concentration in a particular field nor attendance at lengthy courses of continuing legal education.

6.24 We do not positively recommend the establishment of such a scheme. If it is introduced, however, we suggest that it should be a low-medium scheme along the general lines of the scheme which we describe below (paras.6.26-6.40). This scheme would be in addition to the low level scheme, recommended in the previous section of this chapter, concerning willingness to accept work in particular fields.

6.25 The principal purpose of a low-medium scheme of this kind would be to assist clients to identify practitioners who are likely to be competent in the field of practice relevant to their problem. It would seek to avoid the dangers of excessive specialisation and fragmentation within the profession which are the major weakness of medium or high level schemes. We turn now to an outline of the scheme.

II. “Preference” or “Special Interest”

6.26 Subject to meeting certain qualifications, solicitors would be permitted to advertise themselves as having certain “preferred’ fields of practice, or as being “specially interested” in particular fields, or in such equivalent terms as are approved by the general regulatory body.

6.27 The terminology to which we have referred is, in our view, pitched sufficiently low as not to claim, or be likely to be perceived as claiming, special competence or expertise. But it connotes, and is likely to be interpreted as connoting, more than the mere willingness to accept work which could be advertised under the low level scheme recommended earlier. It should be noted here that advertising of “preferred areas of practice” is now permitted in several Canadian provinces ¹⁵ and has been approved in the reports of the Professional Organisations Committee in Ontario ¹⁶ and the Royal Commission on Legal Services in Scotland. ¹⁷

III. Qualifications

A Possible Package

6.28 The qualifications for advertising under the scheme could be:

• three years in active practice as a lawyer;

(i) for two years prior to commencing to advertise, attendance at specified continuing legal education (say, 20 hours each year);

(ii) for each year after commencing to advertise, attendance at specified continuing legal education (say, 20 hours for each of the first two years after commencing advertisements, and 10 hours for each subsequent year); and

• payment to the general regulatory body of a modest registration fee for each field advertised, the fee to be used to defray the cost of administering the scheme.

These qualifications are intended to be sufficiently substantial to require special interest and education in particular fields on a continuing basis, but not to require high levels of concentration or expertise. We look at each of the qualifications in turn.

6.29 Three years in active practice. We think three years is a reasonable qualifying period to enable a practitioner to acquire a basic familiarity with legal practice and to develop a special interest. Moreover, we do not favour practitioners being encouraged or pressured into specialising from the very outset of their career, before they have had some chance to assess their aptitudes and options. A longer minimum requirement, however, would be likely to discriminate unfairly against young practitioners.

6.30 Modest continuing legal education requirements. These requirements should involve attendance at lectures or seminars but should not involve passing any examinations. They should not involve practitioners in substantial commitments of time or money, nor should they pose substantial difficulties of accessibility for country practitioners. Save in the initial stages, they should amount to only one day, or several evenings, per year in each field. Failure to attend the required courses in occasional years should be permissible. In order to reduce the danger of practitioners concentrating excessively on particular fields, the annual course in each field should include a brief outline of major developments in other fields. The courses could be supplemented by educational material distributed from time to time under the auspices of the general regulatory body.

6.31 Registration fee. This fee should be fixed at a level sufficient to meet all or most of the cost of the required continuing legal education But it is essential that the fee should not be so high as to constitute a significant barrier to registration including registration in a number of different fields.

6.32 We have explained earlier our reasons for not proposing more onerous qualifications. It may be noted here that of the three Canadian provinces in which advertising of “preferred areas of practice” is permitted, only the Ontario scheme requires practitioners to satisfy specified qualifications. ¹⁸

Other Possibilities

6.33 The package of qualifications which we have described above might be varied somewhat without becoming what we would regard as either too high level or too low level. But there are some possible qualifications which we do not favour and upon which we comment briefly below.

6.34 Examinations.Written or oral examinations are likely to be expensive to administer and are not necessarily a reliable guide to practical competence or expertise. Similar criticisms may be made in relation to requiring attendance at lengthy, non-examination courses.

6.35 Specified levels of concentration. We have referred earlier to some of the complexities and difficulties involved in the use of such levels. ¹⁹ It would be arbitrary and unfair to require the same level in each field and in each part of the State. And requirements concerning levels of concentration can operate unfairly and undesirably in relation to practitioners who are young, or are in small or outlying firms. Moreover, concentration is not an accurate indicator of those practitioners who are competent and those who are not. ²⁰ These arguments apply particularly to arithmetical definitions of concentration but they apply also to criteria such as substantial involvement. ²¹

6.36 References. We do not consider that requiring references from fellow practitioners is a desirable element in a fields of practice scheme. Practitioners may be thoroughly competent in a field, yet their work will not be well-known to many practitioners outside their own firm. Moreover, many practitioners may well have reasons for being unjustifiably compliant, or unreasonably uncooperative, in response to a request for a reference. A reference requirement provides great scope for abuse and is unlikely to be a reliable indicator of competence or experience.

