First-tier Tribunal Grants Landlord Dispensation for Long-term Insurance Agreement

OUTCOME: Allowed

1

FIRST-TIER TRIBUNAL PROPERTY CHAMBER (RESIDENTIAL PROPERTY) Case reference : BIR/00CN/LDC/2024/0018 Properties : Various Properties in the ownership of [APPELLANT] as Landlord Applicant : [redacted] : [APPELLANT] Respondents : [redacted] this decision Representatives : None Type of application : An application under section 20ZA of the Landlord and Tenant Act 1985 for the dispensation of the consultation requirements in respect of qualifying works Tribunal member : Judge C [NAME] and place of hearing : Paper determination Date of decision : 13 December 2024

DECISION

© CROWN COPYRIGHT 2024

2 Decision We determine that the Application is granted. The Applicant may dispense with the consultation requirements contained in section 20 of the Act in respect of the entering into of a long term qualifying agreement with [COMPANY]. The grant of dispensation is conditional upon the Applicant not seeking any of its costs of the Application from any Respondent.

Background

1. The Applicant has applied for a decision by this Tribunal that it may dispense with the consultation requirements contained in section 20 of the Landlord and Tenant Act 1985 and the Service Charges (Consultation Requirements) (England) Regulations 2003 in respect of a qualifying long term agreement to provide insurance services to insure its portfolio of residential properties. These legal provisions are explained in more detail below.

2. Unless there is full compliance with the consultation requirements, or a dispensation application is granted, the Applicant is prevented by law from recovering more that £100.00 per Respondent in respect of costs under the QLTA. Therefore it has made the Application, which was dated 8 April 2024. The Application contained a detailed Statement of Case setting out the reason for making the Application.

3. Directions were issued requiring the Applicant to serve all the Respondents with a copy of the Application and explaining why it had decided to seek dispensation rather than carry out a full consultation.

4. The Respondents were all given an opportunity to respond to the Application and make their views known as to whether the Tribunal should grant it. Two objections were received which are dealt with below.

5. The Application has been referred to the Tribunal for determination. This is the decision on the Application. Law

6. The Landlord and Tenant Act 1985 (as amended) imposes statutory controls over the amount of service charge that can be charged to long leaseholders. the costs incurred can only be taken into account in the service charge if they are reasonably incurred or works carried out are of a reasonable standard (section 19).

7. Section 20 imposes an additional control. It limits the leaseholder s contribution towards a service charge to £100 for payments due under a long term service agreement been either complied with or dispensed with. There are thus two options

3 for a person seeking to collect a service charge for services under a long term agreement (i.e. for a term of more than 12 months) costing more than £100. The two options are: obtain dispensation from them. Either option is available.

8. To comply with consultation requirements a person collecting a service charge has to follow procedures set out in the Service Charges (Consultation Requirements) (England) Regulations 2003 (see section 20ZA(4)).

9. To obtain dispensation, an application has to be made to this Tribunal. We may grant it if we are satisfied that it is reasonable to dispense with the consultation requirements (section 20ZA(1) of the Act).

10. in an application under section 20ZA is therefore not to decide whether it would be reasonable to enter into the long term agreement, but to decide whether it would be reasonable to dispense with the consultation requirements.

11. The Supreme Court case of [COMPANY] v Benson [2013] UKSC 14; [2013] 1 WLR 854 (hereafter [NAME]) sets out the current authoritative jurisprudence on section 20ZA. This case is binding on the Tribunal. [NAME] requires the Tribunal to focus on the extent to which the leaseholders would be prejudiced if the landlord did not consult under the consultation regulations. It is for the landlord to satisfy the Tribunal that it is reasonable to dispense with the consultation requirements; if so, it is for the leaseholders to establish that there is some relevant prejudice which they would or might suffer, and for the landlord then to rebut that case.

12. The Tribunal may impose conditions on the grant of dispensation.

13. The general approach to be adopted by the Tribunal, following [NAME], has been summarised in paragraph 17 of the judgement of His Honour Judge Stuart Bridge in Aster Communities v Chapman [2020] UKUT 0177 (LC) as follows:

The exercise of the jurisdiction to dispense with the consultation requirements stands or falls on the issue of prejudice. If the tenants fail to establish prejudice, the tribunal must grant dispensation, and in such circumstances dispensation may well be unconditional, although the tribunal may impose a condition that the landlord pay any costs reasonably incurred by the tenants in resisting the application. If the tenants succeed in proving prejudice, the tribunal may refuse dispensation, even on robust conditions, although it is more likely that conditional dispensation will be granted, the conditions being set to compensate the tenants for the prejudice they have suffered.

