Saqib Bhatti
MP for Meriden and Solihull East · Conservative · United Kingdom
“My constituents in Meriden and Solihull East are greatly concerned about abuse of the European convention on human rights, including article 8. They deem cases like that of the Albanian criminal who was not deported because his son would not eat foreign chicken nuggets to be an insult.”
“I have lots of time for the Minister who will be closing the debate as well, but I have not heard him speak yet, so I will reserve judgment. The hon.”
“It is there to ensure that trade unions and the hand of the state can interfere with private enterprise. We are starting to see the consequences, which will only increase. My right hon.”
“The consequence of the Government’s policies is that youth unemployment is high, at 14.5%—much higher than when they took office in 2024—and among 16 to 17-year-olds it is 30.7%. Those are huge numbers, and I worry about them. I recently held a debate in Westminster Hall on the impact of the Government’s policies on rural pubs.”
“It is basic economics that interference in the labour market will have a consequence: naturally, business owners must make logical decisions and will decide to adjust their employment numbers accordingly; they will do what they can afford, and they must make a profit.”
“I thank my hon. Friend the Member for Mid Bedfordshire (Blake Stephenson) for his excellent speech. I agree with everything he just said. This is a really important debate, and the motion put forward by His Majesty’s Opposition is so significant for young people.”
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“As the Minister said, on 23 March the Department told universities that weekend courses do not qualify for funding. The Student Loans Company’s own guidance changed only this year, and the issue affected 20,000 students, including those in key professions, such as nurses. The Secretary of State has been taken to court by nine universities, the National Union of Students is demanding that she halt her clawback, and Martin Lewis has said that this is an almighty mess. I heard what the Minister had to say, but I know that this Government always find someone else to blame, so will he confirm that any aggressive debt collection will absolutely be stopped and that payments will not be demanded from innocent students?”
“While I will focus on the much-delayed White Paper, let me be clear to the Minister that His Majesty’s Opposition will work constructively with the Government where we see that meaningful progress can be made. I acknowledge that the system is creaking under its own weight. Since I was elected in 2019, almost weekly I have met parents who are tired of fighting a system that was designed to help them and that enshrines their rights in law, but has become a barrier to supporting their children. I have campaigned for those parents, so I want these reforms to work, but I say to the Minister that Opposition Members will not shy away from asking questions that are difficult for the Government to answer. We will not allow the Government to spin their way out of this, because too much is at stake.”
“I thank Members from across the House for contributing to a wide-ranging and passionate debate about an issue that affects each and every one of us, and many of our constituents. I thank my hon. Friend the Member for Farnham and Bordon (Gregory Stafford) for securing this important debate. He has been a passionate and determined champion for parents of children with special educational needs, and I thank him for all his hard work in this area. He was pragmatic and constructive, and he reflected what I have also heard from many parents, teachers and council leaders. I thank all the people who have contributed to the debate, specifically the parents who have reached out to have their voices heard today. This issue affects each and every one of us.”
“My hon. Friend makes the same point that has been made to me by many parents about the one-size-fits-all approach of these reforms. I want to give the Minister the opportunity to try to reassure some of those parents, because parents want answers and the children and families who are affected deserve them. I have spoken to many parents and representative groups. There is a huge amount of anxiety about these reforms—a view that is shared by many parent-carer forums—which has not been helped by the delay to the White Paper or the drip-drip briefings suggesting that EHCPs would simply be scrapped. The Conservative position is clear: any reforms that come forward must enshrine parental rights in law and the Government must not water down those rights.”
“Changes to EHCPs will not begin until around September 2030, so a child who is now six will be 10 or 11 before they and their family feel any difference from any reforms. For a family with a teenager, reform will never arrive in time. That point was made by the hon. Member for St Austell and Newquay (Noah Law). Will the Minister tell the House, according to her analysis, how many children will have left school entirely before a single EHCP reform takes effect?”
“I will take your lead, Madam Deputy Speaker. There is very little detail in the White Paper around deliverability. That concern has been raised to me by a number of council leaders, headteachers and parents. Even the Office for Budget Responsibility, the Government’s own independent watchdog, explicitly says that the impact of reform on underlying costs remains “uncertain”. It is for the Minister to provide that certainty, but the OBR is not convinced that the reforms will close the funding gap. When the Labour party was in opposition, it had 14 years to think about what it wanted to do, so I hope that the Minister can provide some of those answers today. The issue of timelines was raised during the debate. We all agree that the reforms are urgently needed, but full implementation is not expected until 2028-29 at the earliest.”
