Inner Temple Yearbook 2025-26

YEARBOOK

Inner Temple Yearbook 2025–2026

Treasurer:

Richard Salter KC

Reader:

Helen Davies KC

Reader Elect:

The Hon Mrs Justice Juliet May

Sub-Treasurer:

Greg Dorey CVO

Treasury Office: Inner Temple, London EC4Y 7HL 020 7797 8250 yearbook@innertemple.org.uk innertemple.org.uk

Master of the Yearbook: Master Minka Braun

Editor: Lily Walker-Parr

Assistant Editor: Henrietta Amodio

Desk Editor: Sandra Alvarez

Yearbook Manager: Nadia Ruiz

Archivist: Celia Pilkington

Assistant Archivist: Umut Kav

Education & Training: Julia Armfield

Photographs: Garlinda Birkbeck, Miranda Parry Photography, The Inner Temple photograph archive

Yearbook Design: Jon Ashby | Noun Ltd, 10 Kingshill Court, High Wycombe, Buckinghamshire HP13 5FN wearenoun.com

Advertising: HTDL Ltd htdl.co.uk

Printed by: John Good Limited, Progress House, Butlers Leap, Rugby CV21 3RQ johngood.com

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FROM THE EDITOR

Welcome to another edition of The Inner Temple Yearbook. This year’s edition is significant for several reasons. It includes the insightful inaugural speech of Master Barbara Mills, the first Black woman elected as Chair of the Bar Council, supported for the first time by an all-female leadership team: Kirsty Brimelow KC as Vice-Chair and Lucinda Orr as Treasurer. If ever proof were needed of how far the profession has come since women were first called to the Bar in 1922, this moment surely provides it.

It also marks the launch of the Inn’s new five-year Education and Training Plan. Over the next half-decade, students, pupils and new practitioners will continue to benefit from the highest standards of training in their early years of practice, while the Inn renews and expands its offerings for established practitioners. I have particularly enjoyed reading about sessions on appellate advocacy and the inaugural ‘Movers and Returners’ conference, designed to support practitioners resuming their careers after taking time away from the Bar.

In these uncertain times, the Inner Temple’s Social Context of the  Law series feels more vital than ever. This edition captures thoughtprovoking debates on the right to protest, the repatriation of cultural artefacts, and perverse verdicts. The series continues to provide an essential forum for reflection on the relationship between law and the society it serves.

Finally, this Yearbook marks my third and final year as Editor. For my part, it has been a privilege to work on such an important record of Inn life and to witness the depth of knowledge, skill and generosity of my fellow Inner Templars. And it has not been short of surprises: much to my amusement, I was once asked to sign a visiting American Pegasus Scholar’s Yearbook in Ye Old Cheshire Cheese. Oh, the dizzying heights of fame…

Much more impressively, it also marks Nadia Ruiz’s ninth and final year as a member of the editorial team before she moves on to pastures new. On behalf of the team and the wider Inn, I offer heartfelt thanks to Nadia for her invaluable contribution to this publication. Her insight, energy and experience will be much missed.

My thanks also go to our contributors and to Master Braun, Henrietta Amodio and the rest of the editorial team for their considerable efforts in finalising this edition.

For a final time from me, I sincerely hope you enjoy the read.

Lily Walker-Parr 5RB

Sandra Alvarez Henrietta Amodio Julia Armfield Nadia Ruiz

Not Guilty Verdicts

Master

Master Anthony Lloyd

Master Elizabeth Bulter-Sloss C Murder (Abolition of the 20 Penalty) Act 1965: 60 Years – Ruth Ellis

The

L Library Facilities and Services 89

PS Pegasus Scholars 90

T Launch of the 98 International Circuit

Master Joanna Korner

COIC The COIC Pupillage 99

Matched Funding Scheme

TC History of The West Doorway, 100

Temple Church

Master Catherine Callaghan

A History Society Review 104

Master Donald Cryan

T The Inner Temple Summer Party 106

T The Social Context of the Law: 108 Environmental Law: Regulation and the Right to Protest

Master Stephen Simblet, Sudhanshu Swaroop KC, moderated by Master Saira Kabir Sheikh

T The Inns of Court Alliance 112 for Women

Master Leigh-Ann Mulcahy and Master Ingrid Simler

TC Weddings 114

L Literature and Chronicles: 116 Highlights of the Library’s Manuscript and Rare Book Collections

The Assistant Librarian

T LGBTQ+ Society: Pride in Practice 119

Master Barbara Mills and Master Jeremy Richardson

Lawyers as Peacemakers

Rachael Field G Law and Borders

The Head Gardner and the Master of the Garden

Music in the Temple Church:

An Opportunity for All The Director of Music I In Memoriam

T Artificial Intelligence and

Professional Ethics

The Treasurer T After 1925: Reflecting on

years of property legislation

Master Judith Bourne

I New Masters of the Bench

2025–2026

A ARCHIVES

C CELEBRATE THE LIFE

COIC COIC

E EDUCATION & TRAINING

E ESTATES

G GARDEN

I INNER TEMPLE INFORMATION

L LIBRARY

PS PEGASUS SCHOLARS

RL READER’S LECTURE SERIES

TC TEMPLE CHURCH

T TREASURY

FROM THE TREASURER

This July was the 50th anniversary of my own Call to the Bar. I still remember how nervous and awestruck I was, as the state school-educated son of a factory worker and the first of my family to go to university, when I first showed my face in the Inn. But I also remember clearly just how encouraging and supportive to me almost everyone here –particularly the most senior and distinguished – was when I was a student member. Without the Major Law Grant (then the Inn’s largest award) which the Inn gave me, I could never have survived what turned out to be a slightly rocky start to go on to build my career at the Bar.

It therefore gives me great satisfaction to be able, as this year’s Treasurer of the Inn, to say with confidence that it remains the proud tradition of The Inner Temple that it welcomes everyone, whatever their origins, whatever their background, who has the talent and determination needed to become a barrister.

The Inn now has a wide variety of schemes whose object is to ensure that a career at the Bar is, so far as we can possibly make it, open to all.

These start with projects whose aim is to raise the aspirations of those still at school. The Inn has had a ‘discovery day’ schools project since 2008 (now operating in partnership with the Sutton Trust’s Pathways to Law programme), which aims to ensure that all students, regardless of their background, are aware of the opportunities that could be available to them at the Bar. The Inn also joined with the Open University in 2021 to produce a suite of digital resources to help to bring those opportunities to the attention not only of the school children themselves but also of their parents and teachers.

For those at university, the Inn’s outreach team, supported by an enthusiastic cohort of experienced barrister and judicial volunteers, runs a series of ‘insight events’ each year, to give those who might be thinking of a career at the Bar the chance to learn more about the realities of life at the Bar, about the ways to join the profession, and about the support available to those who need it. These insight events are supplemented by access to tours of the Inn and its facilities, and by regular newsletters produced by the Inn, both for those thinking of coming to the Bar and for the academic and careers staff who advise them.

The Inn is particularly proud of its Pegasus Access and Support Scheme (PASS). PASS works in partnership with some 62 different sets of chambers across a range of practice areas, to improve access to the profession by those from less advantaged and under-represented backgrounds. It provides them with the sort of contacts and access to mini pupillages and other experiences that they might not otherwise have, and helps them to develop the advocacy and other skills that they need to prepare them for a career at the Bar.

Richard Salter KC, Treasurer © Garlinda Birkbek

Finally, for those who do eventually make the decision to try to come to the Bar, about £2 million (out of the overall total of about £5 million which the Inn devotes to its education and training activities each year) is given out as scholarships or other awards to our students. These awards are made on merit, but the amount awarded is adjusted by reference to means, including in most cases parental income, so that the Inn’s support is targeted at those who most need it. The Inn also runs mentoring schemes, supports several student societies, and does its best to ensure that its programme of Qualifying Sessions not only provides the necessary educational content but also the contact with the practising Bar and the Judiciary that students need to make them feel part of the profession and to understand its ethics and its traditions.

As the old saying has it, in The Inner Temple, it is not where you have come from that matters, but only where you are going.

When writing this introduction to the Yearbook, my predecessors have all rightly said what a privilege it is to be the Treasurer of our Inn, the most recent in a line of officeholders that stretches back as far as 1484 at the head of an institution that has existed since no later than 1388 (and probably earlier). Not many of my predecessors, though, have said (at least in so many words) just how much fun it is.

I decided on taking up office in January that I would work this year from the Treasurer’s small office in the Treasury Building and, with the help of modern technology, make that room an annexe to my chambers in Gray’s Inn. It has given me the chance to get to know both the Treasury Office team and the staff of the Pegasus Bar, who make the best cappuccinos in EC4. It has also given me the chance, after more than 40 years working in Gray’s, to appreciate once more just how special the working environment is in The Inner Temple. Those of us who have had the privilege of spending any part of our student and working lives here are privileged in so many respects.

First, the place itself. The unique atmosphere of the Inn derives from its combination of fascinating buildings (at least 29 of which are listed) and inviting spaces. Those spaces include our gas-lit lanes and courtyards as well as our wonderful garden. This three-acre oasis overlooking the Thames not only provides a vital breathing space for humans, but also serves as a much-needed refuge for nature, with its mosaic of habitats including ancient trees, herbaceous borders, flowering shrubs, wildflower meadows and open sunny lawns.

As the old saying has it, in The Inner Temple, it is not where you have come from that matters, but only where you are going.

Another space offering a respite from the pressures of the everyday world is the Temple Church, the ‘college chapel’ which we share with our sister Inn, the Middle Temple, and where we hold many of the ceremonies at which we call our student members to the Bar. The round church at its western end dates from the 1160s, a full century before the first colleges were established at Oxford. As one of the places where Magna Carta was negotiated before being sealed at Runnymede in 1215, the Temple Church has a just claim to be regarded as the cradle of the common law. But, sitting now in its pews or walking in its aisles, it is a lightness of spirit rather than the weight of history that one feels.

Secondly, the people. The Inn does its best to provide a collegiate and supportive community for all our members. We try, for example, to be a supportive (but realistic) landlord to our barrister and residential tenants, because it is the rents paid by them that help to fund the extensive programme of educational activities that we provide for our student members, and which pay for the scholarships that we award each year. Without that funding, and without the immense amount of time willingly and voluntarily given by the many barrister and judicial members who organise and teach on our Qualifying Sessions and advocacy training courses, and who supervise our student societies, that programme of educational activities and support simply could not happen.

Finally, our wonderful and dedicated staff. Without them –the catering staff, the carpenters, electricians, plumbers, cleaners and other estates department staff, the car park attendants, the porters, the librarians and archivists, the staff of our friendly and welcoming Education & Training Department, and the staff of the Finance and Treasury offices – the Inn could not function. Perhaps more importantly, without the loyalty and commitment of our staff, The Inner Temple would not be the quite exceptional and friendly place that it is.

I have done my best to make this a more than usually musical year for the Inn. The Temple Music Foundation (TMF) started the year for us in January by putting on a performance in Hall by the Gabrieli Consort & Players of Handel’s sensuous oratorio Solomon. The Brazilian guitarist Plínio Fernandes played for us at another TMF concert in the Inn’s third floor lecture theatre in February: and in October the TMF will be bringing the London Mozart Payers to our Hall. But perhaps the highlight of the year for me was the production of the Prelude to Act 1 and the whole of Act 3 of Parsifal in the Temple Church in April. I was at last able to put my knowledge of the Inn’s compost heap (acquired during the Treasurer’s introductory walkabout) to good use by introducing the production’s set designer, Claudia Fragoso, to the Inn’s Head Gardener, Sean Harkin, when Claudia urgently needed to replenish her supply of dead leaves to decorate the stage. The director of the production, Julia Burbach, and the conductor, Peter Selwyn, both went on to produce Opera Holland Park’s highly successful Flying Dutchman this summer, and Julia’s production of Rossini’s La Cenerentola will open English National Opera’s autumn season at the Coliseum this September. Opera Holland Park themselves came to The Inner Temple to stage Gilbert and Sullivan’s Trial by Jury on 1 July, directed by John Savournin, with a boisterous jury drawn from the audience.

The distinguished accompanist, Anna Tilbrook, has helped me also to put together a programme of music for the Inn’s formal dinners. At Private Guest Night in February, Anna accompanied the violinist, Emily Sun. The young pianist Catriona Mackenzie played at Bencher’s Night in May, and in June our second Private Guest Night was enlivened by a richly satirical performance by the operatic cabaret artist, Melinda Hughes, accompanied by Jeremy Limb.

Looking forward, the tenor Robert Murray will be singing for us at Benchers’ Night in October. Finally, the Evensong preceding our Grand Day dinner in November will feature a performance of the Te Deum for choir, organ and trumpets which my wife’s late father, Philip Cannon FRCM, composed as a result of a personal commission from Queen Elizabeth II for the Quincentenary of St George’s Chapel, Windsor. Afterwards, the trumpeters who will play in that performance will perform at the start of dinner a fanfare which the Inn has specially commissioned from the Scottish composer and RCM professor, Martin Suckling. After dinner, the wonderful and world-famous soprano, Lucy Crowe OBE, will give a short recital, with Anna as her accompanist.

Turning to more practical matters it has also been, I am pleased to say, a year of moving forward. I have done my best to lunch in Hall as often as possible, and have revised the guidelines for lunching on High Table, to encourage my fellow Benchers to resume the habit of doing so. I have revised the guidelines for the operation of the Inn’s many committees. I have also resumed, after a gap of some years, the practice of having termly meetings between our Treasurer and Sub-Treasurer and the Treasurer and Under Treasurer of Middle Temple. This year’s Treasurer of Middle, Lady Justice Thirlwell, and I hope that these regular meetings – as much as the Amity Dinners that we hold each year – will help to foster the proper and necessary spirit of friendship and collaboration between our two Inns, joined as we are by our shared occupation of this special site and by our common Charter obligations.

Our very capable Collector, Jane Whittaker, and Master Philip Moser, the Master of the House and his committee, have between them successfully renegotiated our contract with our catering suppliers, Searcys. Under Jane’s guidance, the Inn has adopted new guidelines for the accounting treatment of its reserves: and, with Jane’s help (and the reduction which the renegotiated contract should bring in the catering deficit), Master Sonia Nolten and her Finance Sub-Committee have produced a realistic plan to bring the Inn’s finances back into balance by 2027.

Thanks to Master Alison Foster, our Master of the Pictures, the plan to improve the gender balance on our walls is also moving forward. We hope to unveil and to hang in Hall this autumn the portrait by Keith Breeden of Master Sue Carr, the Lady Chief Justice: and plans are afoot to follow that in the coming years with portraits of two other distinguished female members, Master Ingrid Simler and Master Joanna Korner (and with a portrait of Master Robin Griffith-Jones, though he of course is a man).

Under the auspices of Master Jeremy Richardson’s EDI Sub-Committee, in June the Inn held a very well-attended and successful dinner to celebrate South Asian heritage, and hosted the first ever cross-profession LBGTQ+ Pride reception. Also in June, the Inn hosted the annual Inns of Court Alliance for Women garden party. We have held lunches with the help of the FCDO’s Rule of Law Adviser for the Caribbean, our Honorary Bencher Master Sirah Abraham, to strengthen our connections with that region. Delegations from India and elsewhere have also come to lunch in the Inn, and I was privileged to attend a dinner at the residence of the Indian High Commissioner to welcome India’s new Chief Justice, B R Gavai, the first Buddhist and only the second Dalit to hold that distinguished post.

I have done my best to make this a more than usually musical year for the Inn. The Temple Music Foundation (TMF) started the year for us in January by putting on a performance in Hall by the Gabrieli Consort & Players of Handel’s sensuous oratorio Solomon.

The Inner Temple, with its well-established reputation for excellence in advocacy training, is ideally placed to help the countries of the Commonwealth to develop and sustain the rule of law.

Finally, we have at last brought Project Pegasus to a conclusion, with a very satisfactory settlement of the litigation which we had been compelled to bring against our architects and other consultants in relation to the fire protection specification in the initial design. The Inn owes a great debt to those who have guided us through this dispute, particularly last year’s Treasurer, Master Michael Soole, our advisory ‘War Cabinet’ of members who practise in construction law, our Director of Properties & Surveyor, Richard Snowdon, and our legal advisers, Calum Lamont KC, Tom Coulson and our Bristol-based solicitors, Foot Anstey LLP. It is very pleasing that we can now put this issue behind us, as we continue to enjoy the aesthetically delightful yet very practical facilities and working environment that Project Pegasus has produced in our Treasury Building.

Away from the Inn, the Sub-Treasurer and I have attended on the Inn’s behalf the Commonwealth Law Association (CLA) conference in Malta, and have visited the Inn’s alumni associations in Malaysia and Singapore, signing a Memorandum of Understanding with the Law Society of Singapore while we were there. In the autumn, we plan as usual, to attend the American Inns of Court Celebration of Excellence in Washington.

Before embarking on these trips, I was perhaps a little sceptical of the benefit to the Inn of these overseas visits as compared with the cost. Our reception in Malta, Malaysia and Singapore has, however, firmly convinced me of how worthwhile this all is.

The common law is one of this country’s great gifts to the world. Good governance and sustainable economic development require the rule of law within a properly functioning legal system. That, in turn, requires adherence to the Commonwealth’s Latimer House Principles on the accountability of, and the relationship between, the three branches of government. Fundamental to these principles is the separation of powers, the independence of the judiciary and zero tolerance of corruption.

The contributions from the floor during the sessions at the CLA conference made it clear to me just how important it is to our fellow lawyers in so many countries where the rule of law is challenged that the UK should stand with and support them, and how much they take heart from the participation by The Inner Temple in these events. Even in the comparatively successful economies of Malaysia and Singapore, those we met there made it clear how much they value the moral support that they derive from their association with the Inn in standing up for the rule of law in their jurisdictions, and how much we can each learn from the other’s experiences.

The Inner Temple, with its well-established reputation for excellence in advocacy training, is ideally placed to help the countries of the Commonwealth to develop and sustain the rule of law. Master Sarah Clarke and her Advocacy Training Committee, the Sub-Treasurer, and I, have therefore been working with the secretariat of the CLA to explore what the Inn can offer by way of training to those countries in the Commonwealth where it is most needed.

All of this is very positive and heartening. Sadly, there may nevertheless still be trouble ahead. Both the Chair of the Legal Services Board and the Chair of the Bar Standards Board came to lunch in the Inn early in the year and, within a couple of weeks, both had resigned. We do not yet know what plans their successors may have for the profession.

Having at last finished with Project Pegasus, we are now faced with the need to develop the rest of our estate to make it as accessible as possible and to prepare it (and the Inn as a whole) for the economic, climatic and technological challenges of the rest of the 21st century. I am pleased to say that Master Roger Stewart and the Estates Committee already have this project well in hand. Doing what is necessary, and doing it well so that it stands the test of time, will not, however, be cheap.

The Bar Council has also put the issue of the timing of Call – whether it should take place, as now, at the conclusion of the Bar Course, or should be deferred until completion of some or all of the required period of pupillage – back on the agenda. The Inns will have to consider their position this autumn in relation to this controversial question. A change in the timing of Call could have profound effects on the Inns, both in their relations with their students and (over longer time) in their relations with the rest of the commonlaw world.

Even so, the Inn seems to me to remain in good heart and good physical and financial shape. We are extremely fortunate in our Sub-Treasurer, Greg Dorey CVO, from whom I have received the most exceptional, diplomatic, and wisest of support. I am profoundly grateful to him. I am also very grateful to the Director of Treasury Office, Henrietta Amodio, and to all of the Treasury Office staff, who have coped seamlessly with the greatly increased workload which my musical ambitions for the year have imposed on them. Finally, I must thank the Reader, Master Helen Davies, and the Reader Elect, Master Juliet May, for their wise counsel and unfailing support.

After all the fun that I have had this year, it is a sobering thought for someone like me that the Treasurer of the Inn in 2027 is to be someone who, although now a Judge of the Court of Appeal, was once (a long time ago) my pupil: but I take comfort from the thought that the Inn will be, with Helen and Juliet, in the very safest of hands.

Richard Salter KC Treasurer 2025

CHAIR OF THE BAR: INAUGURAL SPEECH

On becoming Chair of the Bar, Master Barbara Mills held her inaugural speech on Wednesday 8 January 2025 at The Inner Temple.

Master Barbara Mills giving her speech © Bar Council

INTRODUCTION

Good evening: Master Treasurer, distinguished guests, family, friends and colleagues. A very warm welcome to The Inner Temple Hall.

The baton has been handed over from Sam Townend KC. Sam, thank you for all your work last year and for showing us all what it looks like to be prepared to go the extra mile for the profession. You will be missed, and we owe you a debt of gratitude.

I am delighted and deeply humbled to be given the opportunity to lead our profession in 2025. I will do so flanked by Kirsty Brimelow KC, who is the Vice Chair, and the Treasurer is Lucinda Orr. This is the first time in the Bar Council’s 131-year history that all three of its office holders are women. About time too frankly! It is a proud moment for our profession, and we must celebrate that too this evening. This evening is my opportunity to tell you who I am, what made me put my hand up to be your Chair and outline my – and the Bar Council’s – priorities for 2025.

WHO AM I?

The story began here in this very hall on Tuesday 16 October 1990 when, at 23, I was called to the Bar. With me were two of the most resilient women I have ever known: my (very proud) mother, Rosa and my sister, Linda. Sadly, my mum is no longer with us but, if she were here, she would have the broadest of grins and would be telling the person next to her “Oh yes – she is one of mine!” I am delighted that my sister has travelled from her home in the USA to be with me tonight.

I had secured pupillage at 4 Paper Buildings, then a common law set, but I was assigned to two family practitioners: Anna Pauffley, who specialised in children work, and Jonathan Cohen, who was particularly known for his work in financial remedy cases. Both became High Court judges. I learnt my craft from the best.

To begin with, I did all aspects of family work. Then I specialised in the law involving children. I did not stop there. By the early 2000s, more research was emerging of the real damage that can be caused to families by the litigation process. I, and others, could see that mediation was the future so, in 2005, I jumped at the chance to train as a mediator. That decision baffled my senior clerk who was not convinced that a set of chambers should offer a service that kept people out of court. I convinced him that the world would change and catch up – which, happily, it did. Mediation, and other non-court dispute routes, are now considered to be the first ports of call for family disputes.

The development of my mediation practice was the stepping stone into further forms of dispute resolution as well as into the judiciary. I became a Recorder in 2011, an arbitrator in 2016 and in 2023, a Deputy High Court Judge. Along the way, I took silk in 2020.

Three things have made a real difference to me over the years.

First, very early on, I learnt the importance of actively planning my career. During my pupillage, I spent several months in Toronto as a Pegasus Scholar. There I met young lawyers, most of whom had a clear plan about their professional development. To have such a sense of direction was a revelation and it was an approach that I embraced. Have a plan. Aim high.

Secondly, I learnt that my wellbeing was not something that I turned to occasionally or when things were falling apart –I needed to touch base regularly and assess how things were going. I came to see this as an important skill that had to be woven into practice in order to thrive.

Finally, I owe a debt to the allies and champions from across the sector – judges, more senior barristers, solicitors and clerks – who provided me with work, ensured that I was paid properly, who led me and mentored me. They shone a light on me and helped me to see what I could become.

My involvement with the Bar Council started in the mid1990s, when I was a member of the Professional Conduct and Complaints Committee.

After a break when my daughter was young, I returned in 2018 as the Family Law Bar Association’s representative and joined the Equality Diversity and Social Mobility Committee. Between 2020 and December 2023 I was the Co-Chair of the Race Working Group and delivered the Snapshot of Race at the Bar report in 2021.

In 2022, I decided to seek the profession’s backing to serve as Chair of the Bar… You know the rest.

Why did I decide to stand? In part to show what is now possible in this profession and to pass on what has helped me and many others to succeed. On paper, I didn’t fit the stereotype in 1990, fair or unfair. Not a man. Not white. Didn’t go to Oxbridge, I studied law at Hull University and lacked parents with resources. And – last but not least – I had no connections within the profession.

On paper, I didn’t fit the stereotype in 1990, fair or unfair. Not a man. Not white. Didn’t go to Oxbridge, I studied law at Hull University and lacked parents with resources. And – last but not least – I had no connections within the profession.

But I backed myself, felt resilient and adaptable, and was prepared to work hard and seize opportunities when they came along.

Martin Luther King Jnr, in his “What is Your Life’s Blueprint? ” speech, avowed the critical importance of “a deep belief in your own dignity, your worth and your own ‘somebodiness”.

I felt I was somebody, and I wanted to make something of myself – always driven to show that, if I got there, I could show what’s possible.

THE WIDER CONTEXT FOR 2025

Enough of me: what about the year ahead?

The Chair’s year seems to me to be made up of three parts: the things we inherit, the areas we identify as our own priorities to champion and take forward, and the curveballs – the things that none of us can predict, but that are bound to shape our tenure.

Many of the issues facing the Bar remain the same year after year. I am the latest in a line of Chairs inheriting a justice system in need of repair. Record backlogs in courts across Jurisdictions; delays across the system with people having to wait years for their day in court, undermining trust and confidence; legal aid unavailable despite the increasing number of people who need it; and a criminal justice system at breaking point after over a decade of neglect and insufficient resources.

I know that the publicly funded Bar is disillusioned and exhausted. They are working harder than ever, doing work that is demanding and often unpaid. Barristers working on criminal cases – like family, immigration and housing practitioners – are often working for no money or working on cases that are bounced out of the list at the last minute.

Just before the Christmas break, the Ministry of Justice announced a welcome – and long overdue – increase in criminal legal aid fees for solicitors. But what about the Criminal Bar? We urgently need to see a change, not only in remuneration but also in relation to workload and predictability, as well as parity between defence and prosecution fees. Otherwise, we will continue to lose talented barristers from the Bar.

Ahead of the spending review, expected in June, the Bar Council set out our priorities for restoring the justice system and putting it on a sustainable footing, in line with the new government’s plan to fix the foundations and its missions to kickstart the economy, modernise public services, and halve violent crime and violence against women and girls.

In our manifesto for justice last year, we called for a Royal Commission on the criminal justice system – recognising that real change needs cross-party political support. So, we are pleased to be engaging closely with the Gauke review of sentencing and the Leveson review of criminal justice, and we’ll be highlighting the Bar’s position and perspective on both.

But there is more for us to value and protect beyond the largely publicly funded areas of practice. Legal services contribute huge sums to the British economy (£34bn in 2022) and the Bar plays a key role within the sector – particularly the Commercial and Chancery Bars. The UK accounts for around 10 per cent of the global market for legal services, second only to the US. It is also the largest market in Europe, accounting for around one fifth of Europe’s legal services fee revenue.

Our Bar is often the first choice for citizens and businesses across the world on an ever-growing range of issues. The quality of our legal services coupled with the pre-eminent reputation of the law of England and Wales, the independence of our judiciary and the rule of law is what makes our jurisdiction so attractive. But we cannot take this for granted.

Competing international dispute resolution centres around the world are taking active steps to promote themselves as suitable jurisdictions for the resolution of cross-border disputes. I will continue to promote England and Wales as the law and jurisdiction of choice for international contracts and disputes and highlight the immense and enviable expertise of our Bar.

MY PRIORITIES

As for my personal priorities for the year, I wish to make progress on three broad areas:

A. I intend to raise the profile of family law and to help the government in its mission to halve violence against women and girls.

B. Secondly, I want to pass on the benefits of respecting our wellbeing enough to make it a skill and a core part of effective practice management as a barrister.

C. Finally, I want to ensure we make further strides in our pursuit of equality, diversity and inclusion.

FAMILY JUSTICE – WHY IS IT A PRIORITY?

The Bar has not had a specialist family practitioner as its Chair since 1988. 2025 provides the opportunity to focus on the central importance of effective family law to a civilised society. The family courts hear cases dealing with all aspects of human existence. They attempt to bring order to chaotic lives. They attempt to protect the vulnerable, and to ensure that people can live with means. Much of what is heard is distressing and difficult. The family courts are, it could be said, the courts of life itself, touching us all and, as such, they have work to do for society.

Arguably, no other sector of the law has such a wide variety of cases. Our work spans from the beginning of life – modern family units created by assisted reproduction and surrogacy – to the end of life where the court is asked to intervene in medical treatment cases. If the Assisted Dying Bill becomes law, the Family Division is where cases that require court intervention are likely to be brought. In between life and death, we deal with disputes about land and property, the welfare of children, the protection of the vulnerable from violence, or as a result of incapacity.

It is now time to proclaim why family justice needs attention and, to be clear, this is a request for investment that can both save money and grow the economy.

Over the last decade there have been 22 per cent cuts per person in real terms in our justice system. At the same time, case volumes and backlogs have increased. What remains, following a huge number of closures, is a court infrastructure that has become dog-eared, moth-eaten and unfit for purpose. To complicate things, the social and economic pressures on people have intensified.

Lack of access to legal advice, whether through legal aid or otherwise, has swollen to the point at which, at times, neither party is represented in as many as 40 per cent of family dispute cases. That means four out of ten people may have had no advice, have no real idea about their rights or whether the court is even the best forum to resolve their dispute.

This results in serious dysfunction in our justice system –cost, delay, injustice, fear, uncertainty and lives put on hold are the bitter fruits of under investment.

This results in serious dysfunction in our justice system – cost, delay, injustice, fear, uncertainty and lives put on hold are the bitter fruits of under investment.

Despite the cuts across the civil justice system, barristers have continued to step up and plug the gaps wherever possible. Pro bono work exemplifies the Bar’s integrity. The cost-of-living crisis has driven record demand for the services of our pro bono partners, Advocate and the Free Representation Unit. I thank them for the work they do, but the system must not rely on that goodwill.

The Bar Council has long warned of these strains on the justice system, across the civil and criminal courts, and made the case that investing in justice both saves as well as grows the economy in the long term.

I am hopeful that, even in these cash-strapped times, ministers are beginning to get the message and the early signs from this relatively new government are encouraging with the announcements of new funding for criminal legal aid for solicitors and the promise of additional funding for the housing and immigration sectors.

We continue to make the case, across criminal and civil legal aid, and we are waiting to see what funds will be made available to family justice this year.

Apart from the need to make the case for investment into family justice, I will take the opportunity to showcase how some of the innovations created to provide solutions to families might be transferred to other sectors.

When a family is in crisis, the family justice system is interested in what has gone wrong, but only as a baseline for assisting us to try to predict the future and to formulate sustainable solutions. The family approach could inform new thinking in the work of other courts.

The family approach could inform new thinking in the work of

other courts.

Take for example the Family Drug and Alcohol Court (FDAC) launched in January 2008 as an alternative court for proceedings where parental drug misuse is the reason to worry about the safety and wellbeing of any children. Evaluations since then have shown positive outcomes in the FDAC. Children with a primary carer in FDAC care proceedings are more likely to be reunited with their primary carer at the end of the process. A higher proportion of parents got off drugs or alcohol. And overall, children in the FDAC had a lower probability of being placed in local authority care.

A success story so far, and perhaps one that the criminal jurisdiction could draw from.

Meanwhile, the government has said it wants to halve violence against women and girls (VAWG). An effective and properly funded family court system should be front and centre of hitting that target, and that is plain when you look at some of the data.

In the latest Femicide Census (2021) of the 147 women killed, 78 were killed by a current or former partner and over half occurred as the women were taking steps to leave the relationship. And at least 40 per cent of private children cases in the family courts involve allegations of domestic abuse.

To be successful in tackling VAWG, I urge the government to provide a clear definition of VAWG, one that encompasses all forms of violence and harmful practices specifically aimed at women and girls. I also urge the government to recognise that VAWG is preventable, so that policies extend beyond reactive measures to incorporate prevention and early intervention strategies.

The family courts are ideally placed to tackle VAWG work –but they will need effective and sustained investment. At the very least, every complainant and every alleged perpetrator should have access to legal advice and representation in the family court. And we need a package of measures to enhance the approach to VAWG, including:

specialised domestic abuse and child abuse support and assessment services

trauma-informed measures such as installing screens in all court buildings and providing trauma-awareness training for Cafcass officers and case progression officers, and the rollout of the Pathfinder courts which have been piloted in Wales, Bournemouth and Birmingham

In summary – fund the family courts and end the horrific roll call of violence against women.

WELLBEING

The work that we do as barristers is intense and highly pressured. Barristers in 1990 did not openly talk about mental health and wellbeing or childcare or, heaven forbid, menopause, and any barrister who thought to complain about being under stress would have been met with a derisory snort and encouraged in the direction of a stiff gin and tonic in Daly’s after work.

Most people will agree that by the time a client needs a barrister, things are not going well or as planned in their life. What we now know is that professionals exposed to the trauma and distress experienced by clients can themselves suffer the same vicariously. If you add the relentless pressure and high expectations, the competitiveness required of barristers and the repercussions in an adversarial process of showing any weakness, it is little wonder that this can lead to chronic and unmanageable fatigue, burnout and illness, if left unchecked. Other professions with similar pressures have incorporated systems which support their members’ wellbeing. I would like to explore ways to offer barristers coaching or supervision – which provides the barrister with the opportunity to have regular confidential check ins with a professional.

As Vice Chair, I discussed wellbeing whenever I had the opportunity – to get a sense of how people are looking after themselves. I will never forget asking a member of the Criminal Bar in the robing room how she was doing. Fighting back the tears, she thanked me for asking and then said she was overwhelmed. She did not feel she had been able to support her children, and her daily diet of RASSO work had left her unable to sleep. She did not know how to access help, and she worried about the expense.

And then there was the young civil practitioner who had spent the last two years having therapy, which he was advised to pursue after something went wrong in a case and he lost his confidence. He wondered why he could not claim the costs of therapy as a tax-deductible expense as he could other practice-related work.

It seems to me that while much is said about wellbeing now, the emphasis remains centred around crisis management.

What I would like to see in the profession is wellbeing losing its stigma as a sign of weakness and elevated to the same non-negotiable level as having an accountant or having insurance.

I do not doubt that there is considerable interest in this idea of proactive coaching across the Bar. The benefits can be transformative. My intention is not to reinvent the wheel but to build on the fantastic work that the Bar has done in relation to wellbeing over the last ten years.

I am very grateful to Charlotte May KC who has agreed to chair a working group to explore and pilot some of the options. We hope to collaborate with the Circuits, Inns and the Specialist Bar Associations and will be seeking the views of the profession as we go along.

EQUALITY, DIVERSITY AND INCLUSION

Flowing from my concerns about our overall wellbeing, my third priority is to continue to pursue the Bar Council’s long-term agenda for equality, diversity and inclusion. What is now becoming clear is that the question of one’s wellbeing at the Bar is affected by several factors such as working conditions, remuneration, feeling excluded and experiences of bullying, discrimination, and harassment.

The key findings of the Wellbeing at the Bar report published in January 2024 tell us that those who report lower overall wellbeing are women, barristers from an ethnic minority background, younger and more junior barristers, those in criminal and family practice, and those who had experienced or observed workplace bullying or harassment.

So, what are the next steps? 2025 will be a year in which I will focus on the three As – greater awareness, acceptance and action.

Awareness and acceptance will be achieved by having greater dialogue.

Dr Sanjiv Lingayah, one of the founders and directors of Reframing Race, an organisation focused on race and racism, spoke last year about the importance of dialogue, which I believe bears repeating.

He said: “the thing about talk is that it carries power. Talk is a place where life-affirming ideas, visions and dreams are carried, where we find connection with one another and where we signal who we are and who belongs… When it comes to fostering an inclusive culture, talk is not cheap.”

So, who will I want to talk to? First, to our frontline regulator, the Bar Standards Board (the BSB). In September last year, the BSB published a consultation in which it announced plans to replace Core Duty 8 – ‘do not discriminate’ – with a more proactive duty to advance and promote equality, diversity, and inclusion.

While I do understand why the BSB wants to see faster progress, I do not believe their new proposals will achieve the intended aim and we have provided our reasons in a detailed response to that consultation.

In short, we are concerned about the BSB’s intention to use the code of conduct which is designed to set a minimum professional standard which protects people when we represent them, as the vehicle to attempt to change our culture.

Secondly, we are concerned that the framing of the proposed core duty, to impose a duty to deliver a more diverse profession, is unlawful and misguided. We are concerned that the proposed regulations may hinder progress in this area given what we believe to be ambiguity and potential ineffectiveness of the regulations as proposed.

The consultation has generated more heat than light and is a great reminder of the care which we must take, that any attempt to improve equality, diversity and inclusion does not create unhelpful division. The road to hell, it is often said, is paved with good intentions.

Mark Neale, the Director General of the BSB, was interviewed by Joshua Rozenberg in September last year. I was very encouraged to hear him say that the consultation really is a consultation and that the BSB is keen to hear from the profession. Nothing appears to be set in stone, and that opens up the opportunity to discuss and move in collaboration with the BSB to develop a practical framework that genuinely delivers diversity and inclusion.

I am, therefore, keen to work with the BSB and to open meaningful dialogue. On this and other issues, it is my intention to foster positive and collaborative relationships with both the BSB and the Legal Services Board.

The Bar is a broad church and I represent members who do not agree with me on EDI. So I will continue the conversation that persuades, not forces, those who disagree that it is both reasonable and realistic to expect members of chambers, employers, and Bar stakeholders to put practical measures in place to monitor internal practices and take steps to challenge inequalities. All individuals who work at the Bar should be treated fairly, regardless of their background and protected characteristics.

The Bar is a broad church and I represent members who do not agree with me on EDI. So I will continue the conversation that persuades, not forces, those who disagree that it is both reasonable and realistic to expect members of chambers, employers, and Bar stakeholders to put practical measures in place to monitor internal practices and take steps to challenge inequalities.

So here is my invitation to all who disagree with me on EDI. If you are serious and ready to bridge the gap between us, if you are prepared to have respectful dialogue backed by evidence, then my virtual and real doors are open. Please don’t sit behind your screen and only put your thoughts on social media. This is too nuanced and important. Come and talk to me.

Talking alone is not enough. The actions I will take will focus on what we know from the Wellbeing report about bullying and harassment, the Young Bar, and the earnings disparity, and, finally, the Employed Bar.

BULLYING AND HARASSMENT

One aspect of our workplace culture which is being brought further into the light is bullying and harassment.

The Independent Review into Bullying, Harassment and Sexual Harassment commissioned by Sam Townend KC will report in June this year. I am committed to working with Baroness Harman and providing her with the support she needs to finalise her review, and I look forward to working with her and the profession to consider the findings and her recommendations for action.

The review provides an important opportunity to reset our culture and improve the working lives of all in our profession and I intend to give it the priority it deserves.

While we await the findings, I would remind everyone working in and around the Bar to make use of the support and reporting mechanisms available – from Talk to Spot to the Wellbeing at the Bar resources.

THE YOUNG BAR

Addressing earnings disparities must be at the top of our agenda, especially at the junior end of the profession –earnings in early years can set a trajectory for an entire career.

Appointing barristers from under-represented groups without supporting them to earn as much as their male/white counterparts is discriminatory.

Experience shows advancements in numbers does not ensure better retention, progression, cultural change, or income equality. A focus on earnings highlights inequality in access to work that affects our opportunity to progress.

The Bar Council’s November 2023 report on earnings highlights the variability in barristers’ practices, making comparisons challenging, but the key findings indicate a consistent pattern where men’s median gross earnings surpass women’s. Specifically, the earnings gap begins at the very start of a woman’s career and widens, peaking at a 30 per cent difference in the 11–15 years’ Call band. Women silks earn about 71 per cent of their male counterparts’ median earnings, translating to a nearly 30 per cent shortfall.

Even though both men’s and women’s earnings have slightly increased over the past year, the earnings disparity remains unchanged. Additional analysis reveals that median incomes for Black and Asian barristers are generally lower than those for White barristers, with Asian KCs out-earning White female KCs but earning less than their White male peers. Notably, Black KCs, numbering only 24 in 2023, earn a median of 44 per cent of White KCs’ earnings.

The Young Bar are the lifeblood of the profession so I will start there. During a circuit visit, a group of young barristers revealed they were unaware of the Bar Council’s 2024 report analysing the earning gap for those in the first three years of practice, New practitioner earnings differentials at the self-employed Bar, and the Bar Council’s toolkits for meaningful practice reviews. That lack of knowledge was matched by another group telling me that they find practice and income reviews impossible to deal with.

To address this, I will collaborate with Inns’ course providers to incorporate information about practice management and review into new practitioner programmes and continue to raise awareness of what tools and resources are available to the whole Bar.

THE EMPLOYED BAR

According to our most recent Barristers’ Working Lives survey data, nearly 18 per cent of barristers are in employed practice. Just over half (54 per cent) work in the public sector and the other half work in the private sector.

There is a huge breadth and quality in the work that employed barristers undertake, across many sectors of the economy and justice system. A potential key driver of the success of the Employed Bar is its diversity – the Employed Bar is more diverse than the Self-Employed Bar – and its culture of flexibility.

Career progression has been highlighted to me as a key challenge for the Employed Bar. There is a feeling among some employed barristers, particularly in the public sector, that their skills and experiences are under-utilised, so exploring how we encourage employed barristers to make full use of their skillsets should be a priority.