4 The Application 14. The Applicant has a portfolio of properties, with 4,533 tenants. Each has an obligation to pay a contribution towards the insurance premium payable to insure the properties. The Applicant procures insurance through one single block policy for the whole portfolio, in order to secure economies of scale and keep the premiums and the administrative burden as low as possible. 15. insurance are that insurance policies are ordinarily placed on an annual basis; the Applicant's insurance renewal date is 1 April in each year. The previous insurance policy, which expired on 31 March 2023 was placed with [NAME].

16. In advance of the expiry of the Zurich Policy, the Applicant appointed [APPELLANT], the leading insurance consultancy for [NAME] across England and Wales, to advise in respect of the placement and tendering of the block policy for the portfolio.

17. GLC were appointed as they are a leading insurance consultancy, but they are independent from [NAME] and brokers, ensuring the Applicant would receive impartial advice. Their role was to ensure that a formal and compliant tender process was undertaken. This process commenced in July 2022.

18. The residential block insurance market is currently facing industry wide increases, with some [NAME] being unwilling to insure certain blocks. The main factors impacting upon the premium include: a. inflation; b. increase in the cost of rebuilding and repairs c. a considerable increase in the number of claims with an increase in the value of those claims; d. a high cost for reinsurance, due to significant international events but notably the Covid-19 pandemic, and large scale fires and storms; and e. changing legislation and risk profiles of blocks, notably due to the Building Safety Act 2022 and the consequential fire safety investigations which have identified defects in the construction of various buildings.

19. The industry wide increases in the insurance premiums has a consequential impact upon the insurance for the [NAME] and, in turn, the cost for each of the Respondents. Given the cost of living crisis, the Applicant was keen to limit any increases that would be suffered by the Respondents.

5 20. Advice provided to the Applicant indicated that it would achieve a better premium (to the financial advantage of leaseholders) if the policy were placed for a longer term; by providing the financial commitment to the insurer, it allows the Applicant to negotiate a better premium.

21. It was therefore agreed that the policy would be put out to tender. Given the value and size of the contract, the insured items to be covered were split into categories or "lots". The purpose of splitting the insurance into lots was to allow for maximum interest in the insurance market, and also to attract specialist risk [NAME]. 22. [NAME] who might be interested in the contracts for insurance were initially sought via [NAME] were then selected for inclusion on a shortlist based on their financial standing and technical and professional capacity. A process of shortlisting potential [NAME] via selection questionnaires, receiving price proposals, hearing presentations, receiving final tender proposals, issuing a letter of intent, and finally awarding a contract took place over the period from August 2022 to March 2023. The highest scorer in this process for cost, quality and sustainability was [NAME], to whom the insurance contract was awarded on 23 March 2023.

23. During this time, a parallel consultation under the Regulations had taken place with the [COMPANY] through the issuing of a Notice of Intention and a Notice of Proposal.

24. Around the time of issuing the Notice of Proposal, the Applicant discovered that due to an administrative error, the Notice of Intention was not given to the Respondents. The Applicant therefore wrote to the Respondents on 31 January 2023 to apologise for this oversight and to provide them with a copy of the Notice of Proposal, and invite their written observations. The Respondents were asked to provide written observations by 5 March 2023.

25. The Applicant did not receive a response to the letter dated 31 January 2023 from any of the Respondents, nor did it receive any observations on the Notice of Proposal. 26. [NAME] have objected to the Application. The first is from the [NAME] of a flat in [ADDRESS] in Birmingham. Summarising their objection, their concern is that the granting of dispensation will open the floodgates to the weakening of the statutory protections that parliament has enacted for the benefit of tenants. They suggest that granting dispensation will reduce the value of their property and may make it unsaleable. They also expressed concern that they were not able to access the documents relating to the Application in good time. Finally, they suggest that the costs of this case should not be added to the service charge.