IV. Description of Fields

6.37 Advertising under the scheme would need to be restricted to certain broadly-defined fields of practice. An excessive number of fields would foster over-specialisation in narrow fields and would cause fragmentation of the profession. Moreover, the time and money involved in providing continuing legal education would be unreasonable. The Legal Services Directory currently includes 14 fields of a broad nature. They are examples of the sort of field which might be suitable for adoption in a low-medium scheme.

6.38 We do not suggest any limit on the number of fields in which a practitioner should be permitted to register. The qualifications which we have suggested for the scheme are likely to deter most practitioners from registering in a large number of fields. But, in our view, the requirements should not be set at such a level as to deter an enthusiastic practitioner from registering in, say, three or four different fields.

6.39 We referred earlier to the importance of general practitioners within the legal profession and to the threat to the number and calibre of general practitioners which can arise from excessive encouragement of specialisation. ²² This process has caused great concern in the medical profession, and in recent years steps have been taken to establish General Practice as, in a sense, a specialty in its own right. ²³ In order to encourage an adequate supply of general practitioners within the legal profession we are firmly of the view that if a low-medium scheme is established, one of the fields covered by it should be General Practice.

V. Control of the Scheme

6.40 We described earlier the dangers of fragmentation of the profession into autonomous specialty groups with quasi-monopolies in their respective fields.²⁴ In our view, it is of paramount importance that the scheme, and especially the level of qualifications required in each field, should remain under the effective control of the general regulatory body for all solicitors. This would reduce the likelihood of, for example, excessively high qualifications being set in order to deter practitioners from entering a particular field and competing with those already in it. We stress effective control because it would not be sufficient if the general regulatory body were to act as no more than a rubber stamp for proposals made by specialty groups.

VI. The Law Society’s Proposals

6.41 We mentioned earlier the fields of practice scheme which the Law Society described in its response to our Discussion Paper and which it has circulated for discussion amongst its members.²⁵ That scheme differs from the low-medium scheme which we have described in four principal respects, namely

• it would permit practitioners to advertise themselves as “specialists", rather than as “preferring” or being “specially interested in” particular fields;
• it would require “substantial involvement’ in the field (such as spending 25% of one’s time in it);
• it would require the provision of references from five practitioners in the field;
• it would be limited, at least in its initial stages, to four fields of practice (Family Law and Divorce; Criminal Law - Magistrates Courts; Personal Injuries - Third Party; Personal Injuries - Industrial Accidents).

6.42 In our view, for reasons given earlier,²⁶ the Law Society’s proposed scheme is pitched at too high a level. Moreover, as we said in paragraphs 6.35 and 6.36, we do not favour specified levels of concentration or references from fellow practitioners, as qualifications. These weaknesses in the Society’s proposals are of particular importance in relation to fields of practice where many users of legal services are relatively unsophisticated and are unable to afford substantial legal fees. Yet it is in fields of this kind that the Law Society suggests its scheme should first be tried. We do not disagree with its choice of those fields as ones in which the need for wider dissemination of information about practitioners is especially great. But we consider that the case for a lower level scheme than that proposed by the Society is particularly strong in relation to those fields. As we mentioned earlier, the Society disagrees with our criticisms of its scheme and apparently prefers that scheme to the low-medium one which we have described above.²⁷

E. ASSOCIATIONS OF PRACTITIONERS IN PARTICULAR FIELDS

I. Introduction

6.43 We explained earlier our reasons for recommending that, although associations of practitioners interested in particular fields (“special interest associations”) can be beneficial they should not be permitted to become, in reality, the regulatory bodies for solicitors working in their respective fields. ²⁸ The general regulatory body should retain effective control over the professional activities of all solicitors. The Law Society has expressed its agreement with these principles. ²⁹ The following recommendations are directed towards their realisation.

II. Distinctions in Law or Official Practice

6.44 If membership of a special interest association is used as a basis for distinguishing by law or official practice (such as the practice of the courts, the Government or the Law Society) between practitioners, undue advantages may be conferred on members and unfair prejudice maybe caused to non-members. For example, suppose a court in a certain field of law (such as the Family Court) were to use membership of a particular association in that field as the criterion for compiling a list to be given to people who ask the court s staff for the name of a suitable lawyer in the field. In this way, members of the association could get an unfair advantage over non-members who have at least as much experience and expertise in the field.

6.45 The major danger of basing legal or official distinctions on membership of a special interest association is that it may significantly assist the association’s members to obtain a collectively dominant position in a particular field, and thus result in the association being able to unfairly restrict competition or in other ways adversely affect the public interest. If there is an effective system for regulation of restrictive practices within the profession, this danger may be reduced. But it will usually be preferable to avoid distinctions which contribute to the acquisition of quasi- monopoly power by an association rather than to try to control the manner in which that power, once acquired, is exercised.