“Will the Minister confirm whether the Experts at Hand service will include support for children with dyslexia, and whether specialist dyslexia teachers will form part of that workforce? Let me turn to inclusion in the mainstream. At a recent meeting with Solihull school leaders last month, I heard serious concerns about the capacity pressures that the Government’s approach could place on mainstream schools. There was consensus around the principles, but there was also consensus that far more detail is needed on what inclusion actually means in policy terms and how gaps in staff training and funding will be filled.”
“Has the Minister spoken to the Health Minister? Has there been any progress? The Royal College of Speech and Language Therapists has been very clear that delivering the Experts at Hand service will require an SLT workforce to be incorporated into the 10-year workforce plan, with ringfenced funding. In a written question in March, I asked the Minister how many speech and language therapists will be required to deliver the Experts at Hand service. She gave a great answer, but she avoided giving me the answer that I needed on numbers, so I hope she can answer how many specialists will be needed and where they will come from. The British Dyslexia Association has also posed a question to me. One in three children in our classrooms need support for dyslexia.”
“We do welcome some points, including the principle of support in schools, evidence-led packages, and the idea of more speech and language therapists. There is broad consensus that earlier intervention is essential, and a statement of intent on that is most welcome. I want to focus briefly on speech and language therapists, because I campaigned on this issue as a Back-Bench MP with my constituent Mikey Akers and the famous footballer Chris Kamara. We met the relevant Health Minister more than a year ago; as Mikey said, in March 2024, he met the Minister for Care, the hon. Member for Aberafan Maesteg (Stephen Kinnock), who promised an action plan for speech and language therapy, but more than one year on we still have not seen anything. A point has been raised about liaising with the Department of Health and Social Care.”
“I will come to councils and their funding shortly, but my right hon. Friend makes a really valid point. I hope the Minister heard him and will be able to provide an answer. A number of parents have written to me, asking if I can put their questions directly to the Minister. Natasha and Lindy want to know why a dilution of parental rights has been proposed. Why are the Government removing the legal right to appeal, especially when 98% of cases are currently won by parents and carers? My right hon. Friend the Member for Salisbury (John Glen) made this point very eloquently. If the logic is to reduce the cost of provision by removing some of those rights, the Minister should say so plainly. Parents need that clarity and that level of honesty.”
“When the Minister was asked about that previously, she used the word “scaremongering”, but these are not our figures; they are figures from the OBR, based on information provided by the Government. Will the Minister confirm how large the shortfall is? Having looked at the numbers, I think it has shortened, but maybe she will be able to give a bit more clarity. If the gap was funded entirely from in the DFE’s £69 billion budget, it would imply a 4.9% real fall in mainstream schools’ spending per pupil—this is according to the OBR, by the way. There is no spending review until 2028-29, so maybe the Minister can give me some clarity on which Departments might be giving up their money for the sake of these SEND reforms. I hope she can provide some answers; I will write to her with the questions that I have not been able to ask.”
“I could not have said it better myself. That issue was in my borough, but the truth is that there are special schools across the country where the funding has been taken away. This is going to be essential, because we cannot have a one-size-fits-all approach. Will the Minister explain to those teachers how mainstream schools will be supported in terms of capacity, funding and training as these reforms are rolled out? The founder of the North Solihull Additional Needs Support Group has asked if there will be a legal backing for ISPs, and a number of Members have also made points on enforceability. I want to get straight to the funding point, which is where I will end my remarks. At the Budget, the OBR identified a £6 billion SEND funding black hole.”
“My hon. Friend talks about it being worth the risk, but this is not just about denigrating those victims; it is also about those Labour Back Benchers that the Prime Minister is marching up the hill. It is worth the risk for him to march them up the hill, then do a U-turn later and finally admit after many months that he knew all along?”
“For months the Conservatives have been pushing for clarity so that we can discover the truth about what was going on with Lord Mandelson’s appointment. This goes to the heart of our politics. What did we find out today when the Leader of the Opposition challenged the Prime Minister? He had run out of road and finally had to come clean about the fact that he knew about this relationship. As for the idea that we need to know the depth of the relationship, let me ask Labour Members this: how deep does a relationship with a paedophile need to be before it becomes eligible for declaration?”