Similarly, at the more experienced end of the Employed Bar, there is the issue of how seniority is defined, when KC applications are so heavily focused on advocacy, which some very senior members of the Employed Bar may not exercise.

I will work closely with the Employed Barristers’ Committee to

address these issues.

ENGAGEMENT WITH THE BAR COUNCIL

As to the third part of a Chair’s year – the curveballs. I’ll have to wait and see what’s thrown at me, but I know I will be well supported by Malcolm Cree and the fantastic team at the Bar Council.

I am incredibly grateful to the hundreds of barristers who generously give up their time for the good of the profession, with special thanks to the Chairs of the various committees as well as the Chairs of the Specialist Bar Associations. I want to thank Lorinda Long for her eight years of service as the Bar Council’s Treasurer, and Amrit Kaur Dhanoa – our outgoing Young Barristers’ Committee Chair – for her excellent year supporting and promoting the Young Bar. And I look forward to working with new YBC Chair Lachlan Stewart over the coming year.

This year, I want to draw more colleagues into the Bar Council, and I’d like the Bar to feel – whether you’re working in Newcastle or in Newport – that you’re a part of, and matter to, the Bar Council. I hope that when it comes to subscribing to the Bar Representation Fee that, like me, you see the value in what the Bar Council does with that funding to support and promote the Bar.

I will also be working closely with the Circuit leaders and look forward to my upcoming first visit to the Wales and Chester Circuit next week, as well as hosting the Bar Conference on the Midland Circuit on 6 June – I hope to see you all there.

Thank you, Baroness Hallett, Mrs Justice McGowan, ChantalAimée Doerries KC, and Amanda Pinto KC, for your inspiring leadership as the previous female Chairs of the Bar. Your achievements provided the strong shoulders for me to stand on and enabled me to dream, and eventually achieve, what once seemed impossible, becoming Chair myself.

And to my younger self. Thank you – for ignoring those who said Black women who went to Hull University could not make it at the Bar, for having the audacity to boldly try new things, and to be prepared to do whatever it took to push past the discomfort when you felt you did not belong.

As children growing up in Ghana, our elders needed us to look after one another, so would often keep us in check with a reference to an old African proverb:

“If you want to go fast, go alone. If you want to go far, go together.”

I am ready to serve this amazing profession of ours. Walk with me so we can go far together.

If you want to go fast, go alone. If you want to go far, go together.

Barbara Mills KC Chair of the Bar Council 2025

SOCIAL CONTEXT OF THE LAW: PERVERSE NOT GUILTY VERDICTS SHOULD REMAIN FINAL

Taken from a panel discussion held on 19 May 2025 between Master Peter Blair, Master Konrad Schiemann and moderated by Master Deborah Taylor.

Her Honour Deborah Taylor: What is a perverse verdict? One definition is ‘the verdict of a jury that’s either contrary to the judge’s direction on the question of law, or totally against the weight of the evidence’ or, as in most such cases, both.

For some, the jury system is sacrosanct, described as the cornerstone of criminal justice and, more romantically, as the light that shows that freedom lives. But are we, as a society, content to take perverse verdicts by juries as a necessary component?

If we are to maintain the jury system and rule of law in an era of populism, misinformation and trial by social media, should the prosecution have the right to seek leave to review perverse acquittals? Or are those verdicts an important safeguard of last resort against wrongful imprisonment and government tyranny? Do they assist the development of the law to keep in step with society?

Juries are acknowledged as not infallible. Where a jury is shown to have wrongly convicted an accused person, a higher court can overturn that conviction. Should there also be a similar power for perverse acquittals by juries?

This, of course, is not a totally novel concept in crime. If a district judge sitting in a Magistrate’s Court properly directs himself or herself that there is in law no defence to a charge, but nonetheless decides it is unfair and acquits the defendant, the Crown Prosecution Service would undoubtedly require the judge to state a case for the opinion of the High Court, which would most likely, in turn, return the case to the Magistrate’s Court with the direction to convict.

Is that a power that should now be open to the Crown, or a smaller power, where a jury convicts in the face not only of clear evidence, but a direction from the judge that, in law, there is no defence to the charge? And if not, why not?

Do we consider those sorts of juries as impregnable because the verdicts are of the people, never mind the evidence? Can we ever know, absent a reasoned decision by the jury, how the perverse decision was reached? And can we know if the same verdict would have been reached by a different jury, also giving a verdict of the people on the same evidence and directions from the judge.

His Honour Judge Peter Blair: You will have seen a cartoon of a judge in mid-explosion, with their hands held out wide in exclamation, their face as red as a pillar box and eyes bulging. On occasions, that might secretly have been a picture of my inward reaction to a jury verdict with which I profoundly disagreed. On the whole, I remain completely indifferent to whatever decisions they choose to reach.

In 1960, Mr Justice Stable got in trouble with the Court of Appeal for this legal direction to a jury: “In 10 minutes I shall leave this building, if by that time you have not arrived at a conclusion in this case, you will have to be kept all night. I do not know why you should require all this time to talk about the matter.” He was rewarded with a guilty verdict some six minutes later; the Court of Appeal was less impressed.

Master Peter Blair, Master Deborah Taylor and Master Konrad Schiemann

Just 290 years earlier, the trial judge really did lock up the jury without food for two nights, leading to a writ of habeas corpus before Chief Justice Vaughan in Bushel (1670) 124 ER 1006. The plaque to that event in the Central Criminal Court records that this established the right of jurors to give their verdict according to their convictions or conscience.

In R v Wang in 2005, Lord Bingham gave the House of Lords’ view and upheld the proposition that there are no circumstances in which a judge is entitled to direct a jury to return the verdict of guilty. A judge can get close to directing this but must always add the proviso: “The verdict is ultimately a matter for you to decide.”

A juror takes an oath to try the defendant and give a true verdict according to the evidence. And since we are not permitted to know what happens in the jury deliberations, and they give us no reasons for their verdicts, we have no way of knowing if they have been true to their ‘oath’ or ‘affirmation’.

We have this tension between the obligation to give a true verdict according to the evidence, and the jury’s right to give their verdict according to their conscience.

Can you, as a barrister, address the jury and invite them to vote according to their conscience, rather than according to the evidence and the legal directions they have been given? Absolutely not! That led me to having an exploding reaction within the trial of those who pulled down the statue of Edward Colston in Bristol.

The defence barrister had the audacity in this closing speech to invite the jury to reach a verdict which put them “on the right side of history”. I expressly directed the jury to ignore such irrelevant pleas and considerations, but to focus instead on the legal defences which the prosecution had to disprove. A barrister cannot invite a jury to decide a case on considerations beyond the law and evidence. But what about a member of the public who holds a placard in the sight of potential jurors, reminding them of the principle sometimes known as jury equity? In 2023, many people were protesting outside Crown Courts up and down the land after the Solicitor General sought to bring contempt of court proceedings against a Mrs Warner for doing just that outside Inner London Crown Court during an Insulate Britain protest trial.

Mr Justice Saini refused permission to bring proceedings against her because she had not interfered with the jurors, she had not been inaccurate in what she had said and there had not been a serious risk of interference with justice. Although there was an initial plan to appeal against his judgment, the new government, when it came in, chose not to.

The principle of jury equity should be regarded as a power, but not a right. In simplistic terms, the King has the power to refuse to sign new legislation into law, but he does not have the right to do so under our constitutional monarchy.

Is it perhaps not true to say that a jury has this power, but it is an old, anachronistic power for which there is no rightful justification to exercise in modern times? We do not have a tyrannical state which demands the pressure valve of a perverse verdict to exist as a jury right. All this legal language and the subtle distinctions between power and right ultimately become somewhat meaningless, because a jury will do what it wants.

I was asked to prosecute saboteurs of the US Air Force base at Fairford in Gloucestershire. I advised the Ministry of Defence (MOD) police that I was pessimistic that we would find a jury who would convict, given B52 bombers had dropped cluster bombs on Baghdad and depleted uranium bunker-buster shells in that city. The MOD decided they were going to proceed. Nonetheless, it went all the way up to the House of Lords on a preliminary question of whether they could run the defence of preventing what they believed were war crimes. Not one of the three jury trials was able to reach a verdict in which at least ten jurors were agreed.

In the retrials, two ended up in acquittals and the third in a conviction. Juries will be juries, whatever the lawyers say and whatever the politicians would like.

Sir Konrad Schiemann: Take the case of a landowner who wishes to dig coal on his own land. A number of people invade that land and physically prevent him from doing so. The defence raise a public interest issue, namely, whether burning coal is against the public interest because it aggravates climate warming. Two questions arise: who should resolve the public interest issue, and how should that issue be resolved?

A proper system of law requires that the decision that the jury comes to should be in accordance with the law. If they come to a different decision, the question then arises about what can be done about that?

We accept that prosecutors have the power to decide not to prosecute in particular cases, but I see not the slightest reason why the verdict of a jury should not be capable of being appealed to a higher court to see whether it is in accordance with the law.

If the higher court decides that it is not in accordance with the law, it may be wise for the higher court to send the case back for retrial, and then the prosecution can consider whether indeed there should be a retrial.

But the jury has no right to ignore the law. They are however free to do so without being under any personal risk. When I was trying cases as a judge there were times when the jury reached a perverse verdict and I was delighted that they had done so because that removed from me a terribly difficult sentencing problem.

The one I remember most clearly is a case where a man was charged with rape of his wife in circumstances where they had been married for a very long time, and they had reached a perfectly amicable agreement that she expected to be left alone, except on Fridays. But one day, he came home having had rather too much to drink, forgot which day of the week it was and went ahead all the same.

He turned over and went to sleep. The following day she went to her mother who said, perfectly correctly, that if she had told her husband that it was not Friday, then this was rape. She advised her daughter to report the matter to the police. This the daughter did. The police arrested her husband at work and took him to a hostel and forbad him to go home. The case came in for trial in front of me. I was a rather inexperienced judge at the time and asked more senior judges for advice. They said, “the Guidance is quite clear. You must sentence her to at least three years.”

I asked to see the visitors’ book at the hostel; I saw that the wife had visited him every day.

And I said to the wife, “When did you last see your husband?” And she said, “Oh, I saw him yesterday.” “Oh, was that the first time you’d seen him?” “Oh, no, no, I see him every day.” “Why do you do that?” “Because I want him to come home!”

At this point, I looked at the jury and they were sort of casting their eyes up to heaven. I then had to instruct the jury as to what the law was. The law was perfectly clear, I read to them the definition of rape and said, “You have to decide whether the husband is guilty of the serious crime of rape, or of serious bad behaviour on that particular occasion. And I leave it to you to decide what to do.”

When I was trying cases as a judge, there were times when the jury reached a perverse verdict and I was delighted that they had done so because that removed from me a terribly difficult sentencing problem.

They retired and came back after five minutes and found him not guilty. I was very relieved. There have been one or two other cases like that where one has been spared a difficult decision on sentencing. I am grateful to juries who, by a series of acquittal verdicts, in such circumstances can encourage parliament to consider altering the law to bring it into line with what juries appear to think appropriate. Yet it remains for parliament to make the law and to define what the task of the jury is. The jury should not be regarded as having a right to define their own task.

To do otherwise produces a situation of complete uncertainty in the law and the law ought to be certain. We have lived together on the basis that we forego our right to make our own decisions in certain fields for the bigger benefit of living in a society where the law is clear and regulated.

His Honour Judge Peter Blair: The problem, in that parallel, is knowing what the jury’s reasoning is, and our inability to find that out. We are all awaiting Sir Brian Leveson’s proposals about how we are going to cope with the problems in the criminal justice system and the backlogs of trials. I can’t imagine that there will be anything other than a parallel to the magistrates’ appeal, so that if we reach a perverse acquittal in the eyes of the prosecutor, then we will be able to appeal by case stated.

I can see how, when you know what the attempted rationale is for the acquittal, that there should be a permitted appeal. There are very few cases where a jury’s verdict is rationalised by reference to their slightly contrary view of a witness’s credibility.

Her Honour Deborah Taylor: One of those cases was the prosecution of Clive Ponting under the Official Secrets Act, where it was quite accepted, and the evidence was very clear, that he had leaked documents, but the jury nonetheless acquitted him. The question is whether a perverse verdict undermines the rule of law and democracy, whilst the jury may think it upholds democracy.

Sir Konrad Schiemann: In the last analysis it is a question of who should decide. Jurors are not the people who are being paid to decide that in our constitution. It is for parliament to decide how that sort of case should be decided; and parliament can say ‘this is to be decided by the jury’, in which case I have no problem at all. But if parliament has not said that, for the jury to be regarded as having had a right to do this seems to be very odd indeed.

His Honour Judge Peter Blair: In the United States, a perverse acquittal can, in certain instances, involve a judge overturning it and saying it is nonsense. That decision of the judge can and would ordinarily be appealed, and the higher court would decide whether the judge should or should not have intervened. They do it more often than not with inconsistent verdicts or their perception that a jury could not have acquitted on one count and convicted on another.

Sir Konrad Schiemann: The practicalities of producing a reasoned verdict from a jury of 12 people who may have had 12 perfectly different reasons for getting to precisely the same answer, is a huge problem. But that difficulty is, by its nature, inherent in having juries at all.

Her Honour Deborah Taylor: In a sense, that is the difficulty with a perverse verdict, that you simply do not know how the verdict has been arrived at, who arrived at it or in what proportion.

Sir Konrad Schiemann: If the perversity consists of it being against the law, as opposed to a misappreciation of the evidence, it doesn’t matter how the jury came to the conclusion that the law was one to be ignored. It may be a useful guide for future action by other people, but it should not decide the case.

His Honour Judge Blair KC Recorder of Bristol

The Rt Hon Sir Konrad Schiemann Her Honour Deborah Taylor

For the full video recording: innertemple.org.uk/notguilty

CELEBRATE THE LIFE: MASTER ANTHONY LLOYD

A tribute given by Master Elizabeth Bulter-Sloss at a memorial service held on 12 June in the Temple Church for The Right Honourable The Lord Lloyd of Berwick, Treasurer of The Inner Temple in 1999.

There is so much to say about Tony Lloyd, Lord Lloyd of Berwick, and his long and distinguished career, that you will not be surprised that I have had to be extremely selective. So many of you here will have seen him in different contexts. I thought I knew him well until I started to realise while writing this tribute how much I did not know.

It might be said that Tony sailed through life, and everything came easily to him. He had a formidable personality: clever, athletic, charming and delightful to meet. He was also hard working, a good lawyer and much concerned with justice and fairness throughout his career. He stuck to things he believed in and persisted in supporting them. He also had a great sense of humour and mischief. Unfortunately, no one will give me a repeatable example of his mischievous side. He was summed up very appropriately by one of his nephews as having a joie de vivre

Born on 9 May 1929, Tony was a King’s Scholar at Eton and later became a Trustee of the College. In Douglas Hurd’s memoirs he refers to his friendship with Tony at Eton. He was Douglas Hurd’s main competitor, and they had “an affectionate rivalry with frequent ructions in the early years”. I heard from Nick Hurd that Tony would take him and his brother as children in a silver sports Sunbeam Alpine along the Sussex lanes at 100 miles an hour.

In 1948, Tony was commissioned into the Coldstream Guards. After his service in the Army, he went on to Trinity College, Cambridge where he read Law. It was there that he got a Blue running the mile for Cambridge and, I am told, ran against Roger Bannister. He also became a Law Fellow and, later, an Honorary Fellow at Peterhouse and a Choate Scholar at Harvard.

Tony was called to the Bar by The Inner Temple in 1955 and went on to practise in maritime and commercial law at No 3 Essex Court. He took Silk in 1967 and served as a Judge of the Queen’s Bench Division from 1978–1984 and as a Lord Justice of Appeal from 1984–1993, when he became a Law Lord, Privy Counsellor and life peer. He remained active in the House of Lords as a Crossbencher until his retirement in 2015.

At the Bar he took on other commitments such as becoming Attorney General to the Prince of Wales, now His Majesty King Charles III. While at the Court of Appeal he was also the Interception of Communications Commissioner.

Tony was very determined and, when necessary, courageous. In a case brought by a Home Secretary which went to the Judicial Committee, Tony was the only one of all the judges who heard the case who supported the Home Secretary. After hearing an appeal on an intellectual property case concerned with teddy bears, he kept the teddy bear exhibit.

Anthony Lloyd © Garlinda Birkbek

Master Anthony Lloyd

While he was on the Bench, he was largely responsible for the setting up of the Judicial Studies Board, now the Judicial College.

In 1960, he married Jane; they had a long and happy marriage, though the absence of children was a great sadness for them, but always with them were one, sometimes two, dogs whom they adored. Jane, a strong personality herself is very kind, gentle and generous. She was Tony’s anchor, and he relied on her commonsense and support throughout their married life. She kept him grounded and he was very proud of her becoming High Sheriff of East Sussex.

Tony was also the best possible uncle to his nephews and nieces, giving some of them grand lunches before their return to boarding school and taking them skiing.

As a Crossbencher and a regular attender in the House of Lords, he was a member of and chaired various committees including the Select Committee on the Speakership and the Ecclesiastical Committee.

Among many other commitments, he was Chair of the Security Commission, Vice Chair of the Parole Board, Vice Chair of the Top Salaries Review Body, Vice President of the Maritime Law Association and Master of the Salters’ Company where he and Jane were much involved in the company’s charitable work.

As Chair of the Inquiry into Legislation against terrorism he suggested that the task was to try to bring potential terrorists over to our side.

Alf Morris, The Lord Morris of Manchester, campaigned for veterans of the First Gulf War. He persuaded Tony to chair the Inquiry into Gulf War Syndrome in 2004. Many of those who served in the first Gulf War became ill from causes which the Ministry of Defence did not understand and would not accept the medical consequences. Tony’s conclusions were typically clear and robust. He told the government to acknowledge publicly that the veterans who made claims were suffering injury or disease as a result of their service in the first Gulf War and to pay compensation. In his speech in the Lords on the report, Lord Morris congratulated Tony and said, “Scrupulously fair and balanced in its judgment, his report’s conclusions are presented with excelling clarity and a relentless and compelling logic. Its purpose is not to apportion blame but to end deadlock and, by unravelling the truth, to let right be done.”

Tony’s valedictory speech in the Lords was based on his campaign to help prisoners held on indeterminate sentences.

Tony was elected as a Bencher of The Inner Temple in 1976, becoming Treasurer in 1999. He retired as a Law Lord in order to become Treasurer and gave it his full attention. He said it was the happiest year of his professional life. As Master of the Pictures, he once said of the rather severe portrait of Elizabeth Lane in the Inn’s collection, that he would write on the back that she was female.

Tony and Jane had a flat in The Inner Temple and, until last year, regularly attended the Temple Church. Tony was also very attached to the Diocese of Chichester where he was Chair of the Diocesan Board of Finance.

Tony was Vice President of the Sons of the Clergy and a member of the Bishop’s Council.

Tony and Jane much enjoyed music: he was an Honorary Fellow of the Royal Academy of Music (RAM) and Chair of Glyndebourne Arts Committee. He and Jane regularly went to the Wigmore Hall. As he became deafer his voice could be heard across the Hall when he arrived for a concert. He was also a trustee of Henry Smith’s Charity.

Tony was a generous supporter of many institutions such as Eton, Trinity and Peterhouse, Cambridge and the Salters’ Company. He also was generous to Glyndebourne the RAM, Chichester Cathedral, the Temple Church and Berwick Church and was known to dress up as Father Christmas for some of his charities.

The Ptolemy column in Church Court with two Knights Templar on a single horse was a gift of Tony and Jane to mark the Millenium.

Alongside the flat in The Inner Temple, Tony and Jane also had an entirely separate life in Sussex. They bought their house many years ago in poor condition and went on to improve it enormously over a 50-year period. They farmed about 50 acres with a special breed of cows and a flock of sheep. Tony told me with pride that they did their own lambing, once, I am told, helped by one of Jane’s nephews.

Tony became a Deputy Lieutenant of East Sussex, Chair of the Sussex Association for Rehabilitation of Offenders and President of the Sussex Downsmen.

Tony was good with his hands and keen on carpentry and bricklaying. He loved a fight, and I am told that there is a large pile of papers referring to his battles against Congestion Charges.

This a very brief summary of a very successful, much respected and loved man who will be remembered by so many whose lives were affected by their contact with him. Elizabeth Roskill said, some 20 years ago, “Dear Tony, such a clever man. If only he had not been such a flibbertigibbet, he might have made something of his career”. You might think he did!

Tony died on 8 December 2024.

The Rt Hon the Baroness Butler-Sloss GBE Retired Judge, President of the Family Division, 1999–2005 Treasurer of The Inner Temple 1998

© Garlinda Birkbek

MURDER (ABOLITION OF THE DEATH PENALTY)

ACT 1965:

60 YEARS – RUTH ELLIS

In this anniversary year of the abolition of the death penalty, the Sub-Treasurer recalls the case of Ruth Ellis, the last woman to be sentenced to death in the United Kingdom, seventy years ago on 13 July 1955.

As is well known, Ruth Ellis was the last woman to be sentenced to death and executed in the UK, her hanging taking place on 13 July 1955. A long-time nightclub hostess and manageress, and much abused by the men in her life, she shot dead her lover, David Blakely, outside the Magdala Pub in South Hill Park on 10 April 1955. She fired six shots from a revolver, four of which hit him.

The Ruth Ellis Files: A Very British Crime Story was filmed partly at The Inner Temple by the BBC towards the end of 2017 and first shown on BBC Four in 2018. More recently the ITV drama A Cruel Love: The Ruth Ellis Story was also partly filmed at the Inn. However, the wider connection between her trial and The Inner Temple is less commonly known. The trial took place in Number One Court at the Old Bailey on 20 June 1955 before Mr Justice Havers (Sir Cecil Havers), who was Treasurer of The Inner Temple in 1971 and father of Master Elizabeth Butler-Sloss.

Aubrey Melford Stevenson, Ellis’s counsel, led for the defence. Peter Rawlinson (whose portrait is in the Inn’s Drawing Room and who presented the Rawlinson Cup, which is awarded annually in a debating competition) was his Junior. Rawlinson got to know Ellis well through briefing her in the cells of Old Bailey each day. Both barristers expressed concern about the way in which she was strikingly dressed for the trial, with dyed blonde hair, but she did not wish to alter her appearance. The prosecution was led by Christmas Humphreys, founder of the British Buddhist Society. All of these barristers were Inner Templars, the first two being Treasurers of the Inn in 1972 and 1984, respectively. Humphreys’ junior was Mervyn GriffithJones, a Middle Templar and the father of the present Reverend and Valiant Master of the Temple, Master Robin Griffith-Jones.

A Cruel Love: The Ruth Ellis Story © Ian Johnson Publicity and ITV

At the trial, Ellis freely admitted to shooting David Blakely. Christmas Humphreys (who was opposed to the death penalty in principle as a Buddhist) then asked her only one question in cross-examination, “When you fired the revolver at close range into the body of David Blakely, what did you intend to do?” to which she replied, “It’s obvious, when I shot him I intended to kill him.” On the law as it then was, she had no defence. So, he sat down. The jury took 20 minutes to convict her, and the unanimous guilty verdict led to what was then a mandatory death sentence.

The jury took 20 minutes to convict her, and the unanimous guilty verdict led to what was then a mandatory death sentence.

In a television interview in 2010, the judge’s grandson, actor Nigel Havers, revealed that his grandfather had written to the then-Home Secretary Gwilym Lloyd George recommending a reprieve for Ellis, as he regarded the shooting as a crime of passion. Lloyd George sent a curt refusal and refused to allow any further enquiries. Sir Cecil Havers subsequently sent money annually for the upkeep of Ellis’s son, Andy. The latter committed suicide in 1982, and Humphreys paid for his funeral. There have been subsequent attempts, so far unsuccessful, to obtain a posthumous pardon for Ellis.

Greg Dorey CVO Sub-Treasurer

A Cruel Love: The Ruth Ellis Story

© Ian Johnson Publicity and ITV

Lord Darling wearing the Black Cap to pronounce the death penalty, by Sir John Lavery RA © Inner Temple Collection

The Right Honourable Lord (Peter) Rawlinson of Ewell by Keith Breeden RP

© The Inner Temple Collection

READER’S LECTURE SERIES:

THE WORK OF UNIDROIT AND THE FUTURE FOR THE INTERNATIONAL HARMONISATION OF COMMERCIAL LAW

From a Reader’s Lecture delivered on 9 October 2024 by Professor Louise Gullifer, Rouse Ball Professor of English Law, University of Cambridge.

INTRODUCTION

I am delighted to be able to talk to you this evening about transnational commercial law, and the work of UNIDROIT. Transnational commercial law is an area of legal endeavour that is important for the world, for the ongoing development of trade, commerce and finance, and for the integration of private law across the world.

Commercial activity is one of the areas of law where the issues to be solved by law are pretty much the same everywhere. Examples of ‘old’ issues are those thrown up by global supply chains, the need for access to credit and dispute resolution. Examples of ‘new’ issues are those relating to the evolution of new types of assets and the shift in many areas of commerce to digitisation. States tackle these common issues in a way that reflects their own legal culture and system. This leads to at least two problems. The first is that some states’ law will work better than others. The second is that market participants, and their lawyers, have to become familiar with, and deal with, many different rules. This leads to increased transaction costs.

Transnational law instruments can address these problems at their roots. They provide a text which reflects the ‘best’ law that can be designed to fit within every legal culture. Transnational law can either provide a uniform body of rules (‘hard law’), so that, in theory, the law in every state will be the same; or it can provide a model for states to adopt, to improve their domestic law and to achieve harmonisation (‘soft law’). This talk will address a number of basic questions about transnational commercial law.

WHERE, AND BY WHOM, ARE THESE TRANSNATIONAL LAW INSTRUMENTS CREATED?

There are three organisations doing this type of work. UNICTRAL is based in Vienna, was established in 1966 and is part of the United Nations. UNIDROIT is based in Rome and was founded by the League of Nations in 1926. The Hague Conference on Private International Law dates from 1893 and focuses entirely on conflict of laws instruments, though not necessarily on commercial law.

WHY ARE THESE INSTRUMENTS CREATED?

The primary argument is the resulting reduction of transaction costs, since the instrument obviates the need to ascertain the details of different laws in cross-border transactions. Second, the application of different laws leads to unpredictability and uncertainty, both as to which law may apply, and to the content of the law. Unification (or harmonisation) increases predictability and certainty. It also facilitates co-ordination in the provision of information. An example of this is the International Registry set up by the UNIDROIT Cape Town Convention (2001), which provides unified rules for the financing of mobile equipment.

The arguments in favour of unification and harmonisation are often countered by an argument that their benefits can be outweighed by those of regulatory competition. However, the regulatory competition argument only really works if there is complete freedom of choice, which works in some contexts (such as contract law) but not in others (such as property law). Moreover, regulatory competition can lead to a ‘race to the bottom’ resulting in sub-optimal law.

HOW ARE THESE INSTRUMENTS CREATED?

To discuss this, I need to explain the different types of instruments. Hard law consists of treaties and conventions which bind ratifying states. While very effective at harmonising law, they are costly and time-consuming to produce via a process which involves negotiations between state representatives. It also takes quite some time to get ratifications: their binding nature means that careful (and lengthy) consideration is required before states ratify. In the commercial sphere the support of market players is crucial here.

Alternatively, soft law instruments such as Model Laws and Principles are texts which are designed to be implemented by states into their national law with varying degrees of adaptation to enable them to be able to fit into existing law. It is quicker and easier to produce than hard law and provides flexibility for states in implementation.

In terms of the creation process, I am going to describe the methods used at UNIDROIT but the methods of the other organisations are similar, at least in outline.

First, a topic is chosen after a proposal from a government, an intergovernmental organisation such as the World Bank, an NGO, for example the International Swaps and Derivatives Association (ISDA), or an international financial institution such as the European Central Bank. All proposals go through an internal vetting procedure and then, in relation to each project, a working group of independent international experts from different legal cultures and countries is set up. Their discussion sessions are usually also attended by observers from international organisations, NGOs, industry and market players, who contribute to the debate and the drafting. After a number of meetings, a near-final draft is produced and sent out for public consultation.

There is a big difference between hard law and soft law as to how an instrument is adopted. A draft hard law goes to a committee of governmental experts (appointed by states) and then to a diplomatic conference, where state representatives discuss and amend the text before adoption. A draft soft law is finalised by the working group and then approved and adopted by the Governing Council.

Once adopted, the instrument can be implemented by states. In relation to hard law, a state has to ratify the treaty. This is a process internal to the state, but each of the transnational law organisations keeps a public record of ratifications of their instruments. Depending on the constitutional law of the relevant state, the treaty will either take effect as national law on its ratification (monist) or (as in the UK) it will take effect when implemented in national legislation, so that ratification and implementation go hand in hand.

The implementation of soft law is rather more interesting. A Model Law is a fully drafted legislative text that can just be implemented with very minor local modifications. See, for example, s.2(1) of the Cross-Border Insolvency Regulations 2006 implementing the UNCITRAL Model Law on cross-border insolvency 1997. However, implementation does not always have to be verbatim, see, for example, the UK Electronic Trade Documents Act 2023 implementing the UNCITRAL Model Law on Transferable Electronic Records 2017 (although this Model Law has been implemented nearly verbatim in some other states, such as Singapore).

Principles are not designed for specific linguistic enactment, but so that domestic law can be aligned with them. It may be that national law already reflects the principles (or some of them) in which case there is nothing to do in relation to implementation. Principles, however, may inspire states to craft their own law. For example, the UNIDROIT Principles on the operation of close-out netting provisions 2013 have been influential in the legislation of many states. Principles may also be reflected in parties’ contracts eg UNIDROIT Principles of International Commercial Contracts 1994 (2016).

WHAT TYPES OF ISSUES DO THESE INSTRUMENTS ADDRESS?

Transnational commercial law instruments cover a wide variety of subject areas within the commercial sphere. Some instances have already been mentioned; this section will focus on just two examples.

The first is the UNIDROIT Model Law on Factoring 2023 (MLF). Factoring is a term used internationally for the sale of receivables to a financier in order to obtain immediate finance. Globally, it is considered particularly suitable for micro, small and medium sized enterprises (MSMEs), which generally suffer from a huge lack of finance.

The English law of assignment, which is complicated but flexible, facilitates this type of finance and is very widely used. However, in many countries, particularly in developing economies, there are frictions and barriers to a smooth receivables financing market, such as formal requirements, which mean that it is impossible to do this type of financing without paper, and a lack of clear priority rules, which leads to a concern about fraud. The MLF project was proposed by the World Bank Group, which wants to use factoring as a way of increasing access to credit in developing economies. The idea was to have a targeted set of rules, which a state can enact reasonably easily without having to change their entire law on secured transactions. The MLF includes a simple method of effecting factoring transactions, a national notice-based registry for such transactions, and clear priority rules based on registration, which reduces dramatically concern about fraud. The MLF is a good example of how transnational commercial law can improve the domestic law through harmonisation.

A current UNIDROIT project is on the Legal Nature of Verified Carbon Credits (VCCs). This project concerns carbon credits that are created for trading in the private markets, as opposed to those created for compliance with legal regimes imposing caps on emissions. VCCs are a means of financing projects designed to remove carbon emissions from the atmosphere or to reduce the amount of carbon emitted, such as carbon capture and planting of forests. Once a project has successfully removed a certain amount of carbon, that fact is verified by an independent verifier as, say, removing 1,000 tonnes of CO2 from the atmosphere. The verification is used to issue 1,000 VCCs, which are credited in a registry to the account of the person who removed the carbon. That person can then transfer the VCCs or any of them to other people: traders, or businesses who themselves emit carbon. A credit can be ‘used’ by a business when stating how it is meeting its aim to be carbon neutral. At this point it must retire the VCCs, which cannot then be transferred to anyone else, thus preventing double counting.

The VCC project aims to provide principles of private law, which will bring some legal certainty and enable the secondary market to be scaled up. The first problem, then, is to work out how these things can be the object of proprietary rights. The problem is that, unlike securities, VCCs don’t represent any rights against anyone. Nor are they tangibles, as they are not issued electronically. So the challenge is to explain, in a way that will make sense to all jurisdictions, how they can be the object of proprietary rights, that is, rights with third party effects, and then to work out how private law rules can apply to the registries, to custodians, the taking of security over VCCs, and whether there should be a taking free rule (a ‘nemo dat’ exception) when VCCs are transferred, in the way that most jurisdictions have a taking free rule in relation to securities.

One major challenge is to decide whether we are responding to how the market is now, or to try and shape the market for the future. This is a difficult project, and a very important one that could have a major effect on the financing of green projects, especially in developing economies.

HOW IS THE FIELD OF TRANSNATIONAL COMMERCIAL LAW LIKELY TO DEVELOP IN THE FUTURE?

Hard law is expensive to produce and may not lead to unification. For example, the UNCITRAL Convention on the International Sale of Goods 1980 (CISG) can, and often is, excluded by contracting parties even where it would otherwise apply. Another example is the UNIDROIT Geneva Securities Convention 2009 (GSC), which has no ratifications at all. However, a treaty, even if not used as a treaty, may become the basis for national law reform. The CISG has acted as an inspiration for law reform in the area of sale of goods, especially in civil law jurisdictions. Despite not being a ratified treaty, the principles in the GSC have found their way into intermediated securities law in many countries.

Realistically, the future is probably mainly in the creation of soft law, which not only is easier to create, but which has considerable international power coming from its flexibility. Soft law is seen as less threatening by states and is therefore more likely to be adopted in some form or other, as well as being easier to negotiate, and has become an important tool for economic progress in developing economies. It also plays a role as a standard setter (demonstrating what a ‘good’ and ‘best practice’ law looks like) and an educational tool. As a legal culture neutral model, it is easier to use than any particular national law, which requires an understanding of the general legal culture of the relevant state. Soft law can also be used to promote market certainty, as, for example, in relation to VCCs.

WHAT ROLE CAN THE UK PLAY?

First, it can examine commercial law treaties carefully and decide whether there are good reasons to ratify. For example, will it result in a wider market for the UK or enable UK businesses to access finance more easily? It should also consider whether UK ratification would be seen as setting an example. Hard law works better the more states ratify the treaty. Once there is a critical mass of ratifications, other states will join; thus, states seen as leaders in commercial law can lead by example and encourage other states to ratify. How else can the UK contribute? The UK can provide experts to be involved in development and drafting of instruments. English lawyers have very deep common law experience, and our drafting style is prized: ‘English English’ is still at a premium as is our succinct drafting. But it is a two-way street. We can also learn from international instruments to improve our law. For example, in the course of its work on digital assets, the Law Commission of England and Wales attended the sessions of the UNIDROIT project, enabling a very helpful sharing of ideas.

In relation to transnational commercial law, any state has a choice: to embrace harmonisation (and unification where relevant) or to go it alone. The UK has an even more important choice, since English law is seen as a globally leading law. We can be either global leaders or outliers. The picture is quite mixed: we are very involved in some areas, and less so in others (for example, the CISG and secured transactions law reform). But even in these areas, I, and many others, are engaging academically and practically, and walking both ways down the two-way street. We are still very fortunate to be seen as global leaders in this area at the moment: the future is in the hands of the next generation of academics and practitioners.

Louise Gullifer

Rouse Ball Professor of English Law, University of Cambridge

For the full video recording: innertemple.org.uk/unidroit

THE NUREMBERG TRIALS

By the Archives Volunteer

“The Trial which is now about to begin is unique in the history of the jurisprudence of the world and it is of supreme importance to millions of people all over the globe… [It] is a public Trial in the fullest sense.”

These words by Sir Geoffrey Lawrence, later Lord Oaksey, opened his first speech as the President of the International Military Tribunal (IMT) in Nuremberg. The magnitude of Lawrence’s historic statement continues to resonate 80 years after the trials, in a world where the legacy of Nuremberg has shaped both international law and collective memories. Members of The Inner Temple – such as Lawrence, Treasurer in 1954 – played a key role in the trials and their legacy, cementing the Inn’s place as a major institution in the development of international justice and human rights law. Traces of this legacy can be found in the Archives and Library of The Inner Temple and are reflected in work still carried out today by members of the Inn.

The Nuremberg Trials were held between November 1945 and October 1946, prosecuting senior members of Nazi leadership following the surrender of the regime in May 1945. The International Military Tribunal, composed of legal representatives from Britain, France, the Soviet Union and the United States, judged 22 defendants on counts including crimes against peace and crimes against humanity – novel legal frameworks born out of the unprecedented horrors of the Second World War and the Holocaust. Several members of The Inner Temple were actively involved in the application of these new charges within the British prosecution team at Nuremberg – among them Sir Geoffrey Lawrence (called 1906), British President of the International Military Tribunal (IMT); Sir Norman Birkett (called 1913), seconding Lawrence as alternate judge; Geoffrey Dorling ‘Khaki’ Roberts (called 1912), leading counsel; and Anthony Marreco (called 1941), junior counsel. Many of these men kept diaries and wrote memoirs about their time in Nuremberg, several of which have been kept at the Inn, preserving first-hand experiences of the trials.

Before the commencement of the trials, however, other members of the Inn were involved in the long negotiations regarding the planning of the post-war prosecution of German war criminals. From October 1942, John Simon, 1st Viscount Simon (called 1899), proposed to the House of Lords the creation of an Allied commission for the investigation of Nazi war crimes to “collect material, supported wherever possible by depositions or by other documents, to establish such crimes […] and to name and identify those responsible for their perpetration”. Another member of the Inn, Lord Wright of Durley (called 1900, Treasurer 1946), chaired this commission on its creation in 1943 as the United Nations War Crimes Commission (UNWCC). The commission collected evidence against the Nazi regime as Allied armies progressed through Europe, providing the bulk of the evidence used in the post-war prosecution process. In Lord Wright’s words in his History of the United Nations War Crimes Commission, the UNWCC would “investigate and record the evidence of war crimes, identifying where possible the individuals responsible”, directly referencing Simon’s demands of 1942.

With the formal German surrender in May 1945, the fournation UNWCC met in London between 31 May and 2 June 1945 to agree the next steps. In his opening speech, Lord Wright of Durley emphasised the need to move towards “the punishment of the criminals for the double purpose of retribution to satisfy the people’s demand for justice, and of warning and example to deter such crimes in the future”, already highlighting the role of Nuremberg as a template for a new model of international criminal law. Ratified on 8 August 1945 as the London Agreement, with an annexed charter creating the IMT and outlining new charges presented at the Nuremberg Trials, the agreement became a landmark moment in the development of international jurisdiction on war crimes. Building on the recommendations first articulated by John Simon to the House of Lords in 1942, Lord Wright’s actions as chair of the UNWCC would cement the ties between The Inner Temple and Nuremberg – ties that continued through the active participation of its members at the trials.

History of the United Nations War Crimes Commission and the Development of the Laws of War (1948), introduction and foreword by Lord Wright of Durley. © The Inner Temple Library

AWith the opening of the trials in November 1945, four members of The Inner Temple were present in the courtroom of the Justizpalast. Several files have survived which recount their role in the indictment of Nazi war criminals. In his memoir, Without My Wig, Geoffrey Dorling Roberts recounts his first impression of the German leaders in the dock: “There was Göring, not jovial, with the ghost of a smile on his lips; Hess, reading a book, taking no interest in the proceedings; and Ribbentrop with his nose in the air, […] obviously strongly disapproving of the whole thing.” Anthony Marreco also noticed these attitudes in an interview given in 1998, where he described Göring as the “star of the show”, a disgraced leader with his “white field marshal’s uniform [which] was hanging like a toga loosely on him”, oscillating between good form and “tremendous depression”. Marreco would play a key part in the case against Admiral Karl Dönitz for his role in the unrestricted submarine warfare against merchant ships in the Atlantic. This case saw the application of the new charges of crimes against peace and crimes against humanity, ultimately only costing Dönitz a ten-year sentence. For Marreco, the sentences carried out at Nuremberg were lenient considering the gravity of the crimes. Following the testimony of a French Auschwitz survivor, Marie Claude Vaillant-Couturier, Sir Norman Birkett described with revulsion what he saw as the “most terrible and convincing case of complete horror and inhumanity in the concentration camps”. Geoffrey Dorling Roberts similarly recounted the projection of the American documentary Nazi Concentration Camps in the courtroom: “A normal vocabulary is unequal to describe the horrors of this historic record: reel after reel of corpses, exhumations, gas chambers, body disposal plants, instruments of torture; men and women, all skeletons, some just alive.” The exposition of such crimes to the public, thanks to the extensive mediatisation of the trials, is another central aspect of Nuremberg’s impact on collective memory. These images would shape public awareness in the extent and barbarity of Nazi crimes and lead to a series of Holocaust trials in the decades following Nuremberg.