6 27. The second [NAME] is the lessee of a flat in [ADDRESS], Halesowen. She is of the view that the Applicant should have had the knowledge and resources to be able to ensure that procedural mistakes did not occur, and she does not feel she should incur the burden of costs arising as a result of the Application. 28. [NAME] also requested that the Tribunal should hold a hearing. They were invited by letter to confirm they wished to participate at a hearing by making oral representations or calling evidence. Neither responded to the letters. Discussion and decision 29. Our view is that the Application was brought because of the administrative error described above. Dispensation is requested because otherwise the Applicant will be unable to recover the real cost of insurance premiums from the Respondents, as they will be limited to recovering the statutory cap of £100 from each of them.

30. The Tribunal accepts the rationale for making the Application. [NAME], it has been clear that the grant of dispensation or otherwise should not be an exercise in punishing the landlord for not carrying out a full section 20 consultation. The Tribunal should concentrate on whether prejudice is suffered through the lack of full section 20 consultation.

31. Neither of the objectors has explained how they might be prejudiced by not having been part of the consultation exercise, and all the Respondents were given a belated opportunity to raise issues of concern before the insurance contract was finally granted. None did.

32. No Respondent appears to the Tribunal to have suffered or be likely to suffer any prejudice as a result of the grant of the Application. We do not accept that the first [NAME] will have suffered any loss of statutory rights, or that the impact of being obliged to pay their contractual contribution towards the insurance premium for their flat will have any impact upon its value or saleability.

33. So far as the first objectors issue about accessing the documents relevant to the Application is concerned, it appears to us that whilst there may have been an initial difficulty, this was resolved and those objectors have not been denied an opportunity to make their representations in the light of the same documents that the Tribunal has seen.

34. We therefore determine that the Application is granted. The Applicant may dispense with the consultation requirements contained in section 20 of the Act in respect of the entering into of the long term qualifying agreement with [COMPANY].

35. Two issues remain. Should the Tribunal have had a hearing of the Application, and costs. Both objectors have specifically objected to having to pay any costs arising from the Application.

7 36. On the first issue, the Tribunal is obliged to have regard to the overriding objective set out in Rule 3 of the Tribunal Procedure (First-tier Tribunal) (Property Chamber) Rules 2013, which includes dealing with cases in a way that is proportionate to the importance of the case, the complexity of the issues, the anticipated costs, and the resources of the parties and the Tribunal. Our view it that in the light of there being no response to the letters referred to in paragraph 28 above, holding a hearing would have been disproportionately costly and we have not done so.

37. On the question of costs, the Applicant has been entirely open in the Application that the reason the Respondents were not included in the section 20 consultation process that was properly carried out by the Applicant for the other 4,154 tenants of the Applicant was due to an administrative error, though no details of the error have been provided. The Tribunal assumes that had the error not been made, the Respondents to this application would have been included in the consultation, and the Application would not have been required.

38. We find it difficult to reach any other view than that the costs of this Applicant.

39. We have not been provided with any copies of the leases of the properties. We do not know whether they, or any of them, allow the costs of the Application to be passed on to the Respondents. If they do, the Respondents would have a right to bring proceedings under section 27A of the Landlord and Tenant Act 1985 to challenge the inclusion of the costs of these proceedings in any service charge levied.

40. The list of Respondents supplied to the Tribunal does not identify how many properties the Application relates to, but the addresses suggest there may be upwards of 40 separate properties.

41. We have considered whether to leave the question of costs alone in this decision as it has not been raised by 375 of the 377 Respondents, allowing the Respondents who wish to challenge any costs liability to do so individually under section 27A.

42. However the sheer logistical challenge of managing a large number of applications objecting to costs being claimed, and achieving any consistency in approach, leads us to consider that we should make the grant of dispensation in this Application conditional upon the Applicant not seeking any of its costs of the Application from any Respondent. That seems, to us, to be the fair and logical decision.

43. In accordance with the Directions given in this case, the Applicant shall place a copy of this decision together with an explanation of the shall maintain it there for at least 3 months, with a sufficiently prominent link to both on their home page.

8 Appeal

44. Any appeal against this decision must be made to the Upper Tribunal (Lands Chamber). Prior to making such an appeal the party appealing must apply, in writing, to this Tribunal for permission to appeal within 28 days of the date of issue of this decision (or, if applicable, within 28 days of any decision on a review or application to set aside) identifying the decision to which the appeal relates, stating the grounds on which that party intends to rely in the appeal, and stating the result sought by the party making the application.