“They did not demonstrate leadership. They got here because they were dragged here; they got here because there had been a dump of documents by the Department of Justice, the Leader of the Opposition tabled a motion that forced their hand, and they finally had to confront the fact that Peter Mandelson had a relationship with Epstein for much longer than many of us knew—although certainly the Prime Minister knew, as we found out earlier today. The idea that the Government have demonstrated leadership is for the birds. I have heard Members on both sides of the House talk about the victims of Epstein, but I say to Labour Members that those are just words if they are not followed up with action. Although the ISC amendment is important, it is not the end of the journey.”
“It is a great honour to follow my hon. Friend, although I have to say that was one of his shortest speeches. We come here for a serious matter of the utmost gravity. I have heard a number of good speeches from all parts of the House, including Members on the Government Benches. I commend all those Members who have stood up and said that they are not happy with the Government’s position. That is not an easy thing to do. I am pleased that there is now a manuscript amendment that will force the Government’s hand and ensure that the ISC has a pivotal and critical role. A number of observations have been made today, some of which I agreed with and some of which I did not. I did agree with a great many of them, but a couple of Members said that the Government had demonstrated leadership in getting to this point.”
“I agree with my hon. Friend. We were sitting together earlier in the debate and reflecting on some of the speeches. I think it was the Health Secretary who talked about the “toxic culture” at No. 10. The amendment was a demonstration of that toxic culture. It was not tabled for the victims of Jeffrey Epstein; it was tabled to protect the Prime Minister.”
“We should all share anger about that, because it speaks to a rot that, as we are finding out, has infected our politics and Government—Labour Government—in this country for decades. I understand that people make mistakes, in all parts of the House, but this is of such gravity that it speaks to a corruption that we need to get to the heart of. What my right hon. Friend has just said is extremely important, because this is one issue involving corruption, but we cannot get away from the fact that Mandelson had a role at every echelon of the Labour party’s journey—whether it was new Labour before we came to power in 2010 or the “new new Labour” that is now in charge; whether it was helping in the selection of candidates, or—Members are shaking their heads. I am more than happy to take an intervention.”
“I am glad to say that I did not mention any single Member of the House, so I am happy that the hon. Lady has put that on that record, but I do not trust Mandelson— [Interruption.] I am responding to the hon. Lady’s intervention. I do not trust Mandelson following what he has done, and I do not know how far his reach was in this Government or in that party. I do not trust him because we know he had a very close relationship—”
“The hon. Member can shake her head all she wants; we know that Mandelson had a close relationship with Morgan McSweeney, the Prime Minister’s chief of staff. The Labour party has not even started to address that point about the chief of staff. I hope the hon. Lady is right, by the way, but if she is not and documents do come to the fore, I am sure we will come back to this House to scrutinise which Members he had a hand in appointing.”
“I could not have said it better myself—although I might not have used the word “you”. It is important to recognise the reach that Mandelson had, how he was enabled, and the fact that, at every step of the way, there was no regard for Jeffrey Epstein’s victims. That is a really important point, because there has been a lot of obfuscation today. We have had to drag the Government into tabling the new amendment so that they will now release the documents to the ISC. Hon. Friends have made important points about the role of the ISC. I say again that this is not the end of the journey; Labour Members have a role to play in doing right by the victims. What we know is that Mandelson was an enabler, so anyone who has enabled Mandelson needs to take a long, hard look at themselves.”
“That journey is not over yet, because he is going to use those people over and over again; he will throw other people under the bus before he throws his chief of staff under the bus—but that will happen too, I can almost guarantee it.”
“Well, it is not bizarre, because we have been here many times before. The Government have been dragged along time after time, scandal after scandal. I say to Government Back Benchers: this is a Prime Minister who is flailing. He has admitted, after months and months of pushing, that he knew—he knew about the relationship that Mandelson had with Epstein, and yet he thought it was a risk worth taking anyway. I made this point earlier, but that “risk” was not just in denigrating the experience of the victims; it was in marching all those Labour Members up the hill and risking their careers. We are Members of Parliament; it is okay that we care about our careers, wherever they may end up, but the truth is that the Prime Minister did not care about them.”