The British duo of judges at Nuremberg, Sir Geoffrey Lawrence and his second, Sir Norman Birkett, sat for the 11 months of the trials. Their involvement in every step of the proceedings and gained them the admiration of colleagues. For the American alternate judge John J Parker, “no one connected with the Tribunal, member or otherwise, had a greater part than Birkett in shaping the final result”, with Birkett handdrafting a large part of the judgment and whose opinion was heard in every deliberation. Despite Lawrence’s commanding and respected authority over the trial as President, some noted the major influence of Birkett, who assembled the bulk of the British delegation’s case against German leaders. This exacerbated pre-existing tensions between both men, with Birkett snubbed for the role of leading judge in favour of Lawrence, an experienced judge from the Court of Appeal. Marreco praised the performance of both men, noting that Lawrence “had the respect of the whole bench”, yet saw that Birkett, under strenuous pressure and disappointed with his appointment as alternate judge, “was never very happy at Nuremberg”. Despite such disagreements, the trials ran smoothly with the final verdict given on 1 October 1946 by Sir Geoffrey Lawrence: 12 defendants were sentenced to death, seven to imprisonment and three acquitted.

Sir Norman Birkett, 1946 © IWM (Art.IWM ART LD 5863)

The bench of the accused, Nuremberg © IWM (Art.IWM ART LD 5798)

Lord Justice Lawrence, 1946 © IWM (Art.IWM ART LD 5865)

Geoffrey Dorling Roberts, 1946 © IWM (Art.IWM ART LD 5862)

The involvement of The Inner Temple members in these historic trials, however, transcends the walls of the Nuremberg Palace of Justice. Two members also played an active role in the resistance against the very crimes discussed at the trials, a further notable connection between the Inn and the fight against Nazi violence. Within the German administration, Helmuth James von Moltke (called 1938) pursued undercover resistance to the regime as an agent within the Abwehr foreign intelligence service. With access to clear reports about atrocities committed by German forces in occupied territories, Moltke leaked plans for the deportations of Danish Jews, allowing for the majority to find safety in Sweden, and planned two visits with British contacts in Turkey to transfer confidential information to the intelligence services, some of which found its way as evidence in the Nuremberg courtroom. His organisation of secret anti-Nazi meetings at his family home in Kreisau would involve him with other activists envisioning Germany’s future after the fall of the Reich, with Moltke himself advocating for a special international criminal tribunal to be convened after the conflict to judge war criminals. The ‘Kreisau Circle’ and much of the Abwehr leadership would, however, be purged by the Gestapo in 1944, with Moltke found guilty of treason and executed on 23 January 1945 in Berlin. A book collecting Moltke’s moving letters to his wife, Freya, is held at the Inn’s library, underscoring his humanist values; writing in 1940, Moltke affirmed that “whoever knows at all times the difference between good and evil, and does not doubt it, however great the triumph of evil seems to be, has laid the first stone for the overcoming of evil”.

Members of The Inner Temple thus played a fundamental role in exposing war crimes committed during the conflict as prosecutors, informants and dissidents. After the war, members were actively involved in the perpetuation of Nuremberg’s – and Moltke and Karadja’s – visions of international justice and fight for human rights. Junior counsel Anthony Marreco later became a founding director of Amnesty International alongside Peter Benenson in 1961 – an organisation created in The Inner Temple’s Mitre Court, defending the human rights of prisoners across the world. The same year, Lord Russell of Liverpool (admitted 1928), who had served as legal adviser in later trials of German criminals in the 1950s, attended the Adolf Eichmann trial in Jerusalem, bringing back a collection of original evidence that was kept in The Inner Temple archives until 2008. Such an enterprise directly echoed Sir Norman Birkett’s wish for trials “secure against all criticism, […] convincing and built on evidence that cannot be shaken as the years go past”, and for the precise documentation of the horror and extent of crimes against humanity for future generations (Norman Birkett: The Life of Lord Birkett of Ulverston (1964), H Montgomery Hyde).

Elsewhere in occupied Europe, Prince Constantin Karadja (called 1922) would play a paramount role in the saving of 51,000 Romanian Jews from deportation to extermination camps by German forces and the collaborationist regime. Through his role as a senior member of the Foreign Ministry, Karadja signed off the repatriation of Romanian Jews from Hungary, Germany and France to their homeland, supplying them with travel documents and convincing colleagues at the ministry that this relocation would be temporary until emigration to Palestine. Karadja had seen first-hand the extent of Nazi violence towards Jews as Consul General in Berlin between 1931 and 1941, writing reports to his government about the Kristallnacht in November 1938 and the growing climate of antisemitic hostility driven by Nazi rhetoric. Karadja continued to follow his clear sense of justice and humanity after the commencement of hostilities, supported by his training as a lawyer. In a 1943 letter to the Minister of Foreign Affairs, he denounced the open violation of rights exercised by German troops, stating that “in international law, the principles of universal ethics and the fundamental rights of mankind are not taken into account by the German authorities” and that “every minority, like the Jews, has to submit not only to the laws of the country, but also has the right to diplomatic and consular protection”. For his brave actions, Karadja would be posthumously awarded the title of Righteous Among the Nations in 2005.

The trials were finally a watershed moment in the development of the international prosecution of war crimes, as the first instance of violators of international law being charged for their actions. The Nuremberg Principles were enshrined by the United Nations International Law Commission in 1947 to define the scope of war crimes and were followed a year later by the United Nation’s Convention of Human Rights, which asserted the rights and liberties of citizens on a global scale. Despite the strong initiatives taken in the years following the Second World War, the 20th century bore witness to new genocides in clear violation of international law in Rwanda and Yugoslavia. Born out of the ashes of the International Criminal Tribunals for both genocides, the permanent International Criminal Court’s creation in 1998 was a clear continuation of Nuremberg’s goals. Today’s members of the Inn have built upon the work undertaken by Inner Templars at Nuremberg and beyond for the protection of human rights and prosecution of perpetrators, serving in institutions such as the International Criminal Court, the International Court of Justice and the International Criminal Tribunal for the former Yugoslavia, perpetuating the clear commitment of the Inn to the defence of human rights.

Hector Le Luel Archives Volunteer

Helmuth James Von Moltke’s Letters to Freya: 1939–1945 (1990) © The Inner Temple Library

Prince Constantin Karadja’s Call Paper, 15 June 1922 © The Inner Temple Archives

Collection of primary evidence used in the Adolf Eichmann trial of 1961. Kept at The Inner Temple Archives, now on long-term loan to the Wiener Library.

© The Inner Temple Library

ACROSS CONTINENTS, ONE COMMUNITY: THE INNER TEMPLE IN MALAYSIA AND SINGAPORE

By the Head of the Sub-Treasurer’s Office

The Inner Temple has maintained warm relationships with its members and the wider legal communities in Malaysia and Singapore for many years. These connections are steeped in history, with archival records showing that some of the earliest women admitted to the Inn in the 1920s were Chinese students from the then Straits Settlements, British North Borneo and Sarawak.

Formal links with Malaysia were cemented in 2006, when Master Elizabeth Butler-Sloss, as Treasurer, and the late Master Patrick Maddams, as Sub-Treasurer, visited Kuala Lumpur to inaugurate the Malaysia Inner Temple Alumni Association (MITAA). This initiative had been inspired by the late Master Abdul Malek, a Court of Appeal Judge who was called to the Bar in 1965 and was determined to create a forum for Malaysian Inner Templars to remain connected with the Inn.

Since then, successive Treasurers and Sub-Treasurers have travelled to Malaysia almost annually (except during the pandemic) for programmes organised in partnership with MITAA. These visits have helped maintain strong engagement with our 485 members currently residing in Malaysia (with a total of 1,056 worldwide); raised the Inn’s profile within local legal circles – including universities, the judiciary, the Bar and government departments; and fostered close ties with the Royal Household of Negeri Sembilan, in particular. MITAA, now under the continuing leadership of Master Faizah Jamaludin, a Judge of the Court of Appeal, remains the Inn’s most active overseas alumni association, with around 100 members. Other distinguished Benchers include Masters Tunku Ali and James Foong.

Our relationship with Singapore has also flourished in recent years. The first formal visit by a Treasurer in recent memory was made by Master Jonathan Hirst in 2012. Since then, the Inn has maintained a regular presence, including by contributing to litigation conferences and workshops organised by the Law Society of Singapore; a performance by the Temple Church boys’ choir in 2016; and a sculpture installation – Angles of Incidence – transferred from the Singapore Botanic Gardens and hosted in the Inn’s Garden in 2014. These visits have included educational and social events with the Supreme Court, the Singapore Academy of Law and others.

In 2017, Master Pittaway’s visit as Treasurer marked another milestone, with the establishment of the Singapore Inner Temple Members Association (SITMA), since led by Master Lawrence Teh, Senior Partner and Global Co-Head of International Arbitration at Dentons Rodyk LLP. SITMA provides a platform for local networking, professional development and engagement with the Inn. We currently have 140 members residing in Singapore (241 worldwide) and around 30 are active members of SITMA. Among our distinguished Benchers is Master Sundaresh Menon, Chief Justice of Singapore, and we have strong ties with Lisa Sam, President of the Law Society of Singapore.

Master Treasurer’s recent visit to Malaysia and Singapore in Spring 2025, accompanied by the SubTreasurer, was a highlight of the year, reaffirming the Inn’s international connections and its commitment to meaningful legal exchange. It followed hot on the heels of a visit by Master Michael Soole as Treasurer in autumn 2024, with a complementary programme.

Tour of the Child Sexual Offences Court at the Palace of Justice, Putrajaya

Master Treasurer, Sub-Treasurer and Master Tunku Ali –Tea at Istana Negeri Sembilan Visit

Official signing of Memorandum of Understanding with Law Society of Singapore and initiation of Affiliate Scheme with Master Treasurer, SubTreasurer, Lisa Sam (Chair of the Law Society) and Master Teh

Visit to the Palace of Justice in Putrajaya – Master Treasurer and the SubTreasurer were hosted by Master Jamaludin and other members of the Malaysian Court of Appeal and Federal Court

MALAYSIA

In Malaysia, Master Treasurer’s programme was (again) expertly co-ordinated by Master Jamaludin and included a keynote address by him at the Securities Commission on Regulating Cryptocurrencies and Digital Assets: Current Issues and Emerging Trends. The event drew a large audience of legal and regulatory professionals and featured further contributions from senior figures at the Securities Commission and the Central Bank of Malaysia. The topic was particularly timely, given active national debates on how best to regulate virtual assets. In a spirit of camaraderie and exchange, an Inner Temple dinner was hosted for key stakeholders and speakers following the event, reinforcing professional bonds and friendships.

The Treasurer also visited the Palace of Justice in Putrajaya, where he was briefed on the workings of the Court and the Registry for Sexual Offences Against Children; observed a Court of Appeal hearing on employment laws; toured the Judicial Museum; and was welcomed into Master Jamaludin’s chambers.

Engagement with the future generation of legal minds was also a key focus. A tea party provided an opportunity for informal engagement with law students, pupils and junior MITAA members.

Another memorable moment was an audience with Master Tunku Ali, Senior Prince of Negeri Sembilan, at the Istana Negeri Sembilan in Kuala Lumpur, which concluded with tea with Master Ali and his father, His Royal Highness the Yang di-Pertuan Besar Negeri Sembilan.

The visit concluded with a splendid dinner for MITAA members, hosted by Ariff Rozhan and attended by His Excellency Ajay Sharma, the newly appointed British High Commissioner. The visit occurred against the backdrop of significant developments in Malaysia’s judiciary, including debate over judicial appointments and concerns about judicial independence. These broader legal and constitutional discussions served to underscore the importance of professional dialogue and institutional integrity – values shared across our jurisdictions.

SINGAPORE

The Singapore leg of the visit was anchored by the Treasurer’s participation in the Singapore Litigation Conference Workshop, at the invitation of Master Teh. Organised by the Law Society, the workshop focused on AI and ethics, and the Treasurer’s Opening Address was delivered to a large audience just before the keynote by Supreme Court Justice Valerie Thean. A closing panel allowed the Treasurer to reflect on the ethical challenges emerging from the integration of AI into legal practice.

Engagements in Singapore included a dinner for Litigation Conference speakers, a SITMA dinner and a high-level briefing with British High Commissioner His Excellency Nik Mehta. During the briefing, concern was noted over the perceived decline in UK-Singapore judicial relations – something Master Menon is reportedly eager to address. A reduction in the number of approved UK law schools by the Singaporean government was raised, prompting discussion on the importance of ensuring accurate understanding of legal education standards.

The programme also included a productive lunch with the board of the Singapore branch of the Chartered Institute of Arbitrators, where Master Treasurer contributed his expertise in arbitration to discussions around the conduct of counsel in arbitration proceedings and professional obligations and standards in international disputes.

A key outcome of the visit was the signing of a Memorandum of Understanding between the Inn and the Law Society of Singapore, thanks to the support of their President, Lisa Sam. This lays the foundation for initiatives such as a pilot Affiliate Scheme (enabling Singaporean lawyers to engage with selected Inn events and facilities) and a bilateral Pegasus Trust placement programme. These developments were warmly welcomed and represent an exciting new phase of collaboration. We look forward to welcoming a delegation from the Singapore Law Society to The Inner Temple towards the end of 2026.

Lasting a full five working days in total, this visit was a powerful testament to the Inn’s global reach and the value of its overseas alumni networks. We are immensely grateful for the generous hospitality and thoughtful organisation by our members in both jurisdictions.

Special thanks go to Master Faizah Jamaludin and Master Lawrence Teh, whose tireless leadership continues to ensure that the spirit of the Inn thrives in Malaysia and Singapore. Their efforts are central to our ongoing engagement with the region and the professional development of members at all stages of their careers.

LOOKING FORWARD

2026 will mark MITAA’s 20th anniversary, which we hope to celebrate with special events both in Malaysia and at the Inn. We also look forward to welcoming new Singaporean affiliates to the Inn and continuing to build on this foundation of fellowship, excellence and mutual respect.

Jennie Collis Price Head of the Sub-Treasurer’s Office

SOCIAL CONTEXT OF THE LAW: CULTURAL REPATRIATION: HANDING BACK THE PAST

Taken from a panel discussion held on 18 March 2025 between Mona Yapova and Master Gus Casely-Hayford, moderated by Master James Lee.

Professor James Lee introduced the speakers, and the session’s aims, which were to discuss the moral and political questions in the context of the legal complications that cultural institutions encounter, particularly statutory charities, such as most of our very well-known museums. He emphasised that it was valuable to have a range of perspectives on what are urgent and controversial issues, and the discussion would be respectful of the sensitivities engaged.

Mona Yapova: Cultural repatriation and restitution are some of the most layered topics that I come across in my field. They are often not topics that can be resolved by the law alone, or at least the law is not yet fit to do them justice fully. Disputes and conversations about restitution and repatriation have for many years been stuck behind legal hurdles. However, these topics are increasingly being approached from a cross-disciplinary perspective, taking into account historical, art historical and cultural perspectives in an effort to find more balanced resolutions.

There is a history to the legislation that led to the complex and legal framework that we work with today. It took a long time to start legislating on the international protection of cultural heritage. As is often the norm with legal reform, we have legislated better for the future than we can for the past. Yet, when we speak of looting, we often think of looting during historic instances of armed conflict, such as colonialera looting, Roman conquests, or the Napoleonic wars, all of which precede the history of international efforts to regulate the protection of cultural property.

This encompasses many years of established practices of what we refer to as looting – forcible taking, confiscations, takings under duress, and the concept of ‘prize rights’ and ‘trophies of war’. The countries that have suffered those removals have often had laws that regulate theft, but it has not been straightforward to rely on those laws to resist such takings.

What is key to understand in the context of historic looting, as it is in modern-day looting, is the need for international enforcement frameworks and co-operation. Heritage protection, insofar as it depends on legislation, is, by necessity because of the very nature of its subject matter, both a national and international effort.

International efforts to regulate heritage started in part with efforts to codify the laws of armed conflict. An example is the Lieber Code of 1863 in the United States, the Brussels Conference of 1874 and the work of the Institute of International Law. Those early efforts did not immediately translate into binding rules, but laid important foundations. They were, for example, followed by the Hague Conventions of 1899 and 1907. The latter was one of the first instruments to include provisions regarding the seizure of cultural property.

James Lee, Mona Yapova, and Gus Casely-Hayford

By the 1950s, more states that had been under foreign rule were gaining independence. Concerns about the growth of the black market began to rise. The first international convention dedicated to cultural heritage protection is the 1954 Hague Convention for the Protection of Cultural Property in the Event of Armed Conflict. It establishes the norms for military conduct among its ratifying States and is often used as a basis for military training. The commitments made by the States Parties to the Convention largely focus on conduct during times of armed conflict and serve to preserve cultural heritage.

However, the need to protect heritage from plunder during times of peace remained after the 1954 Convention. This led to the adoption of the 1970 UNESCO Convention on the Means of Prohibiting and Preventing the Illicit Import, Export and Transfer of Ownership of Cultural Property which set out to curb the illicit trade in cultural property. The difficulty with the 1970 UNESCO Convention is that its material and temporal scope are very limited. The value of the Convention has mainly been in standard-setting. For example, it provided guidance for ‘source’ countries on how to monitor heritage on their territory, and ‘soft law’ for best practice and co-operation between states. Almost every major museum now treats ‘1970’ as a hard line and will refuse to acquire objects that left their country of origin after that year without full documentation.

The 1970 UNESCO Convention was followed by the 1995 UNIDROIT Convention on Stolen or Illegally Exported Cultural Objects, which unfortunately did not have as much support as other conventions. Its aim was to rectify some of the shortcomings in the scope of the UNESCO Convention and amongst others bring private parties into the regulatory equation a little more. This was an important shift in the burden placed on collectors – not just museums, but also private parties that interact with the market – to increase their due diligence.

Later, in 1998, a number of governments that participated in the Washington Conference on Holocaust-Era Assets reached a consensus on and endorsed 11 non-binding principles known as the Washington Principles to assist in resolving issues surrounding specifically Nazi-looted art. The UK was one of those participating countries, and we have legislation that has come into force after those principles.

These are only some of the key international instruments in the sphere of restitution. The European Union has also passed directives about the return of cultural objects. We also have a regulation that is about to come into force at EU level that regulates the import of cultural heritage into the EU that has been illegally exported from its country of origin. This regulation places further increasingly stringent due diligence burdens on importers to establish the source of objects.

In the UK, the regulatory framework for restitution remains limited. It is often not designed to take into account all the intricacies of historical events, because much of it applies to all types of restitution. There are several civil and criminal statutes that regulate the liability of private individuals, but the key current limitation lies in national museums’ restricted powers to deaccession works. For example, under the National Heritage Act of 1983, the trustees of some national museums in the UK are specifically prevented from deaccessioning objects, except in very limited circumstances.

This is not necessarily ever only a blanket rule. We have legislation, such as the Holocaust (Return of Cultural Objects) Act 2009, which gives the governing bodies of listed national museums an additional power to return objects where the Spoliation Advisory Panel recommends that the object should be returned to a claimant and the Secretary of State approves the Panel’s recommendation. This is an example of a tailored framework designed to address and recognise the intricacies of a specific historical event, within the general rule.

The result of the restrictions placed on national museums is that we see objects that have a common history – like Benin Bronzes taken during the British Punitive Expedition to Benin City 1897 – face different barriers to repatriation depending on the institutional collection they are now in. Claims for repatriation and restitution of Benin Bronzes have been made to the British Museum, the University of Cambridge and the Horniman Museum recently, and, of course, museums across Europe. However, in the UK only the University of Cambridge has returned over 100 Benin artefacts, the Horniman Museum has restituted 72, but the British Museum has not been able to honour those claims in the same way. This is partly because charity law allows institutions in the UK that are not national museums to apply to the Charity Commission to make ex-gratia payments, which can include deaccessioning and returns, based on moral obligations. Recently and for a moment, the government considered giving national museums the power to apply to make such disposals under the Charities Act 2022, but eventually retracted this.

The most important national collections are often locked under strict legal provisions, and the UK is not alone in this. International frameworks have often had more buy-in from source countries than from important market countries, and we have better legal frameworks for present and future protection of heritage than we do for historic events. This being said, none of this necessarily is or should be static. It is only the law as it is now, and governments around the world are recognising these shortcomings and the importance of a considered, cross-disciplinary approach to reform.

Master Gus Casely-Hayford: My parents came to this country in the 1950s and we lived in South London, which felt like a different planet from the place that my parents would occasionally talk to me about as their place of origin, West Africa – my mother from Sierra Leone and my father from Ghana.

Then, one summer, my aunts came to visit. They came not just with stories, but with cases full of amazing kinds of fruits, which brought smells and tastes that I had never encountered. They also brought cloth – lengths of Kente, Ankara and Adire. Alongside these came incredible stories. They would unravel a piece of cloth that may have sat on a coffin a generation ago, telling the story of that moment and bringing history to life. And it was history. But it was history unlike anything that I had heard before, and I knew immediately what it was that I wanted to do.

I wanted to get to West Africa and to see these amazing objects in the context in which they were created, to see the museums and the spaces where I could really embed myself in the rich histories. I remember going to the National Museum of Ghana. I must have been about 16; I saved up and took myself there, with a huge amount of expectation and excitement. Only to see a space that was well-loved, but unable to tell those histories that I had heard and read about. The material culture, the material evidence of those peoples, simply was not in those spaces.

Even though I already had an understanding that I wanted to do something in the space of heritage, in that moment I also understood that there was a kind of moral imperative, something that really needed to change. The cultural representation of the stories of African people is something that we, in this country, have the privilege of being able to explore in ways that so many people in their countries of origin simply aren’t.

As soon as I was able, I applied for a role at the British Museum. I was part of the first team that moved the Africa collection from the old Museum of Mankind back into the British Museum space. It was a really deeply emotional moment to see those objects become part of the wider British Museum collection.

At the heart of the collection were those Benin plaques, and they looked absolutely incredible. But there was that lingering question of how can we feel comfortable that we can tell these stories in such rich and wide ways when the countries of origin are simply unable to do so?

It always felt uncomfortable to me. I would ask my colleagues and my superiors about when we might be able to begin those debates – when might it be possible for us to think about the return? This was 25 years ago. I was told, not within my career. I was aware that the 1963 Act did allow for the return of objects if they were duplicates. Any amount of research will tell you that the British Museum quietly deaccessioned some Benin plaques in the post-war period. Because of the way that those plaques are individually created using the lost-wax process and hung as pairs, the idea that they could have been duplicates is obviously not the case. But some of them were returned; there were precedents for the return of objects.

I began to think about how we could begin to shift hearts and minds. One area I invested time in was thinking about the situation in Ghana. The national museums there had begun to think about building a new suite of buildings so they might be able to establish loans and build a new collection. Curators there were constantly in touch, asking about the possibility of us building curatorial partnerships, beginning to develop the conversation which would at some point end in the beginning of loans and the return of those objects.

The situation in Ghana is personal to me. In 1873, the British sent a force of about 1,500 soldiers, armed with Enfield rifles and Gatling guns. By the Spring of 1874, they had marched on the capital, Kumasi. They burnt most of the capital to the ground, captured the King and stole the contents of the royal treasury. Much was then transported to the coast, and from there it was taken to London. Some of it was sold by Garrard in an auction, and it was spread to the high winds, some ending up in the Wallace Collection, the British Museum, V&A and private collections. These amazing gold objects then sat in various collections for 170 years, and the law didn’t change. We still cannot return these objects, but the will and the shift in consciousness has changed.

Even though I already had an understanding that I wanted to do something in the space of heritage, in that moment I also understood that there was a kind of moral imperative, something that really needed to change.

Benin bronze, Benin kingdom, Nigeria, British Museum, London © Creative Commons / Michel Wal

That George Floyd moment, that shift in consciousness across the world around issues of equity and diversity, had a profound impact on museums. There was a sense of urgency, and locked gates suddenly opened. The conversations that had been put on hold suddenly began to move. The French made promises; my old institution, the Smithsonian National Museum of Art, returned objects. And then, the Horniman, Cambridge. The pressure began to mount on the nationals to do something. There are two acts, the 1963 Act and the 1983 Act, which make it very difficult for us to return objects. Even though we couldn’t return them, there was something else that we could do. We could potentially broker the opportunity for a long-term loan of objects.

That George Floyd moment, that shift in consciousness across the world around issues of equity and diversity, had a profound impact on museums.

In the V&A collection, we had a range of exquisite objects. As part of the programme of events in advance of the opening of my museum, V&A East, I made a commitment to visit every single school in East London – more than 80 of them. I was keen for us to take these objects out into the communities and give people the chance to handle them, to get up close to them. Some of those encounters were enormously emotional. I would sit in front of whole school assemblies in East London, where there would be 600 students, only a handful of whom weren’t of African descent.

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I would talk to them about the stories of these objects, and you could see in their eyes that they felt the sense of wonder to be close to these objects, but also the sense of them questioning, ‘How can we have national institutions that are doing this on our behalf?’

It felt to me that a time in which this had been acceptable had passed, and I was proud that the collection of objects was loaned back to Ghana, and they are now on display in the Palace Museum. Limited by statute, we could only return them on loan, but the Fowler Museum returned theirs without any conditions. They are on display in the palace in a new space. It’s one of the things that I think over the course of my career I feel most delighted to have witnessed and, for me, a point of closure on a chapter that began with my aunts coming into our living room and not just opening up their cases with amazing cloth and incredible gifts, but also with stories. It is wonderful now to see them, in some way, continuing their course in West Africa again.

Mona Yapova Art Law Specialist, Mishcon de Reya

Dr Gus Casely-Hayford OBE Director, V&A East Professor James Lee Professor of English Law, King’s College London

For the full video recording: innertemple.org.uk/handingback

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EMPLOYED PUPILLAGES

On 25 March 2025, Carlé Philbin, Daisy Caldwell, Alfie Evans, Commodore James Farrant RN and Rebecca Paterson shared their experiences of employed pupillages. They offered insights and tips about the application process and the pros and cons of being employed. Introduced by the Chair of the Employed Bar Forum, Master Sara Lawson, the session was chaired by Master Simon Regis.

Alfie Evans: I’m a barrister at the Government Legal Department, currently at the Attorney General’s office, and I qualified last September. After studying law at the University of Bristol and obtaining a scholarship from The Inner Temple, I was called to the Bar in 2021. I didn’t immediately get a pupillage straight off the back of the Bar Course, so I worked as a paralegal in the insolvency service.

While there, and somewhat randomly, I came across the Government Legal Department (GLD) pupillage, not having known much about the GLD, or been particularly interested in public law at university. I successfully applied and started pupillage in 2023, working as a paralegal for the Department of Transport in the interim. My first seat, or six as it would be in the self-employed Bar, was in immigration litigation, where I managed a caseload of judicial reviews against the Home Office in respect of asylum claims and decisions.

My second seat was spent on secondment to 39 Essex Chambers. My work there was quite varied, but it generally had a public theme. My supervisors did a lot of immigration work, environmental work, procurement, and planning.

I qualified in September last year, but the GLD training scheme is two years’ long, so although you qualify after one year, you then have another year where you do two six month stints of advisory work, such as advising on government policy, having the opportunity to draft secondary legislation and working with the Office of Parliamentary Council on primary legislation. My advisory year was split between two different departments; the first was at the Department for Environment, Food and Rural Affairs (DEFRA), where I worked on animal diseases, trade, and the water industry.

I’m now at my fourth and final seat, at the Attorney General’s office, where I advise and brief the Attorney General and Solicitor General on bills and policies across Whitehall.

The first seat will always be doing immigration, and the second seat will always be on secondment – secondment is broadly similar to what the first six would be like in a self-employed pupillage. That could be drafting skeleton arguments or drafting grants of appeal. The only exception is that you only take instructions from the GLD, and you only do those in respect of immigration matters in the other tribunal – known as oral commission hearings.

There are five stages to the application to the GLD: a situational judgment test; verbal reasoning tests; and a critical reasoning test. All three tests are multiple choice. I recommend doing the gov.uk practice tests. The fourth stage is a video interview that’s pre-recorded, so the questions flash up on screen and you’re given a set amount of time to answer them – in my opinion they’re probably the hardest part of the process. The fifth stage is the assessment centre, which is split between two core parts. The first part is a written exercise to analyse a practical legal issue. It’s not a test of legal knowledge as you’re given all the law in advance, it’s more to see how well you can analyse the issue, especially within the context of policy and politics.

The second part of the assessment centre is an in-person interview. You’re asked questions about your response to the written exercise to hear why you responded the way you did. The second set of questions is the largest part of the interview. These are behaviour-based questions to assess how you’ve handled past situations against defined behaviours listed in the person specification, such as delivering at pace, making effective decisions, communicating and influencing.

My biggest tip for preparing for these interviews is to focus on the behaviour-based questions. You should always follow the STAR method when you’re responding, (Situation, Task, Action, Results). The third type of question you’re asked is strength-based to assess what you enjoy and what motivates you. The fourth type of question is motivational such as “Why the public sector? Why the public Bar?”

Some of the most enjoyable work that I’ve done during my pupillage was drafting my first Statutory Instrument at DEFRA – a personal proud moment.

Another was drafting detailed grounds of resistance for the government’s defence in the Court of Appeal case, Save Stonehenge World Heritage Site Ltd v Secretary of State for Transport 2024 EWCA Civ 1227, which was in relation to the proposed tunnel that would be going under Stonehenge, and preparing speaking notes for my supervisor in the Court of Appeal.

While at DEFRA, I worked with senior policy officials and the Chief Veterinary Officer to respond to an outbreak of foot and mouth disease in Germany and drafted measures which prohibited the import of certain goods from entering the UK from Germany. For obvious reasons, I can’t talk about the work I do in the Attorney General’s Office but, take my word for it, it has been really interesting.

L–R: Master Simon Regis, Alfie Evans, Commodore James Farrant RN, Carlé Philbin, Daisy Caldwell and Rebecca Paterson

Commodore James Farrant RN: I’ve been in the Royal Navy for 26 years. All three of the armed forces have lawyers in uniform dealing in three areas: crime and discipline, employment (or terms and conditions, and terms of engagement), and operational law, which is probably the one that varies the most between the three services.

As a naval lawyer I’ve spent a lot of time advising on the law of the sea, the law of maritime operations, law of naval warfare, weapons law, both in terms of advising on principles, but also engaging with the academics whose work is based on those issues.

Aspects of operational law – employment, crime and discipline – are similar across all three Services. However, the operational legal advice, is where it differs the most between the army, the navy, and the air force. Obviously, I’ve spent a lot of time advising on the law of the sea but, if you’re an army lawyer, you advise on land-based operations, including detention-type operations, for example, when you can detain an individual, for what reasons, and in what conditions. Whereas, if you’re in the air force, you’ll spend a lot more time advising on kinetic targeting operations, such as strike operations from bomber and fighter aircraft.

There are two routes to joining the army: the first is to qualify as a barrister or a solicitor and then apply to join the army (ditto with the RAF); the alternative route is via pupillages.

For the first time, in the last year or so, the army is offering a small number of pupillages.

Once you’ve joined the army, they will find you a pupillage in a set of chambers. Once you’ve completed pupillage in chambers you then go back to the army as an army lawyer.

The Royal Air Force is not currently offering pupillages, but it is offering trainee solicitor placements. In the navy, the method is more complicated. You join the Royal Navy as something other than a lawyer, because the navy doesn’t have a legal branch at all. You must be good enough for them to invest in you, send you to Bar school, and pay you through pupillage. That is the only mechanism to become a lawyer in the navy. We recruit all our lawyers internally, but we only recruit barristers, sending them to sets like Red Lion for pupillage, whereas the army and the air force recruit both solicitors and barristers. In terms of employed pupillages, you can certainly have one with the army but there aren’t very many of them. You can have one with the navy, but you have to do something else for a little while first, and, if you want to join the Royal Air Force, you either qualify as a barrister or apply to join in a trainee capacity as a trainee solicitor.

Carlé Philbin: I am an employed barrister at DAC Beachcroft based in Manchester, specialising in personal injury, so I’m in court nearly every day. When I’m not in court, I’ll be at home doing paperwork. Having just completed my pupillage in March 2024, I’m doing a lot of trials now.

Personal injury involves road traffic accidents (RTAs), employer’s liability, and public liability. The interesting part is the access DAC Beachcroft have to different types of work. Being such a large international law firm, they have many clients who instruct them. I’m now able to do fraud.

After completing the Bar Course, and unsuccessfully applying for pupillage, I turned to DAC Beachcroft to be an employed advocate. I hadn’t been there that long when I, and others, were encouraged to apply for the first pupillage they’d ever offered.

Pupillage was structured in a similar way to pupillage at the self-employed Bar, with a first and second six. In the first six, you’re following around various members in chambers, not limited to Manchester, so you have to travel quite far, which is definitely something to consider. The second six months is tailored more to you and hopefully based nearer to home which, for me is on the the Northern Circuit.

I had two pupil supervisors; one for personal injury work, and the other for property-based work, which enabled me to conclude that I do not want to go into property damage!

In pupillage, there are six pieces of assessed drafting work to do. You are given feedback on each piece of work that is marked each time so that you can improve your drafting. There are, of course, regular meetings to discuss that work.

DAC Beechcroft have plans to offer pupillage every year if you are interested in applying through that route. You have to get through the paper sift, which is assessed by various barristers. The second part is an advocacy-based task. I was given different statements from which to choose one to argue for or against in front of three barristers. After that, there’s a second round advocacy based interview. I had to do an application to set aside a default judgment. I also had to read a Court of Appeal judgment and answer questions about that.

The advantages of the employed Bar depend on what type of person you are. Many people like being employed.

You’ll get paid the same amount every month, whereas some people at the self-employed Bar are often waiting to get their billed money.

Master Simon Regis talking to guests

R: Alfie Evans and Daisy Caldwell with guests

Daisy Caldwell: I work for the Crown Prosecution Service (CPS) as a barrister; we’re called Crown Advocates. I finished my pupillage in September of last year, so I’m in my first six months on my feet as a Crown Advocate. My pupillage was not dissimilar to a self-employed pupillage as you have a pupil supervisor. I spent a lot of my time in both the Crown Court and the Magistrates’ Court shadowing and doing a lot of written work as well. Similar to Alfie’s experience, we have secondments to self-employed chambers.

I spent a couple of months over at Foundry Chambers, which was an excellent and really interesting experience – as well as being very useful to have a comparison about how things work at the self-employed Bar versus the employed Bar.

A big advantage of a CPS pupillage is also the ability to take on internal secondments. We have specialist teams in RASSO (rape and serious sexual offences); serious fraud; terrorism; and homicide that you can shadow with some ease. In terms of advantages of pupillage with the CPS, I’m sure many of you will be aware of the difficulties that face criminal barristers at the present time. Having been employed by the CPS, you do have a level of insulation from some of those issues.

Carlé has just referenced the pay, which is something that I know a lot of criminal barristers really struggle with, especially now assessing trial dates. I was at Snaresbrook Crown Court yesterday and set a trial date in 2029, so that barrister won’t get paid until that trial is finished. There’s also, of course, all of the amazing benefits that come with being employed: holiday, pension, sick pay. Now that I’m fully qualified, I’m on my feet in the Crown Court most days with a really varied practice.

Another huge benefit of being in-house is the range of training available to you; training put on internally at the CPS, but also mock trial training sessions with Red Lion, and we get paid to undergo the training offered at the Inns of Court. There are many resources available to you as well as a fantastic cohort of barristers who are always incredibly willing to lend a helping hand.

Another huge benefit of being in-house is the range of training available to you.

It’s amazing to have that cohort of people to share your pupillage with, without the fear of whether or not you’re going to get tenancy. At the CPS – if you progress – there’s no competitive application for tenancy at the end of the year, which is a huge advantage that really allows you to focus on your development during pupillage.

Some disadvantages: you are working for a large organisation that sometimes moves slowly, which I know a lot of people can find frustrating, and many of you may be considering life at the Bar because you are very driven, very motivated and interested in a fast-paced life.

Other than that, there aren’t too many disadvantages. Unlike Carlé and most self-employed barristers, I don’t have to travel around the country. I’m based in London, so I never have to travel outside of London. In terms of the application process, we are a government organisation, so applicants must make a civil service application, although slightly modified for barristers, and very similar to what Alfie has described.

At the CPS, you will be given really incredible work every day of the week and develop at your own pace, thanks to the large amounts of support and training offered.

Rebecca Paterson: I am a tenant at Pump Court Chambers. I did an employed pupillage at the Nursing and Midwifery Council (NMC), and then, after a period of practice as an employed barrister, I began a third six pupillage at Pump Court.

The NMC is a healthcare regulator for midwives and nurses. Some people think that the NMC’s regulatory proceedings are to do with clinical negligence. They’re not; the focus is on fitness to practice.

Of all the different applications I completed for pupillage, the NMC had the lengthiest process. There were very specific questions that asked about specific competencies. It was suggested that I answer those in a STAR format. I felt that really helped me think about all the skills that I had and how they could be transferable into such a niche area of practice. There was then a written assessment, followed by a two- or three-hour interview with an advocacy exercise. I had a couple of interviews in chambers which I found very intimidating. I felt a little bit like I was being cross-examined in my interviews. It was all good practice, but when I had my interview with the NMC, it was much more open and supportive.

The pupillage itself was fairly standard in that the first six months were shadowing fitness to practice proceedings and practising undertaking legal reviews of evidence.

I didn’t observe any other types of hearing during my first six. I did about two weeks with the General Counsel team, so I saw a little bit about policy and employment. At the time of my pupillage, NMC pupils no longer engaged in secondments to other organisations or chambers. In my second six, it was all about getting advocacy experience. I was presenting fitness to practice proceedings at hearings, starting with the one-day hearings through to eight-day hearings with multiple witnesses by the end of my pupillage.

There were a couple of things that I experienced as a pupil at the NMC that I don’t think that I would have experienced as a pupil at the self-employed Bar. One was getting to present in the High Court. At the NMC, they deal with interim injunctiontype applications, and they’re done before a High Court judge, so I was regularly appearing before a High Court judge making those applications.

It can be quite scary at times, because you’re put against people of many years’ Call, often established in criminal practice. It taught me a lot in terms of witness handling, thinking on my feet, and not being intimidated by my opponent.

I have since left the employed Bar and started a third six at Pump Court in June last year. I realised that I wanted to expand my practice to include employment law. The role involved a lot of case management; dealing with early witness issues, encouraging them to come to a hearing, and deciding what goes in the bundle. These are all key parts of a case before it gets to the final hearing – all very useful but not necessarily my favourite part of the role, and not where my skills lie.

One of the best things about the employed Bar and why I’m so happy that I did do an employed pupillage, is the support. I felt that there were so many people who were willing to help me. I got 30 days of paid annual leave, which is just astounding to me now! I felt more like I was part of a team rather than a sole practitioner whilst at the employed Bar.

Alfie Evans

Called 2021, The Inner Temple

Cdre James Farrant RN Called 2007, Gray’s Inn

Daisy Caldwell Called 2022, Lincoln’s Inn

Carlé Philbin

Called 2021, The Inner Temple

Rebecca Paterson Called 2021, Gray’s Inn

For the full video recording: innertemple.org.uk/employedpupillages

READER’S LECTURE:

THE ENGLISH APPROACH TO DECIDING COMMERCIAL CASES

By Sir Ross Cranston

From a Reader’s Lecture held on 13 November 2024

Let me begin with some history, building to an extent on my book Making Commercial Law Through Practice 1830–1970 (2021). I’ll then say a little about people, and finally move on to what I call, rather misleadingly, practical judging, drawing to an extent on my current book, Judging (forthcoming, 2025). I’ll do this by using as a staging post for some thoughts about these huge topics a member of this Inn, one of the England’s great commercial judges, and also one who had an academic bent.

SOME HISTORY

Robert Alderson Wright did not have early success at the Bar. He lectured for over a decade in the evenings at the London School of Economics (LSE) in Industrial and Commercial Law. His teaching is recalled in the dedication to Holdsworth’s 12th volume of A History of English Law. Indeed, at one point Wright considered becoming an academic lawyer. But he stuck with the Bar and his practice eventually took off during World War I when others went into the services – he was too old. He was appointed to the High Court in 1925, going straight to the House of Lords in 1932.

Lord Wright GCMG, Treasurer 1946, Lord of Appeal in Ordinary 1932–1935 and 1937–1947, Master of the Rolls 1935–1937., by Sir Gerald Kelly PRA 1952 © The Inner Temple Collection

My colleague at the LSE, Professor Neil Duxbury, characterises Wright as a “innovative traditionalist”. Wright was effective as a judge in subtly developing the law, without undermining established precedent and statutory authority. He describes how Wright applied his belief that development of the law is necessary because rules sometimes produce absurd and irrational consequences if rigidly applied. In his speech in Northumbrian Shipping Co. v Timm [1939] AC 397, Wright said: “Commercial law has always been ready, so far as possible, to sacrifice pedantic logical consistency in favour of the convenience in the conduct of business.”