Judge C Goodall Chair First-tier Tribunal (Property Chamber)

1 [NAME] 40 [NAME] [NAME] 2 Mr & [NAME] [NAME] 41 Mr [NAME] & [NAME] J [NAME] 3 Mr [NAME] A [NAME] 42 Miss [NAME] 4 Mr [NAME] & [NAME] [NAME] 43 [NAME] [NAME] 5 Mr & [NAME] [NAME] 44 [NAME] [NAME] 6 Miss [NAME] 45 [NAME] [NAME] 7 Mr [NAME] & [NAME] [NAME] 46 [NAME] [NAME] E [NAME] 8 Mr [NAME] & [NAME] [NAME] 47 [NAME] [NAME] J [NAME] 9 Mr [NAME] 48 Mr [NAME] & [NAME] [NAME] 10 [NAME] [NAME] 49 [NAME] [NAME] 11 [NAME] [NAME] 50 [NAME] [NAME] 12 Mr [NAME] & [NAME] [NAME] 51 Mr [NAME] 13 [NAME] [NAME] 52 [NAME] [NAME] 14 [NAME] [NAME] 53 Mr [NAME] 15 Mr [NAME] 54 [NAME] [NAME] 16 [NAME] [NAME] [NAME] 55 [NAME] [NAME] 17 Mr [NAME] 56 Mr [NAME] 18 [NAME] [NAME] 57 [NAME] & [NAME] [NAME] 19 [NAME] [NAME] 58 [NAME] [NAME] [NAME] 20 Miss [NAME] 59 [NAME] [NAME] 21 Mr [NAME] 60 [NAME] [NAME] 22 Mr [NAME] & [NAME] [NAME] 61 Mr [NAME] 23 [NAME] [NAME] E [NAME] 62 [NAME] [NAME] [NAME] & [NAME] [NAME] 24 [NAME] A [NAME] 63 [NAME] [NAME] 25 [NAME] N [NAME] 64 [NAME] [NAME] 26 [NAME] [NAME] 65 Mr [NAME] 27 [NAME] [NAME] 66 Mr [NAME] & [NAME] [NAME] 28 Miss M [NAME] 67 Mr [NAME] 29 Mr [NAME] [NAME] 68 [NAME] [NAME] 30 The Estate Of [NAME] M [NAME] 69 [NAME] [NAME] 31 [NAME] [NAME] 70 [NAME] [NAME] 32 [NAME] [NAME] 71 Mr [NAME] 33 Mr [NAME] 72 [NAME] H [NAME] 34 [NAME] [NAME] 73 Miss E [NAME] 35 [NAME] [NAME] 74 Mr H [NAME] 36 Mr [NAME] 75 Mr [NAME] 37 [NAME] [NAME] 76 [NAME] 38 [NAME] [NAME] 77 Mr [NAME] & [NAME] [NAME] 39 [NAME] V [NAME] 78 [NAME] [NAME] RESPONDENTS

79 Mr [NAME] 119 Mr [NAME] And [NAME] [NAME] 80 [NAME] [NAME] & Mr [NAME] 120 Mr [NAME] & [NAME] [NAME] 81 Ms [NAME] 121 [NAME] [NAME] 82 [NAME] [NAME] 122 [NAME] [NAME] & [NAME] 83 Miss [NAME] 123 Mr G & [NAME] 84 [NAME] 124 [NAME] 85 [NAME] 125 [NAME] 86 The Estate Of [NAME] 126 Mr G & [NAME] 87 [NAME] [NAME] 127 Mr [NAME] & [NAME] [NAME] 88 Miss [NAME] 128 Miss [NAME] & Mr [NAME] 89 [NAME] [NAME] 129 Mr [NAME] & [NAME] [NAME] 90 Mr [NAME] 130 [NAME] [NAME] 91 Mr [NAME] 131 Mr J & [NAME] [NAME] 92 Mr [NAME] & [NAME] [NAME] 132 [NAME] 93 [NAME] 133 Mr B & [NAME] [NAME] 94 [NAME] [NAME] 134 Mr [NAME] & [NAME] [NAME] 95 Mr [NAME] 135 Mr [NAME] 96 [NAME] [NAME] 136 Miss A [NAME] 97 Mr [NAME] (estate) 137 [NAME] [NAME] And Mr K [NAME] 98 Mr K [NAME] 138 [NAME] [NAME] 99 Mr D & [NAME] S [NAME] 139 Mr K & [NAME] J [NAME] 100 [NAME] [NAME] 140 [NAME] [NAME] 101 Mr [NAME] & [NAME] A [NAME] 141 [NAME] [NAME] 102 Miss S [NAME] 142 [NAME] [NAME] 103 Miss [NAME] 143 [NAME] [NAME] 104 [NAME] [NAME] 144 [NAME] [NAME] 105 [NAME] [NAME] 145 Mr D & [NAME] [NAME] 106 [NAME] [NAME] 146 Mr [NAME] & [NAME] V [NAME] 107 Mr [NAME] 147 [NAME] [NAME] 108 Mr [NAME] & [NAME] E [NAME] 148 [NAME] [NAME] 109 [NAME] H & Mr J [NAME] 149 [NAME] [NAME] 110 Mr [NAME] 150 [NAME] [NAME] 111 [NAME] [NAME] 151 [NAME] [NAME] 112 Miss G [NAME] 152 [NAME] [NAME] 113 [NAME] [NAME] 153 [NAME] [NAME] And Mr [NAME] 114 [NAME] [NAME] 154 [NAME] [NAME] 115 Mr [NAME] 155 Mr [NAME] 116 Mr [NAME] 156 Mr [NAME] & [NAME] [NAME] 117 Mr [NAME] & [NAME] [NAME] 157 [NAME] [NAME] 118 [NAME] [NAME] 158 Mr [NAME] & [NAME] M [NAME]