“My right hon. Friend’s exasperation is exactly the exasperation that the British public will be feeling as they read the headlines. That is how they have felt as the stories have unfolded over the last few days and months. This speaks to a fundamental point: the toxicity at No. 10. The rot starts at the top. Labour Members have the authority and the power to do something about this. The relationship that Mandelson was obvious to all of us. It was obvious to us when the Prime Minister appointed him to one of the most important positions in our country—and to a position in one of the most important capitals in the world—but the Prime Minister did it anyway, because he thought it was a risk worth taking.”
“We all know that trust in politicians is at an all-time low—we see it on the doorstep and in our inboxes. I was at a birthday party with my four-and-a-half-year-old son at the weekend. I was chatting to some parents, and the Mandelson headlines came up. I had to say, “Look, it’s not normal for a billionaire to fly politicians out. We have a pretty strict expenses regime following the expenses scandal.” We cannot move left or right, yet the British public do not trust us, because they think that we take them for granted. I had to explain to those parents that it is not normal to be invited to islands and to have luxuries thrown at you. This was not normal behaviour, yet the Prime Minister knew about this relationship and let it happen. That is a really important point.”
“My hon. Friend always makes excellent points. I was going to talk about Gordon Brown later, but I will do so now. He raised the question back in September. He wanted to know what had gone on, and he was batted away. Has the Minister asked the Cabinet Secretary why the former Prime Minister was batted away? Did that former Prime Minister not have enough respect in No. 10 to get a legitimate answer about what went down? The public deserve to know, and this House deserves to know. I want to make another point about integrity, which was raised by a number of Members earlier, including my right hon. Friend the Member for Skipton and Ripon (Sir Julian Smith). The Prime Minister, by his own admission, has called into question the integrity of every Member of this House.”
“The reality is that there is clearly a culture of men who thought they were above the law, and the DOJ is grappling with that issue over in America. We have talked about some very important things in today’s debate, for which I commend hon. Members, but we have to be honest about the fact that this matter came on to our shores. It is possible that there are victims whom we still do not know about, and that criminal investigations still need to happen. I need an assurance from Ministers that if that comes to the fore, the Government will act quickly to make sure that criminal investigations are started. The public require that to help us on the journey towards rebuilding trust, and we should not underestimate the need for that.”
“I find it disgusting. What Epstein did was absolutely disgusting in its own right: he trafficked, he was a child sex offender, and in many ways he was a coward in how he left this world. I wish he had faced the full force of the law. The hon. Member for Bolsover (Natalie Fleet) talked about enablers and the role that powerful men played. I say to Labour Members that they are at a crossroads. If they really care about Epstein’s victims, they need to ask how this was allowed to happen. By the way, it is not just about Mandelson and Epstein. My hon. Friend the Member for Rutland and Stamford (Alicia Kearns) made a point about Bill Gates. I watched the video of Melinda Gates yesterday, and I was talking to my wife about how horrible it must have been to see the emails and what he was up to. My hon. Friend also mentioned Richard Branson.”
“The Prime Minister has brought his judgment into question. The Opposition have been saying that for a couple of years—Oppositions do that—but on this issue, he has marched everyone up the hill and Ministers have gone out to defend him on this issue time and again. His position really is now untenable. I guarantee Labour Members that when they go home and talk to their constituents, they will have to answer questions about why the Prime Minister allowed this to happen.”
“I will leave Labour Members to reflect on that because many have spoken up today, but I say once again that they are just words if there is no action. The judgment of the Prime Minister is deeply, deeply flawed. He alone is responsible for the culture at No. 10. I ran a business. If something was going wrong, the buck stopped with me. He alone is responsible for the culture at No. 10. It is not Morgan McSweeney. He enabled Morgan McSweeney. He needs to be held accountable for his relationship. We need to see the emails and we need to see what the conversations were—that is why this is important—but the buck stops with the Prime Minister.”
“We need to know that under the amendment, it will have the full authority to deal with what comes in front of it, so that we and the public can make a judgment. Secondly, why did Gordon Brown’s calls fall on deaf ears? Why was he not given the respect, as a former Prime Minister, of his calls being dealt with? Was Mandelson so strong that, despite his toxicity, he was protected and enabled? Finally—I have made this point repeatedly—the judgment of the Prime Minister surely has to be in question. We will now find out what else was known. The Minister has the opportunity to share anything else that he might want to share at the Dispatch Box.”