So that’s my first point: as a matter of what I would call legal policy, historically, English judges have sought to accommodate the law to commercial life. They have done this in various ways. The first was the employment of commercial custom, used in two ways, to interpret contracts and to supplement their language by implying terms. There is a volume of cases where judges recognised the custom of ports, trades, and markets, but it was also used at the beginning of asset finance and in 1875 in high finance in the famous case of Goodwin v Robarts (1875) L R 10 Exch 337 to extend negotiability to the international bonds. In a 1940 case involving the sale of American wheat Lord Wright held (the other Law Lords agreeing) that the arbitrators could cure the ambiguity in a clause in a standard form commodity contract “by importing the custom and practice of the trade”: (1940) 67 L l L Rep 147. By the 1950s, however, as Lord Devlin put it in a lecture at the LSE, custom “can no longer be regarded as a revivifying source of commercial law”. Secondly, English judges played a facilitative role historically in areas of doctrinal law. An example is sales, at one time the very centre of commercial law. In the early 19th century judges recognised that there needed to be implied terms in a contract of sale – terms which became a cardinal feature of our law, and also our language – goods had to be fit for purpose and merchantable, the latter graphically expressed in Lord Ellenborough’s famous dictum: “The purchaser cannot be supposed to buy goods to lay them on a dunghill ”. Judges held that sale had a wide reach as with Lord Wright’s decision in 1934 in Cammell Laird and Co Ltd v Manganese Bronze and Brass [1934] AC 402. The terms were codified at the end of the century by Mackenzie Chalmers in the Sale of Goods Act 1893. In codifying these and the other rules in what became the Sale of Goods Act 1893, Chalmers’ stated aim was to further “certainty and definitiveness” and to facilitate commerce. But the key point is this: Chalmers saw his codification as containing default rules, which only applied when the parties had not formed an intention or failed to express it. And this freedom to contract out of statutory and doctrinal law regimes is the third, and a vital feature of English commercial law. As a result of party autonomy, historically commercial parties have been able to engage in private law-making. So there were standard form contracts for markets, shipping, and insurance; institutional rules for places like the Baltic Exchange, the home for chartering and buying and selling ships and until the mid-20th century international grain trading; the London Clearing House, which provided and still provides clearing services for international trades, these days in commodities, swaps, derivatives, foreign exchange products, etc, and other financial institutions such as the London Clearing House for payments. Party autonomy is precisely what happened in practice with sales, as with international commodity sales where quality standards and remedies implied by law were excluded and laid down instead by the various trade associations in their standard form contracts.

The other side of the coin to freedom of contract – the fourth feature of English commercial law – stood sanctity of contract, as Wright put it on one occasion, only to be overridden by the strongest possible counterbalancing circumstances. Bright line rules – legal certainty – enabled parties to plan their transactions. It did mean that just because a turn of events bore heavily on parties to a commercial arrangement, or circumstances significantly changed to their detriment, that was no justification for curial intervention. But in a more general sense freedom of contract came to the rescue. If parties to a standard form contract or in a particular market were caught out by a situation or a judicial ruling, there was the legal possibility of rewriting the contract, although given the power configurations in a market commercially this might not be feasible.

None of this means that the English judges were always supportive of commercial practices or in the vanguard in making new law. When they were it was often after a commercial practice had been developed by merchants, or an innovative legal technique had been contrived by the profession, and these had become entrenched. What the judges did – and we shouldn’t underestimate its value – was to give their imprimatur to those practices and techniques. Hire purchase, now asset finance, offers just one example of the courts approving a well-established commercial practice, when the hire purchase trade took the test case of Helby v Matthews [1895] AC 471. Other examples are bank overdrafts (the main avenue for trade credit) and letters of credit. With documentary credits, as with the work of confirming agents, the courts brushed aside what might have been a doctrinal roadblock, the lack of consideration, to endorse a well-established commercial practice. And with the Gaming Acts, legislation was read down, so as not to disrupt dealings on futures markets.

In Professor Sir Roy Goode’s colourful phrase, there was the power of a market “to pull itself up by its own legal bootstraps.”

PEOPLE

Let me turn to my second topic, people, specifically, to some of the leading commercial judges who set the tone – although in focusing on the judges one should not underestimate the importance of the legal profession in forging English commercial law. For present purposes, the key point is the role of specialist judges in the success of English commercial law, not generalist judges, and certainly not career judges in the civil law tradition, judges who worked their way up in a state civil service tradition. Lord Wright is an example. Little is known of his background, schooling, and early adulthood, but his father was a marine superintendent on Tyneside, and the late Dr Robert Stevens opined that it is almost certain that Wright absorbed a good sense of commercial practice from his father and in his early years of work, possibly was employed with him. This connection to commerce features with other judges making notable contributions to commercial law as well. Lord Blackburn’s father was a Glasgow merchant, who owned sugar plantations. Of course that meant he had enslaved people, in Jamaica, and as a corollary received substantial compensation after emancipation. Following his well-known book, Treatise on the effect of the Contract Sale (1845), Blackburn appeared as a junior in heavy mercantile cases. George Bramwell’s father was a banker and Bramwell served an apprenticeship as a clerk in the bank. Once the Commercial Court was established a considerable number of its judges had commerce in their family, Pickford was from the famous family of carriers, Walton, from a prosperous family of Liverpool merchants. There were merchants on Adair Roche’s mother’s side, and Frank Mackinnon was the son of a Lloyd’s underwriter, his mother the daughter of a timber broker, and his brother the chair of Lloyd’s on a number of occasions. Alan Mocatta’s family were bullion brokers.

JUDGING

That leads to my third theme, that judging involves more than legal knowledge and skills. One aspect is what the American jurist, and the main author of the US Uniform Commercial Code, Professor Karl Llewellyn called ‘situation sense’ which David Foxton draws on in his outstanding biography of Scrutton. It’s a feeling for what is the practical solution when faced with the circumstances of a case. Scrutton’s situation sense was not lightly worn and frequently expressed to justify his conclusions. So he paraded his knowledge of the China trade, timber dealings, the cold storage business, and so on in his reasoning. That did not mean that Scrutton always approved commercial practice. There are several decisions where he refused to endorse it. In the case law there are examples of other judges adopting commercial practice as a template for reasoning, albeit that it fell short of commercial custom.

And there are others as well, including of course Lord Justice Scrutton, a big figure in commercial law with his family history in shipping, shipbroking, insurance broking, marine salvage surveying, and later stevedoring. As with some others, Scrutton was an author on the subject, with books on mercantile law, The Merchant Shipping Act, and, still with us, in its 25th edition his Charter Parties and Bills of Lading. Scrutton appeared regularly in commercial cases against another of the great, albeit controversial figures here at The Inner Temple, J A Hamilton, Lord Sumner, the son of a Manchester iron merchant, the “Last Political Law Lord” as one biographer describes him. Even without vicarious knowledge of commerce through family background, English commercial judges learnt their trade in commercial chambers. Lord Wright for example was, along with Richard Atkin and Mackinnon, a pupil of Scrutton with his enormous practice in shipping and insurance, as well as banking and sales. Later they too acquired large commercial practices and pupils, and so it continues to this day. So English commercial litigation, certainly after the foundation of the Commercial Court, was heard by judges and argued by counsel familiar with the ethos of commerce and its practices, in addition to their knowledge of substantive commercial law and procedure. No doubt they have brought that knowledge and sentiment to bear in their judging.

In the case law there are examples of other judges adopting commercial practice as a template for reasoning, albeit that it fell short of commercial practice.

The notion of ‘situation sense’ cannot be pressed too far. One reason is that even outstanding commercial judges cannot know every conceivable part of the commercial world. These days, in particular, specialisation sets in fairly early in practice. But intuition does play a role in judicial decision making. Lord Sumption, another member of this Inn, told Alan Paterson –the close student of Law Lords and Supreme Court justices for over five decades – that he had instinctive feelings, although their strength turned on the subject matter: “How often I am persuaded my initial instinct is just wrong in principle, well probably not very often. When it happens it tends to be in cases in subject areas which I am not so familiar with as some of my colleagues”: (Final Judgment, 2013).

Other than ‘situation sense’ and intuition, there is an enormous amount of US literature explaining judicial decision-making is a judge’s ‘attitudes’ and that their legal reasoning can be a rationalisation of these factors. One dimension is the judge’s notion of public policy. Another of this Inn’s great Commercial judges, Lord Goff, said on one occasion that the commercial judge’s role was “to help businessmen, not to hinder them. We are there to give effect to their transactions, not to frustrate them: we are to oil the wheels of commerce, not to put a spanner in the works, or even grit in the oil.”

CONCLUSIONS

A few high-level conclusions. First, English Commercial Court and commercial judges have generally attempted to facilitate commercial transactions. Secondly, people matter, in particular, the expertise of those settling (and litigating) commercial disputes, both the judges and the commercial Bar working together. Thirdly, we need more than the conventional tools of legal reasoning to understand judging. Practical judging involves factors like ‘situation sense’, intuition, and the judge’s notions of public policy.

Sir Ross Cranston FBA Professor of Law, London School of Economics

For the full video recording: innertemple.org.uk/englishapproach

Lord Atkin of Aberdovey around 1935, on the seafront of the Welsh harbour resort from which he took his title

THE INNER TEMPLE BIG PICNIC

PARSIFAL: ACT 3 WITH PRELUDE TO

ACT 1

Anthony Negus, leading Wagnerian conductor and Music Director of Longborough Festival Opera, reviews The Inner Temple and Temple Music Foundation specially commissioned production of Act 3, with prelude to Act 1, of Wagner’s Parsifal, held on 3 and 4 April 2025 in the Temple Church.

The Temple Church is a wonderful setting in which to experience this beautiful performance of Parsifal Act 3, preceded by the prelude to Act 1. I remember a performance of Act 1 in Gloucester Cathedral years ago, with full Wagnerian orchestra; here in a much smaller space, it was appropriate to have a chamber-sized orchestra and chorus. Having recently conducted this myself in Strathpeffer, Scotland with Tomas Leakey’s Mahler Players, I pay tribute to Matthew King who has so lovingly and expertly arranged Wagner’s score for an orchestra of 40. It sounds and feels like the real score – very rarely does one miss the original.

The stage setting was a long walkway with dried leaves which spanned the length of the aisle. Director Julia Burbach used the space imaginatively with the flowing path of people journeying, seeking, during the Act 1 prelude, and with Kundry (Natasha Jouhl) guiding us. Although she only sings one word (“Dienen” – “let me serve”) twice in Act 3, she gave a deeply moving performance that emphasised the centrality of her character.

With the audience all around the stage, Julia Burbach effectively used all parts of the walkway for the different scenes, and in particular brought out the tension and inherent danger of the knights’ desperation in scene two, with much movement and counter movement; whilst in scene one where Gurnemanz discovers Kundry, and Parsifal returns ignorant of the fact that it is Karfreitag (Good Friday) until informed by Gurnemanz, there was a beautiful stillness at the heart of the movement, and well-chosen parts of the walkway stage.

With the audience all around the stage, Julia Burbach effectively used all parts of the walkway for the different scenes.

L–R: Simon Wilding, Gurnemanz, Paul Carey Jones, Tuturel, Nastasha Jouhl, Kundry and Freddie Tong, Amfortas

L–R: Simon Wilding, Gurnemanz, Natasha Jouhl, Kundry, and Neal Cooper as Parsifal

It is Gurnemanz who dominates the first part of Act 3: I have known Simon Wilding for many years at Longborough as an excellent Wagnerian performer, but I have never heard him sing so eloquently and beautifully as he did here. And Neal Cooper, whom I know as a great Tristan and Tannhauser, gave a strongly sung and moving performance of the journeyweary, mature Parsifal of Act 3. Freddy Tong sang a fine and histrionic performance of Amfortas who, after a long tribute to his dead father Titurel (sensitively portrayed by Paul Carey Jones), bursts out in desperate longing for death. At this critical moment Wagner the genius brings about a magical transformative moment as Parsifal arrives, and in radiant music shiningly sung by Neal Cooper, heals Amfortas’s terrible wound with the point of the sacred spear, now to be reunited with the Holy Grail.

Peter Selwyn conducted a well-paced performance in which the music had time to breathe and unfold naturally, thereby allowing us, the audience, to relish the beautiful playing of the Orpheus Sinfonia. Although he did not have direct contact with the cast and chorus, the ensemble was good, and the singing of the small chorus filled the space well and brought magic to the final pages of the score.

At the end I felt thankful that the whole team had approached their task with great sensitivity and humility, resulting in a truly moving experience that honoured the intangible and unique quality of this sublime Act.

Anthony Negus Music Director Longborough Festival Opera

Peter Selwyn conducting the Orpheus Sinfonia

AMITY DINNER FOR MIDDLE TEMPLE

In Celebration of the Inns’ Amity, Wednesday 12 March 2025

SPEECH BY MASTER TREASURER

Master Treasurer (Kate, if I may be so bold), it is with great pleasure that I welcome you and all from Middle Temple to this Amity dinner.

The barristers of The Inner Temple and the Middle Temple began their cohabitation on this site in the 14th century, more than 200 years before we were united in perpetuity by the wisest fool in Christendom, King James I, by the charter which he granted to us both in 1608.

Those who came to this dinner in 2023 were reminded by my predecessor, but one, Sir Robert Francis, of the letter dated 28 July 1978, written by The Inner Temple’s then Sub-Treasurer, the redoubtable Commander Flynn, which baldly asserted that no ‘Amity’ can exist between the Inner and Middle Temples, since The Inner Temple’s only official Amity is with Gray’s Inn.

Only Rodney Flynn – a man who kept his black poodle in the bottom drawer of his desk – could have written such a misconceived missive. As someone who has had chambers in Gray’s Inn for over 40 years, I yield to no one in my affection for that more northerly institution. But The Inner Temple’s institutional affection for Gray’s is a mere dalliance – a cinq à sept – compared to our long union, both in location and in spirit, with the Middle Temple.

Some of The Inner Temple’s very earliest records reflect the ancient tradition of mutual hospitality between our two Inns. The record of the meeting of the Parliament of The Inner Temple, which was held on All Souls’ Day 1512, includes an order directed to those in charge of the Inn’s Christmas festivities, which takes for granted that it was the custom at Christmas time for the members of each of the two Inns to go as a group to visit the other’s hall.

Speaking of Christmas festivities, my own happy memories of the Middle Temple date from my earliest days as an aspiring lawyer, back when dinosaurs roamed legal London. Middle Temple had a bar, whereas The Inner Temple did not, and I spent many convivial evenings there. As a result, and despite being an Inner Templar, I was persuaded to produce and direct a modern version of Christmas Revels in Middle Temple Hall.

The world was different then, and the production included a high-kicking chorus line of female students in black satin hotpants, wigs and gowns. We were, of course, only trying to live up to the great 17th-century diarist and Middle Templar, John Evelyn’s, description of the Middle Temple’s Revels as “an old, but riotous custom” with “relation to neither virtue nor policy”.

One of the dancers in this chorus line was the woman who shortly thereafter became my partner (now of nearly 50 years) and wife, Ginny. By way of thanks for allowing us to use the hall, at the end of the performance, Ginny was delegated to present to Middle Temple’s Treasurer, Lord Diplock, a photograph of himself on his horse – a beast which allegedly was named Circuit so that Diplock’s clerk could say that his governor was “out on Circuit” if he was absent when duty called.

To make the presentation more graceful, Ginny borrowed one of Middle’s elegant silver salvers from the serving staff, only for Lord Diplock – one of the bigger beasts of the time and, towards the end of his career, more Tyrannosaur than Diplodocus – to assume that he was being presented with the silver salver, rather than just the photograph that was on it.

REPLY BY THE TREASURER OF MIDDLE TEMPLE

Master Treasurer (Richard), on behalf of all your guests from Middle Temple may I thank you for this perfect evening. A delicious dinner, superb wines and excellent company. Add to those essential elements your kind words mixed with hilarious anecdotes, and you have entertained us royally. More importantly you have made us feel very welcome indeed. Thank you.

Until your speech, I had always assumed that describing Amity dinners as enmity dinners was just a mildly amusing play on words – one I’d heard a lot over the years. It was quite funny the first time. And the second. Maybe even the third. Each generation thinks it’s original. And it isn’t. But how very satisfying to know that as between our two Inns there was a relatively recent (and I still think of the 1970s as recent) explanation for the absence of amity – or perhaps even the presence of enmity. How magnificently narrow minded to declare that there could be no amity with Middle because there could only be amity with Gray’s. I think the young might put it thus “Yes, well I’ve been seeing Gray’s for a while, I wasn’t sure but, you know, I’ve been persuaded it’s time.

A more modern memory that I have of the great affection and trust between our two Inns is of arriving at 8.30am on a cold Wednesday morning in November 2023 for The Inner Temple’s weekly Principal Officers’ meeting, only to be greeted by the sight of Middle Temple’s Under Treasurer standing on the terrace, making arrangements to move The Inner Temple’s Grand Day dinner over to the Middle Temple because The Inner Temple Treasury building had no electricity. Greater love hath no Inn than to cancel its own function to make way for that of another.

Writing in the time of King Charles I, Chief Baron Wilde (an Inner Templar) recorded that he knew “of no precedency between [the two Inns], they being alike equal in antiquity, honour and estimation”.

Between us, the Inner and Middle Temples have, over the years, given shelter to many famous adventurers – Francis Drake, Walter Raleigh and John Buchan among them. I hope that we, their successors, can take that historical delight in adventure into our 21st-century future, with a renewed spirit of confidence, co-operation and – yes – amity between our two learned, ancient and wonderful institutions.

Inner Templars, may I therefore ask you now to rise and drink a toast: to our cherished neighbours and partners in law, The Honourable Society of the Middle Temple.

We’ve finally decided to go exclusive.” I’m sorry to say Master Treasurer that Rodney Flynn, forever to be remembered as the man who kept his dog in a drawer, would have been outraged to know that you were flirting with Middle while living with Gray’s – right under his nose. We Middle Templars are not outraged. On the contrary we salute you.

I had thought about including in this speech a few lines about the wearing of hotpants – a garment which no cool teenage girl of the 1970s would be without – but that is for another time. Tonight is about the long and enduring friendship between our two Inns.

We all know that Middle Temple took a battering last year with the death of our beloved Treasurer Paul Darling KC in August, and then in December the Inn’s long serving staff member, John Morrissey died suddenly, barely a week after his retirement party. Sobering time for us all. Also, a time for great reflection. When preparing to speak this evening it seemed right to tell this story. Some of you will know it already. It bears repetition and I hope Inner Temple Benchers will not mind too much.

Richard Salter KC Treasurer 2025

John was one of the warmest and sunniest men you could ever meet. As you came through the door he greeted you as if there was no one he would rather see in that moment than you. He would call you by your name. I happen to know that when the Under Treasurer came into the Inn every morning he would say “Now then young Christopher” – cheered the Under Treasurer up no end – every day. We all loved John and he loved us. Some years ago, when John was in his early 60s he was on his way into work at about 6.30am in the morning. As he was about to leave his home station for the Temple he was set upon by four violent young men. Having dealt him several blows they lifted him up and smashed him against a wall. Keeping his hands up, they removed from his wrist his treasured gold watch. Then threw him to the ground and made their escape. John collected himself. The police were called. They took his details and suggested he should go home. John would hear none of that and continued to the Temple, to go to work as always. He was in by 7.30am. Quite extraordinary. What had happened to John spread through the Temple in hours.

The next morning, or perhaps the following day, a distinguished Bencher of the Honourable Society of the Inner Temple came to see John in Middle Temple. She asked how he was, and he told her he was recovering very well. She then handed him a box and opened it. She brought out a watch. As told by John, she said “This was my husband’s watch. He doesn’t need it anymore and I’d like you to have it.” John, unusually for him, was speechless. He was moved and profoundly grateful. What a wonderful, kind and generous act. Whenever John told that story he always added “That’s the Temple. We’re family. We look after each other.” And he was right.

As between individuals – a watch of great personal significance. As between the institutions, all hands on deck and the use of a hall when the electricity blew. Ours is true deep and enduring amity.

Middle Templars, I invite you all to stand to thank and toast our hosts and friends at the Inner Temple.

The Right Honourable Lady Justice Thirlwall Middle Temple Treasurer 2025

He was moved and profoundly grateful. What a wonderful, kind and generous act. Whenever John told that story he always added “That’s the Temple. We’re family. We look after each other.” And he was right.

THE INNER TEMPLE STUDENT ASSOCIATION ESSAY PRIZE 2024:

IS IT EVER ETHICALLY JUSTIFIABLE FOR A LAWYER TO BREACH CLIENT CONFIDENTIALITY? EXAMINE THE LIMITS OF PROFESSIONAL ETHICS IN EXTREME CASES

By Athena Kam

In recent years, the #MeToo movement and the Post Office Inquiry have highlighted how lawyers can facilitate wrongdoing by maintaining client confidentiality using non-disclosure agreements (‘NDAs’). International organisations have also criticised lawyers for relying on the guise of confidentiality to conceal complex corporate structures and financial transactions, facilitating the commission of financial crimes. While the principle of client confidentiality provides that the affairs of clients should be kept confidential, these examples reveal how the principle can be misused to conceal injustices. This raises the question of whether it can ever be ethically justifiable for a lawyer to breach client confidentiality, and if so, where the limits of professional ethics lie in extreme cases.

To answer the questions, the essay will proceed in two parts. The first part will examine the justifications for client confidentiality, which will answer whether breaches of confidentiality can ever be supported. The second part will examine three cases of (1) preventing serious crime; (2) protecting vulnerable individuals; and (3) misuse of confidentiality to argue that while client confidentiality is essential, it can be outweighed by the need to uphold public interest in the administration of justice and the rule of law. In such extreme cases, breaches of client confidentiality can, and indeed must, be ethically justified.

PART I: THE CASE FOR CLIENT CONFIDENTIALITY

To understand when breaching confidentiality may be justified, it is important to first consider the justifications for this duty. Client confidentiality is not just a matter of protecting a client’s privacy; it is integral to the functioning of the legal system and the pursuit of justice, as emphasised by the International Bar Association. A key distinction between the lawyer’s duty of confidentiality against other professional confidentiality duties is that lawyers are performing the public function of administering justice and not merely serving clients’ private interests; resultingly, the duty of confidentiality is the bedrock of the rule of law.

A powerful justification for client confidentiality is that it enables clients to obtain independent and confidential legal advice without fear that their statements could be used against them. This is especially important in situations where individuals may be vulnerable or unsure of their legal position. For example, lesser-resourced parties may not disclose their position, fearing it will expose their weaker bargaining power and leave them vulnerable to unfair settlement offers. However, they may be pushed towards litigation if a lawyer does not have the full picture, which may be more detrimental in practice if it is economically unviable. Moreover, the independence of lawyers would be compromised without client confidentiality. This point was made by Lord Justice Bingham in Ventouris v Mountain, when he noted that lawyers should be “free to give honest and candid advice on a sound factual basis, without fear that these communications may be relied on by an opposing party if the dispute comes before the Court for decision.” The point can be taken further; breaches of confidentiality could be exploited by more powerful parties to undermine the lawyer’s independence. Taking the same example as above, if a lawyer breached confidentiality on the client’s economic situation, the stronger party may offer to ‘buy out’ the lawyer and deprive the other side of legal advantages. Such commercialisation of legal services creates a tiered system of justice, which operates to the detriment of the public. A related but distinct justification is that client confidentiality protects lawyers from personal harms or external pressures, enabling them to serve clients impartially. For example, an immigration lawyer acting for a refugee may be at risk of attack from extremists if no client confidentiality existed. One can look at the June 2024 UK riots, where up to 60 immigration centres were circulated as targets online, to infer that lawyers and clients could be personally attacked if confidentiality was breached. Indeed, a London immigration law firm was subject to an armed attack by a knifeman motivated by racism in 2020; the initial nondisclosure of the firm name only highlights the importance of preserving confidentiality to prevent further danger. When a lawyer’s safety is at risk, their ability to represent clients impartially and effectively is impaired. Confidentiality therefore safeguards the integrity of the legal process itself, which is integral to clients accessing justice.

Finally, client confidentiality is necessary for the efficiency of administering justice. As Lord Justice Bingham identified in Ventouris, the principle of confidentiality is “rooted in the public interest, which requires that hopeless and exaggerated claims and unsound and spurious defences be so far as possible discouraged, and civil disputes so far as possible settled without resort to judicial decision.” This can only be achieved if clients speak candidly and disclose all relevant facts, including their positions and weaknesses, which allows their lawyers to properly evaluate the merits of the case. In turn, lawyers can then “give their clients sound advice, accurate as to the law and sensible as to their conduct”, whether that involves pursuing litigation or redirecting the matter to alternative dispute resolution mechanisms.

However, the strength of the point may be undermined by the possibility that clients do not necessarily have to follow through legal advice. Mere discouragement does not necessarily prevent vexatious litigation – the example of the litigant who brought over 40 discrimination claims in the employment tribunal suggests otherwise. On the contrary, client confidentiality may have an unintended adverse consequence of increasing illegitimate defences when parties become aware of the difficulty in proving the case. For example, an unscrupulous defendant facing potential corporate criminal liability may be emboldened to defend their claim after obtaining legal advice, having learnt of the claimant’s difficulty in proving the requisite state of mind. In this case, breaching confidentiality to prevent further wrongdoing may be justified. This demonstrates that confidentiality is an “important, but not untrammelled” aspect of the rule of law. Consequently, the question is not whether, but when it is ethically justifiable for a lawyer to breach client confidentiality.

PART II: ETHICAL JUSTIFICATIONS FOR BREACHING CLIENT CONFIDENTIALITY

Despite the strong justifications for preserving client confidentiality presented above, it neither requires, nor justifies, rigid adherence to the duty. The duty to maintain client confidentiality must be balanced against the duty to protect and promote the public interest, as reflected in S.1(1) (a) Legal Services Act 2007. This balancing exercise is not straightforward or necessarily intuitive, as demonstrated by the case of Stephen Chittenden, who breached client confidentiality to help convict a man who may otherwise have avoided punishment for murder and agreed to leave the legal profession post-retirement. While consequentialists may argue that any private interests harmed through breaching confidence is outweighed by the injustice of someone going unpunished for murder, the practical reality of financial consequences and reputational risks create disincentives for lawyers to weigh in favour of apparent public interest. To explore when it can be ethically justifiable for a lawyer to breach client confidentiality, three extreme cases will be evaluated to better understand the limits of professional ethics.

(i)

Preventing Serious Crime

Breaching client confidentiality in cases of preventing serious crime or ‘iniquity’, such as “fraud, dishonesty, bad faith or sharp practice”, is one of the most “well-established” exceptions with clear ethical justifications. In principle, a client has no legitimate expectation of confidentiality when they disclose information relating criminal activity. Nor does public policy require “those who misapprehend the law to be privileged in circumstances where no privilege attaches to those who correctly understand the situation.” Furthering the criticisms from international organisations, lawyers who facilitate fraud and corruption under the guise of client confidentiality undermine the rule of law as these entities

have no legitimate expectations of confidentiality ab initio by deliberately misusing legal instruments. Therefore, breaching ‘confidentiality’ in such cases is not just justifiable, but necessary.

It may be countered that this line is more difficult to draw in practice. Clients may be unable to distinguish between incriminating information, where no legitimate expectation of confidentiality arises, and exculpatory information, where confidentiality may be required to ascertain the true legal position. If an exception is carved out for preventing serious crime, clients could be deterred from being fully honest in their correspondences, with serious consequences for their liberty if they are resultingly imprisoned due to receiving incomplete legal advice. However, strict adherence to client confidentiality will not resolve such fears, and limits can be drawn to mitigate such risks. Taking the same example of lawyers allegedly furthering corrupt and fraudulent practices, financial or administrative advice could be disclosed to establish the true picture and prevent wrongdoing, while core legal advice remains confidential to allow clients to ascertain an accurate view of their legal position without prejudice. Doing so promotes public interest in the administration of justice and the rule of law with greater flexibility, providing a more justifiable solution than rigid adherence.

(ii) Protecting Vulnerable Individuals

Preventing harm to children and other vulnerable adults may also justify breaches of confidentiality, particularly as they may be unable to fully appreciate the possibility and severity of harm by themselves. While acknowledging that difficult questions of capacity fall outside the scope of this essay, the fact remains that such individuals warrant greater protection under the law because of their vulnerability. At first glance, this may point towards heightened levels of confidentiality to ensure that no harm is caused by inadvertently revealing potential victims to abusers. However, such a fear can be mitigated by clearly defining the exception to exclude the breach of confidential identification information, preventing perpetrators from identifying victims.

The disclosure of confidential client information can be required to fully assess the situation and ascertain how harm can best be prevented. Lawyers may be the first to learn of potential abuse, neglect, or threats of harm by virtue of their duty and position. Such cases often require balancing a myriad of complex, non-legal factors such as welfare and public protection. Although lawyers can conduct such balancing exercises, it is a distinct question from whether they should. Arguably, it would be inappropriate for lawyers to do so because they lack specific expertise, and it falls outside their core function of administering justice given the possible policy implications. For example, if a schizophrenic patient feels compelled to injure other members in a mental health ward and discloses this to a lawyer when obtaining advice or during a capacity assessment, lawyers are less well-placed than trained medical professionals to suggest the best course of harm prevention. As such, breaching client confidentiality may be justified to prevent injury to other vulnerable persons, and to prevent harm (in a broad sense) to the patient who is suffering from false perceptions that compel such action.

Breaches in these cases can be further justified as the other professionals often have their own confidentiality duties, providing an additional safeguard for minimum and proportionate breaches. As such, breaches are more justifiable than maintaining confidentiality when protecting vulnerable individuals, as it allows for deference to expertise and takes account of the specific facts of the case, better serving the client’s interest and the ends of justice.

(iii) Misuse of Confidentiality

Finally, breaches of confidentiality may be justified when lawyers suspect that clients are misusing confidentiality (as through NDAs), as no other party may know of the true situation to hold wrongdoers to account. The justifications for breach in such cases are particularly forceful following the #MeToo movement, where NDAs were systematically and serially abused to enable workplace sexual harassment. Similarly, NDAs allowed much wrongdoing to be hidden in the shadows as revealed in the Post Office Inquiry. Such misuse of confidentiality cannot be said to warrant the protections normally afforded, given that they “frustrate, and might pervert in the criminal sense, the administration of justice”, which undermines the very justifications for having confidentiality in the first place.

It may be objected that this places a stringent requirement on lawyers to act diligently and lead to defensive breaches of client confidentiality out of caution. However, the duty not to behave in a manner that diminishes public trust and confidence (as enshrined for barristers in Core Duty 5) addresses this point precisely. Lawyers should be acting diligently to prevent diminished public trust following the uncovering of such misuse, and should uphold positive

public perception by not acting in a self-interested manner. Further, anecdotal evidence suggests that lawyers would be more inclined to maintain client confidentiality when the boundaries are unclear, further diminishing the force of such criticism. When coupled with the forceful criticisms against lawyers for ‘turning a blind eye’, accepting the paramountcy of client confidentiality without question is no longer possible; breaches are justifiable in extreme cases to support the administration of justice and rule of law.

CONCLUSION

While client confidentiality is vital for justice, it cannot be absolute when it facilitates wrongdoing or injustice. In extreme cases, clearly defined exceptions for breach triumph over rigid adherence to duty by accounting for case-specific facts and allowing deference to expertise. This ultimately ensures better adherence with the ends of administering justice and upholding the rule of law. In these circumstances, breaches can, and should, be ethically justifiable.

Athena Kam, BA (Oxon), LLM (UCL)

Essay Prize with footnotes

JUNIOR BAR ASSOCIATION ROUND-UP

By Christie O’Connell and Nancy Kelehar

This year has marked a fresh chapter for The Inner Temple Junior Bar Association (JBA), with several new faces joining the committee. We were pleased to welcome Christie O’Connell as Co-President, who now shares the helm with Nancy Kelehar. We were also delighted to appoint Alex Ferrigno as our new Treasurer, who has already brought energy, efficiency and a suspiciously well-formatted spreadsheet or two.

The JBA continues to champion the professional and social development of junior members of the Inn. Our aim remains the same: to provide events that support junior barristers in building meaningful connections and navigating the early years of practice.

We were thrilled to end last year on a high note with the inaugural JBA Annual Dinner – a black tie evening of fine food, wine and general merriment. Junior barristers gathered in force, proving once and for all that the junior Bar scrubs up well. Given the success of the evening, we are delighted to confirm its return to the calendar as an annual tradition.

This year began in earnest with Surviving on Your Feet, a well-attended panel discussion for first and second six pupils. Seasoned juniors shared practical advice on managing court appearances, avoiding rookie errors and keeping your wig on (literally and figuratively).

We also welcomed prospective barristers to an event focused on cracking the pupillage process, with a panel of barristers sharing tips on making it through second-round interviews and securing those elusive offers. The atmosphere was equal parts inspirational and reassuring: proof that everyone starts somewhere, and nobody forgets the terror of a ten-minute advocacy exercise.

In June, we hosted our Summer Soirée on The Inner Temple terrace. The weather was kind, the canapés plentiful and the drinks cold – an ideal setting for junior barristers (and a healthy contingent of clerks, solicitors and friends of the Bar) to enjoy a relaxed evening of conversation and camaraderie.

LOOKING AHEAD

We are very much looking forward to a busy and engaging autumn. The ever-popular Autumn Quiz returns, offering an opportunity to showcase your obscure legal trivia, niche pop culture knowledge and questionable team names. Finally, following the success of last year’s event, we will once again be hosting our Career Sustainability Networking Evening. This event provides junior barristers with an opportunity to explore important topics such as financial planning, career breaks, well-being and how to have constructive conversations with clerks (without needing to rehearse them in the shower first).

The ever-popular Autumn Quiz returns, offering an opportunity to showcase your obscure legal trivia, niche pop culture knowledge and questionable team names.

Tickets for all upcoming events will be available via The Inner Temple Members Area. JBA events during 2025 are generously sponsored by expert mortgage advisers Henry Dannell, ensuring that we can keep our ticket prices affordable for junior members.

If you would like to get involved with the JBA or have ideas for future events, we would love to hear from you. Please email us at jba@innertemplesocieties.org and follow us on social media by searching ‘Inner Temple Junior Bar Association’

Christie O’Connell & Nancy Kelehar Co-Presidents, Inner Temple Junior Bar Association

Junior Bar Association Summer Soiree

Junior Bar Association Halloween Quiz

RETIREMENT OF THE READER OF THE TEMPLE

By Master Rory Phillips and The Rev’d Mark Hatcher

MASTER RORY PHILLIPS, CHAIR OF THE TEMPLE CHURCH TRUST, WRITES…

Mark Hatcher arrived as Reader of the Temple in September 2015. He quickly became a superlative colleague and a dear friend. He initially remained at the Bar Council as Special Adviser to the Chair of the Bar. In 2019, he moved down Chancery Lane to be here in the Temple Church full time. He has thereby been able to transform the role of Reader. He has been a most welcome and welcoming presence, unfailingly generous in spirit and warm-hearted, a true representative of the Temple Church at its best. He also has an encyclopaedic mental Rolodex: he knows everyone and remembers everything. He has to the full, then, that most sympathetic of gifts: he recognises judges, barristers, clerks, our annual visitors from around the world and our regular congregation from 30 yards as they cross Church Court towards a service, or concert or special event.

Mark’s preaching is utterly true to himself: kind and nonjudgmental, capacious in his understanding and care of others. He has remained true, too, to his passion for justice: in his own preaching and the organisation of visiting speakers and special discussions on socio-legal topics. It is a rare person who will say no to such an invitation from Mark to speak here.

After a full decade, Mark retired in July, with well-deserved acclaim and with the heartfelt thanks and best wishes of us all. He remains, of course, a Bencher of Middle Temple and an Honorary Bencher of The Inner Temple; he has good reason to be back here to see his many friends, and we all hope that he will be. All of us will remember, for a long time to come, Mark’s smile and his greeting, his sensitivity and his good cheer. He has helped to make the Church what it is, and what we all hope it will – thanks to the years of his presence and his work here – remain. We are very grateful to him indeed, and we send to both him and Clare our very best wishes for the future.

Reader of the Temple Church and Master HRH The Princess Royal at Grand Day 2023

Reader of the Temple Church at Choral Evensong preceeding Grand Day 2023 © Abhimanyu Bose

THE REV’D MARK HATCHER WRITES…

When I climbed, with a little trepidation, the steps of the Temple Church’s vertiginous pulpit to give my first sermon as Reader, I was conscious of the ‘Battle of the Pulpits’. My 16th-century predecessor, Walter Travers, regularly disagreed publicly with the Master of the Temple, Richard Hooker, on matters of worship and doctrine. It was, of course, a time of religious ferment, but their increasingly acrimonious disputes led to a prolonged gladiatorial contest. Their sermons were not for the faint-hearted; they could last an hour or more apiece. These disputes became famous, then scandalous. Eventually, Travers was banned from preaching in 1586. I am happy to say that relations between the Master and the Reader over the past ten years have been very harmonious. Under Robin Griffith-Jones’s distinguished leadership as Master and with the dedicated support of the Temple Church Trust, the Church has gone from strength to strength.

During my tenure as Reader, there have been three Chairs of the Church Committee (Ian Mayes KC, Sir Stephen Tomlinson and Andrew Spink KC) and a fourth, Rory Phillips KC, who became Chair of the Temple Church Trust. This was created in 2024 following important changes in the governance arrangements between the Inns and the Church. The Benchers of the Inner and Middle Temple, who have served and continue to serve on these two bodies, have been extremely generous with their time and expertise on behalf of the two Inns to oversee the work of the Church. This work is supported by a small executive team in the Church Office, led (since 2024) by Chief Executive Paul Cutts and with input from the Inns’ staff. Their contributions have increasingly focused on ensuring that the Church is sustainable for the future and remains ‘the beating heart of the Temple’.

I have been blessed to participate in the life of the Temple community, to have shared ministry with Robin Griffith-Jones and to have worked with the Church’s music department led by Tom Allery, Matt Power the Verger and Catherine de Satgé, the Church Administrator and the whole Church team. It has been an enormous privilege to have worked with such a dedicated and talented group of colleagues to inspire our worship, sustain the Church and help promote its vitality. There is a great deal to thank Rory Phillips and his fellow trustees for, as well as the Church team for their considerable parts in safeguarding and promoting the Church’s future. The Temple Church is in very good hands.

Rory Phillips KC Chair of the Temple Church Trust 3 Verulam Buildings

The Rev’d Mark Hatcher Reader of the Temple Church 2015–2025

Accommodation at your convenience

The Inn’s two equally stunning rooms, the Boswell and Chaucer, are available every day and are located on the third floor of 3 Dr Johnson’s Buildings which was built in 1858 by the architect Sydney Smirke.

Whether you are in town for business or pleasure, our accommodation, along with the Pegasus Bar which is open Monday-Friday, o ers respite from a long day of meetings or sightseeing.

Choose from the four-poster luxury of the Chaucer or the more modern Boswell with views overlooking Temple Church.

020 7797 8230 | venuehire@innertemple.org.uk | innertemplevenuehire.co.uk

FOUR DISHES

By the Master of Silver and Richard Parsons

EX DONO W W M 1864

Master Michael Lawson: This is the rather bland engraving on the bases of four curiously decorated, but beautiful, dishes in our collection. The announcement of William Mackeson’s death on 4 March 1892 is equally lacking in detail about the person, save that he was an Inner Temple barrister.

“On the 4th March at Lancaster, England, at the residence of his son-in-law, Lieutenant-Colonel Sidney Cargill, William Wyllys Mackeson, barrister-at-law, Bencher Inner Temple in his 80th Year.”

In fact, he enjoyed an interesting and multi-faceted life lived in Victorian times. He was the second son, born in August 1812, of his parents Captain John Mackeson and Olive (née McKeand), and one of five children. His delightfully named sister Delicia Jane married the Sidney Cargill mentioned above, then a Captain, in 1877. William’s father was a member of the brewing family, Mackeson, and that branch of the family lived on a coffee plantation on Blue Mountain in the parish of Manchester, Jamaica. William appears to have retained an active interest in local affairs throughout his life and is noted in 1845 as being a member of the Assembly and Standing Counsel for the Parish of Manchester, and later also of the Parish of St Ann, even after he had started practice in England. He was listed on the door of chambers in Spanish Town, Jamaica from 1836–1849. In 1887 he was listed as a Director of the Colonial Sugar Refining Company.

In 1843, William and David Smith, also coffee plantation owners, set up a private company to introduce railways to Jamaica soon after their introduction in England, naming the endeavour as the ‘Atmospheric Railway Project’, an ambitious venture to link the port of Kingston to Port Antonio on the north-east coast and Montego Bay in the north-west across the interior of the island.

William Mackeson was described as an “influential committee member”. The railway appears to have thrived and was bought by the Jamaican Government in 1879. In 1900, the government, with the assistance of American consortia, extended the network to complete the project. Initially used to transport people and agricultural produce, the railway later became the preferred method of transporting the Bauxite deposits, discovered in the 1940s, to the sea. It appears that the lines are now unused, although there are plans to use parts of the network as tourist attractions.

Mackeson was admitted to The Inner Temple in 1832, aged 19. He had gone up to Oxford aged 16 in March 1829. He graduated from Queen’s College in 1833 with a 3rd in Classical Honours and a 1st in Mathematical Honours and was Called to the Bar in 1836. From 1850–1885, he was a Chancery Practitioner at 1 New Square for most of his practising life but for a few years before his death he is listed as a being a tenant at 8, Fig Tree Court, paying £80 annual rent. His executor, Colonel Cargill, is given Notice to Quit by Michaelmas “or sooner if a tenant can be found”.

William Mackeson was listed as Patent Counsel in 1864 and took Silk in 1868. Little is known of the detailed nature of his practice. However, we know that he was the joint editor of the 5th Edition of Coote on Mortgage (1881) and of a text book on The Supreme Court of Judicature Acts 1873 and 1875, radical Acts which amalgamated the different courts of Common Law and Equity into one Supreme Court.