6.46 Accordingly,werecommendthatdistinctionsinlaworofficialpracticeshouldrarelyif ever, be based on whether or not a solicitor belongs to a special interest association There may be some circumstances in which distinctions based on membership of such an association can be justified. We see no such circumstances at present but our recommendation does not exclude the possibility of them arising. We note that in its response to our Discussion Paper the Law Society said that it is opposed to any distinctions based on membership of special interest associations, but that it “has little control over such discrimination” ³⁰

III. Regulation of Restrictive Practices

6.47 In our First Report, we recommended the vesting in the Council of the Law Society of a statutory power to regulate restrictive practices amongst practitioners who are subject to its governance. ³¹ That recommendation would cover restrictive practices engaged in by practitioners as members of special interest associations. For example, it would regulate the extent to which associations could require their members to observe fee scales or refuse to accept work directly from clients. It would reduce the dangers of fragmentation of the profession to which we referred earlier in this Report.

6.48 We recommended in the First Report that the Council of the Bar Association should have a corresponding power to regulate restrictive practices amongst practitioners who are subject to its governance. ³² Many existing special interest associations include amongst their members lawyers who, under our recommendations in the First Report, would be subject to governance by the Bar Council as well as lawyers who would be subject to governance by the Law Society Council. Accordingly, it will be desirable for the two Councils to confer, and seek to co-ordinate, with each other in the exercise of their powers to regulate restrictive practices engaged in by special interest associations.

IV. Sections

6.49 We described in our Discussion Paper the growth of Sections under the auspices of some law societies in other parts of Australia. ³³ Many of these Sections consist of practitioners who are interested in a particular field of practice. In New South Wales, however, the only Section is the Young Lawyers Section.

6.50 Membership of each of these Sections is open to any member of the parent body on payment of a small fee. Their activities consist principally of lectures, seminars, distribution of educational material to members, and preparation of law reform proposals. The establishment of Sections requires the approval of the parent body, as do their rules.

6.51 In our view, Sections of this kind can do much to promote competence within the profession as well as having other benefits such as generating proposals for improvement of the law in particular fields. An important aspect of them in the present context is that they are subject to ultimate control by the general regulatory body, rather than being totally autonomous. This reduces the danger of excessively self interested policies being adopted to the detriment of the remainder of the profession and of the general public. The Law Society’s response to our Discussion Paper expressed agreement with these views. ³⁴

FOOTNOTES

1. Para. 3.21.

2. Chapter 12.

3. Chapter 13.

4. See our Discussion Paper, Advertising and Specialisation, chapter 2 and 4; and this Report, chapters 3 and 5.

5. See eg. Esau (note 1.28.1 above).

6. See paras.3.25-3.26 of this Report.

7. “The Certification of Legal Practitioners as Specialists in Particular Fields” Submission No.201), pp.8-9; and “Advertising and Specialisation” (Submission No.412) p.10.

8. See para.6.15-6.19.

9. Examples would include the Law Society Journal, the Australian Law News, and the Australian Legal Directory.

10. See American Bar Association, Standing Committee on Specialisation, Information Bulletin No.7 (1980), pp.18-22.

11. See para.3.18 of this Report.

12. A preferable description, used in the corresponding directory in South Australia, is “appeals against government decisions”.

13. See para.4.15.

14. Chapter 5 and paras.6.6-6.8 of this Report.

15. See paras.3.27 and 3.28 of this Report.

16. Report (Ontario Government Bookstore, Toronto, 1980) p.296.

17. Report (HMSO, Edinburgh, 1980, Cmnd. 7846), p.63.

18. See paras.3.27 and 3.28 of this Report.

19. See paras.3.3-3.7 of this Report; and our Discussion Paper, Advertising and Specialisation, pp.9-12.

20. See paras.5.35-5.43 of this Report.

21. See the sources cited in note. 6.35.1 above.

22. See paras.5.35-5.38 of this Report.

23. For discussion and relevant sources, see our Discussion Paper, Advertising and Specialisation, pp.54-56 and 209.

24. See chapter 5. esp. Paras.5.3-5.8 of this Report.

25. See paras.3.20-3.21 and 4.14 of this Report.

26. See chapter 5. and paras.6.6-6.8. of this Report.

27. See “Advertising and Specialisation” (Submission No.412).

28. See eg. paras.5.3-5.8 and 6.9 of this Report.

29. “Advertising and Specialisation” (Submission No.412), p.13.

30. See Source cited in note 6.41.2 above.

31. Paras.7.7-7.11.

32. Paras.7.7-7.11.

33. P.77

34. See source cited in note 6.43.2 above.