“I will end with two responses to that intervention. First, my right hon. Friend is obviously absolutely right. I say to Labour Members, who were shaking their heads, that every decision—every decision—the Government have made is brought into question by the lack of judgment the Prime Minister has shown. I stood at the Dispatch Box and repeatedly called for a national grooming inquiry. I am a British-Pakistani Muslim male. I have two sons. I want them to grow up without aspersions being cast on them. One day, I hope to have a daughter—apologies to my wife—and I want her to grow up in a safe environment. We have to be honest and we have to be strong in making those calls. I say to the Minister, as he answers those questions, that the question about the ISC is really important.”
“My right hon. Friend is making a serious and important point. She has talked about how she ended up in this place, and I do not think anyone should denigrate all the hard work she has done to achieve what she has.”
“If the Government truly want to give children the freedom to learn and grow through play, they should confirm that they are committed to ensuring that the core skills of reading, writing and numeracy, which children need to succeed, will be part of that. If more play is needed for children, there is another way of achieving that. I would like to talk about the use of screens by children. According to Ofcom, 25% of children—”
“It was Sir Tony Blair whose Government championed the initial academisation of schools. I know he is greatly concerned about this, because it is a reversal of 30 years of consensus around academic achievement and development. Although we also welcome the curriculum review, I have worries. It was a relief that the Government chose not to follow the example of their counterparts in Labour-run Wales by dropping phonics from the curriculum. However, as the Opposition have stated at the Dispatch Box, if everything is a priority, nothing is. If the Government want more play, they need to make clear which part of the curriculum has to be pushed to the side, and will stand to suffer, as a result.”
“I know that many hon. Members have pointed out that that is not what they are talking about, but there must be clarity about how play is delivered, because we all agree that we are preparing our children for the future. That desire for freedom is why the official Opposition strongly oppose parts of the Government’s Children’s Wellbeing and Schools Bill that restrict academy freedoms and seek to impose a one-size-fits-all approach on our education system. Why does the Education Secretary think that centralising decision making in Whitehall is more effective than empowering school leaders? The transfer of power from headteachers to unelected officials at the Department will be deeply damaging for children, and will see their education suffer as a result. It is not just the Conservatives who believe this.”
“It is thanks to the knowledge-rich curriculum, underpinned by phonics, introduced by the last Government under the excellent leadership of Lord Gove and Sir Nick Gibb, that primary school children in England are now the best readers in the western world, with 80% of six-year-olds now reaching the expected reading standard, compared with only 58% in 2012. Millions more children are in good or outstanding schools, with tougher exams, better teaching standards, a rigorous curriculum and thousands of new academies. I say that because, having heard the debate, it is important to be clear about what we are discussing. While play should certainly be part of that delivery, we believe that schools are best placed to decide how the curriculum is delivered to their pupils, and it is important that precious time in the classroom is not missed out on.”
“Indeed, without play, none of these other achievements would be possible.” That is why the early years foundation stage statutory framework includes play in delivering learning and development. The official Opposition support that framework, which sets out this responsibility for early years education providers. As a father of two young children, I recognise the importance of play. I know that key stage 1 is a crucial time in a child’s learning and development, when children are set up for future academic success based on the foundation of knowledge and learning skills they receive when they first start school.”
“Friend the Member for South West Devon (Rebecca Smith), who made an excellent contribution, highlighting the need for consistency; I echo her question for the Minister on that point. Having heard hon. Members at length today, it is quite clear that we all accept that play has an important role in children’s cognitive and social development, particularly in their early years. There is strong evidence to suggest that play is an important factor in a child’s development. It teaches young people resilience, problem solving and social skills, enhances cognitive development and so much more. Dr David Whitebread of the University of Cambridge argues: “Play in all its rich variety is one of the highest achievements of the human species, alongside language, culture and technology.”
“It is a pleasure to serve under your chairmanship, Mrs Barker, and to take part in this debate on play in the key stage 1 curriculum. First, I thank the 106,082 signatories of this petition, including the 200 signatories from my constituency. I thank the hon. Member for South Cotswolds (Dr Savage) for her opening remarks, and I also wish the son of the hon. Member for St Helens North (David Baines) a very happy birthday, on behalf of His Majesty’s official Opposition. I am sure that is all he ever wanted. I praise the contributions from all hon. Members. It has been a thoughtful debate, which covered a whole array of issues. We may not agree on all aspects, I found it very fruitful to consider the different points of view. In particular, I commend my hon.”