Chamber records for Mackeson

Underside of the silver dish with William Wyllys Mackeson’s initials

The William Wyllys Mackeson coat of arms

Another interest, revealed by our research, and probably prompted by his plantation experience, was slavery. In 1857, he was part of a seven-man delegation, led by Lord Salisbury, which petitioned Lord Palmerston to do more to end slavery and the slave trade, although it had already been abolished in the Empire by the Slavery Abolition Act 1833. He maintained that the trade was still carried out by France, Spain and Portugal using Cuba as their staging post. He argued that plantation owners were slave owners only because there was no other source of labour and that slavery could only be rooted out by African emigration treaties allowing Africans to leave their countries as free men. The Prime Minister is recorded as thanking the delegates for their thoughtful contributions, and stating that the government would give full consideration to their arguments and that it was committed to the crushing of the slave trade. Government responses do not appear to have altered greatly over time!

Mackeson was elected Treasurer in 1884. Inner Temple records only refer to correspondence during his year with barristers in Australia about the role of the Inns of Court in the English profession and, curiously, if they did not then have Inns of Court, an interest in a report on the conditions of ‘laundresses’ (ladies who looked after residential chambers) working in the Temple. At the end of his year, he generously gave the Inn the four silver dishes about which Richard Parsons writes more fully overleaf.

In 1857, he was part of a sevenman delegation, led by Lord Salisbury, which petitioned Lord Palmerston to do more to end slavery and the slave trade…

In March 1839, he married Ann, second daughter of Hugh Godfray, a Jersey resident. They had two sons and three daughters and lived at various addresses in the Paddington and Kensington areas of west London.

His name also appears in later years on the chessgames. com website as a member of the British Chess Club and a competition chess player, with six games for 1885 listed on their database. Sadly, he lost most of those games. In tournaments in London and Dublin he did rather better. He was also one of a team of eight Inner Templars who challenged a Dr Zukertort in The Inner Temple Hall. Dr Zuckertort was obviously a very remarkable chess player, although reputedly partial to laudanum, and played blindfolded throughout the six hours of play. He nevertheless won four games (including against Mackeson) and drew in three of them. One game was left unfinished.

Dr Zuckertort was of Polish origin and won the 1878 Paris Tournament and the 1883 International Tournament in London, after which he toured the US and Canada competing in simultaneous and blindfold exhibition matches. He obviously had a phenomenal memory.

The dishes remained in our collection until 1982 when the Executive Committee decided that some pieces had to be sold to finance a scholarship fund. We know that these dishes were bought by Master Woolf because he generously returned them to the Inn on his retirement as Lord Chief Justice in 2005. Having enjoyed them at his home he felt they should come back to their original home.

There is a pleasing coincidence that both the original donor, William Wyllys Mackeson – about whom we now know a little more – and the subsequent donor were both involved in momentous changes to our court system: Mackeson in explaining the Judicature Acts and Master Woolf in proposing equally substantial changes to our Civil Justice system in the Woolf Report 1996.

WILLIAM GALLAGHER

The Silver team met on Friday 25 July for its summer inspection of the Inn’s silver collection. We did so with some anxiety as it was the first time we had gathered since William Gallagher’ s retirement. He knew every piece, its catalogue number and who gave it to the Inn. He treated the items with such care, cleaning them and taking a selection of them up to Hall several times a month for dinners, returning them late in the evening before going home. He shared our concern if any piece was inadvertently damaged and identified them for us at our biannual silver counts. His love and care of the silver was in addition to his many other duties in the Inn which required him to arrive daily at 8.00am and work often till late.

We invited him back to join us for lunch to recognise over 30 years of stewardship of the Inn’s silver. We missed his help and cheerful banter in the morning but happily he gave us a hand to catch up after lunch. We noted how well he looked and that he had developed a taste for trips to Scotland to which he had previously never been. It was good to see him in such good spirits.

Thank you, William, for all that you have done for us – and the Inn – so brilliantly for many years.

His Honour Michael Lawson KC Master of the Silver

L–R: Kevin Athow (Bar Liaison Committee), Richard Parsons (Jeweller and Silversmith), Master Michael Lawson (Master of the Silver), Master Desiree Artesi (Assistant Master of the Silver, William Gallagher.

Richard Parsons: From time to time, a piece or group of silver objects appear on the market, or is viewed in a private collection, whose use or function is not immediately obvious. The set of four charming silver dishes in the Inn’s collection, made by James Fox in 1885/6, are an example. Oval in appearance the dishes are each raised on four small turtle feet, with shell form-edges, a scroll handle at one end and a Pegasus at the other. The Pegasus indicates that the dishes were made as a commission for The Inner Temple and their appearance gives an indication that they were made for some shellfish related food.

The maker, James Fox, was a member of a distinguished family of silversmiths who sold work directly to clients and worked for retailers. The dishes are also marked under the base with the retailers’ name of Lambert of Coventry Street, and it is likely that the dishes were commissioned from them, the manufacturing order being placed with James Fox, who was a regular supplier. The mark of other members of the Fox family and the retailer Lambert are found on a number of pieces in The Inner Temple collection suggesting that the two companies were employed as suppliers; for example the large Victorian rosewater dish of 1878, located in the Hall showcase and a reproduction of the 1563 silver gilt melon cup, copied in 1898, the original of which is also in the Hall display.

The functional answer for the dishes might be revealed by the shell sides which are scallop in appearance but not actual scallop shells. They more closely resemble a cockle shell, with a curved end but without the wedge end to the shell seen on a scallop shell. The dishes bear the London Assay Office date letters for 1885/6 and an inscription engraved underneath ‘EX DONO /WWM/1884’. Master Lawson gives details of the WWM initials in his interesting article, but the engraved date and the date of the dishes might lead to understanding their function. Master Lawson identifies the WWM as being for William Wyllyss Mackeson and also mentions that his chess playing took him to Dublin as a member of the British

A 17TH CENTURY MENU FOR COCKLES

For anyone who might like to try cockles, food historian Marc Meltonville has researched a possible 17th century menu found in the cookery book, The Accomplished Cook by Robert May. He also prepared the 1660 recipe with fresh cockles, remarking that it was “Tasty but unremarkable, a little sharp for modern tastes”.

If the shells are cockle shells, the chorus of the song Molly Malone “Cockles and mussels, alive, alive, oh! ” is part of a well-known song associated with Dublin. The song tells the fictional tale of a fish wife who plied her trade on the streets of Dublin by day (and was a part-time sex worker by night) who died of a fever as a young woman. At the time the dishes were made the Molly Malone song was published by Francis Brothers and Day, one of the leading publishers of music hall and popular songs of the time in London in 1884, as a work written and composed by James Yorkston, of Edinburgh with music arranged by Edmund Forman. The first verse of the song reads:

In Dublin’s fair city, Where the girls are so pretty, I first set my eyes on sweet Molly Malone, As she wheeled her wheel-barrow, Through streets broad and narrow, Crying, “Cockles and mussels, alive, alive, oh!

Alive, alive, oh, Alive, alive, oh, Crying “Cockles and mussels, alive, alive, oh

The dishes are quite small in size. Measured over the handles they have a length of slightly more than 12 inches and a width of 6.1/2 inches. They are large enough to receive scallops but would be better suited to the smaller cockle and are perfectly formed for table service. The traditional cooking method is to either boil or steam the cockles and serve them with vinegar and pepper.

By coincidence, the author was staying at St David’s in Pembrokeshire, South Wales a few weeks ago before taking a ferry to Ireland and at breakfast, apart from the usual table fare, was served an oval dish of cockles.

“Cockles and mussels, alive, alive, oh!”

Richard Parsons

Jeweller and Silversmith

Four Dishes

REDISCOVERING JOHN CALVERT: FOUNDING CHOIRMASTER OF THE TEMPLE CHURCH CHOIR

By Kristina Guiguet

The Temple Church Choir has an excellent reputation today, but history has forgotten that John Calvert was the founding choirmaster who established that reputation within his first year. In 1842, to mark the reopening of the Church after a long renovation, the societies of The Inner and Middle Temple hired Calvert to create a new choir to revive the treasures of English cathedral music by Renaissance and Baroque composers such as Thomas Tallis and Henry Purcell.

Deeply religious, Calvert felt this music gave listeners a foretaste of heaven. He built a star-studded choir that performed much rare music, attracting large congregations, royalty, and national press coverage. He resigned abruptly in 1844, undone by inexperience, idealism – and the duplicity of Inner Temple barrister William Burge.

This is the story of how Calvert founded the Temple choir, under the musical leadership of The Inner and Middle Temple. Calvert later roamed the Empire, leaving few papers. My main sources are the Inner Temple Archives’ rich collection and period publications. Unattributed quotations are Calvert’s words.

John Calvert (1816–1880) was a musical outsider. Most professional musicians had musical parents; Calvert’s were ivory turners, famed for exquisite chess sets. His widowed mother, Dorothy, educated three sons at Stockwell Park Grammar School. Two went to Cambridge. Christopher Alderson Calvert was at Middle Temple by 1838; William Calvert was an Anglican curate by 1843. John partnered his mother in D Calvert & Son until she died in 1840. Somehow, he trained in music and joined the cathedral musicians then beginning to revive early English music.

In 1841, he sang a concert with George Cooper Junior, assistant organist at St Paul’s Cathedral choir, where Calvert occasionally sang as deputy. Cooper’s circle included singers Enoch Hawkins and John Hobbs, both of the Chapel Royal and Westminster Abbey, and organists John Goss of St Paul’s and James Turle of the Abbey. All were famous stars and leading antiquarians, keen to strengthen the nation’s devotional life by reviving the early cathedral music. All of them – and Calvert – belonged to the Musical Antiquarian Society, then republishing early music, hard though it was to find.

Inside pages of the choir book © Inner Temple Archives

These men supported Calvert as Temple choirmaster. Cooper and Bishop Copleston (Dean of St Paul’s) provided testimonials. Goss and Turle played for two public rehearsals before the launch. Hawkins and Hobbs became Calvert’s core singers and worked overtime helping him train the choir and find the music. None needed another job. Hobbs had declined a richer offer, “in preference for the Temple Church, for several reasons”.

Why? I think they wanted the Temple to set a national example of a well-paid choir singing the masterpieces of English musical heritage. Perhaps they hoped that the inexperienced Calvert’s charm, energy and antiquarian zeal would suffice until they could teach him how to run a choir.

The cathedral stars could not leave their lifetime appointments to lead the Temple choir. They also could not improve the infamously poor quality of Britain’s cathedral and collegiate choirs, then unable to afford enough good singers, their choral endowments having been long diverted elsewhere. The Temple, a collegiate church run by barristers, not clergy, and with no choir or endowment, could start afresh.

Barrister William Burge shared their goals. He led the two societies to start a choir that he later wrote “could become an example for other choirs, of infinitely greater influence… on the general character of Church music than… any other choral establishment.”

Calvert risked everything to get the job. He needed a permanent double choir for the characteristic antiphonal effect of Baroque cathedral music. In July 1842, he agreed to prepare a temporary single choir for the November reopening. The Church Committee had no hiring authority, so if the societies said no when they returned in autumn, Calvert was out, unpaid.

Days before the reopening, the societies said yes to one Sunday; days after, to eight more. He thrilled them with a double choir at Christmas, and in February 1843, they made him Master of a permanent double choir, for £450 per year, plus organist and music, far more than their previous budget of £120. Calvert took only £32 as choirmaster, half the going rate; but ultimately persuaded the societies to spend over £340 on a choir room and oak choir stalls, 25 guineas on a rehearsal piano, and £198 on music.

Calvert risked everything to get the job. He needed a permanent double choir for the characteristic antiphonal effect of Baroque cathedral music.

THE CHOIR

Calvert sang bass with his star soloists, but until the societies made the double choir permanent, he struggled to attract enough singers – most wanted stable jobs. So, he had his brother William sing five services. While training his new choristers, Calvert programmed simpler choruses. A year later, Master Lloyd dazzled in treble showpieces – and stayed with the choir for decades. Enoch Hawkins had never known boys so admirably prepared.

THE MUSIC WAS THE POINT

In a beautiful Choir Book, Calvert documented a mountain of music by 40 English composers performed in 112 services. Most was Baroque: 60 of 65 anthems, 11 of 16 services, and 13 of 23 chants. His listeners heard touchstones of English musical heritage, including Tallis’s chant in F, services by William Boyce, and glorious anthems by Purcell, Maurice Greene and William Croft.

Reviving the gorgeous old music was risky, often criticised as a popish distraction from worship. Indeed, Temple Church Master Christopher Benson briefly stopped Calvert’s choral chanting until hundreds of barristers petitioned for its return, and the societies backed Calvert.

Calvert’s choir won immediate national coverage in over 50 newspapers. Press often named the music, said it was “very beautifully performed”, and that the double choir enhanced “the fine effect of the exquisitely harmonious chanting”. Congregations flocked in, over 20,000 in nine months. Royalty came and socialised with the Benchers – gratifyingly mentioned by the press – after Prince Albert dropped in to a rehearsal.

Calvert meant the Temple choir “to further the use and love of Cathedral Music in this country”. Writing while running the choir, he published two choir manuals in 1844. His Psalter explained the intricacies of choral chanting. His Collection of Anthems listed 900 works. Burge promised to have it published. Instead, he read Calvert’s draft, then published his own choir book first.

Discussion about Calvert © Inner Temple Archives

John Calvert

TROUBLES

Calvert waded through choir politics, including months of bitter drama, to replace George Warne, the existing organist, with Edward Hopkins, who started on 25 May 1843. The societies were enthusiastic but new to choir management, so Calvert constantly had to explain the professional realities. The Benchers suggested singers; Calvert found they were unavailable, better paid elsewhere, or sang in “low taverns”! Burge managed Calvert, directing all music purchases and micromanaging rehearsals.

In May 1843, the societies fired the excellent, reliable tenor John Hobbs for a legitimate absence. Without Hobbs’ guidance, the inexperienced Calvert made mistakes.

In July, the societies pressed to hear music they did not own, so Calvert proposed a purchase list to Burge. In August, Burge gave verbal orders to spend £130 on music, nearly twice what had already been spent, promising reimbursement in November. Burge, knowing he had no such authority, left no paper trail.

To get the music in time for the new season, Calvert ran through his own cash, borrowed money, delayed some payments and quietly marked up a few prices. He submitted his bill in late October.

Startled, the Inner Temple Treasurer asked who had authorised it. Burge brazenly blamed Calvert. Without written orders, the Committee offered only partial reimbursement. Calvert furiously replied that he was too honest to lie and asked to prove Burge’s verbal orders.

An Inner Temple Bench examination of witnesses including Hopkins and Hawkins concluded that Calvert believed he had been properly authorised and directed the Committee to reimburse his actual costs.

Racing about to find “one volume here and another there” had left chaotic accounts. After exhaustive assessment, the societies paid Calvert £128 for music. He was saved! He wrote an incandescent (though unsuccessful) plea to reinstate Hobbs.

Fatally, he then embarrassed the societies. In January 1844, they discovered that he had told some singers and shops that he could not pay them because the societies had not paid his own salary. True enough, but only because he had not submitted the required salary receipts. It was over. The societies, scrupulously fair, paid £112 for early termination and allowed him to resign.

Tellingly, Calvert never blamed the societies, but only “the deceit and falsehood of Mr Burge whose conduct to me… has been one system of underhanded deception… So rests this piece of treachery til God who knows all hearts shall judge between us”.

Resolute, he sang every service until his last, on 11 February 1844. His final anthem was Boyce’s By the waters of Babylon I sat down and wept

HISTORICAL LEGACY

Four days later, the Morning Chronicle wrote, “The choir of the Temple church… is greatly superior to that of any other church in London, excepting the cathedrals…”. He handed his successor, Edward Hopkins, a permanent, well-trained choir with a big repertoire (that Hopkins used in 1844 and beyond), a music library, a choir room, permanent choir stalls, and –an unexpected legacy – crisper oversight by the societies. Hawkins, Hobbs and Cooper were gone, but with their help, Calvert’s Temple choir had restored a vast swathe of ancient music that endured in the nation’s devotional life. For example, in May 1857, 17 cathedrals performed 22 works from Calvert’s Temple repertoire. He had launched the musical vision of The Inner and Middle Temple.

The Temple job reshaped Calvert’s life but not his values. His devotion to music as the “glorious harmony of the starry world above” undimmed, in 1844 he started a choir for St James’s Cathedral, in Jamaica.

Kristina Guiguet Independent Researcher

In Celebration of South Asian Heritage Month: ‘Roots to Routes’

IN CELEBRATION OF SOUTH ASIAN HERITAGE MONTH: ‘ROOTS TO ROUTES’

On Wednesday 4 June 2025, the Treasurer hosted a dinner in celebration of the upcoming South Asian Heritage Month. In her after-dinner speech, guest speaker Master Anupama Thompson described her own ‘roots to routes’.

Master Treasurer, ladies and gentlemen, it is a great pleasure to be here with you all this evening. As I look around the room and see the wonderful hues reflected in the variety of outfits from across cultures, I am reminded of an observation made by Master Robin Griffith-Jones, Master of the Temple, who married my husband and me 25 years ago. As he looked at the congregation gathered in Temple Church on our wedding day, he remarked on the joyful sight of kilts down one side of the aisle and saris down the other. I have always thought that observation so wonderfully captured the meeting of our cultures and experiences when Lyall and I married. In a similar way, the wonderful array of colours and national costumes in this room epitomises the rich tapestry of our profession that we are here to celebrate this evening. As you have heard, I was born in India and brought up in Glasgow. My parents, before they retired, were doctors. Most of their friends were doctors, and most of their friends’ children went on to become doctors. So when I was a child I was asked the question, the unimaginative and tedious question which we all feel compelled to ask young children, “what do you want to be when you grow up, a doctor like your mummy and daddy?” I thought I was being imaginative, rebellious and nonconformist when I replied, “I want to be a barrister”.

What I didn’t really acknowledge, was the fact that on my mother’s side of the family ran a long line of advocates in our home state Kerala. My grandfather was an advocate as was my great uncle, my uncle and his son, who continues to practise as a criminal advocate in the High Court in Kerala. It turns out it was my mother who had been the rebellious one by becoming a doctor. My late uncle, under the auspices of the Bar Council of India visited the UK and the Inns of Court many times in the 1970s and 80s. He was thrilled to come here, to The Inner Temple for our wedding. When I showed him round my chambers and he saw the clerks’ room and the shelves lined with folded briefs tied up neatly with white and pink ribbons, he was overjoyed to see the familiarity of the setup, so similar to that of his own chambers in Kerala.

In the same way that I thought my interest in the Bar was new, there is perhaps a misconception that members of the Bar who hail from South Asia are a new phenomenon. In fact, as many of you will know, the first Indian to be called to the Bar was Ganendra Mohan Tagore who was called to the Bar by Lincoln’s Inn in June 1862. The first Indian to be called to the Bar by The Inner Temple was Aviet Agabeg from Calcutta, who was called to the Bar in 1868.

The number of Asian students continued to rise in the 1870s and 1880s and of course famously included Mohandas Gandhi, who was admitted to The Inner Temple in 1888. Inner is rich with information about Gandhi’s time here. One of the snippets I particularly enjoy is that he apparently went for violin lessons and tried to learn to speak without an Indian accent. I often wonder if this is why my mother sent me for elocution lessons – she was convinced I would never make it at the Bar unless I could talk ‘proper’ and if it was good enough for Gandhi – gee, it was certainly good enough for me!

Of course, I acknowledge that the vast majority of those who came to the Bar from South Asia in the 19th century went back to their home countries to practise law. It was not until later in the 20th century we see the larger numbers of those of South Asian heritage being called and practising at the Bar of England and Wales. I have witnessed myself, in my 30 years at the Bar, the welcome change of the complexion of the Bar in every sense of the word.

I often find myself being asked by students and aspiring lawyers, if my career has suffered because I am Asian? I find this a difficult question. Partly because it would never have occurred to me to ask it when I was a student, and partly because I am aware that some of my peers would answer it very differently from the way that I do. It’s important that we acknowledge that everybody’s experience is different and just because we have a shared heritage does not mean that our experiences are the same. In fact, when I was thinking about what I might say this evening, I did a little bit of research into the purpose of South Asian Heritage Month. As many of you will know, it was set up in 2020 to commemorate, mark and celebrate South Asian cultures, histories, and communities.

This year’s theme is ‘Roots to Routes’ which identifies that each of us carries a unique story shaped by our roots and the routes travelled to get to where we are. So, when I am asked that question, the answer I give, which I give honestly based on my route and my experience, is that I didn’t really ever think about it. Perhaps I’m naïve, perhaps I didn’t get that pupillage or that tenancy or that brief or that appointment because I’m Asian. But every negative outcome that I may have experienced is outnumbered by far by the multitude of positive experiences I have had throughout my career. I have been lucky enough, over the last 30 years to have met people senior to me in the profession who have taught me, commiserated with me, encouraged and championed me. And that is my overwhelming experience of this wonderful profession of ours.

Master Elizabeth Butler-Sloss and Master Anupama Thompson

I was asked a few years ago to take part in a podcast where three non-white female judges were asked to recount their journeys to the bench. I was struck, firstly, by the differences in our experiences and outlooks but also by what one of the barristers who was chairing the panel mentioned – that we all come to the profession with our own insecurities whatever our cultural background. Sometimes the fact that you are from a different cultural heritage might be the thing that troubles you most, but we shouldn’t assume that to be the case. For me, I was much more concerned about the fact that I thought I wasn’t clever enough, I wasn’t posh enough and of course I was, am, a girl. Here, I digress to say how delighted I am to see Master Butler-Sloss here this evening. I don’t mean to embarrass her, but I remember sitting at her table as a student at a mixed dining night and being in awe of her achievement as the first female Court of Appeal Judge. What an inspiration she was to me and to so many! So, being a woman at the Bar was one of the insecurities with which I have struggled over the years. It is why in all honesty when I am asked, as I often am, to speak about my heritage and my experience at the Bar, I feel deeply uncomfortable because it is not something I ever gave a great deal of thought to as I progressed through my career.

I often hear the expression at career fairs and outreach events, “if you don’t see it, you can’t be it”. I’ll confess it’s a concept that never crossed my mind when I was starting out, although, as I’ll come back to in a moment, I’m beginning to understand it a bit better now.

When I started primary school in Glasgow back in the 1970s, I was the first non-white pupil to join the school. I was very unhappy the first few weeks of term. None of the other girls in my class would play with me. My teacher, noticing that I was alone at playtime, got one of the older girls to try to find out what was going on. It transpired that my classmates were all scared of me – they thought that because my skin was brown and I wore my hair in two long plaits, I must be a native Indian and so they were at risk of being shot by me with a bow and arrow. The misunderstanding was quickly corrected, and I went on to make many friends and have a wonderful time at school.

I recount that experience, partly because it still always makes me chuckle, but also to explain that throughout my early life I was used to being the only Asian person in the room. So, when I went on to study law and start my Bar training, I was largely oblivious to the ethnic make up of those who were around me. The closest I came to it was perhaps when I was dining here at the Inn.

The Inn in 1993 was as friendly and welcoming as it is today. As you will be aware, back in the day, to be called to the Bar an aspiring barrister had to eat 24 dinners at the Inn alongside his or her studies. My friends and I would normally try to book our dining together so that we had familiar faces around us when we dined. Of course, with 24 to do, that was not always possible so I on occasion found myself coming to dine on my own. I was astonished at how quickly I made friends, how quickly my fellow students wanted to come and sit beside me. I then discovered it was not my magnetic personality or sparkling conversation that was attracting them. At that time, wine for dinner was placed on the table to be shared by groups of four diners. When that wine was finished, there would be no more. So, if you wanted to ensure that you didn’t run out of wine, the best thing to do was to sit beside somebody who didn’t drink. Hence my new-found popularity! Alas, unbeknown to my new friends, despite my teetotal parents and my Hindu upbringing, I could polish off a bottle of wine as well as the next man! As we say in the criminal courts, “beware members of the jury of the dangers of assumptions!”

As I progressed through pupillage and my early years in practice, I was surrounded by colleagues from every background imaginable, originating from across the world, from every corner of the UK and from every social background. In any given situation, I went from being the only, or maybe one of the few people of South Asian heritage, to being simply one of the many who contribute to the legal life of our country. It is only over the last few years that I have noticed, as I have supposedly become a more senior member of the profession, that I am once again finding that I am the only, or maybe one of the few people from South Asian heritage in the room. I am not going to dwell on the numbers entering the profession versus the numbers reaching the higher echelons of it – but is well documented elsewhere. I want to concentrate on what we, those of us in this room, can do about it.

I said a few moments ago that I never connected with the notion “if you don’t see it, you can’t be it” but amongst the many young people I meet, it is clear that that is something which really resonates with them.

I was recently appointed Co-Director of the Judicial College’s Crown Court induction course, which is the course that all newly appointed criminal recorders and judges are required to undertake. My fellow director on the course is His Honour Judge Avik Mukherjee, a circuit judge also of South Asian heritage from Birmingham. When we were at the last course in March of this year, one of the delegates, a woman of Pakistani heritage, came up to speak to us both. She told us how anxious she had been before she came to the course, how worried she had been that she would be the only non-white delegate there and how much the fact that we were both going to be running the course gave her a sense of belonging, confidence in her ability and aspiration for the future. We were both incredibly moved and humbled by what she said to us.

That experience really crystallised for me why talking about my heritage and my experiences is not something I find easy. It is so important that we put ourselves out there because sometimes just the very fact of our achievement can be enough to spur someone else on.

A few months ago, I was asked to take part in another outreach event involving students of South Asian heritage. I was discussing my reservations about taking part with my Resident Judge, who is a white man in his 60s. His very to the point analysis of the situation was – “Anu, you have a responsibility to go – you’re going to reach people I could never reach, just by being there.”

I used to watch my uncle go to court in India when we visited every summer and I know he felt that that baton had been passed on when he watched me go to court when he came to visit for our wedding. He would have been thrilled to be in this room this evening to see all of you here carrying that baton ready for the next generation.

Those of us who originate from South Asia, those who are in this room, those fighting cases up and down the land, those administering justice, those helping to maintain the rule of law, we are the daily example of the contribution we have made and continue to make to the legal profession. The very fact that we are there doing that is what will inspire those who come behind us. We are the very embodiment of diversity and inclusion at the Bar.

Her Honour Judge Anupama Thompson Harrow Crown Court

CELEBRATE THE LIFE: MASTER ANTHONY MAY

Master Anthony May © Garlinda Birkbeck

Careful, conscientious construction law expert who became President of the Queen’s Bench Division.

In the aftermath of the leaking by a CIA employee of classified documents about UK and US surveillance programmes, it fell to Sir Anthony May to review the state of the country’s spy agencies. As commissioner for the interception of communications, he gave them a clean bill of health, concluding that they did not engage in random mass intrusion into the affairs of law-abiding citizens. Any member of the public “who does not associate with potential terrorists or serious criminals” could be assured, he said, that the interception agencies did not have “the slightest interest in examining their emails, their phone or postal communications or their use of the internet”.

The Prime Minister, David Cameron, welcomed the report while civil liberties campaigners said May had failed to grapple with the leaks about surveillance programmes in use. Yet May, a retired senior Court of Appeal judge, could not simply be dismissed as pro-establishment; in the same report in 2014 he expressed concern over the “very large number (514,608) of requests for information by police and other law enforcement agencies about phone calls and other communications. It has the feel for being too many,” he said, and ordered a review that led to a tighter regime.

It typified the careful and conscientious approach May displayed throughout his career to the top ranks of the judiciary, where he became president of the Queen’s Bench Division. Quiet, reserved and conservative, May had the demeanour of the archetypal aloof judge. But Lord Neuberger of Abbotsbury, the former President of the UK Supreme Court, said: “Underneath his slightly detached, austere manner, he was an extremely kind man, decent, principled, intelligent. He did a good job on every case but didn’t search for headlines.”

Another Court of Appeal judge, Sir Peter Coulson, added: “He was an excellent judge and, in some ways, a little shy, which is why some thought he was a bit austere, but he had a great bark of a laugh which I used to hear a lot.” Coulson recalls a long case when the pair were barristers, Coulson junior to May. “I would relieve the tedium with drawings on Post-it notes. He always marked them out of ten in the bottom right-hand corner. I never got more than seven, so he obviously knew something about art.”

When a judge, May was due to hear the claim by Diana, Princess of Wales, against a gym where photographs were taken of her exercising and published in Paris Match, the first time a royal had sued in her own name. The day before the trial, Coulson bumped into May looking crestfallen. The case had settled at the last minute. “Do you think I could sue for loss of opportunity?” he asked.

Anthony Tristram Kenneth May was born in 1940 in Barnstaple, the only child of Joan (née Oldaker) and Kenneth May. Both were doctors: his mother had been evacuated to Devon while his father stayed working in London. They moved to Herefordshire where Joan was in charge of an evacuee home and from 1944 lived in Edgbaston. May went to Bradfield College and read Greats at Worcester College, Oxford, where he became a fellow.

He began working life in the insurance industry but after six months decided law might suit him better. Impressively able to teach himself new skills, May studied for the Bar exams while teaching classics at Oundle School. He met his wife, Stella (née Pattisson), through friends there over bridge and they married in 1968, soon moving out of London to Surrey. His wife and three children, Charmian, a solicitor, Lavinia, a GP, and Richard, a geologist, and nine grandchildren survive him.

In 1967, May was called to the Bar (Inner Temple, where he was a scholar) and joined a small set at 11 King’s Bench Walk, later Keating Chambers. It had a burgeoning construction practice under Donald Keating QC, a pioneer in that field, which May helped to develop along with the future judges Patrick Garland and John Dyson. There May undertook the editing of the fifth and sixth editions of what became the leading textbook, Keating on Construction Contracts, and he became expert in mastering the detail of massive multiparty construction and professional negligence cases and delivering oral judgments off the cuff.

May was in the vanguard on technology. He taught himself computer coding and was probably the first judge to use a computer in court. Glenys McDonald, his clerk, recalls that when they were first on Circuit, May would make notes in the usual red book and transcribe them in the evenings to his laptop. Back in London he sought permission from the Lord Chief Justice, Lord Lane, to use his laptop in court. Lane invited him to sit on the bench and demonstrate its use while he and Lord Justice Tasker Watkins stood in the well of the court to observe. Permission was granted. In an appeal in the McDonald’s libel trial, May duly sat with his laptop, alongside Lord Justice Pill using a nib pen with glass inkwell, and Mr Justice Keene a Biro. Sadly, his daughter Charmian recalls, his interest in technology did not extend to television. The family was without one until the day before England regained the Ashes in 1985.

May was in the vanguard on technology. He taught himself computer coding and was probably the first judge to use a computer in court.

May took silk in 1979, becoming a recorder in 1985. He went to the High Court bench in 1991 and to the Court of Appeal in 1997. He was Deputy Head of Civil Justice from 2000 to 2003; Vice President of the Queen’s Bench Division from 2002 to 2008 and President from 2008, retiring in 2011. He was popular with the ‘troops’ and gently encouraged them.

He became a Bencher at The Inner Temple in 1991, aged just 50, and was Treasurer in 2008, the year the Temple celebrated the 400th anniversary of the grant of its Royal Charter from James I. More than 22,000 people attended an Open Day. May addressed the congregation at a service in the Temple Church in the presence of Queen Elizabeth II, without a note. He and Michael Blair KC, Treasurer at Middle Temple, raised sufficient funds for a new stained-glass anniversary window and for the repair of the organ. The fabric of the church, said Robin Griffith-Jones, Master, will “forever bear the imprint of Anthony’s tireless work from 2008 to 2013”.

Among many cases, he ruled that soldiers abroad were protected by UK human rights obligations and, when Interceptions Commissioner, that police should not access journalists’ phone records without judicial authorisation. He worked with his fellow judge Sir Rupert Jackson on civil procedure, backing reforms to the Technology and Construction Court as well as Jackson’s later reforms to cut the costs of civil litigation.

An aptitude for hard work and organisation gave time for passions such as DIY. Projects ranged from building a treehouse to laying paving. He turned the wilderness at the family home into a substantial fruit and vegetable garden. Music was central to his life; he and his wife were members of the Guildford Choral Society for decades, with May chairman for ten. He loved walking and walked through most of Italy to Rome.

May retired in 2011 and in 2013 was appointed the Interceptions Commissioner. A year later he sustained near-fatal injuries when hit by a motorbike as he crossed the road in central London. Months of extensive treatment followed but he never fully recovered and retired from public life in 2015. The accident tragically cut short May’s career, but did not eclipse a life so richly lived, from singing and gardening to delivering justice at the highest levels.

Sir Anthony May, Court of Appeal judge and President of the Queen’s Bench Division, was born on 9 September 1940. He died on 30 December 2024, aged 84.

Courtesy of The Times / News Licensing

Master Anthony May with Queen Elizabeth II in 2008

© Chris Christodoulou

TIMELINE

By the Archivist

500 Years Ago 1526

In November 1526, the first reference to the Deputy Treasurer named Master Chydley appears in the Inn’s records.

“Peter Faunt le Roy pardoned all penances for 26s. 8d., whereof he paid to Master Chydley.”

Parliament 16 November, 18 Henry VIII A.D. 1526

Since its inception, the Inn has had a Treasurer annually elected from amongst the Benchers. Their duties were to admit to the Society such as they thought fit, assign chambers to members of the Inn, collect pensions or dues and to receive the fines on admissions to chambers; to pay all wages and appoint all subordinate officials and to render an annual account of their office, which was audited by members of the Inn, and to maintain the Inn.

The Treasurer’s tasks became more extensive as the Inn’s membership grew, making it necessary to employ the assistance of another member of the Inn in the role of an unofficial Deputy Treasurer, who was chiefly responsible for the collection of debts.

In 1682, this was made a permanent position with the appointment of Anthony Belbin as Sub-Treasurer, who undertook many of the tasks previously performed by the Treasurer.

400 Years Ago 1625–6

Account of Thomas Coventry, Treasurer from 3 November 1624 to the Feast of Hilary 1625–6, being one year and a quarter.

The account of the Treasurer provides considerable insight of the goings on at the Inn. It is notable that the largest payments were for the Inn’s wine.

Payments by the Chief Butler:

· For a play on Candlemas Day 1624, 7li.

For the musicians that day, 1 li.

To watchmen for watching the House at Christmas vacation, 1li. 17s. 6d.

Given to the gentlemen revellers three times in Michaelmas and Hilary terms, 3li.

· For torches for the revels, 15s.

· For leather laces for the church Bible, 2d.

For faggots for a bonfire when the Queen landed, 5s.

Given to my Lord Chief Baron and Baron Trevor when they were made Serjeants, 10li.

For two purses to put the money in, 2s.

For a warrant to apprehend Ramsey’s sons for suspicion of breaking open Serjeant Owen’s Chamber, 6s. 4d.

· To the Master of the Temple for his stipend, due to him at Lady Day, 1625 from this House, 4li. 6s. 8d.

To the vintner for the wine, 31li. 8s.

For sack and muscadine, 13s. 6d.

For laying in wine this year, 12s. 10d.

The Manciple in the Ellesmere manuscript of Geoffrey Chaucer’s Canterbury Tales

A family of many generations gathers around a table to hear a will read

Collection

300 Years Ago 1725–6 The Temple Foundlings

The Inns of Court were forced into the role of social welfare for abandoned infants, with large numbers of children abandoned on their doorsteps. This practice had become a regular feature by 1661. In the course of a year, usually three to four children would be ‘dropt’.

At the time, legal responsibility for the poor and destitute fell upon the parish. An illegitimate child was settled in the place it was born. The Inns were extra parochial and so were not part of any parish and were not liable to pay the poor law rate levied by any of the surrounding parishes, resulting in them been left literally holding the baby.

Middle Temple has a book listing these children, entitled Exposed Children, with details of their short lives and the payments required to keep them. The Inner Temple accounts contain numerous references to these children whom it arranged to be baptised and wet nursed by local women and occasionally by servants of the Inn.

The few children who survived the multiple childhood illnesses prevalent at the time were apprenticed to local tradesmen, such as shoemakers or embroiderers. All the children were given the surname ‘Temple’.

In 1725, a girl baby was abandoned in Fig Tree Court (now part of the Eastern end of Elm Court) the ownership of the precise piece of land on which she was found was put on the agenda for a meeting with the Middle Temple. The responsibility was given to the Middle Temple, although sadly she died three weeks later.

The last recorded abandonment was in 1845.

200 Years Ago 1826

Dinner in the old Hall mezzotint by Finlay, 1826.

This mezzotint shows the Inn’s medieval Hall before it was replaced in the late 1860s. It is thought to be built on the site of the old Knights Templar Hall, perhaps incorporating much of the old building within it.

It has been described as homely rather than magnificent, with buttressed walls, gothic windows and a louvre on the roof to take smoke from the central hearth, which served as the only fireplace. In 1632, the Hall was described as “ruinous and decayed”. Until its replacement in 1867–70 this was the oldest of the secular buildings in the Inns of Court.

The image also shows the large furnace used to heat the drafty building, in place of the former fireplace. The members are shown in gowns, dining in their messes (a group of four barristers).

A description of dining in Hall is provided by an Irish student in 1860, just before its destruction:

“Each mess has its dinner served to it separately – the meat on large pewter plates – and enjoys its own bottle of wine. Every mess has its ‘captain,’ an officer whose privilege it is to help himself first to everything and whose duty it is to preserve order amongst the members of his own mess. The meat is not carved by any one individual for the others, as it is at our more modern and more civilized King’s Inns in Dublin, but everyone helps himself.”

Dinner in the old hall mezzotint by Finlay, 1826 © Inner Temple Archives

100 Years Ago 1926

The Sex Disqualification (Removal) Act 2019 opened the legal professions to women and allowed them to become barristers. One such woman was Ma Pwa Hmee, the first Burmese woman barrister.

Ma Pwa Hmee was admitted to this Inn on 25th January 1924.

As a strong supporter of women’s rights, she initially decided to become a lawyer in order to benefit the women of Burma, believing that:

“Many Burmese girls were well educated but were too timid to take up public work and needed encouragement.”

One of her letters of testimonial for entry to this Inn was written by the former Lieutenant Governor of Burma, Harvey Adamson, who stated that:

“Her family is well known and respected in Burma. Her father holds a position of trust in Rangoon Municipality. Ma Pwa Hmee has come to England to study for the Bar, an enterprise which I believe no other Burmese lady has hitherto undertaken. From what I see and hear I am confident she is worthy of encouragement”.

As a strong supporter of women’s rights, she initially decided to become a lawyer in order to benefit the women of Burma, believing that: “Many Burmese girls were well educated but were too timid to take up public work and needed encouragement.”

Ma Pwa Hmee was called to the Bar on 17th November 1926. As only one of two women to be called to the Bar, she attracted the attention of the press and was interviewed, providing us with a description on London and Londoners through the eyes of a Burmese student in London:

“Never in my life had I seen people in such a hurry as those tearing down the streets of London. I thought that their haste must be due to some special attraction in the next street. In one of the busy streets of the West End I remember waiting five or ten minutes to cross the road and expecting the traffic to wait for me. Another of my difficulties was in understanding the language of the bus conductor who several times told me to ‘Ole tight’.”

She also mentioned the dress of the British girl:

“They have none of the daintiness of our national costume, but of course our dress would be ridiculous here, for we wear skirts down to our ankles and we could not possibly run to catch the buses and trains as British girls do.” She admired “the bearing of the British people, their erect bodies and even strides which show they have loved for generations long walks in the open air.”

On 10th December, she boarded the boat back home and in 1927, she became the first woman to be called to the Bar in Rangoon.

Celia Pilkington Archivist

Ma Pwa Hmee

EDUCATION & TRAINING

A YEAR IN EDUCATION

By Master Simon Heptonstall

The overriding theme for the last year in Education and Training (E&T) has been success. There have been tremendous achievements across the whole range of educational activities and at all levels.

Our activities have not been limited to those students joining and setting out in the profession. In November 2024, the Inn hosted an expert symposium on appellate advocacy, with a stellar array of speakers giving practical insights for established practitioners. This has been built on with a series of webinars. The theme for May 2025 was Movers and Returners, to empower retention and progression through the range of opportunities available at the Bar. Both were very well received. In July 2025, we returned to the theme of Open Source Evidence, which generated great interest in 2023. This will be complemented by a series of events in the autumn exploring how artificial intelligence is developing and how it will affect practice at the Bar.

For those at the start of their career, we have had strong feedback from the Bar Standards Board (BSB) on our evaluations of the admissions process and the delivery of Qualifying Sessions. Notable positive comments covered our work on reasonable adjustments and supporting wellbeing. These are the product of preparing transparent policies so that students know how the Inn will support them.

The extracurricular and social activities remain an important aspect of the vocational stage. We are proud to have a thriving group of student societies, each with a busy programme of activities and achieving in their fields. 2025 marked particular success for the Mooting Society, where the team qualified for the finals of the Jessup International Law Moot in Washington, together with other domestic and international achievements. The Debating Society has contributed contestants and judges for events throughout the UK and Europe. New regulatory requirements for the Pupils’ Advocacy Course were introduced by the BSB in September 2024. As a result, the Inn’s programme has been approved, recognising the high quality created and run by a dedicated group of practitioners.