159 [NAME] [NAME] 199 Miss J [NAME] 160 [NAME] [NAME] 200 [NAME] 161 The Estate Of [NAME] J Sales 201 [NAME] [NAME] 162 Mr [NAME] 202 [NAME] [NAME] 163 [NAME] [NAME] 203 [NAME] [NAME] G [NAME] 164 [NAME] [NAME] 204 The Estate Of [NAME] 165 [NAME] [NAME] 205 [NAME] [NAME] 166 Mr [NAME] 206 [NAME] [NAME] 167 Mr [NAME] & [NAME] G [NAME] 207 [NAME] [NAME] 168 [NAME] [NAME] 208 [NAME] [NAME] 169 Mr [NAME] & [NAME] [NAME] 209 [NAME] [NAME] 170 [NAME] [NAME] 210 Mr [NAME] & [NAME] [NAME] 171 [NAME] [NAME] 211 [NAME] [NAME] 172 Mr [NAME] 212 Mr [NAME] & [NAME] J [NAME] 173 Mr [NAME] 213 [NAME] [NAME] 174 [NAME] [NAME] 214 [NAME] [NAME] 175 Mr [NAME] 215 Mr [NAME] 176 [NAME] [NAME] 216 [NAME] [NAME] 177 Mr & [NAME] [NAME] 217 [NAME] [NAME] 178 [NAME] [NAME] & Mr K [NAME] 218 [NAME] [NAME] 179 Mr [NAME] 219 [NAME] [NAME] 180 [NAME] [NAME] 220 [NAME] [NAME] 181 [NAME] [NAME] 221 Mr [NAME] 182 [NAME] [NAME] 222 [NAME] A [NAME] 183 Mr [NAME] 223 [NAME] [NAME] 184 Mr [NAME] & M [NAME] 224 Mr [NAME] & [NAME] [NAME] 185 [NAME] 225 [NAME] [NAME] 186 [NAME] & [NAME] [NAME] 226 [NAME] [NAME] 187 [NAME] M [NAME] 227 Mr [NAME] 188 [NAME] [NAME] 228 [NAME] [NAME] 189 [NAME] 229 Mr [NAME] 190 [NAME] [NAME] 230 Mr [NAME] & [NAME] [NAME] 191 Mr [NAME] 231 Mr [NAME] & [NAME] [NAME] 192 [NAME] [NAME] 232 Mr [NAME] & [NAME] [NAME] 193 [NAME] [NAME] 233 Mr & [NAME] [NAME] 194 Mr & [NAME] [NAME] 234 Ms [NAME] 195 Mr [NAME] 235 Mr [NAME] & [NAME] [NAME] 196 Ms [NAME] 236 Mr [NAME] & [NAME] [NAME] 197 [NAME] [NAME] 237 Mr [NAME] 198 [NAME] [NAME] & [NAME] [NAME] 238 Mr [NAME]