“We have called for the use of phones in schools to be officially banned to allow for greater standards in schools. We are worried about the fact that children now spend more time online. Just last week I read reports that some young people try to swipe, and even tap, on books because they use digital devices.”
“Absolutely, Mrs Barker. The point that I was going to make was that if children are not using social media, that will free up more time for play. That is why that issue is really important. We all want to achieve the same things: more resilience and more capability. Hopefully the Minister will confirm whether the Government agree with us that the use of screens at such a young age can have a detrimental effect, and confirm whether they will progress with the evidence. I accept that many parents are simply trying to do their best, and they want to have the best opportunities for their children. That is why I implore the Government to take a deep, hard look at the official Opposition’s approach to the use of screens and social media, and to the use of phones in schools.”
“I made that very clear. We support the education statutory framework as it is, but I think that the questions around social media and the use of phones are really pertinent. That is what parents are writing to us, as Members of Parliament—”
“I thank all hon. Members who have contributed to the debate, and those people who signed the petition. The Opposition recognise the importance of play, which is why we challenge the Government to give further clarity on the development of the curriculum review, and what will be part of it. If everything is a priority, nothing is, so what will be part of that debate? I also challenge the Government to give more clarity about the freedom of schools, as asked for by my hon. Friend the Member for South West Devon.”
“I note that the Minister, in response to my hon. Friend the Member for Farnham and Bordon (Gregory Stafford), said that the Budget gave much clarity, but the reality is that the Office for Budget Responsibility analysis highlighted a £6 billion funding gap. I almost feel sorry for the Education team, because the Chancellor has backed them into an uncomfortable corner with her own Back Benchers with nowhere to turn, but they do need to be honest with parents and teachers who rely on these provisions. So again we ask: how do they intend to fill the £6 billion black hole hanging over the Department? Will there be cuts to services or to schools?”
“That was a disappointing answer. The Government have been hiding behind the Cass review, which was published more than two years ago, for months. In April last year, the Education Secretary promised to publish the guidance by the end of the year, to give schools and teachers much needed clarity on these sensitive issues. That deadline has been spectacularly missed, and schools have been left in limbo to figure this out themselves. I implore the Secretary of State and the ministerial team to put ideology aside and finally act to protect our children. Will they do that?”
“That example, and the example mentioned by my hon. Friend the Member for Mid Buckinghamshire (Greg Smith), illustrates Labour Government spin perfectly. That £3 billion is short-changing parents and children with special educational needs. The decision to cut schools was rolled out without scrutiny, slipped out before the Christmas recess. Some 46 free schools and 18 special schools have been axed, with a further 59 in doubt. Why did the Secretary of State cancel the much-needed special schools and make life harder for families and children with SEND?”
“Those who run pubs in my constituency are really worried about the Budget and its impact on their business rates bills. Last week the Business Secretary said that there was no way the Government could have known about the impact of their decisions, but the valuation office then confirmed that it had told Ministers about the impact of their decisions, which I think the Minister has confirmed. He also confirmed that that data was easily accessible, so why did that happen? Was it wilful ignorance, was it incompetence or did they just go ahead anyway?”
“This right is set out in Magna Carta—and how clever they were in 1215 to come up with a legal mechanism that made sure that individual citizens have the right to pass judgment on their peers. This mechanism goes right to the heart of our society and shapes the relationship between the individual, or group of individuals, and the state. That is so the state cannot abuse its power in making a decision about taking away someone’s liberty or livelihood, or their reputation; a panel of peers makes that judgment. That is what is at stake.”
“It is an honour to follow the hon. Member for Derby North (Catherine Atkinson). I listened to her speech very closely, and it was largely invalidated by the admission of the Minister that she would have made this change anyway, irrespective of any backlog. The hon. Member cannot guarantee the House—neither can the Minister—that the backlog would come down after the abolition, or partial abolition, of trial by jury, because there has been no impact assessment or modelling shown to the House. I am sure that the hon. Member will concede that. The Minister is making this change under the guise of modernisation, but we must be very clear about what is at stake: 800 years of legal precedent.”