Student and pupil ambassador roles, which had already been embedded in the E&T Committee, have been incorporated into the design and delivery of the range of educational programmes. Their perspective has informed and enhanced the experience for the cohorts that shall follow.

The Inner Temple Education & Training Strategy Cover

In order to ensure the continued success of the variety of educational programmes, after a working group in 2024, a new strategy for the next five years was developed and introduced. This strategy encapsulates the vision:

“ We aspire to attract diverse talent to the Bar and provide excellent education and support through all stages of our members’ careers, being inclusive to all. We embrace innovation whilst respecting the history and heritage of the Inn, shaping a legal community where all thrive.”

Six priorities were set out: aspiring to excellence, supporting the members, valuing our volunteers, being innovative, being inclusive and collaborating with others. Those are aligned to each of the E&T programmes. To deliver that vision, specific projects have been allocated for more intense activity at different stages during the five years to ensure that we continue to deliver our core programmes. The first tranche of projects includes an independent evaluation of the scholarship process that supports so many promising candidates, an evaluation of the highly successful Pegasus Access and Support Scheme, and a review of the scope and operation of the mentoring scheme – all of which impact those at the early stages. Supporting the range of activities will be the introduction of a volunteering strategy, backed by research sent to members before the vacation, designed to draw on the talent and provide opportunities for members across the spectrum of practice and experience.

The development of that strategy and the expansion of offerings for established practitioners have been shining achievements of Master Juliet May’s leadership of the E&T Committee in recent years, prior to her election as Reader. We are grateful for the vision and focus that Master Juliet May has brought to the E&T Committee and we look forward to delivering on these initiatives over the next year. I hope that all willing members of the Inn can join us and benefit from the thriving range of activities.

His Honour Judge Simon Heptonstall Circuit Judge Chair, Education and Training Committee

OUTREACH outreach@innertemple.org.uk 020 7797 8240

OUTREACH PREPUPILLAGE SCHOLARSHIPS

SCHOLARSHIPS scholarships@innertemple.org.uk 020 7797 8211

PEGASUS SCHOLARSHIP TRUST pegasus@innertemple.org.uk 020 7797 8210

PROFESSIONAL TRAINING

PUPILS AND NEW PRACTITIONERS pupils-practitioners @innertemple.org.uk 020 7438 2310

ESTABLISHED BARRISTERS establishedbarristers @innertemple.org.uk 020 7797 8209

PRE-PUPILLAGE

pre-pupillage@innertemple.org.uk 020 7438 2311

CALL TO THE BAR call@innertemple.org.uk 020 7797 8257

QUALIFYING SESSIONS

qs@innertemple.org.uk 020 7438 2311

GENERAL AND VOLUNTEERING

EDUCATION education@innertemple.org.uk 020 7797 8208

THE INNER TEMPLE ADVOCACY PRIZES

A Snapshot of the Year

The Inn runs multiple Advocacy Prizes per year, celebrating mooting and advocacy amongst the student and pupil cohorts, and working to prepare our members for a life at the Bar. We are exceptionally grateful to all the member volunteers who are integral to the success of these prizes, and we send our congratulations to all this year’s winners!

THE INNER TEMPLE’S ADVOCACY PRIZE FOR PUPILS – NICHOLAS JARMAN QC PRIZE

Each year, the Inn runs an Advocacy Prize for Pupils. Pupils are shortlisted based on their performance at the Pupils’ Advocacy Training Programme Residential Weekend.

The Pupils’ Advocacy Training Programme is a compulsory part of training, which pupils must complete before commencing their second six. The Inn runs two courses per year (Course A and B). Course A runs from October to November and Course B runs from January to February. At the residential weekend, pupils engage in a series of exercises designed to assess their ability to perform as an advocate using the Hampel Method.

To determine the winner of the £1000 cash prize (generously donated to the Inn by Mrs Julia Jarman, widow of Nicholas Jarman QC), shortlisted candidates participate in a mock trial final.

This year’s mock trial final took place at the Inn on Thursday 3 July 2025, featuring Ellie Mullet from 39 Essex Chambers (Prosecution) and Emily Jarron from 5 Paper Buildings (Defence).

The final was attended by the Master Treasurer, Mrs Julia Jarman, the deputy course directors for the pupils’ course, both of the candidates’ lead trainers from the residential weekend and members of the Inn’s Education and Training Department.

The competition was judged by Master James Dingemans, Master Anthony Leonard and Master Sarah Clake (Advocacy Training Committee, Chair).

After a series of performances, which included witness handling and a closing speech, the judging panel concluded that Emily Jarron (5 Paper Buildings) would be crowned winner of The Inner Temple’s Advocacy Prize for Pupils 2024/25.

The evening concluded with a drinks reception, and the winner was also formally announced at the Inn’s annual Advocacy Dinner for Trainers in July.

THE ALEXANDER CAMERON KC CRIMINAL MOCK TRIAL

The Alexander Cameron KC Criminal Mock Trial is a three-round knockout competition, named in honour of Alexander Cameron KC, one of the UK’s leading criminal silks, who passed away in 2023. Participants must be members of The Inner Temple who have been called in the past five years but have not yet obtained pupillage. The winner receives a large monetary prize, as well as one-to-one mentoring and a mini-pupillage. The runner-up also receives a monetary prize and a mini-pupillage. Round one of the competition took place online on Tuesday 14 January 2025. Round two took place online on Tuesday 21 January 2025. On 28 January, the final round took place at the Old Bailey. The final round was judged by Master Simon Heptonstall. Casey-Mae Kellett and Neel Rokad, the winner and runner-up, respectively, of the inaugural competition last year, played the key witness and defendant. After an intense final round, Bethany Birkett was announced as the winner of the 2025 Alexander Cameron KC Criminal Mock Trial competition, with Jesler van Houdt announced as the runner-up.

Three Raymond Buildings provided a cash prize to the two winners and the runner-up, totalling £1500, which was awarded by James Lewis KC. Special thanks were given to the sponsors of the competition – Three Raymond Buildings and 5KBW (notably Alejandra Llorente Tascon, who has played a crucial role in planning and organising the prize) – and the volunteer judges from the earlier rounds which took place online, including Master David Wood, Sarah Prager, Lavalina Sawmy, James Meredith, Helen Dawson, Lyall Thompson and Elizabeth Garcia.

(L–R) HHJ Anthony Leonard KC, Lord Justice Dingemans, Ellie Mullett, Emily Jarron, Mrs Julia Jarman and Sarah Clarke KC

(L–R) Ellie Mullett, Sarah Clarke KC, and Emily Jarron (Prize Winner) at the Advocacy Dinner for Trainers

NOTES ON PASS

2024/2025

The Pegasus Access and Support Scheme (PASS) is our flagship outreach programme. PASS is for aspiring barristers from underrepresented socioeconomic backgrounds and is designed to give them contact with the profession through a minipupillage, contact with barristers and judges, and spending time at the Inn, as well as the provision of skills workshops. This year, we asked our 2024/25 PASS scholars to provide some feedback about their time on the programme.

Dinner to the Universities

OUR TIME ON PASS

“The Honourable Society of The Inner Temple truly exemplifies inclusivity and welcomes people from all walks of life.”

“Extremely useful. Inspired a newfound confidence in me to pursue a career at the Bar and helped me understand that people who look like me, and who come from similar backgrounds, can be successful as an advocate.”

“The networking and practical skills that PASS has allowed me to strengthen have been invaluable – along with the fantastic, deep connections I’ve made along the way.”

“I think there’s a better than 50 per cent chance I wouldn’t have been offered pupillage without being involved in the PASS programme.”

We would like to thank the numerous barristers and judges who happily gave up their Saturdays and evenings to deliver skills workshops and panel discussions to encourage the next generation of aspiring barristers. Our thanks, too, go to our partner chambers who facilitate the scholars’ mini-pupillage placements. PASS would be nothing without you all.

“PASS has given me the confidence in my ability to pursue a career at the Bar. It has shown me and taught me things I otherwise wouldn’t have known, and given me the opportunity to develop further relationships with barristers/ judges and even other scholars, who have been able to further the advice and support. Thank you so much!”

“As a PASS scholar, I’ve gained invaluable insights, advocacy experience and friends for life, all of which have shaped my journey to the Bar. I hope PASS continues to be the foundation for many future barristers to come.”

“Incredibly valuable experience that offered me a chance I wouldn’t otherwise have been able to take to understand more about the profession.”

“Thank you for not just teaching me the skills to get to the Bar, but for making me believe someone like me can get there.”

The Treasurer speaking at the Dinner to the Universities

The Inn’s Annual Dinner to the Universities, a flagship event for undergraduate students aspiring to a career at the Bar

PERSUADING THE HIGHEST COURTS

By Master Craig Hassall, Master Anthony Leonard and Tom Lazur. Appellate Advocacy Training, 23 November 2024.

Any barrister who has appeared in an appellate court would acknowledge that appellate advocacy is fundamentally different to advocacy at first instance. The art of persuading the appellate court that something went sufficiently wrong at first instance to justify overturning the original result is quite different to how we argue before a judge or a jury in the court below. The procedural rules are necessarily different and so are the powers of the appellate courts to remedy what they decide went wrong.

Notwithstanding those fundamental differences, little specialist training has been available in this area. Because the Inns are only required to train barristers of up to four years’ Call, and with such little time available to do so, training has to be focused on key trial and application skills because that is what advocates need to be able to do at the start of their careers.

The Education and Training Department is now expanding the training they provide to encompass skills which established practitioners need to learn or have refreshed. As part of an expanded Established Practitioners’ Programme, on 23 November 2024, the Inn organised and hosted a one-day appellate advocacy training course. We were fortunate to be able to call on a wealth of talent from our members to assist with the training.

Master Sue Carr gave an introductory welcome speech, highlighting the need for a different approach to advocacy in appellate cases and what can go wrong when no such approach is taken. She emphasised the need to get straight to why the submission is important and correct. The work of the Court of Appeal is conducted under constant and immense pressure of time which leads the judges to ask themselves “What is the point? ”, closely followed by “Why is it a good point? ”. She explained that there is always the risk that a potentially good point is missed because it is hidden away in long-winded narrative about the facts of the original trial.

Master Anthony Hughes gave the keynote address in the form of a perspective from the Supreme Court. He provided fascinating insights into the internal workings of the highest of our domestic courts, reminding delegates of that which advocates before the Supreme Court might forget at their peril: Supreme Courts Justices might be inexperienced in a particular area of law, but they are not unintelligent.

Delegates were then given the option of a series of talks in the two broad practice areas covered by the civil and criminal divisions of the Court of Appeal. Each group received advice from a practitioner specialising in appellate work and from two judges of the Court of Appeal.

Farrhat Arshad KC, Master Craig Hassall, Master James Dingemans and Master William Davis

In relation to the Civil Division, Master Teertha Gupta entertained with lessons from his extensive appellate advocacy experience, highlighting the need to look at the issues from all possible angles so you can prepare yourself as best as possible for the inquisition to come. Master Nicholas Green and Master Andrew Popplewell lifted the veil on the way the Court of Appeal approaches its work, often considering points of appeal over many months before the hearing so that they have a clear agenda for the hearing itself. Both pleaded for brevity in written submissions and preferred advocates who are willing to engage with the Court’s agenda over those who stick rigidly to a script.

Meanwhile, Farrhat Arshad KC provided criminal practitioners with a seven-point plan of attack for bringing a criminal appeal, which included insider knowledge on maintaining a good working relationship with not only the Court itself but also with its Registrar and their Office. Further behind-the-scenes insights into the approach of the Criminal Division were provided by Master James Dingemans on written advocacy and the late Master Bill Davis who focused on oral advocacy. Together, they provided an invaluable account of how judges in the criminal division approach the task of deciding appeals, how a winning point can be identified and developed, and conversely how a potentially winning point can be hidden amongst the irrelevant and thereby lost.

The afternoon was devoted to appellate advocacy training exercises in civil or criminal appeals.

The criminal advocacy exercise, written by Master Anthony Leonard, was based on the recently promulgated Private Members’ Bill on joint participation together with the admissibility of bad character evidence as it related to a multi-handed murder trial.

The civil advocacy exercise, written by Tom Lazur, considered the application of an agreement to exclude consequential losses after an agent failed to supply concert tickets to a popular social media influencer.

Each exercise provided delegates with the opportunity to receive structured feedback on their appellate advocacy from the Inn’s accredited advocacy trainers in a mock appeal presided over by Master of the Bench, each of whom is a High Court Judge. Advocates from a few years’ call to those in silk took part.

The training day provided a rare opportunity for practitioners from all four Inns to receive guidance about the particular craft of appellate advocacy from those who hear submissions from the Bar on a daily basis. The day’s success highlights, again, the Inn’s position as a leading provider of advocacy training of the highest calibre. The day attracted excellent feedback from delegates, many asking for more of the same, resulting in the intention to repeat the appellate course regularly and to expand into other areas where there is a demand for advanced training.

Craig Hassall KC Park Square Barristers Advocacy Training Committee

His Honour Judge Anthony Leonard KC Senior Circuit Judge, Central Criminal Court Advocacy Training Committee

Tom Lazur Keating Chambers

Each exercise provided delegates with the opportunity to receive structured feedback on their appellate advocacy from the Inn’s accredited advocacy trainers in a mock appeal presided over by Master of the Bench, each of whom is a High Court Judge. Advocates from a few years’ call to those in silk took part.

Master William Davis, Master Craig Hassall and Master James Dingemans

THE INNER TEMPLE ON CIRCUIT

LEEDS

The Education & Training department has had a successful year on circuit! The Outreach and Pre-Pupillage teams have travelled across the country throughout the year to deliver panels, lectures, workshops and sustenance to students at all stages of their education. Below are a few facts, figures and comments about the events held. Plans are already underway to deliver a similar programme next year. We look forward to welcoming both students and volunteers on our travels again.

members of staff 42trains 352 86 students attending hours travelling

“As a Polish career-changer with caring responsibilities, having the chance to attend The Inner Temple Education Day in Leeds was genuinely invaluable. Being able to access such a high-quality event locally made it far more accessible and manageable. The day was both engaging and practical – from learning about inclusivity to hearing “10 Ways to Annoy a Judge.” It was also a chance to test my advocacy skills, advocate for myself, and speak with local judge, HHJ Clark, from whom I was able to request a marshalling opportunity. What once felt like an unreachable dream suddenly felt possible. Thank you.”

MANCHESTER

“ Thank you for this invaluable opportunity, it has only solidified my decision to study the bar after graduation!”

LIVERPOOL

BIRMINGHAM

“Overall the event was excellent. The CV workshop was particularly useful.”

CARDIFF

“Everyone at the event was great and receiving the information first hand really helped regarding how to become involved in a career at the Bar.”

LEEDS

“Jess is an absolute credit to Inner Temple. She is warm, approachable and meticulously organised. She did her best not to fill our heads with lots of jargon and kept things simple. I loved this approach. Sometimes people can throw acronyms around and it just gets confusing. The panel members were perfect. The location couldn’t be better and the drinks and food provided were splendid.”

450

NEWCASTLE

“I wanted to thank the team at Inner Temple for their efforts in bringing QS’s to students outside of London. It must take an enormous effort on their part to do it, so I just wanted to say thanks!”

MANCHESTER

“ Very well presented and informative allowing the engagement on a more personal level with members who have already reached the Bar.”

NOTTINGHAM

hours of volunteering from our practising members

600

400

117.5 sandwiches ordered* cups of tea and coffee* canapés eaten*

*Figures are an estimate, we didn’t actually count how many cups of tea and coffee they had!

THE INNER TEMPLE SCHOLARSHIPS

INNER TEMPLE 2025 BAR COURSE AWARDS

PETER TAYLOR SCHOLARSHIP

Megan Bradley.

STEPHEN CHAPMAN AWARD

Skye Black.

PRINCESS ROYAL (Five Awarded)

Bethany Hermaszewska, Colin Vanelli, Ewan Jenkins Wendon, Lucas Jones, Mali Pink.

MAJOR SCHOLARSHIPS (20 Awarded)

Anna Jimenez, Barnaby Potts, Bernd Wong, Dorothy Richardson, Felix Parsons, Georgina Withers-Boalch, Katie Harney, Lindsey Ponsonby, Lora Izvorova, Matthew Wesson, Max Linton, Naomi Jennings, Nicholas Harrison, Orla Heatley, Rebecca Ebner-Landy, Rhianna Dorrian, Sam Flannery, Teck Wei Tan, Vian Teresa Saggo, William Daci.

EXHIBITION SCHOLARSHIPS (92 Awarded)

Alba Kapoor, Albert Cammack, Alexander Baxter, Alexander Hetterley, Alexander Mannix, Alice Taylor, Amber MacOscar, Amelia Bradley, Amelia-Jo Sharp-Saxby, Amelie Adams, Amrit Dawood, Anna Selian, Anton Konshin, Ayesha Bhatti, Barnaby Burrowes, Bethany Tipping, Catherine James, Chloe Brough, Christopher Clocchiatti, Daniel Kerr-Dando, Daniel Martin, Daria Koukoleva, Douglas Izzard, Dylan Panesar, Edward Lamb, Eleanor May, Elia Mennecillo, Elise Oh, Emilia Robinson, Emma-Jane Harris, Eniola Atere, Eve von der Heyde, Frankie Shepley, Freya Walker, Hannah Amiri, Hannah Phillips, Hannah Pryor, Harry Lederman, Harry Pell, Harvey Bowen, Henry Clement-Jones, Imogen Halcrow, Isaac Mittoo, Jamuna Bothe, Jawad Razzaq Khan, Jaymie Burns, Jemma JenkinsFerrett, John Clough, Jordan Rees, Joseph Stone, Justin Kong, Kate Grimsdale, Katie Bourner, Katie Wright, Kiera Bayne, Lara Canivari, Leila Kerley, Louie Wells, Luke Geary, Maahum Nazir, Madeleine West-Nelson, Madura Lokesh, Marwa Mohammed, Megan Walsh Killen, Mia Hodge, Mollie Breen, Monique Fremder, Myles Scotland, Myria Antony, Nathan Trotter, Nehal Rughoonauth, Niranjana Ramkumar, Oscar Minto, Patrick Howard, Qingning Zhang, Raegan Wignall, Raoul Lee, Robert Blyth, Robert Durdin, Robert Syratt, Rory Fazan, Ruth Savile, Sam Peters, Samuel Makin, Sara Hussain, Soryoung Han, Sunya Qureshi, Thomas Simcox, Thomas Wroblewski, Tialani Chauhan, William Ratoff, Zak Kaufman.

This year, the Inn received 510 applications for the Bar Course Awards and, after allowing for withdrawals, interviewed 463 candidates in February 2025. We have awarded 119 scholarships, to a total value of over £1.8 million.

INNER TEMPLE 2025 GDL AWARDS

PRINCESS ROYAL (Two Awarded)

Jordan Parsons, Jacob Kellagher. MAJOR SCHOLARSHIPS (Four Awarded)

Rebecca Ebner-Landy, Harry Lederman, Tomaz O’Donoghue, Teck Wei Tan

EXHIBITION SCHOLARSHIPS (23 Awarded)

Abdullahi Yussuf, Aidan Woo, Alina Chanysheva, Amalie Dakyns, Amelia Holloway, Anas Qazi, Anna Herzog, Ciaron Tobin, Eashan Nakra, Freya Williams, Gwynfor Dafydd, Isabel van Rhee, Jack McKenna, Joe Atkinson, Kian Richardson, Lara Scadding, Maggie Easton, Naomi Hunter-Epson, Olivia Millard, Richard Griffiths, Rohini Jaswal, Samantha Walton, Yasar Cohen-Shah.

This year, the Inn received 142 applications for the GDL Awards and, after allowing for withdrawals, interviewed 134 candidates in June 2025. We have awarded 29 scholarships, to a total value of over £200,000.

What does being awarded a scholarship mean to you?

Jawad Razzaq Khan Exhibition Scholarship:

“Being awarded this scholarship has significantly alleviated my financial concerns regarding the Bar course, allowing me to fully focus on my studies without the burden of financial stress. Beyond the financial support, it has also opened valuable opportunities to connect and engage with accomplished students and professionals, enriching both my academic and professional development.”

Christopher Clocchiatti Exhibition Scholarship:

“For me, it represents a recognition of my progress so far towards the Bar, but also an invaluable encouragement to continue. In a way, it’s the first real mountain to climb on what can be a very long way to becoming a barrister.”

Myria Antony Exhibition Scholarship:

“As a career changer, this scholarship validates my leap of faith into the law. As someone from a nontraditional background who did not grow up in this country, I have often felt like an outsider on this journey. Knowing that a panel of experienced barristers believed in my potential transformed how I saw myself and how I performed in pupillage interviews. This means that someone like me can belong at the Bar. For that, I will always be grateful to The Inner Temple.”

What was your experience of the application process?

Vian Saggo Major Scholarship:

“ The Inner Temple scholarship process was an exceptionally thoughtful and supportive experience throughout. The application form was rigorously designed, affording me, as a candidate, the space to reflect not only on my achievements but also on the challenges I had encountered along the way and how I had grown through them. It served as a welcome reminder that the Inn values the journey as much as the destination.”

Eleanor May Exhibition Scholarship:

“I felt that the process was incredibly transparent. I got the impression that Inner wanted us all to do well and made a huge effort to make the process as clear as possible. The webinars with Georgina, both about the written application and the interviews with previous scholars, were incredibly helpful. It meant I felt confident in the application process, meaning I could put my best foot forward.”

Max Linton Major Scholarship:

“It was a smooth and seamless process. I was always kept informed and was given all the information anyone in an applicant’s shoes would need to succeed.”

What was your experience of the scholarship interview?

Megan Bradley Peter Taylor Scholarship:

“I enjoyed the interview more than I thought I would! The day felt very organised, from the pre-interview briefing to the end of the interview. There are no surprises, and it seems to be structured to get the best out of applicants. The panellists were encouraging and welcoming, and wanted to know what I had to say.”

Jemma Jenkins-Ferrett Exhibition Scholarship:

“ The interview format was well communicated and the selection criteria was transparent. Moreover, the interview panel were encouraging and friendly, which made the whole process much less anxiety-inducing than I had expected.”

Tialani Chauhan

Exhibition Scholarship:

“ The interview process was straightforward, despite being a naturally intimidating event. Once I got into the interview room, it became clear that the interviewers were there to help me show the best of myself, and I enjoyed discussing topics I am passionate about and being challenged on my legal analysis.”

Do you have any tips for future candidates?

Mali Pink

Princess Royal Scholarship:

“ The only way to be certain you will not receive a scholarship is by not applying. Feeling daunted is natural; it indicates that you care. However, you should not let self-doubt hamper your potential. If a career at the Bar is truly what you want, your drive and sincerity will come through. Make full use of the various webinars and resources offered by the Inn to support you. If you are consistent and organised, the process is manageable and, dare I say, enjoyable.”

Barnaby Burrowes

Exhibition Scholarship:

“Engage with every bit of advice you can find, doublecheck all the information so you are not caught out and relax. Everyone wants you to do well!

Max Linton

Major Scholarship:

“Although it may sound obvious, constantly think about the scholarship criteria. Every answer in your application and interview should be made with the aim of demonstrating at least one of those

HOME FROM HOME RESIDENTIAL WEEKENDS AT THE INNER TEMPLE

Over the weekend of 9–11 May 2025, the Inn held the third of its three annual residential weekends, each of which are designed to allow students an insight into niche topics of the law, whilst also developing their oral advocacy.

The May weekend, expertly led by Master Thea Wilson and Master Oliver Lewis, concerned advocacy in the Coroner’s Court, and featured a blend of advocacy and ethics training, as well as talks and advice from experts and experienced practitioners. Students were treated to a particularly compelling Friday night keynote speech from Master Henrietta Hill and The Hon Mr Justice Jeremy Johnson, introducing the concept of work in the Coroner’s Court and public inquiries more widely. The knowledge from this talk was consolidated on the Saturday by an involved panel on varied aspects of inquest work, featuring Rachel Kelly (Hill Dickinson), Master Stephen Simblet (Garden Court Chambers), HM Coroner Andrew Harris, Deborah Coles (INQUEST), Serena Sekhon (No5 Chambers) and Rachel Woodward (Doughty Street Chambers). In addition to this, Master Rachel Spearing also delivered a highly practical talk on wellbeing in practice in the Coroner’s Court – a session which strove to be dually useful to practitioners taking on inquest work and students dealing with the topic at the weekend itself. The advocacy exercise, written by Master Wilson and Master Lewis, required the students to prepare oral submissions to the coroner at an inquest hearing, operating either for the family of the deceased, for the care home, for the GP practice or for the hospital. They were led through the exercise by knowledgeable and dedicated group leaders, who supported them further on the Sunday when they made their formal oral submission in front of a judge. As ever, we are hugely indebted to our volunteers, particularly the group leaders and judges who created, in the words of one student, a “very safe environment to ask questions”.

The weekend was also unusual in that it was held at The Inner Temple itself, rather than at one of the residential hubs we typically use to host our residential events. This is not the first time this has happened – a residential weekend was held at The Inner Temple in May 2023 when the coronation required a short-notice date change – but it is the first time we have planned a weekend this way from the outset. The decision was made by the Qualifying Sessions Committee, primarily as a means of fostering stronger ties between the students and their professional home. The new era of online and hybrid learning – whilst it fosters crucial accessibility – can mean that some students are unlikely to visit the Inn during their time on the Bar course. Holding a weekend event at the Inn itself (with accommodation built into their booking fee) provides an opportunity for students from across the country to familiarise themselves with their Inn and to make use of the state-of-theart training facilities that were the result of Project Pegasus. Students were able to utilise the Inn’s redeveloped training rooms and auditorium for group learning and plenary sessions across the course of the weekend and were also invited to attend two formal dinners and drinks receptions in the Parliament Chamber and Luncheon Room. Student responses to this new residential location were extremely positive, with one noting that “the venue is stunning as always”, whilst another responded: “the venue, being the Inn, could not be better. It has the dual benefit of not only providing the training, but also an opportunity to engage with the volunteers, Benchers, staff and the building itself, over a longer period than other Qualifying Sessions.”

We are hugely grateful to all of our volunteers, but also to The Inner Temple’s peerless catering department, who managed the specific demands of a full-blown residential weekend without a hitch. On the strength of extremely positive feedback from students and volunteers, we are hoping to factor the use of the Inn more permanently into our residential Qualifying Sessions Programme.

THE INNER TEMPLE STUDENT SOCIETIES

THE INNER TEMPLE RACIAL EQUALITY SOCIETY

The Society has had an impactful year, delivering a range of events focused on widening participation at the Bar and fostering meaningful dialogue across the profession.

Following the success of our inaugural South Asian Heritage Month event, it has become a cornerstone of the Society’s annual programme. Last year’s panel discussion prompted thoughtful reflection on identity, belonging and cultural heritage. We continue to be inspired by the experiences of practitioners with South Asian backgrounds and are grateful to our speakers: Kiran Channa, Grace Ong, Zacharias Miah, Adiba Bassam, Zeenat Islam and Dr S Chelvan.

In October 2024, our in-person Black History Month event brought together over 70 attendees, creating valuable opportunities for networking across professional and academic communities. The event featured an exceptional panel:

Jason Jackson – Deputy Mayor of Islington Council

Elpha LeCointe – Deputy District Judge

Alison Stuart – Director of Law, Governance and Monitoring Officer, Islington Council

Dr Natasha Shotunde – Founder of the Black Barristers’ Network and Barrister at Garden Court Chambers

Nathan Alleyne-Brown – Barrister at No5 Barristers’ Chambers

Councillor Valerie Bossman-Quarshie – historian, activist and councillor

In addition to our flagship Pupillage Panel, we were proud to host our first wellbeing event, exploring topics such as imposter syndrome, burnout and mental health at the Bar. Master Rachel Spearing KC offered particularly valuable insight on maintaining work-life boundaries and prioritising wellbeing in a demanding profession.

We remain deeply appreciative of the ongoing support and guidance of the Master of the Society, Selva Ramasamy KC. His motivation and thoughtful encouragement continue to inspire the Committee in our collective efforts to promote equality and inclusion at the Bar.

THE INNER TEMPLE MOOTING SOCIETY (ITMS)

The ITMS runs internal mooting competitions, provides teams for external competitions and hosts training events for student members. This year, we have had great success both nationally and internationally.

Internal Competitions:

The Intervarsity Moot featured 16 university teams. The final, judged by Master Reader, Master Kabir Sheikh KC and Master Willbourne, was won by the University of Swansea.

In the Pepperdine Moot, advocates were selected via the Introduction to Mooting training session. Susanna Breslin was named Best Advocate, as judged by Master Willbourne and Sarah Hair.

This year, 82 students registered for the Lawson Moot. William Dobbs was named the winner.

We recently held the Commercial Law Moot, sponsored by One Essex Court Chambers. 32 students registered to participate and Yousif Shami won the competition.

External Competitions:

Jessup Moot (Washington DC)

At the world’s largest moot, with 805 teams, The Inner Temple team (Lucas Jones, George Sheldon Grun, Pragya Sinha Kumar, Anjali Gananathan, Matthew Wesson; coached by Sajid Suleman) placed in the top 16 globally.

VIS Moot (Vienna)

The VIS Moot focused on international commercial arbitration, with 385 teams from 88 countries. The Inner Temple team (Vigneshwari Manivannan, Cody Lai, Aaron Rajesh, Vikita Khetani, James Piercy, Grace Okafor, Saujanya Vinayy; coached by Louis Flannery KC) ranked 163rd.

Children’s Rights Moot (online)

With 31 teams globally, The Inner Temple team (Gemma Gould, Jack Clayton, Catherine Berus, Sylvia Chukualim; coached by Sarah Hair) reached the top four and won Best Memorial for the Applicant.

Sports Arbitration Moot (Madrid)

73 teams entered and 16 progressed to the finals in Madrid. The Inner Temple team (Helin Yaren Usal, Maddie Underhill, Jovana Koprivica, Sam Grankin, Tom Regis, Sarah Hair; coached by John Mehrzad KC and David Sharpe KC SC) placed in the top four.

Black History Month Event (Oct 2024)

Jessup moot team 2025

DRAMA SOCIETY

The Inner Temple Drama Society kicked off the academic year in slapstick fashion with their annual Christmas pantomime in December 2024. Comedy met tragedy in Cinderella: the play that goes awry, written by Nicole Terry and Tom Isaac. Featuring an incredibly talented cast, the pantomime saw a group of amateur actors put on a production of Cinderella in which everything that can go wrong, does.

In May 2025, the society took part in the annual The Temple Shakespeare Cup, once again competing with Middle Temple in producing the best hour-long adaptation of a Shakespeare play. This year, The Inner Temple performed a charged and thoughtprovoking performance of The Merchant of Venice, directed by Kat Cutler and featuring wonderful costumes from the National Theatre. Middle Temple opted to humour their way to the prize by performing The Merry Wives of Windsor, a strategy that ultimately proved successful as Middle Temple won Best Play. Nevertheless, The Inner Temple cast were exceptionally proud of their romantic leads, Bassanio, played by Thomas Phillips, and Portia, played by Amelia Leventhorpe, who jointly won the prize of Best Actor for their memorable performances and indisputable chemistry on stage.

After a sell-out show in 2024, the society took a production to the Edinburgh Festival Fringe in August 2025. The Trial: In Absurdia, written by Blue DeBell and directed by Tom Isaac, is a modern retelling of Franz Kafka’s The Trial, portraying an absurdist legal system where justice comes second to the humorous shenanigans of the court. This production will also be performed for one night only at The Inner Temple on Monday 29 September 2025.

A friendly and welcoming society, it is now open to all members up to seven years’ Call.

DEBATING SOCIETY (ITDS)

The Debating Society ran an inaugural ‘collaborative’ competition with Middle Temple on 23 March 2025, where students from Middle Temple competed alongside students from The Inner Temple. The winning team was Saujanya Vinayy from The Inner Temple and David Horvarth-Franco from Middle Temple.

The Harrison Cup took place again this year on 1 February, with 24 teams competing across six rooms. Teams came from Edinburgh, Exeter, Glasgow, KCL, UCL, Bristol, SOAS, ICCA, Buckingham, Dublin and Zurich. A silver final and a gold final were held, and the gold final was judged by Master May, Master Hiddleston and Master Sutherland Williams, alongside two university judges. Cyrus Braden and Joshua Stone from Edinburgh/KCL won the gold final. The winners of the silver final were Brian Jones and Nikhil Akappuram from Bristol.

The Inner Temple Debating Society competed in the following intervarsity competitions:

Cambridge IV

Birmingham Pro Am

KCL Open

Imperial Online Open

Liverpool IV

ITDS are also sending a team to the European Championships in Copenhagen in August 2025.

The Debating Society competed in the Inter-Inn competition in June this year, reaching the semi-final. The team comprised Rhiannon Hobby, Kelvin Ma, Grace Okafor and Nathalie Podder.

DEBATING SOCIETY ON CIRCUIT

We took over two courtrooms at Bristol Magistrates’ Court on the 28 June for the BP Debating Shield semi-final and final. 16 competitors, three volunteer judges, three committee members and a member of The Inner Temple Education and Training team were there for 10.00am. The team positions and courtrooms were drawn from a hat. The two top-ranking teams in the semi-final debates went through to the final in courtroom nine. The semi-final motion was ‘This House believes that the ends always justify the means’ and the final motion was ‘This House would incentivise voting’.

A competitor shared the following feedback: “A positively challenging experience that pushed me to become a better advocate, with the added benefit of being in an actual courtroom.”

The winning team of the 2025 BP Debating Shield was Henry Clement-Jones and Tom Morris.

Volunteers from the Inn who judged the final were Master Oliver Lewis, Iain Wightwick and Jocelynne Scutt.

The Debating Society also held the final of the Public Speaking Competition at Manchester University of Law on 12 July 2025. This is the second year that Manchester ULaw have generously lent us their space. The winner of this competition was Kate Grimsdale; Joshua Hurst was the runner-up. The motions were ‘This House believes that commercial surrogacy is empowering for women’ and ‘This House would never vote in a democratic election’. The competition was judged by Master Samantha Hillas KC, Nigel Booth and Peter Anderson. Judges throughout the competition noted that the standard of public speaking was particularly high.

The Cast

The Cast

THE INNER TEMPLE STUDENT ASSOCIATION (ITSA)

Pupillage Panels

The Pupillage Panels were organised by the 2025 ITSA Committee. This is a series of panels delving into various areas of law, in preparation for Pupillage Gateway applications. The events held are as follows:

All panels except the Circuit Panel were held in-person at The Inner Temple Treasury building. Mrs Louis-Byfield helped us secure the venue free of charge, and also organised the registration link.

8 January 2025 Civil Law

Ms Grace Okafor

9 January 2025 Criminal Law Ms Chloe Barnes

13 January 2025 Public Law

Ms Grace Okafor

15 January 2025 Family Law Mr Johnley Videña

20 January 2025 Commercial & Chancery Law Ms Mahera Sarkar

29 January 2025 Circuit Panel

Ms Grace Okafor and Ms Denise Osei

The panellists comprised of barristers with varying tenure. The majority of them were pupils, probationary tenants and recent juniors. It is noted that some of them were previous members of The Inner Temple Drama Society, and we are grateful for their consistent support to the panels.

Originally we also planned to host panels in the Circuits but opted to merge these into one online event on Zoom. This consisted of seven panellists, the majority of whom were from the Wales and Chester, and Western circuits.

Attendance for the London panels ranged from 20 to full capacity (50). Attendance for the Circuit panel was around 40.

There were no costs in running the panels.

Burns Night 2025

On 23 January 2025, The Inner Temple and ITSA hosted Burns Night. This was mainly organised by Mrs Louis-Byfield; we are sincerely grateful for her efforts.

• Charles Bagot KC (Gatehouse)

• Benjamin Gray (Littleton)

• Colleen Cumbers (Crown Office)

• Alex Ferrigno (5 Pump Court)

• Joanne Cecil KC (Garden Court)

• Mark Robinson (Garden Court)

• Jacob Bindman (Garden Court)

• Matthew Jollife (4BB)

• Nina Reinarch (33BR)

• HHJ Owen Davies KC (retired)

• Richard Honey KC (FTB)

• Paul Bowen KC (Brick Court)

• Nozima Rakhimjonova (Fraser)

• Master Philip Moor (1HC)

• Charlotte McDonald (42BR)

• Imogen Todd (Deka)

• Imogen Pitts (Harcourt)

• Iona Gallagher (New Court)

• Emma Germany (5 Stone Buildings)

• Mercy Milgo (Keating)

• Max Schofield (Devereux)

• Weishi Yang (Henderson)

• Ryan Bowen (Angel Chambers)

• Sarah Riley (St John’s)

• Benedict Harwood (St John’s)

• Michael Rivelin (St John’s)

• Emily Jermin (Apex)

• Zoe Laugharne (Apex)

Panel Event: The Bar for International Students

On 25 March 2025, we hosted a panel event called The Bar for International Students, in collaboration with the International Future Barrister Mentorship. The aim was to have a panel of barristers of international backgrounds to discuss their pathways to the Bar, encouraging international students to pursue their aspirations.

The panel consisted of:

Nia Marshall – Exchange Chambers (Co-Founder of IFBM; attended online)

Emily Hayward – 3 Paper Buildings

Jason Mitchell – Maitland Chambers

Mikhail Charles – 5 Pump Court

Of the 68 sign-ups, 30 attended via Zoom and 12 attended in person. Our feedback form data stated the following recommendations:

Better tech preparation is required

More advertisement is required

More events catered to international students

This was the first event of our Enrichment Series. We are aiming to organise five more events as part of this series.

CALL TO THE BAR

“Being called to the Bar with my family by my side was the biggest honour. The support of my family has been instrumental to my success throughout this journey. To have my mum see me be called to the Bar is a memory I shall treasure.”

Chloe Wilson

“A truly magical day I will never forget. I am incredibly grateful to The Inner Temple for its unwavering support throughout my professional journey and for making the Call such a joyous and memorable occasion. My family and I will treasure it always.”

Dunya Amini

“Call Night was wonderful, the culmination of all of our hard work. It was a privilege to be called to the Bar with peers from across the country and the world. Thank you to all at The Inner Temple for a day I will never forget.”

Elizabeth Shanks

Carla Jones

Thomas David Rowland

Maxim Barnes and James Piercy

Chloe Wilson

David Miller

“Walking into Temple Church for my Call felt surreal. Surrounded by family, friends, and centuries of tradition, I was overwhelmed with pride and gratitude. It was a moment I’ll never forget. It marked the start of a journey I’ve worked so hard for and a dream finally becoming reality.”

David Miller

“My journey to the Bar has been a long and turbulent one, and the Call Night marked the end of that chapter and the beginning of a new one. It was a glorious evening filled with joy, laughter, celebration, and deep gratitude –knowing that all my hard work, and the unwavering support and investment of my family and friends, had finally paid off. I’m especially thankful to my mentor, Emma Akuwudike, for her guidance, encouragement, and belief in me throughout this journey. I’m honoured and grateful for the opportunity to be a member of the Inn. Above all, I thank God for such a smooth and perfect evening.”

Pearl Opoku-Amankwa

“Attending the 2025 Trinity Call Ceremony was deeply inspiring and emotional. Witnessing my sister’s hard work turn into achievement filled me with pride. The presence of family made it even more meaningful, and the solemn tradition of the ceremony created an unforgettable atmosphere that honoured both personal journey and historic significance. A truly special moment.”

Sister of Ann-Marie Pinkney

Nicole Deakin

Master Treasurer

MOVERS AND RETURNERS

By Master Rachel Spearing

Thursday 22 May 2025 saw The Inner Temple host the first Movers and Returners conference. The initiative, led by the Bar Council and supported by all four Inns, seeks to retain talent, support the progression of all groups at the Bar and assist those wishing to transfer their practice area or status.

There will always be changing trends and profiles within the Bar as we evolve as a profession, but a consistent theme, according to the Bar Standards Board and the Bar Council data, remains the challenge of retention.

Barristers may take time out of practice for many reasons, including maternity leave, paternity leave, adoption leave, caring responsibilities, ill health, further study, time-out or to pursue other ventures. It is also a reality with the pressure of pupillage and early years in practice that many find themselves practising in areas which were not their first choice or where they no longer find meaning, purpose or financial security. A recent Criminal Bar Association survey suggested that one in three were actively considering moving their practice into another discipline.

Time out of practice may be for many reasons, including maternity leave, paternity leave, adoption leave, caring responsibilities, ill health, further study, time-out or to pursue other ventures.

Supporting career breaks, returners and those seeking to move between practice areas is a vital way of encouraging diversity, equality and inclusion. It also fosters the development of richer skill sets and creates opportunities to enhance lived experience, learning and cognitive diversity within the profession –better serving the public and the organisations we work with. Additional skills, qualifications or experiences accrued during career breaks can help practitioners to grow and sustain their careers.