239 Mr [NAME] 279 [NAME] [NAME] 240 Mr [NAME] & [NAME] [NAME] 280 Mr [NAME] 241 [NAME] [NAME] 281 [NAME] [NAME] 242 [NAME] [NAME] 282 [NAME] [NAME] 243 [NAME] [NAME] 283 [NAME] [NAME] 244 [NAME] [NAME] 284 [NAME] [NAME] 245 Mr [NAME] 285 [NAME] [NAME] 246 [NAME] [NAME] 286 [NAME] [NAME] 247 [NAME] [NAME] 287 Mr [NAME] 248 [NAME] [NAME] 288 [NAME] [NAME] & Mr [NAME] 249 [NAME] [NAME] 289 The Estate Of [NAME] [NAME] 250 Mr R & [NAME] [NAME] 290 [NAME] [NAME] 251 Mr & [NAME] [NAME] 291 Mr [NAME] 252 Mr [NAME] & [NAME] W [NAME] 292 Mr & [NAME] [NAME] 253 [NAME] [NAME] 293 [NAME] [NAME] 254 [NAME] [NAME] 294 [NAME] [NAME] 255 Mr [NAME] & J [NAME] 295 Miss [NAME] 256 [NAME] [NAME] 296 Mr [NAME] 257 Mr M [NAME] 297 Mr [NAME] 258 [NAME] [NAME] 298 Mr [NAME] 259 [NAME] [NAME] 299 [NAME] [NAME] & Mr T [NAME] 260 [NAME] [NAME] 300 Mr [NAME] & [NAME] M [NAME] 261 [NAME] [NAME] 301 Mr [NAME] 262 Mr [NAME] 302 [NAME] [NAME] 263 [NAME] [NAME] 303 Dr [NAME] 264 [NAME] [NAME] 304 Mr [NAME] And [NAME] [NAME] 265 [NAME] [NAME] 305 Mr [NAME] 266 [NAME] [NAME] 306 Mr [NAME] 267 [NAME] [NAME] 307 Mr [NAME] 268 [NAME] [NAME] 308 Mr [NAME] 269 [NAME] [NAME] 309 Mr [NAME] & Ms [NAME] 270 [NAME] [NAME] 310 Mr & [NAME] [NAME] 271 [NAME] 311 [NAME] 272 [NAME] 312 Mr [NAME] & [NAME] [NAME] 273 [NAME] [NAME] 313 Mr [NAME] 274 Mr [NAME] 314 [NAME] [NAME] 275 [NAME] [NAME] 315 Miss J [NAME] 276 [NAME] [NAME] 316 Lichfield District Council 277 Mr [NAME] & [NAME] [NAME] 317 [NAME] 278 Mr [NAME] And [NAME] [NAME] 318 Mr [NAME] M [NAME]

319 Mr [NAME] 359 Ms [NAME] 320 Mr [NAME] 360 Ms [NAME] 321 Mr [NAME] J [NAME] 361 Mr [NAME] 322 Ms [NAME] H [NAME] 362 Miss T [NAME] 323 [NAME] [NAME] 363 Miss T [NAME] 324 Mr [NAME] 364 Mr [NAME] & [NAME] [NAME] 325 [NAME] [NAME] 365 [NAME] & [NAME] 326 Miss [NAME] 366 Mr [NAME] & [NAME] A [NAME] 327 Mr [NAME] J Mian 367 Miss [NAME] 328 Mr [NAME] & Ms S [NAME] 368 [NAME] 329 [NAME] 369 [NAME] 330 Mr W & Mr D [NAME] 370 Mr A [NAME] & [NAME] 331 Dr [NAME] 371 [NAME] 332 Mr [NAME] 372 Miss [NAME] & [NAME] 333 [NAME] & [NAME] 373 [NAME] [NAME] [NAME] 334 Ms [NAME] 374 Mr [NAME] 335 [NAME] [NAME] 375 Mr [NAME] & [NAME] [NAME] 336 Ms [NAME] & [NAME] 376 Mr [NAME] 337 Mr [NAME] & [NAME] N [NAME] 338 [NAME] M [NAME] 339 [NAME] [NAME] 340 Mr [NAME] 341 [NAME] 342 [NAME] [NAME] & [NAME] 343 [NAME] 344 Mr J [NAME] 345 [NAME] 346 [NAME] 347 [NAME] 348 Mr I & [NAME] 349 [NAME] & [NAME] 350 Mr J R Scollon 351 [NAME] & [NAME] 352 [NAME] 353 [NAME] 354 Mr D & [NAME] 355 [NAME] 356 [NAME] 357 [NAME] 358 [NAME]