Joint working between the Inns, led initially by Middle Temple, has seen the development of online resources that incorporate guidance, shared lived experiences and skills workshops from professionals to support members navigating the professional, practical and emotional challenges of change.

Master Barbara Mills, the 2025 Chair of the Bar, placed the education, training and wellbeing of the profession within her leadership agenda. Recognising that while the focus for many years had been on widening access to the profession, the consistent theme of retention – and understanding the emerging data on its current impact – had waned. Refreshing the message to the profession that retention remains a key priority for all, alongside continued education and the flourishing of the Bar, is where all the Inns are aligned. In October 2024, we set about the creation of a tasked working group of Inner members and Benchers to develop a programme of support.

The wide and diverse working group included junior, senior, governing and judicial members. The aim of our work was to provide positive leadership and support with practice planning, managing career breaks, navigating return challenges and supporting continuing education for those considering pursuing or returning from breaks, or seeking to transfer areas and status.

After creating a specific web page within the Inns’ platform to collate and provide access to existing guidance and resources for members, we identified further useful areas and issues for discussion through analysis of recent data gathered on the profession. Drawing together the aims and objectives in a practical and discursive interactive conference allowed delegates to attend a free one-day event for CPD and networking.

Drawing together the aims and objectives in a practical and discursive interactive conference allowed delegates to attend a free one-day event for CPD and networking.

We had 96 delegates in attendance, plus two babies, and a wait list for others. Of these, 41% were Inner members, 20% Lincoln’s, 19% Middle, 9% Gray’s and 11% ‘other’, comprising students and solicitors in the process of transferring. The Inn was a buzz on the day of the conference. Delegates found a safe and supportive space to engage with sessions, approach speakers and mentors with questions, and share learning. The working group and Inns’ teams, which extended to the librarians (following their helpful materials for returning to research and library use), received a lot of positive feedback on the day from participants.

There was extensive positive social media feedback sharing gratitude, impact and encouragement to others regarding the initiative. The feedback captured the demographics, learning outcomes and future needs of the delegates. The motivation for attending the conference was very broad, with an equal 15% interest from those currently on a break from practice (other than maternity) and from those moving practice. Only 19% had caring responsibilities, with others wishing to learn more about moving/returning in general. The programme reflected our ‘One Bar’ message, with keynote speakers comprising the Chair of the Bar, judicial leaders and LGBT equality leaders. Their candid and inspiring messages shared their journeys, coaching advice, and personal resilience and reflections. Learning to ‘run your own race’ was Mrs Justice Whipple’s highlight in managing career planning, alongside the necessity to build skills to “be brave” when tackling a difficult moment. Panel sessions shared lived experiences and leadership discussions on best practice. Break-out sessions and presentations were designed to support resilience and confidence, refresh advocacy skills and provide guidance on the financial and practical aspects of practice planning.

The final task of our working group was to make recommendations after reflecting upon the feedback and data. We reflected with a sense of achievement and value for our joint leadership of the Inns’ conference agenda and resources. A final report, shared with the Inns’ Executive Committees, requested the continued recognition of movers and returners as a key focus within the Established Barristers programme. It recommended continued collaborative working between the Bar Council and the Inns, and that specific consideration be given to making advocacy and CPD legal content refreshers available to support members returning to or moving practice. A podcast series of eight episodes is planned to start next term, spotlighting specific themes of moving and returning in practice. Enormous thanks is due to the Education and Training team’s Established Barristers initiative for 2025–26.

Rachel Spearing KC Serjeant’s Inn Chambers Vice Chair, Equality, Diversity and Inclusivity Sub-Committee

ADVOCACY TRAINING AND THE FAMILY BAR

By Master Bibi Badejo

I would never have signed up to be an advocacy trainer if it hadn’t been for Sarah Clarke KC. After I gave a truly stunning car crash of a performance at the Keble Advocacy Course in 2017, she somehow saw something salvageable in me. Sarah invited me to consider becoming a trainer, suggesting it would transform how I approached advocacy. She was right.

Shortly after I completed the Keble Course, I attended and luckily passed the Inn’s Advocacy Trainers’ Course. I discovered I loved teaching – there’s something magical about watching junior barristers find their voice and confidence over the course of a day. Seeing someone transform from hesitant to commanding in just a few hours never gets old.

As well as giving back, training others sharpens our own advocacy. When we teach, we must deconstruct what someone has said, identify precisely why it wasn’t effective, explain it clearly and demonstrate an alternative. It trains the brain to think faster and more strategically. It also deepens our own learning; just as participants benefit from observing each other, we learn constantly from our fellow trainers’ insights, approaches and feedback. It’s an incredibly collegiate, constructive and rewarding experience.

There are also extraordinary opportunities to train internationally. Thanks to my accreditation, I’ve had the privilege of training at Keble College and further afield –in Australia, America, Jamaica, Germany, Sierra Leone, South Africa and Namibia, to name just a few. Some in person, some online – all unforgettable experiences.

As a family practitioner, I have found it particularly valuable to train across different practice areas, from crime to civil. Like my colleagues at the Family Bar, I am in court almost daily and therefore spend a great deal of time on my feet. The skills I’ve developed as a trainer are highly transferable; there’s real overlap in technique and approach. Training across disciplines has made me a stronger, more agile advocate.

While cross-training brings invaluable breadth, there’s also real value in family-specific expertise. That’s why it’s so exciting that the Advocacy Training Committee is now introducing fact patterns and sessions designed specifically for family practitioners, delivered by experienced family advocates and judges.

So here’s the plug: if you’re a family practitioner, please consider signing up for the Advocacy Trainers’ Course. You’ll not only strengthen your own practice but also help shape the next generation of advocates in our field.

The Advocacy Training Committee is especially keen to recruit more family specialists and to widen the diversity of our trainer cohort. The more backgrounds and perspectives we bring to the table, the stronger the training becomes for everyone.

Bibi Badejo 4 Brick Court

Advocacy Training Committee

If you would like more information about the Inn’s Advocacy Trainer’s Course, contact establishedbarristers@innertemple.org.uk

Master Bibi Badejo

WE NEED YOUR HELP!

The education and training provided by The Inner Temple would not be possible without the support and commitment of members, who give up their time to support a wide range of activities including outreach, scholarships, qualifying sessions and training for pupils and barristers.

This year, we asked some of our most dedicated members to share their experiences of volunteering with us. If you are interested in hearing more about volunteering opportunities, please visit our website: innertemple.org.uk/membershipservices-support/volunteering-opportunities

Ashley Lord Spire Barristers

I have been volunteering with the Inn for around two years. It’s great to see how students develop and grow in confidence, even over the short space of a weekend, and to know that the time you have invested has helped them in that regard. I would encourage anybody thinking about volunteering to take the plunge and get involved, you won’t regret it!

Master Baldip Singh Aulak No5 Chambers

Richard Beynon Red Lion Chambers

Brought up in a mining community in South Wales, with no legal connections, I have never forgotten the kindness, wisdom and encouraging warmth of the late Sir Henry Brooke CMG, who called me to the Bar, and I never will. Not that I could ever replicate his qualities, but in volunteering and giving back to the Inn, I hope I continue to reflect even a small element of them. It is incredibly fulfilling, rewarding and a privilege to encourage, teach, advise and support those who aspire to follow a similar path into the profession as I did.

When I came to the Bar, I rarely saw people who looked like me or shared my background. That absence made a lasting impression and a clear decision: I would do what I could to change that. Volunteering with the Inn for over a decade has allowed me to help open doors for others, promote equality, diversity and inclusion, and ensure the Bar better reflects the society it serves. It’s about making space, holding it open and inviting others in, because the Inn has space for all.

I’ve had the privilege of volunteering in a variety of ways, through outreach events on circuit, interviewing scholarship candidates, training Bar students and later, pupils. But nothing compares to the moment when a Barrister comes up to say, “You trained me at the advocacy weekend when I was a student/pupil.” Watching someone progress from tentative beginnings to tenancy and knowing you played a small part in their journey is incredibly rewarding. It’s those moments that remind me why we give our time: to light the way for others.

Master Paul Infield The 36 Group

Volunteering for the Inn is not just about giving something back to the profession, it’s also great fun. The student events enable me to teach them professional skills, but they also enable me to learn how people coming to the Bar now feel, the opportunities they have and the difficulties they face. That enriches my life and helps me in my professional outlook.

Master Sophie Cartwright KC Deans Court Chambers

It is a huge privilege to volunteer through the various schemes run by the Inn. Having been a grateful recipient of an Inner bursary back in the 1990s, I appreciate first-hand the access to a career at the Bar which The Inner Temple facilitates.

On many occasions, students ask questions which reveal that there is still a common misconception that the Bar is not a profession for all. For that reason alone, I feel lucky to participate and provide my personal views and experience when this question is asked.

You truly do get out of Inn volunteering as much as you put in.

Andrew Day St Ives Chambers

I have been volunteering with the Inn in a variety of ways for a number of years now and all have their own different rewards, but this year delivered a real highlight for me as a mentor: I spent a number of months working with three mentees, two of whom were taking the BTC and one of whom had recently completed it. All three were successful in securing pupillage! It is so gratifying to watch such talented newcomers taking their first steps in the profession and I really look forward to seeing their careers flourish in the years to come.

Master Ian Dove

Simon Atkinson Wilberforce Chambers

My favourite moments volunteering for the Inn include advocacy training at Wotton House with pupils.  Working with some exceptional young barristers always leaves me feeling confident about the future of the Bar.  (It also helps me immensely with my own advocacy; there is so much one can learn from the next generation of advocates!)  Working with PASS scholars is also hugely rewarding.  The Bar is at its strongest when it attracts the most talented people.  To do that, the Bar must be accessible to all, irrespective of background and financial means.

District Judge

Deborah Dinan-Hayward

Volunteering gives me the chance to support junior barristers and students who are just starting out. Helping others gain confidence and seeing them improve over a week-end of advocacy training is extremely rewarding. It reminds me how lucky I am to have been part of this profession. Sharing my experiences and answering questions from young people also allows me to reflect on my own journey and career choices. It also keeps me connected with others at the Inn. Volunteering is important because it helps the Bar become more diverse and accessible and ensures future barristers better represent the clients they serve. I would like to think that my time and advice can encourage someone else, even years later, which makes it worthwhile.

Just about a year ago I was persuaded by Master Jill Frances to have a go at training to be an advocacy trainer for the Inn. I am so pleased that I took the chance to get involved in helping this really important work. The training course was excellent. We were given plenty of briefing material prior to the course and the experienced practitioners training us could not have been more supportive and helpful. The friendly and collegiate approach of the trainers has been the hallmark of all the events I have attended. Having passed the course, I have really enjoyed working with students and trying to help them hone their skills as an advocate. But the real reward of this work is watching students grow in confidence and their skills develop as a result of their participation in the training events.

Master Jennie Oborne Deka Chambers

I became an advocacy trainer in 2014, at seven years Call. Inspired by own experience of advocacy training at the Keble Advanced Advocacy Course I was looking for a way to become more involved with the Inn. Since then, I have volunteered on more than thirty residential weekends and taught in numerous jurisdictions all over the world. Advocacy training has given me far more than I could ever hope to give back.

Teaching is a joy. Over the course of an advocacy training weekend we see huge improvement in the performance of the pupils and new practitioners. There is great satisfaction in seeing the next generation of advocates gain skill and confidence.

It improves your own advocacy. If you are in court with an advocacy trainer, the chances are they are silently reviewing you (and themselves). Training teaches you to think critically about oral and written advocacy: what works, what doesn’t, and why.

It provides international opportunities. I have trained advocates in Turkey, Kenya, Rwanda, Jersey and at the International Criminal Court. There are also opportunities to train in Singapore, Hong Kong, Australia, America and South Africa. Advocacy training is truly international. You are part of the advocacy training community. Through advocacy training, I have made friends from all practice areas, among the judiciary and in the Inn’s E&T department. Their support and encouragement and has been invaluable as I have progressed through the ups and downs of life at the Bar.

LIBRARY FACILITIES AND SERVICES

The Library is open to all members of the Inner Temple and to members of the other Inns of Court. It is a legal reference Library, staffed by experienced information professionals, which offers users access to a wide range of print and electronic resources in a comfortable working environment.

The Library offers the following facilities and services:

A quiet environment for study with a designated silent room

A range of commercial legal research databases

A comprehensive collection of English legal materials, including the most up-to-date editions of major practitioner texts

Specialist Commonwealth & Scottish collections

An extensive archive of old editions of practitioners’ works

Open access computers with MS office applications and online access

A variety of inclusive equipment, software and service adaptations

Photocopying, scanning and printing facilities

Free Wi-Fi throughout

Bookable Basement Reading Room to take longer calls or for small group discussions

Phone booth to make and receive calls

A document supply service

An enquiry service (in person, by telephone and by email)

Overnight and weekly loans

Patron-driven Acquisition Scheme

Bookable 1-to-1 training sessions

Legal research training for pupils and students

Tours for students and pupils

Library and research guides available in print and on the website

Web access to the library catalogues of the four Inns

Current Awareness blog for legal news, changes in legislation and new case law (innertemplelibrary.com)

Social media pages with information on Library services, news and events: Bluesky, Facebook and LinkedIn

More information on the Library’s collections, services and contact details can be viewed at innertemplelibrary.org.uk

USA

By Afiya Amesu

A COMPLEX RELATIONSHIP WITH RACE AND THE LEGAL SYSTEM

The history of the United States cannot be separated from its legacy of slavery, segregation and racial inequality. These injustices have profoundly shaped the legal system, influencing laws, judicial administration and the lived experiences of marginalised communities. Today, systemic disparities remain evident across criminal justice outcomes, access to representation and broader inequities.

Notwithstanding this history, significant strides have been made toward fostering greater representation and inclusivity in the US legal profession. The US judiciary has become increasingly diverse, with judges from historically underrepresented communities assuming prominent roles. This representation is vital, not only for public confidence but also for ensuring that justice reflects the lived realities of those it serves.

It was within this context that I pursued the Pegasus Scholarship. In the UK, where Black people remain starkly underrepresented in both the Bar and the judiciary, the scholarship presented an invaluable chance to study how positive action can foster inclusivity. As a Black barrister, I saw this as an opportunity to examine how diversity is cultivated and to reflect on lessons for my own jurisdiction.

THE JUDICIARY

California was the first stop, where I observed the state’s success in expanding diversity on the bench. Over the last 18 years, the number of Asian, Black and Hispanic judicial officers has doubled. Conversations with leaders such as Luis Céspedes, Governor Newsom’s Judicial Appointments Secretary, highlighted how transparency, mentorship and valuing varied experience could broaden eligibility without compromising meritocracy.

Meeting judges such as Chief Judge Troy Nunley and Sacramento’s Presiding Judge Bunmi Awoniyi, whose journey from British barrister to US judge was deeply inspiring, provided tangible examples of representation in action. Further discussions at the California Supreme Court with Chief Justice Patricia Guerrero and Justices Martin Jenkins and Carol Corrigan underscored how diversity enriches judicial philosophy and enhances public trust. These experiences collectively illustrated how inclusive judicial appointments strengthen justice by incorporating broader perspectives.

INDIGENOUS LAW

A critical dimension of America’s reckoning with race lies in its treatment of Native peoples. Lectures at Arizona State University and visits to the tribal legal clinic revealed the unique challenges faced by Native American communities in areas such as sovereignty, land rights and cultural preservation. Judging a moot concerning the adoption of a Native American child reinforced the significance of the Indian Child Welfare Act in protecting cultural continuity.

The appointment of Judge Paula Lomayesva as the first member of a federally recognised California tribe to the state’s superior court, during my time in the US, was particularly significant, symbolising progress in recognising Indigenous voices within the judiciary.

ADVOCACY

The Pegasus programme also provided insights into advocacy practices across the US. Observing a deposition in Chicago highlighted the contrast between American discovery, with its emphasis on live questioning, and the UK’s reliance on written statements. Witnessing voir dire in Phoenix revealed how jury selection itself becomes a critical stage of advocacy, allowing lawyers to shape the trial before opening arguments, compared to the UK’s randomised process.

From local criminal trials to oral arguments before the Maryland Supreme Court, I observed a range of advocacy styles, culminating in exposure to the highest levels of federal practice. Encounters with leaders such as Solicitor General Elizabeth Prelogar and Assistant Attorney General Kristen Clarke demonstrated the interplay between politics and litigation.

Equally significant were specialised courts in Arizona, such as Veteran and Mental Health Courts, which address the root causes of offending to reduce recidivism. These initiatives illustrated how advocacy can extend beyond adversarial models to embrace problem-solving approaches that prioritise rehabilitation and justice.

LEGISLATION

The programme also offered a window into lawmaking at both state and federal levels. In California, discussions with legislative advisors illuminated the process of transforming policy into statute, while Maryland highlighted the challenge of part-time legislators balancing civic duty with professional life.

In Washington DC, visits to the Capitol, Pentagon and Library of Congress allowed us to delve into the nation’s legal and political history. Observing Supreme Court oral arguments on election day underscored the ongoing dialogue between law, politics and democracy. Further, standing on the House Floor, where historic debates shaped the nation, was a humbling reminder of the law’s power to shape society.

THE LEGAL COMMUNITY

A particularly striking aspect of US legal culture was the strength of the American Inns of Court. Inspired by their English counterparts, these Inns provide mentorship, collegiality and shared learning across the profession. From lively ethics skits in California to Thanksgiving-themed discussions in Maryland, the Inns demonstrated how community and camaraderie strengthen the practice of law.

REFLECTIONS AND LEGACY

The Pegasus Scholarship was an extraordinary journey –challenging, inspiring and deeply enriching. It revealed the progress the US has made in confronting historic inequities, while also acknowledging the work that remains. Across every state, I saw how diversity, innovation and community can strengthen the legal system.

These lessons resonate strongly for the UK. While our contexts differ, the challenges of representation, access to justice and inclusion are universal.

Above all, the programme highlighted the importance of global dialogue. The exchange of ideas across jurisdictions not only enriches individual practitioners but also strengthens the profession collectively. The connections I forged and the insights I gained will continue to shape my approach to advocacy and my vision for a more inclusive Bar.

A thank you to my partner in crime, Hannah Gilliland, who made this experience even more special!

Afiya Amesuw No5 Barristers’ Chambers

NEW ZEALAND

By Anna Dannreuther

I was lucky enough to spend six weeks at Stout Street Chambers in Wellington, New Zealand. Stout Street barristers practise across public and commercial law.

In my first week, I was struck by the differences between practising at the Bar of England and Wales versus practice in New Zealand. For instance:

No clerks! Every barrister at Stout Street largely generates their own instructions and manages their own diary. Many senior barristers were formerly partners at law firms. The juniors are hard-working and brilliant and generate their own work.

Generalists: a commercial barrister is very happy to speak about the Resources Management Act 1991, or the Principles of the Treaty of Waitangi Bill or the NZ Bill of Rights Act. There’s less of a culture of specialisation and a greater focus on multiple areas of practice. This suits a group litigation practice, where no practice area is off limits.

Litigation temperature: Even during high-stakes, challenging litigation, there seems to be a strong sense of reasonableness in conducting the litigation, possibly down to New Zealand’s smaller legal community, often with few degrees of separation. Plaintiff rather than Claimant: a small point but I’m proud of England and Wales for being modern and using plain(er) English here.

Judicial Review: no permission is required and there is no three-month deadline to file. This is perhaps explained by the much higher High Court judges per capita in New Zealand. England and Wales’ King’s Bench Division, which hears judicial reviews, has 71 full-time judges (for a population of 68 million), against New Zealand’s 46 (for a population of five million).

Legal personality: Mount Taranaki has legal personality, alongside Te Urewera and Whanganui River.

More than 300,000 submissions had been received on the Principles of the Treaty of Waitangi Bill, which, according to the Bill’s promoter, seeks to “set out the principles of the Treaty of Waitangi in legislation”.

In my second and third weeks as a Pegasus Scholar in New Zealand, I attended a Court of Appeal hearing concerning the mandatory wearing of face masks from 2021 on public transport, essential retail businesses, certain public facilities and, later, only in certain health service premises. The main challenge was on the basis of a mistake of fact (ie did the Minister make the Orders on the mistaken basis that face masks are effective at stopping the spread of COVID-19?), which principle comes from an English and Welsh Court of Appeal case E v SSHD [2004] 2 WLR 1351. It was encouraging to see all (even more junior) members of the legal teams provide submissions to the Court.

I also observed High Court civil advocacy dispassionately, and noted some phrases I would like to steal for my own practice:

Where I’d like to start the story is…

[Read out letter] What they’re saying is: [translate to plain English]

I may sound like a broken record and I’m sorry for that, Judge, but [reinforce key point]

The best answer I can give you to that is…[cite your client’s evidence]

I enjoyed reading New Zealand’s excellent advocacy books, one edited by the former Chief Justice of New Zealand, Sir Thomas Eichelbaum. The chapter on cross-examination was particularly good.

I was further encouraged by brilliant lawyers to read more legal theory: Sian Elias, Cardozo, Bingham, Brandeis, Holmes, Winkelmann, Glazebrook. That way, it is possible to better understand what the common law is doing and how.

I then enjoyed reading my colleague Monique van Alphen Fyfe’s brilliant 2013 article on challenges facing women in law, which highlighted (pithily) how 60 per cent of graduating law students in New Zealand were women, but only 27.7 per cent of judges and 19 per cent of partners in law firms were women. She called the movement toward equality at senior levels in law “abnormally slow” and proposed mechanisms for change.

I also enjoyed working on equitable estoppel (purportedly a unified estoppel in New Zealand), tort law in Samoa, investigations and fast-track planning procedures under COVID-19-era legislation.

In my last couple of weeks as a Pegasus Scholar in New Zealand, I learned about NZ’s climate change litigation (and their interesting and novel approaches to it). My key takeaways were:

Lawyers for Climate Action NZ (https://lnkd.in/ePaNwduB) – a phenomenal group of lawyers and academics using the law to drive more effective action on the climate crisis. Smith v Fonterra [2024] NZSC 5 – the Supreme Court refused to strike out Mr Smith’s claim that eight polluting companies were causing a public nuisance, actionable in tort law (amongst other torts).

Lawyers for Climate Action NZ v Climate Change Commission & Minister for Climate Change [2022] NZHC 3064 – judicial review proceedings against the Climate Change Commission alleging its advice to the Minister was not ambitious enough to contribute to limiting global warming to 1.5°C over the course of the decade. This was based on an alleged mathematical or logical error in recommending emissions reduction targets by reference to NZ’s gross 2010 emissions rather than net. The application was dismissed, but is being appealed to the Court of Appeal.

Overall, I had a fantastic time learning about legal life in New Zealand. I gained important insights into novel legal strategies on topics such as climate change litigation, and I improved my advocacy skills by observing some powerful advocates in the High Court and appellate courts. I also made fantastic friends and am glad we are staying in touch via lunches in Lincoln’s Inn in London when my colleagues visit this way.

Anna Dannreuther Old Square

USA

By Hannah Gilliland

One of the benefits of other corporate jobs is that there are often opportunities for international travel. Having become a barrister, and one practising in defamation which is uniquely defined by English and Welsh law, I accepted that such opportunities may not await me. So, when I found out about the Pegasus Scholarship, I knew I had to apply.

The first stop on our USA trip was Sacramento, California and the incredible programme put together by Justice Scotland. California brought so many highlights, including the opportunity to see appellate advocacy. I was interested to learn that in appellate courts the judges would often frontload the case and have an idea of how the case would be decided before oral arguments were heard. The emphasis on the written brief and the timed oral arguments (policed in some occasions by traffic lights) was also fascinating. While this loses some of the spontaneity and the flexibility to pursue different areas of the argument, I couldn’t help but think that, in terms of efficiency, this was a more effective system. Our California trip was incredible and thanks must go to our hosts, Parker White and Carole McCook. Not only did they let us stay in their home, but they also took us to their cabin on Lake Tahoe where we were lucky to see an enormous bear sitting just outside the window!

Our arrival in Phoenix, Arizona was thankfully precipitated by the first rainfall for months following a 113 day streak of temperatures over 37 degrees Celsius! Our first day included a tour of the various community courts in Phoenix. These included a veteran’s court, a community court dealing with homelessness, and a mental health court. I was impressed with the more empathetic approach to justice, yet I also questioned whether if, for example, there had been more investment in veterans after they left service, such courts would need to exist. Another interesting aspect of the US legal system which we were fortunate enough to watch was jury selection. I was fascinated to watch as the jurors were asked various questions by the judge and counsel before both sides could choose to strike certain jurors based on their answers. Jury selection, whilst interesting, seemed to be somewhat inefficient. Days can be spent questioning potential jurors looking for bias and partiality. The result is that many more jurors must give up their time to sit for selection, only to be sent home without having served. I must admit to preferring the English system. Phoenix was a vibrant city and, away from law, we enjoyed visiting the Desert Botanical Garden, hiking amongst the unique desert rocks, sampling Mexican food and drinking margaritas! It was also a treat to see Air Force One take off from the runway at Phoenix as we departed. Thank you to John DeStefano who kindly hosted us during this leg.

Our arrival in Washington DC began with the Supreme Court Celebration of Excellence dinner, which set the bar for a fantastic two weeks. There were so many highlights of our time spent in DC, including our meeting with the Solicitor General of the United States, Elizabeth Prelogar. Another highlight was watching a moot court at the Supreme Court Institute. Moot courts take on a greater role in the US, with legal teams frequently running their entire case as a dress rehearsal before the main event. It was amazing to see how much preparation had gone into preparing for the moot: the full legal team attended, the Bench was comprised of multiple esteemed ‘judges’ and the moot court room was made to be a replica of the Supreme Court, even down to the pattern on

the carpet and the distance of the podium away from the bench. Another highlight of DC for me was speaking on a panel at the William B. Bryant Inn of Court alongside Adam Nadelhaft, a member of Amber Heard’s counsel team in the famous Johnny Depp litigation. It was exciting to hear Adam’s perspective on the case and to share with the audience the differences in our two countries’ defamation laws. Away from the law, it was, of course, an incredibly exciting time to be in DC in the build up to the election. We were able to attend the Democratic Party’s election night event at Howard University and, in a standout moment of the trip, we saw Kamala Harris speak at Howard University the next day.

Thanks must go to Ellen and Tim DelSole, Jesse Binnall and everyone from Binnall Law Group who so kindly hosted us.

The final stop on our tour was to Chicago, a vibrant and exciting city. During our time there, we had a varied schedule which began with a tour of the FBI offices. Next, we paid a visit to the Circuit Court of Cook County criminal division, commonly known as ‘26 and Cal’, to observe proceedings with Judge Byrne. I was particularly interested to learn about the Grand Jury where jurors are called to serve for a month in proceedings from which the public are excluded. It was interesting to learn that the jury sits in secret to protect them from intimidation, ensuring their independence and objectivity in assessing the evidence and protecting innocent people from unfounded prosecution. Chicago was a brilliant place to visit and I must thank Peggy Herrmann, Adam Kelly and Julianne Hartzell for hosting us so well.

Finally, a big thank you to Cindy Dennis who put together this incredible programme; it exceeded all my expectations. Thank you also to my co-scholar Afiya for being so much fun. We had the trip of a lifetime!

Hannah Gilliland 5 RB

NEW ZEALAND

By Ian Cooper

I am a business and property barrister at King’s Chambers (2019 Call) and was fortunate to be a New Zealand Scholar in the 2024 Pegasus Scholarship Scheme.

I spent three months at Bankside Chambers in Auckland, from September to November 2024. The placement was co-ordinated by my ‘handler’, Jason Goodall KC, a commercial practitioner at Bankside.

Out in New Zealand, I did not have any rights of audience to appear in court. As such, while I would normally be in court three or four times a week in England, as the ‘pom’ in chambers, I had three months of junior briefs, assisting senior members in chambers with their ongoing cases.

Over the three-month placement, I saw a huge range of commercial work, much of it, unsurprisingly, with its own Kiwi-stamp. The very first case I was involved in was a private nuisance case in which a wine vineyard on the South Island alleged that a neighbouring farmer’s fires had caused smoke damage to their vines, thus impairing their wine.

Unfortunately, not all of my cases involved vineyards. Nevertheless, one feature of commercial litigation in New Zealand is the extent of Chinese investment. During my time, I saw a number of interesting matters concerning Chinese litigants and investors, including a three-week commercial trial with Jason Goodall KC focusing primarily upon alleged penalty clauses.

One distinctive aspect of New Zealand litigation more generally is the role of the Māori people and their history. While I was at Bankside, Justice Kós, the chairman of the Pegasus Committee in New Zealand, organised a day for me to observe an appeal in the Supreme Court in Wellington. The case concerned the test to be applied when asserting customary marine title and associated rights over the foreshore and seabed under the Marine and Coastal Area Act 2011.

Sitting as an English lawyer in the Supreme Court of a common-law country, there were a lot of te reo Māori terms being used that I simply had not come across before. The case raised issues such as whether the mandate to bring an application for customary title was still held by an iwi, or whether it had been lost by virtue of hapū making their own applications. Without any hyperbole, it really was fascinating to observe the case. To understand the issues, one first had to understand Māori culture and society, as well as New Zealand constitutional history. The case also demonstrated the need for lawyers to show both intellectual flexibility and cultural sensitivity when working at the precarious interface of the common law and Māori tikanga.

Away from the courtroom, one of the stated purposes of the Pegasus scheme is to forge links with lawyers abroad. Looking back, it is this aspect of my time I value most highly. Members of chambers welcomed me with open arms, showing great warmth and support. For example, one member of chambers hosted me for a weekend of skiing on the South Island and later invited my partner and me over for dinner on Christmas Day.

A particular chambers highlight away from the courtroom was helping Bankside beat Shortland Chambers in their inaugural golf competition (mainly down to a generous handicap!).

Finally, it would be remiss not to mention life away from chambers more generally. The Pegasus Scholarship offers scholars the opportunity to spend a prolonged period of time abroad, exploring a foreign country. Having never visited New Zealand before, it did not disappoint. While I was based in Auckland, I never got over the fact that you could leave chambers at 6.00pm and be on a surfboard or sitting in a sailing dinghy less than an hour later.

Further away from the city, the beauty of New Zealand is well-documented, and I took the opportunity to travel on the South Island after my placement in Auckland finished. Indeed, the South Island will hold a special place, as my partner and I got engaged on our trip while kayaking in Abel Tasman.

To summarise, for anyone considering the Pegasus Scholarship, I could not recommend it highly enough. I thoroughly enjoyed my time out in New Zealand and regard it as one of the highlights of my professional career to date. I made a number of firm friends, who I have stayed in touch with since. Indeed, I am hosting some next year to return the kindness they showed me.

I should finish by extending my particular thanks to Justice Kós and Jason Goodall KC for making the placement possible; to Michael Morrison for letting me squat in his room; to Simon Foote KC, James Clarke and Josie Butcher for all of their advice, travel tips and support; and, finally, to Sam Jeffs and his family for Christmas lunch!

Ian Cooper King’s Chambers

NEW ZEALAND

By Amy Taylor

I was delighted to be selected as a Pegasus Scholar in 2024. I was placed in the Constitutional and Human Rights (CHuR) team at Crown Law Office (CLO). CLO provides legal advice and representation to the government of New Zealand in matters affecting the executive government particularly criminal, public and administrative law.

My line manager in CHuR was keen to ensure that the scholarship lived up to my expectations and asked whether I would like to get involved with the other teams and the type of cases I wished to observe and work on. My practice at the Bar in the UK includes crime and therefore I was keen to observe criminal cases and speak to the criminal lawyers at CLO this was arranged almost immediately. Prior to starting my placement, I travelled around New Zealand, exploring the North Island, South Island and Stewart Island. I became increasingly interested in the Treaty of Waitangi and Waitangi Tribunals and I am grateful that the Treaty team at CLO welcomed me with open arms: I attended their weekly meetings, team away day and training sessions (as well as some of their homes, having been invited over for dinner and drinks).

My time at CLO surpassed my expectations. My first week involved a drinks reception at the Supreme Court with several Supreme Court judges, clerks (the equivalent of judicial assistants in the UK), colleagues and a fellow Pegasus Scholar who was placed with Stout Street Chambers. Over the course of three months, I observed cases in the High Court, Court of Appeal and Supreme Court. I undertook research and drafted documents, including submissions in respect of a long standing extradition case and a memorandum for the Solicitor General on whether a second inquest should be ordered.

Each hearing or case would draw my attention to similarities and differences between the legal system in England and Wales and that in New Zealand. One difference is that there is a much greater focus on written submissions in New Zealand. The oral hearings I observed focused on key points or additional information and did not involve taking the judge(s) through the written submissions in detail. This saved a significant amount of court time. For Supreme Court cases, the written submissions from parties are published on the website and I think this is something we should adopt in the UK. Having such documents readily available enables people of all levels (including students) to easily read and learn from high quality submissions.

Within CLO, there is a strong focus on improving your legal knowledge and skills. This includes frequent training sessions within the office, for instance on pleadings and theory of cases and giving effective legal advice. As well as attending those training sessions, CLO arranged for me to attend a tour of Parliament, a talk by Justice Miller (a Supreme Court judge) and Daniel Kalderimis KC regarding appellate advocacy and the Government Legal Network Conference.

The Government Legal Network Conference began with a waiata (a traditional Māori song) and a showing of a video made for the opening of Tākina (Wellington’s Convention and Exhibition Centre where the event was held). I found the video very moving and felt so privileged to be present at that conference (the video can be found here: youtube.com/ watch?v=J-xbrq1B_vQ). At the conference, there were talks on a variety of topics and the speakers included the Solicitor General, Deputy Public Service Commissioner and Executive Director for the Justice Sector (Ministry of Justice).

My clerks at Six Pump Court were supportive of me making the most of my time in New Zealand and so my three month placement became a five month adventure. My partner came with me and before I started at CLO, we bought a campervan which we lived and travelled in for several weeks. Highlights of my trip include sandboarding at Te Paki sand dunes, hiking the Mueller Hut route and looking for kiwis on Kapiti Island.

I will always look back on my time at CLO with very fond memories and I am extremely grateful to the Pegasus Scholarship Trust and CLO for the opportunity. The exposure to human rights law and different types of government work inspired me to work towards incorporating these areas into my practice in the UK.

I am extremely grateful to the Pegasus Scholarship Trust for the opportunity to immerse myself in the legal system in New Zealand. I was placed at Crown Law Office, which provides legal advice and representation to the government of New Zealand in matters affecting the executive government. I spent most of my time working in the Constitutional and Human Rights team, dealing with cases concerning breaches of the New Zealand Bill of Rights Act 1990, extradition and inquests.

I thoroughly enjoyed observing and working alongside impressive and inspiring lawyers and discussing the differences and similarities between the legal system in New Zealand and that in the UK. I found the cases incredibly interesting, and this experience motivated me to include human rights and different types of government work in my practice in the UK.

Amy Taylor Six Pump Court Chambers

INDIA

By Toby Roseman

You hear vastly varying opinions of Delhi, but my experience was a positive one, and I count myself lucky to have spent two months there as a Pegasus Scholar in 2024. The people, the food and the culture in Delhi made for a truly unforgettable experience.

As a criminal practitioner, the Hingorani Foundation (the point of contact for Pegasus Scholars) went to great lengths to ensure that I was able to experience all levels of the criminal justice system in Delhi.

My first placement was with an eminent Senior Advocate (similar to our King’s Counsel) named Maninder Singh, who kindly took me under his wing for the first few weeks. I shadowed him in the High Court, where he primarily practises. I witnessed various serious matters, including murder, rape and terrorist offences. Most strikingly, the High Court judges each have between 100 and 200 cases in their lists each day. Therefore, each courtroom was crammed full of advocates, accompanied by colleagues and a clerk or two. The result of such busy lists meant that each case would only ever have a few minutes to be heard. As such, advocates would have to be quick, precise and to the point; with a small window to grab the judge’s attention, the punchier their submissions, the better. Not only was the experience in the courtrooms fascinating, but the High Court’s canteen boasts the best fare of any of the courts (as argued by the regulars of the High Court, but I wholeheartedly agree, having taken it upon myself to try the canteens at every other court I visited). As such, my time outside of the courtroom was usually spent talking to one of the many friendly, intriguing and engaging advocates that frequent the High Court, over an iced coffee, butter chicken curry, or a bun samosa (a truly wonderful invention consisting of a samosa in a burger bun).

My next placement took me around various District Courts with Akhand Pratap Singh and his office. A standout experience here was observing the cross-examination of an eyewitness in a murder trial. The witness only spoke Hindi, but the Court conducts its business in English. To manage this, the witness was seated in between the defence and prosecution advocates on one side of the courtroom. The defence would ask his question in English, which would be noted by the stenographer. He would then repeat the question in Hindi, the witness would answer in Hindi, and then both advocates along with the judge would agree on an English translation for the stenographer. Meanwhile, the judge was presiding over other matters: an application being made in the middle of the courtroom, and new hearing dates being given on the far side. It was an awe-inspiring exercise in multitasking.

Next, I was in the Supreme Court with Vikramjit Banerjee and his colleagues. One of the most fascinating cases here was in the Supreme Court, when watching the submissions of the Appellant in a case concerning changing the law to criminalise a husband raping his wife. This seemed like a momentous moment in the progression of women’s rights in India, and the standard of advocacy involved was inspiring.

My placement culminated in spending two weeks working under the Attorney General for India, R Venkataramani. The casework I was exposed to here was of great importance and magnitude, often concerning cases between various Indian states and the Indian government. These ranged from matters involving the extent of taxes levied on grain to the legality of the restitution of conjugal rights within Hindu marriages. I was extremely fortunate to be afforded the opportunity of working in this particular office.

Aside from my exposure to the legal system in Delhi, I spent much of my spare time exploring the plethora of historical and cultural sights that Delhi has to offer and eating my way through many of the incredible eateries that abound.

I was extremely fortunate in the accommodation I found, because I was hosted by a wonderful, fascinating and rather eccentric old gentleman named Murad Ali Baig. He is a retired author and historian, and he took great delight in telling me about the history of Delhi and recommending what sights to see (even providing me with a book on the history of India that he had written: 80 Questions to Understand India).

In keeping with the generosity and kindness that I was met with from so many of the people I encountered, I was fortunate enough to be invited to several Diwali parties at the end of my placement. I had a particularly enjoyable evening, hosted by Maninder Singh, which consisted of eating, drinking and playing cards into the small hours of the morning with many of his wonderful colleagues. I even left the evening with more rupees than I came with.

This whole endeavour would not have been possible without the assistance of The Inner Temple and the Pegasus Trust, or the wonderful Hingorani Foundation. One of the standout features of this placement was the opportunity to spend time with the Hingorani family, Dr Aman, Priya and Shweta. The three siblings have such impressive careers and were a delight to speak with. They were extremely kind and welcoming, and I am very grateful to them for hosting me in Delhi. The placement was a truly enriching experience that I will never forget.

Toby Roseman Goldsmith Chambers

BERMUDA

By Scarlet Taylor-Waller

With work keeping me busy, it wasn’t until I was sitting on the BA flight to Bermuda on a late August afternoon that it sank in – I was moving to an island in the middle of the ocean, where I didn’t know a soul and had no idea where I’d be living! But I needn’t have worried. What followed were six incredibly rewarding weeks filled with interesting work, welcoming people and some of the most beautiful beaches I’ve ever seen.

Bermuda is an island located around 640 miles off the coast of North Carolina, with a population of around 64,550 people. Roughly 20–30 per cent of the population are expats. Whilst most expats work in insurance or reinsurance, a good portion are foreign-qualified lawyers from the UK, Ireland, Australia, New Zealand and South Africa. Its legal system is very similar to that of the UK, and it offers a unique opportunity for junior lawyers to engage with the Supreme Court Rules 1985. The Bermuda court system consists of the Magistrates’ Court (handling both criminal and civil claims), the Supreme Court and the Court of Appeal. The final court of appeal is the Privy Council. The legal profession is a fused one, with lawyers being known as attorneys, and only after a year of local practice can foreign-qualified lawyers be called to the Bermuda Bar.

During my time in Bermuda, I was placed with Carey Olsen, a leading offshore law firm which specialises in corporate and finance, restructuring and insolvency, private client, and litigation. I was lucky enough to assist with a variety of complex and high-value matters, including trusts, reinsurance and property disputes. Many of the matters I assisted with also had a cross-border element, which is different from my everyday practice back home. My work

included drafting grounds of appeal, conducting research and assisting with written advice. From day one, I was trusted to get involved and even had the chance to attend a variety of court hearings. Beyond work, I was invited to numerous networking events organised both by Carey Olsen and their clients – networking on a boat or at a beach club in the sun is certainly a far cry from your typical Bar scene! These events were a key part of the placement, and it wasn’t long before I was bumping into familiar faces around the island and forging relationships with lawyers all around the world.

Outside of work, I took every opportunity to explore the island. Personal favourites were relaxing at Elbow Beach, seeing the UNESCO site at St George’s, scuba diving shipwrecks in the triangle and the Swizzle Inn for a famous rum swizzle. That said, be prepared for rain! August to October is hurricane season, and when it rained, it poured! Fortunately, it was never long before the sun came out again, and my colleagues were happy to join me in ticking off all the tourist sites.

My time in Bermuda was an incredible adventure, and I am very grateful to Carey Olsen and the Pegasus Trust. Professionally, I now have practical first-hand knowledge of how another jurisdiction works and have seen how different legal and cultural settings can push you to adapt and become a better lawyer. It is truly a one-of-a-kind opportunity to experience offshore life like this, and I would encourage anyone considering it to apply.

Scarlet Taylor-Waller Five Paper

INDIA

By Siân Beaven

Nothing quite prepares you for India: its warmth, its hospitality, its vibrancy or its volume. The court system is no different. Think queuing for security with the monkeys and buying your court supplies from the High Court kiosk that sells everything from practitioner texts to the most bejewelled cufflinks. But, more than that, think ‘sharpen your elbows’ and abandon that British sense of awkwardness. The courtrooms are packed wall to wall with advocates, most of them junior, acting as an army of support to their senior Head of Chambers. The cases come at an attrition rate I have never seen before.

The court hearings are listed on an almost airport-style departure board, so you can track what is happening in each courtroom. This allows you to sit around in the canteen with a cold coffee and catch up with the juniors from other chambers. One of my big takeaways from India is that you would recognise the Bar anywhere. That sense of camaraderie, the incestuous nature of everyone knowing everyone, the slight hero worship when a big name walks into the room. It doesn’t matter where it is, the Bar is the Bar all over the world. When it’s your case, forget the niceties, you force your way into a court as full as the Northern line at Clapham Common on a Monday morning and you push your way to the judge. As I was told repeatedly, when you have a population of over a billion people, there is a lot of demand and a lot to do, and you just have to roll your sleeves up and get on with it. The courts are extremely busy, the workload is high, the turnaround is quick and the pressure on these young advocates is relentless. From what I can see, they handle it with style.

Unlike in the UK, where the goal is to be taken on, here, the goal is to set up your own practice. I got to watch this sort of reverse-tenancy rite of passage for one of the juniors, Advocate Garvil Singh. Again, the support of the Bar was so apparent, with cake and speeches from his mentor and now former boss, as he set off on this new adventure.

Some of the differences I managed to observe were the legal ones. In India, the blurring between family and criminal jurisdictions is common. I was introduced to the concept of the presumption of a ‘dowry death’, something that is culturally common in India but unheard of in the UK. I witnessed criminal cases being settled by mediation, much more akin to a family

approach. Additionally, it was explained to me that the Indian government is the top litigator in the country. Unlike in the UK, where we are constantly in battle with branches of the government to fund justice, in India, the government is the biggest client, supporting somewhat of a legal boom.

I was blessed to be in Delhi for Diwali. The court holidays provided ample opportunity to explore the history and see the incredible architecture that India has to offer. In Delhi, you are never more than an auto ride away from something breathtaking. The other great part of Diwali is the parties. An especially memorable one came from Senior Advocate Mr Singh, whose rooftop bar and jubilant card games were a particular highlight. Perhaps unsurprisingly, I had no victories to share. My co-scholar Toby was either far more skilled or just much more fortunate!

I spent Diwali day with the amazing Advocate Sanskriti Shakuntala-Gupta and her family, who informed me that “in India, no one does festivals alone”. Sans introduced me to my first Puja, took me to watch her address Indian national television on the importance of representation for female advocates on the Bar council and treated me like a sister throughout my time stationed with her chambers. I will forever be indebted to her kindness.

I wish to extend a particular thanks to everyone at the chambers of Senior Advocate Vikas Pahwa and to all those involved in organising at the Hingorani Foundation. I spent most of my placement with Mr Pahwa’s chambers, who were the most welcoming and inclusive people you could ever hope to meet. Mr Pahwa is an absolute legend of the profession. His knowledge is unrivalled and his advocacy formidable, and yet, he is a kind and devoted mentor who assisted me greatly in my time spent with him. I was also afforded the opportunity to have lunch with a judge, which was all facilitated by another fantastic junior, Advocate Nancy Shamim. This was another once-in-a-lifetime experience that I feel very blessed to have had.

India is a place that gets under your skin, but it is the people that I met and the friendships I have made that I shall cherish most about my time as a Pegasus Scholar! That, and the fact that my name means ‘pride’ in Hindi.

Siân Beaven Pump Court Chambers

LAUNCH OF THE INTERNATIONAL CIRCUIT

By the Master of the International Circuit

On 5 February 2025, the Inn hosted a reception to launch its International Circuit (formerly the European Circuit). It was attended by about 80 people comprised not only of members of the Bar and Judiciary (from all Inns), but also by guests representing international organisations with which the Inn has developed a working relationship.

As was pointed out during the course of my welcoming remarks, the Inn is privileged to have amongst its Benchers those who hold or have held distinguished positions in international organisations, including Dame Rosalyn Higgins (first female President of the ICJ), Sir Konrad Schiemann (Judge at the Court of Justice of the European Union) and Justice Adrian Saunders (President of the Caribbean Court of Justice), to name but a few (see link to more details below).

The Inn has an extremely active International Committee, which in the past 12 months has contributed to – and in some cases initiated – projects as wide-ranging as international moot competitions, seminars on diverse legal topics and rule of law matters, the most important of which is the provision of assistance to lawyers and judges in Argentina which is transitioning from an inquisitorial to an adversarial form of trial. Additionally, members of the committee assist with requests from the Bar Council, Judicial Office and Foreign, Commonwealth & Development Office (FCDO), and others, to host overseas visitors.

The purpose of the Circuit is to build upon the work of the International Committee and encourage those who join to take part in and, indeed, initiate projects in which the Inn may be of assistance. Amongst the Inn’s staff are individuals, such as Jennie Collis Price, who have developed considerable experience in dealing with international projects. However, it is also intended that it will provide a forum for exchanges of ideas with overseas colleagues and thereby promote contacts with such colleagues.

The Inn plans to hold at least one major social event each year in pursuit of these goals. Members of the Inn who have an international practice or are interested in international affairs are strongly urged not only to join the Circuit but to contact either Jennie or the Secretary to the Circuits Committee, Jude Hodgson, with any proposals they may have for projects relevant to the aims of the Circuit.

Her Excellency Judge Korner CMG KC Master of the International Circuit

Distinguished International Members | The Inner Temple innertemple.org.uk/intlaunch

THE COIC MATCHED FUNDING SCHEME

COIC welcomes applications for matched funding for 2026–27 and 2027–28 pupillages.

The COIC Pupillage Matched Funded Scheme (PMF) helps provide additional pupillages in Chambers, and other approved training organisations, predominantly engaged in legally aided work. Encouragingly, a growing number of Chambers are applying for COIC matched funded grants.

How the scheme works

The Inns provide the funds for the Pupillage Matched Funded scheme administered by COIC. It is a prerequisite of the scheme that chambers understand that matched funded pupillages are in addition to those they would have offered in any event. COIC match pupillage funding already provided by chambers with a total grant of £12,000 for 2026–2027 London pupillages and £11,000 for 2026–2027 out of London pupillages and, £12,400 for 2027–28 London pupillages and £11,350 for 2027–28 out of London pupillages, to fund the first six months of a second pupillage. Chambers are responsible for ensuring that the total pupillage award meets the BSB’s minimum award for the year in question.

COIC works with the Inns of Court in strengthening the rule of law through excellence in professional and ethical education and in maintaining the highest standards of professional conduct. As an AETO funded primarily through publicly funded advocacy, Furnival Chambers especially welcomes the opportunity enabled by the COIC’s Matched Funding scheme. Furnival Chambers’ pupillage selection process is focused upon intellectual ability, analytical skills, advocacy abilities (written and oral), temperament and interpersonal skills, and commitment to the Bar. The COIC Matched Funding scheme allows us to fund and support more pupils (4 per year, and therefore also allows greater scope still for inclusivity and diversity. We are hugely grateful for this initiative, and will continue to reciprocate with COIC towards our common goals.

Julian Bradley Chambers Manager, Furnival Chambers

How to apply

Applications to match fund 2026–2027 and 2027–2028 pupillages are invited between 1 September and 17 October 2025. Decisions will be communicated during the week commencing 3 November 2025. Online applications can be made at coic.org.uk/pupillage-matched-funding

To find out more please email Hayley Dawes at COIC on hdawes@coic.org.uk

Mrs Justice Lieven Chair, COIC Pupillage Matched Funding Grants Committee

At Mountford Chambers, pupillage marks the start of a transformative journey, one that challenges, inspires and shapes the foundation of a lasting career in criminal advocacy. We offer 12 to 18 month pupillages grounded in criminal law, but shaped by the diversity of our work. Our Chambers is defined by a strong sense of community, uncompromising standards and a forward-thinking commitment to the evolving demands of modern criminal practice.

We invest deeply in our pupils. Training is structured, supportive and practical. Pupils are exposed to serious work and mentored by leading practitioners throughout. Our members invest significant time and care in both pupillage and mini pupillage, ensuring that each candidate receives meaningful insight, guidance and support.

Our application process is transparent and we welcome candidates from all backgrounds who can demonstrate sharp thinking, integrity and a commitment to advocacy. At Mountford Chambers, you’re not just learning the job, you are learning how to thrive in it.

We are incredibly grateful for initiatives like COIC’s matched funding scheme, which plays a crucial role in enabling us to offer high-quality pupillage programmes and continue investing in the future of the profession.

Alan Kent KC Head of Pupillage, Mountford Chambers

HISTORY OF THE WEST DOORWAY, TEMPLE CHURCH

By Master Catherine Callaghan

At the time of preparing this edition of the Yearbook, the Inn learned of the sudden and untimely death of Master Catherine Callaghan. Master Callaghan had, a short while before her death, generously offered for publication in the Yearbook this study of the Temple Church West Door, a project close to her heart, especially because she and Andreas Gledhill were married there on 21 April 2018.

Catherine was also a Trustee of the Temple Church Trust. We are most grateful to Andreas for his permission to publish Catherine’s article as a testament to her work – and are privileged to do so.

Temple Church is situated at the heart of legal London, in an enclosed enclave between Fleet Street and the Thames (Figure 1). The church serves as the collegiate chapel of The Inner and Middle Temples. But it was originally built as the main English church of the Knights Templar, the medieval religious-military order founded to protect pilgrims to the Holy Land. As they did elsewhere in Europe, the Templars built a round-naved church (Figures 2A–B), which was intended to recreate the Rotunda of the Church of the Holy Sepulchre in Jerusalem (Figure 3). At the western end of the round nave is the West Doorway, which is protected by a deep porch (Figures 5A–B).

Figure 1. Unknown artist, Map of the Temple area, London, present day © Temple Music Foundation

Figure 2B. View of interior of round nave and chancel looking east, Temple Church, London © Temple Church

Figure 2A. View of exterior of round nave, Temple Church, London, 3 December 2024 © Photo by author

Figure 3. Gerd Eichmann, View of exterior of Church of the Holy Sepulchre, Jerusalem © Gerd Eichmann

The West Doorway Is built of Caen stone from Normandy, a cream-coloured durable limestone. It is large and imposing, measuring approximately 4 metres high and 4.4 metres wide. It consists of a semi-circular Romanesque arch recessed in seven orders of alternating high-relief foliage carving and plain mouldings. The moulded arches spring from leafpattern capitals with plain columns below, while the carved arches sit above unusual half-figure busts, supported on shafts embellished with geometric and floral patterns (Figure 6).

There are four busts on each side of the door. The busts on the north side are wearing caps or turbans, and several wear tunics with buttons down the front (Figure 7). Before the 14th century, buttons were not generally worn in England and were considered oriental, so these figures may have been intended to represent Muslim infidels whom the Templars were called to fight. The busts on the south side are bareheaded and may have been intended to represent Christians (Figure 8).

No foundation documentation survives, but scholars now date the construction of the round nave (and therefore the West Doorway) to circa 1160s based on documentary and architectural evidence. In 1161, the Knights Templar sold their initial London base in Holborn, which included a round church, to the Bishop of Lincoln, and relocated to the current Temple site, so the replacement round church is likely to have been useable by then. In 1163, the body of Geoffrey de Mandeville was buried in the cemetery or ‘the porch before the west door’ of the church. The first reference to a completed church appears in the Archbishop of York’s indulgence, issued sometime between 1164 and 1181. Christopher Wilson considers that the similarities between the foliage scrolls on the archivolts of the West Doorway and the scrolls on the hemicycle capitals at Dommartin in northern France (c 1153) are so strong that they are likely to have been made by the same sculptors.

Figure 5B. View of Western Porch, Temple Church, London, 3 December 2024

© Photo by author

Figure 6. Frederick Nash, Entrance to the Temple Church, circa 1818, watercolour (Royal Society of Antiquaries)

Figure 4b. William Emmett, The South Side of the Temple Church, 1702 © Royal Society of Antiquaries

Figure 4c. View of chancel, Temple Church, London, 3 December 2024 © Photo by author

Figure 5A. View of West Doorway, Temple Church, London, 3 December 2024

© Photo by author

The West Doorway, with its ornate and imported Norman stone, would have powerfully conveyed the wealth, status and French origins of the Knights Templar. Medieval visitors would have viewed the West Doorway as the gateway to a church that directly evoked the place of Christ’s death and resurrection, and indeed Jerusalem itself, the centre of the medieval world.

After the Knights Templar were suppressed in the early 14th century and their property was seized by the Crown, lawyers moved in to lease the Temple area. In 1608, King James I granted the freehold of the Temple area to The Inner and Middle Temple in perpetuity on condition that they maintain Temple Church at their own expense, a sign of its religious and historic value.

By the late 17th century, shops and lodgings had been built against and around the church, including under the porch against the West Doorway, suggesting it fell out of use and lost significance at this time. However, a revived interest in the early Gothic architecture of the church, together with the Inns’ concern to protect the fabric of the church and improve the urban environment, led to the removal of the adjacent buildings in the 1820s. The West Doorway was visible again!

From 1840 to 1843, Temple Church underwent a major restoration under architects Sydney Smirke and Decimus Burton, costing an eye-watering £70,000. In 1842, the architects reported that the carved arches on the West Doorway were “so perished as to be for the most part incapable of receiving reparations and … ought to be entirely new”. Surprisingly, their 1845 report on the church restoration contains no reference to any work carried out on the West Doorway. However, at least four original voussoirs from the arch of the West Doorway were removed during that period and subsequently donated to the Victoria & Albert Museum (Figures 9A–D). Recent investigations have found that at least the innermost order of the arch, the leaf-pattern capitals and the plain columns were rebuilt with Caen stone in the 1840s (Figure 10).

The Victorian restorers made two well-intentioned but ultimately disastrous interventions. First, they used Caen stone quarries of lower quality than those in use in the 12th century; as a result, the 19th century replacements decayed rapidly. Second, the entire doorway was then painted with white lead, presumably to unite the appearance of old and new stonework. The application of an impermeable leadbased paint caused “gross damage” to the stonework. Multiple treatments were applied to arrest the decay over the next hundred years.

Figure 7. Frederick Nash, West Door Temple Church (north side), circa 1818, pencil on paper © Royal Society of Antiquaries

Figure 9C. Voussoirs from West Doorway, 12th century © V&A, London

Figure 9A. Voussoirs from West Doorway, 12th century © V&A, London

Figure 9B. Voussoirs from West Doorway, 12th century © V&A, London

Figure 8. Frederick Nash, West Door Temple Church (south side), circa 1818, pencil on paper © Royal Society of Antiquaries

Figure 9D. Voussoirs from West Doorway, 12th century © V&A, London

On 10 May 1941, German incendiary bombs destroyed the roof and interior of Temple Church but left the West Doorway largely unscathed (Figures 11A–C). As a result, the doorway was untouched during the subsequent extensive restoration by Walter Godfrey. However, the wartime damage to the roof likely caused water ingress which further decayed the stonework.

By the 1980s, soot deposits combined with traditional treatments of hot oil or wax and limewash had resulted in an impervious skin of calcium sulphate with a build-up of moisture and chemical salts beneath. Where this skin had burst, more rapid decay set in. In 1984, the West Doorway was cleaned by air abrasive methods. In 1998, further cleaning was undertaken by laser.

Today, although much of the stone is in an advanced state of decay, the West Doorway retains a faded magnificence. The doorway and the church have become a tourist destination, particularly for fans of The Da Vinci Code. The doorway is used for special occasions, such as Call to the Bar ceremonies and weddings of members of Inner or Middle Temple (including the author) (Figure 12). As a result, it lives on in countless graduation and wedding photos.

Now the next chapter begins, as the Inns embark on a major programme of repair and restoration to the West Doorway, aimed at minimising the rate of decay, preserving the integrity of the 12th century carving, and re-introducing the West Doorway as the principal entrance to the church. Funding worth millions of pounds has been secured from the Inns and generous donors around the world, a mark of the doorway’s continued social and cultural significance.

Catherine Callaghan KC 1971–2025

For the full article with footnotes: innertemple.org.uk/westdoorway

Figure 11C. Unknown artist, View of interior of Temple Church after bombing and fire on 10 May 1941 © Temple Church

Figure 11B. Unknown artist, View of Temple Church exterior after bombing and fire on 10 May 1941 © Daily Mirror

Figure 11A. Unknown artist, Fire to roof of Temple Church, 10 May 1941 © Temple Church

Figure 12. Fran Hales, View of author and author’s husband in front of West Doorway, Temple Church, London, 21 April 2018 © Author’s own collection

Figure 10. Odgers, David. Temple Church, West Doorway: Final report on investigations and trials. Odgers Conservation Consultants. January 2018. Unpublished. Figure 61.

HISTORY SOCIETY REVIEW REFLECTING ON A YEAR OF INSIGHT AND SCHOLARSHIP AT THE INNER TEMPLE

By Master Donald Cryan

The Inn’s commitment to legal education and intellectual engagement has thrived in the last year. There are various series of lectures and discussions aimed at not only expanding our understanding of the law in its social context but also celebrating the rich history that moulds it. This year, The Inner Temple History Society has shot its spotlight on influential legal figures, historical rivalries and landmark cases, each contributing to the tapestry of our legal heritage.

For the last five years, The Inner Temple History Society has collaborated with the Selden Society and the history societies of the other Inns to present an important public lecture on aspects of legal history which are of general interest.

In October 2024, Rt Hon Lord Neuberger delivered the Selden Society’s Inns of Court Annual Lecture. In the talk A Scotsman Caught Young: Influences Which Shaped Lord Mansfield, Lord Neuberger spoke of the formative experiences that shaped one of the most pivotal figures in English law. Lord Mansfield’s exceptional legal mind and innovative approach have left an indelible mark on the common law, particularly regarding the emergence of commercial law and the concept of justice.

Lord Neuberger not only considered Lord Mansfield’s legacy but encouraged an examination of how the influences of culture and personal experience shape legal thought. His insights into Mansfield’s early years provided a compelling narrative of intellectual evolution and personal hardship, prompting reflection on the intersection of biography and legal history in shaping the working of the judicial mind and, through that, precedent.

Also in October 2024, The Inner Temple’s own History Society in its Michaelmas term talk dealt further with that theme. The Rt Hon Jesse Norman MP captured the audience’s attention with his exploration of the intense rivalry between Sir Edward Coke and Sir Francis Bacon in his lecture, The Winding Stair: Inside the Bitter Rivalry of Edward Coke and Francis Bacon (and its consequences). These two seminal figures, from The Inner Temple and Gray’s Inn respectively, not only vied for power during a politically tumultuous era but also engaged in a profound intellectual contest that had an impact on the course of English and, indeed, American legal thought.

The vivid narrative underscored how personal vendettas transcended professional boundaries, influencing judicial decisions and public policies. The friction between Coke’s use of legal history and, in particular, the Magna Carta to support what we now think of as human rights and Bacon’s pragmatic pro-executive approach resonates to this day. Understanding this rivalry illuminates the ongoing struggle to maintain the rule of law in the face of a wilful executive.

The spring 2025 talk involved further collaboration between the Inns, this time between Inner and Middle Temple, and a change of format. On March 26, Master Doe and the Dean of Arches, Morag Ellis KC, spoke of the rich history of the ecclesiastical legal system in their joint lecture entitled The Court of Arches: The Appeal Court of the Archbishop of Canterbury. Through meticulous historical analysis, Professor Doe traced the evolution of the Court of Arches from its medieval roots through the Reformation, whilst the Dean of Arches highlighted the present-day workings of the court since the Ecclesiastical Jurisdiction Act of 1963.

Together, their exploration demonstrated the enduring relevance of ecclesiastical law in contemporary legal practice, emphasising its foundational principles and ongoing contribution.

Together, their exploration demonstrated the enduring relevance of ecclesiastical law in contemporary legal practice, emphasising its foundational principles and ongoing contribution.

In the summer term talk, Professor Michael Lobban of Oxford University provided another compelling narrative with Religious Disputes and the Custody of Children: Dr Barnado in the House of Lords. In the context of the 19th century, he examined the pivotal role of religion in shaping child custody disputes, particularly through the lens of Dr Barnado’s fervour against Catholic agencies seeking custody of children.

The cases he highlighted reflected broader societal tensions regarding religious identity and parental rights, situating Dr Barnado’s battles within a framework of legal reform that would ripple through subsequent generations. The challenges he faced continue to resonate in modern debates concerning the intersection of religion and family law.

The past year at The Inner Temple has fostered a rich dialogue around the intertwining of law, history and literature. Each session has brought forth new insights and questions, while reminding us of our duty to learn from the past as we navigate the challenges of the future. Looking ahead, we eagerly anticipate more opportunities for engagement, scholarship and growth as we build upon the foundations laid by those who came before us.

The next legal year will be equally interesting. On 29 October 2025, The Inner Temple History Society will host an important symposium. The Inn has acquired an early (fourth edition) of John Milton’s Paradise Lost, once owned by Charles Killigrew, Queen Anne’s Master of the Revels, and annotated with the names of various nobles and notable members of the Inn.

The Inn’s current Master of Revels, Dr Tom Kinninmont, in conversations with Professor Joe Moshenka and Dr William Poole, will consider the cultural and historical significance of Milton’s work within the legal and political sphere. The inclusion of stage directions and annotations revealing the names of influential figures presents new avenues for exploration of the role of literary works in shaping the cultural life of the Inn in the late 17th and early 18th centuries. As far as current research shows, it was never in fact performed in the Inn, but it is hoped that Master Kinninmont will direct a semi-staged version of part of the work in 2026.

Two further important talks will be of very great interest, not least because of the eminence of the speakers. The 2025 Selden Society and Four Inns’ talk will be delivered on 11 November 2025 by Master Jonathan Sumption (Lord Sumption) on the subject The Judge as Historian. In the spring of 2026, Master Professor Sir John Baker will talk on the earlier history of the Bar, attorneys and serjeants at law. He will address some of the misapprehensions about the divided profession, the reason why we had serjeants and how the domestic degree of barrister became a qualification. In so doing, he will also correct some of the urban myths that have begun to appear on the web and elsewhere about the Inn and the early profession.

His Honour Donald Cryan (Hon) LLM Chair of the History Society

innertemple.org.uk/historylectures

Selden Society-Inns of Court Annual Lecture 2024: innertemple.org.uk/mansfield

Publicity image for The Winding Stair: Inside the bitter rivalry of Edward Coke and Francis Bacon (and its consequences)

THE INNER TEMPLE SUMMER PARTY

SOCIAL CONTEXT OF THE LAW: ENVIRONMENTAL LAW: REGULATION AND THE RIGHT TO PROTEST

Taken from a panel discussion held on 15 October 2024, between Master Stephen Simblet and Sudhanshu Swaroop KC, moderated by Master Saira Kabir Sheikh.

Saira Kabir Sheikh KC: Climate change and environmental catastrophe are real and pressing issues. They are the issues of today. But there is nonetheless a view that protests need to be within the boundaries of the law and to respect the rights of others who are also entitled to exercise the rights that have been given to them in a democratic society.

We’re going to explore some of the recent decisions of the civil and criminal courts, talk about Articles 10 and 11 of the European Convention on Human Rights (ECHR), and look at the way they’ve been dealt with by the courts.

Stephen Simblet KC: The first thing to say is that very few of the rights and freedoms that we all enjoy would have occurred without some form of disruptive protest. Magna Carta was the product of armed confrontation between the King and the barons. We’re sitting in The Inner Temple, one of the places stormed by Wat Tyler in the Peasants’ Revolt, where it was burned. Subsequently, the serfs gained more freedom, the Poll Tax was abolished and we didn’t have another Poll Tax introduced until Margaret Thatcher tried in 1990, resulting in a series of demonstrations and protests, and the Poll Tax was defeated.

The planning for this talk took place in the Gandhi Room, which is a room commemorating a man disbarred by The Inner Temple for his actions campaigning successfully for the independence of India by disruptive protest.

Even basic democratic rights, such as voting, came about through disruptive protest. The extension of the franchise introduced in the Reform Act 1832 followed riots across England in 1831, and it’s only just over 100 years since women have had the vote. The suffragettes had a window-smashing campaign, and they also disrupted sporting events.

Everyone has heard of Emily Davison throwing herself under the King’s horse at the Epsom Derby. The suffragettes also attacked perceived male environments, such as football grounds and golf courses, where they replaced flags with suffragette colours or carved messages in the greens, damaging them. There was similar disruption to sporting events, including rugby and cricket Test matches, in the 60s and 70s by anti-apartheid protesters.

Those things were all hated at the time, just as Just Stop Oil throwing orange dust over the snooker tables at the Crucible in the World Snooker Championship got the same sort of criticism. But sitting here now, who would say women shouldn’t have the vote, or that a country that categorises people by race and prevents the majority of its population from having any sort of rights should be welcome in the UK? But those positions came about, in large part, not through cases brought in the courts, but through disruptive protest. It’s in that context, I say, that we should be considering climate change and environmental catastrophe as real and pressing issues. The question is whether, and to what extent, the law corresponds to what is just.

Over five years ago, the House of Commons unanimously passed a motion declaring a climate emergency. We sit here in 2024 still facing that climate emergency. Some would say that very little of substance has changed, and it is largely by protest that things will be changed. When the Human Rights Act 1998 came into force in 2000, there was something of a heyday about protesters’ rights being perhaps respected more in the courts; the balance being struck now, post-2022 is quite different.

Article 10 gives you the right to freedom of speech, and interference with that can only be done for a range of very limited exceptions. Article 11: Freedom of Association. Those are important things, because, from a protest point of view, the difference between a crank with a one-person campaign and a real social movement is numbers.

When we’re looking at how protest rights are to be considered and what legal limits should be imposed on these, we have to bear in mind that the symbolism of a protest and the numbers of a protest are what’s important, not just what is said. In a case from 2007, R (Tabernacle) v Secretary of State for Defence, a protest to challenge the existence of byelaws prohibiting access to land outside the Aldermaston base –where the purpose of the byelaws was to deter protests –failed at first instance but succeeded in the Court of Appeal. Lord Justice Laws, the year before he became Treasurer of this Inn, said, “Rights worth having are unruly things, demonstrations and protests are liable to be a nuisance. Sometimes they betray a kind of arrogance, an arrogance which assumes that spreading the word is always more important than the mess. In that case, firm but balanced regulation may be well justified.”

But over the last decade or so, a number of things have happened that make it harder for protesters to get their message across. It’s not just governments, but private companies that are resorting to the law to try and suppress protests against their activities. Previously, the court would only proceed against named defendants, but that position has changed to allow people to bring proceedings against unnamed defendants. And that provides a very considerable advantage to the claimant. Quite often, they will go ex parte to court, seeking an injunction that affects everybody –essentially now against the whole world – allowing them to construct a case against an entirely theoretical defendant.

In Ineos Upstream Ltd and others v Persons Unknown and others, the claimants proceeded in secret because they didn’t want to tip off the defendants. They didn’t inform the court at the interim injunction hearing that the claim involved the Human Rights Act, and, in respect of the human rights arguments, relied on a case which held that Article 10 was not, of itself, a defence to someone squatting in a building as part of a protest against possession proceedings. They were seeking extremely wide-ranging and draconian injunctions. It had a vast effect on all sorts of people involved, stayed in place in its entirety over four months and most of it was discharged by the Court of Appeal in 2019, over two years after it had been brought.

People opposing injunctions take on a very considerable risk to themselves. It’s worth remembering that these injunctions bind us all. You may not know that you’re the potential defendant to an injunction brought by Transport for London, but there are currently injunctions in place all around various sites in London, and they have been brought mainly with the support and encouragement of energy companies, because it’s in their interests for protests to be deterred.

The fact an injunction is sought against the world is a real, current and practical problem. These injunctions are often sought on a quia timet basis before anything has happened, and therefore the court, on an ex parte hearing, is unlikely to be able to pay much attention to the weight of the real threat or the weight of the contrary evidence, even on the relatively relaxed test that’s being brought.

An injunction is a serious thing. There are draconian penalties for breaching one. You could be sent to prison. You’re liable to incur extensive financial penalties through fines and costs orders, and that can happen without you having been involved in the proceedings at all in the first place.

In the Public Order Act 2023, there are now specific criminal offences relating to tunnelling and locking on. You might understand why those might be specific offences, as well as obstructing major transport works, and interference with key national infrastructure. But the definition of ‘national infrastructure’ covers any A or B road. So if you do something that goes beyond the bounds of reasonable use of the road, you are committing an offence for which you could go to prison for a year.

Although it used to be the case that the law treated protesters less harshly because of the intent behind the protests, that has very specifically been changed, both by parliament and by recent sentencing decisions in the Court of Appeal.

Rights worth having are unruly things, demonstrations and protests are liable to be a nuisance. Sometimes they betray a kind of arrogance, an arrogance which assumes that spreading the word is always more important than the mess. In that case, firm but balanced regulation may be well justified.

Sudhanshu Swaroop: My expertise is in climate law, particularly in recent test cases that have taken place at the international level.

My contention today is that, on questions of climate protest, the English courts are entitled to – and should – take account of wider developments in the law and practice of climate change.

I will start with the human rights framework in which protest cases are decided. The courts must first consider whether a restriction on the protest, such as an injunction, is consistent with Articles 10 and 11 of the ECHR. The question arises most obviously in the context of injunction cases, but it can also arise in the criminal context, where there is a defence of ‘lawful excuse’.

Generally, the courts accept that measures such as injunctions do restrict protesters’ Article 10 and Article 11 rights. The question then is whether that restriction can be justified as being “necessary in a democratic society” under Articles 10.2 and Article 11.2. In this regard, the courts must decide where a fair balance is to be struck between the legitimate aim of the prevention of disorder and the protection of rights and freedoms. Thus, the court must engage with the question of proportionality.

The leading case is the 2021 Supreme Court judgment in Director of Public Prosecutions v Ziegler and others, where the defendants were being prosecuted for causing a road to be closed during a protest against an arms fair that was taking place at a nearby conference centre. The court observed that proportionality is a fact-specific inquiry. Lord Hamblen and Lord Stevens said it is relevant whether the defendant believed in the views they were expressing, and furthermore: “It is also appropriate to take into account the general character of the views whose expression the convention is being invoked to protect. Political views, unlike tittle tattle, are particularly worthy of protection.”

In my view, when it comes to climate change, the relevant facts and the relevant general character of the views in question should be determined not just by asking the general question “are these political or not?”, but by considering wider developments taking place in relation to climate law. These developments show that the views of climate protesters, to a significant extent, are not just ‘views’, but matters of undisputed fact or matters of opinion that have been universally endorsed – not just by scientists, but by almost every state in the world. I draw attention to four particular developments.

First, there is the Paris Agreement, which was adopted in 2015 by over 190 states, and which is the cornerstone of international climate law. The preamble of the treaty expressly refers to “the urgent threat of climate change.” Thus, the proposition that climate change presents an urgent threat is a view, but it is a view that has been endorsed and recognised in a formal treaty by almost every country on the planet.

The Paris Agreement, which was adopted in 2015 by over 190 states … is the cornerstone of international climate law.

Secondly, the parties to the Paris Agreement have agreed a temperature goal, as set out in Article 2, namely “Holding the increase in the global average temperature to well below 2ºC above preindustrial levels, and pursuing efforts to limit the temperature increase to 1.5ºC above preindustrial levels, recognising that this would significantly reduce the risks and impacts of climate change.” There is debate as to the precise legal nature of this provision. But what matters is that almost every state in the world has agreed this goal as part of the response to the urgent threat of climate change.

Thirdly, there is the nature of the scientific consensus as to climate change. In climate litigation, evidence of the causes and effects of climate change is generally based on the reports of the Intergovernmental Panel on Climate Change (IPCC). For example, the IPCC’s 2018 Special Report analysed the effects of climate change on human health if warming exceeds 1.5ºC. Importantly, the IPCC reports are also endorsed by states, as part of a formal process.

Fourthly, there’s the recent European Court decision in the Swiss climate case, KlimaSeniorinnen. An association of senior women from Switzerland argued that their health was being threatened by heatwaves, being made worse by climate change and that accordingly Switzerland was in breach of its Article 2 obligation, the right to life, and Article 8, the right to family and home.

The court found (based inter alia on the IPCC reports that I mentioned) that “there are sufficiently reliable indications that anthropogenic climate change exists and that it poses a serious current and future threat to the enjoyment of human rights, under the Convention, that states are aware of it and capable of taking measures to effectively address it” and that “the relevant risks are projected to be lower … if action is taken urgently.”

The court determined that the ECHR should be interpreted in what it called an ‘evolutive manner’. Having regard to the scientific evidence about climate change, it found that there is a legal obligation on states under Article 8 to undertake effective measures to reduce fossil fuel emissions, with a view to reaching Net Zero within three decades. It accepted that states have a margin of appreciation, but this depended inter alia whether a state has complied with its procedural obligations, including that “procedures must be available through which the views of the public, and in particular the interests of those affected or at risk of being affected by the relevant regulations and measures or the absence thereof, can be taken into account in the decision-making process.”

The court determined that the ECHR should be interpreted in what it called an ‘evolutive manner’.

In Shell UK Ltd v Persons Unknown, an application was granted for an injunction to restrain climate change protesters from undertaking activities such as damaging petrol pumps and preventing motorists from entering petrol station forecourts. The court accepted that the injunction interfered with the defendants’ rights under Articles 10 and 11. However, it found the interference was justified, stating that even if there was “an overwhelming global scientific consensus that the business in which the claimant is engaged is contributing to the climate crisis” , this was “not a particularly weighty factor.” That was because, “otherwise judges would find themselves giving greater protection to views which they think important” and it was “not for this court, on this application, to adjudicate on the important underlying political and policy issues raised by these protests, that is for parliament.”

I make the following comments. First, the proposition that there is an overwhelming scientific consensus that the fossil fuel trade contributes to the climate crisis, should arguably not be characterised merely as the ‘views’ of climate protesters, for all of the reasons that I have already set out. Secondly, for the UK courts in climate protest cases to recognise a certain foundation of undisputed fact or scientific consensus would not in itself require them to adjudicate policy issues. Thirdly, the Swiss case raises the question as to whether the ‘evolutive approach’ to interpretation should be applied by English courts in the context of climate protest cases. Fourthly the Swiss case also raises the question as to whether procedural safeguards are relevant to the balancing exercise that the court must perform in climate protest cases. I note that under section 2 of the Human Rights Act the English courts must at least take account of the Swiss case.

English courts should integrate broader developments in climate law and practice which may or may not make a difference on any particular facts.

I am not suggesting that in every single case where an issue of protest arises, the court should automatically refuse an injunction. I recognise that all of these cases are heavily fact-dependent. My point is simply that, in protest cases, English courts should integrate broader developments in climate law and practice which may or may not make a difference on any particular facts.

To conclude, I refer to the 2006 House of Lords judgment in Jones: “My Lords, civil disobedience on conscientious grounds has a long and honourable history in this country. People who break the law to affirm their belief in the injustice of the law, or government action, are sometimes vindicated by history.”

Climate change is a special case because we do not need to await the verdict of history in relation to the matters within our subject of climate protest. We already have the verdict of science, and it is a verdict that has been endorsed by states. It is now open to the courts to endorse that verdict in their judgments.

For the full video recording: innertemple.org.uk/righttoprotest

Stephen Simblet KC Garden Court Chambers

Sudhanshu Swaroop KC Twenty Essex

Saira Kabir Sheikh KC FTB

THE INNS OF COURT ALLIANCE FOR WOMEN

INTRODUCTION BY LEIGH-ANN MULCAHY KC

The Inner Temple Co-Convenor of the Inns of Court Alliance for Women opened the annual cross-profession garden party on 23 June 2025. Her words set the scene for an inspiring and thought-provoking speech by Supreme Court Justice, The Rt Hon Lady Simler DBE.

Good evening, everyone. I am The Inner Temple Co-Convenor of the Inns of Court Alliance for Women (ICAW), along with my fellow Co-Convenors, Brie Stevens-Hoare KC representing Lincoln’s Inn, Mrs Justice Lieven representing Gray’s Inn and Ruth Kirby KC representing Middle Temple.

ICAW was originally established in 2011 as a collaboration between Inner and Middle Temple (then known as the Temple Women’s Forum) and in 2022, it became a collaboration between all four Inns.

The Alliance exists in recognition of the fact that there are challenges and barriers to career progression and wellbeing faced by women in the law. It seeks to provide a safe forum where issues facing women in the profession can be discussed in order to foster a culture of mutual support. It supports the Inns’ wider commitment to equality, diversity, inclusion and social mobility. ICAW takes an intersectional approach, recognising that disadvantages can also arise from being of a non-white ethnic background, being disabled or LGBTQ+ or by reason of socio-economic factors.

On behalf of the Committee of the Alliance, can I thank you all for coming. And special thanks also to those male allies who are here with us today.

This is the 11th time we have held an annual networking party, and it continues to be one of the main diversity events of the calendar. I would like to thank the staff of the Inns who support the Alliance’s events throughout the year, and the staff at The Inner Temple for the work they have put into the arrangements to make this party so enjoyable. Whilst on the subject of diversity events, I should also mention that The Inner Temple is hosting another all-Inns event for the Bar and solicitors’ profession later this week as part of Pride month, titled ‘Pride in Practice’.

Now it is my pleasure to introduce our speaker to do the welcome this evening, Dame Ingrid Simler.

Female barrister and human rights activist Amal Clooney has said, “Success is not about the position you hold, but the positive impact you create.” In the case of Lady Simler, her success is about both. She was called to the Bar in 1987 and practised in tax and employment law. She took silk in 2006 and was Head of Devereux Chambers before becoming a judge of the then Queen’s Bench Division in 2013 and then President of the Employment Appeal Tribunal. She was appointed to the Court of Appeal in 2019 and became a Justice of the Supreme Court in 2023 (only the fifth woman to be appointed since its inception). A champion of diversity, she was High Court Liaison Judge for Diversity and then chair of the Diversity Committee of the Judges’ Council. I have personally had the privilege of being a member of The Inner Temple Equality, Diversity & Inclusivity Sub-Committee, which Lady Simler chaired for a number of years with great empathy and sensitivity.

We are very grateful to her for taking time out of her incredibly busy diary to come and be our speaker.

Leigh-Ann Mulcahy KC

Inner Temple Co-Convenor Inns of Court Alliance for Women

The Rt Hon Lady Simler DBE

Leigh-Ann Mulcahy KC

THE RT HON LADY SIMLER DBE

It is a real pleasure to be here in this wonderful garden this evening and to have been asked to say a few words to this distinguished gathering, including, as it does, so many exceptional women who now make up the backbone of the Bar and represent its future.

When I started my career at the Bar in the late 1980s, there were far fewer women barristers, still less in senior roles or silk, and even fewer on the Bench. In fact, my chambers had two women – one a quite senior silk – but that was unusual, and probably a factor in what took me to those chambers. It wasn’t always easy to see what a long-term career at the Bar might look like for me as a woman, and that lack of visibility made the path feel more uncertain.

As I progressed in seniority, balancing my career ambitions with raising a family, then taking silk in 2006, I became increasingly aware of the structural, cultural and other challenges that were holding women back. Many of these challenges are not overt. They are cumulative, often hidden in assumptions about commitment, availability or leadership potential. That awareness led me to take on roles such as Chair of the Bar Council’s Equality and Diversity Committee. It was important to me that we not only highlight these issues but also create practical solutions: flexible working models, fair recruitment practices, support systems that help people stay in the profession rather than pushing them out. But institutional and structural change is only one part of the story.

I had the good fortune in chambers of having people who would now be seen as mentors, though that may not have been how they saw themselves back then – both men and women who offered their precious time to listen and give guidance, encouragement and, critically, belief. Sometimes that belief came at times when I wasn’t sure I had it in myself.

They had had the experience of successfully navigating different obstacles or processes – juggling the Bar and raising children, applying for an appointment of one kind or another, overcoming setbacks – and they could support me in my career.

So, for example, I was strongly encouraged to apply to be a Revenue junior and then for silk, recorder and judicial appointments. That encouragement and support were critical in giving me the confidence to apply. If they thought I could do it, maybe I should. Each time I applied for something, a member of chambers who had done it before helped me go about it and told me what to expect from the particular process. Sometimes it was just a small thing, like you will need at least a week to fill out that particular form; other times, it was a critical read-through of a draft form – though I remember one occasion when the criticism was so critical I almost didn’t apply!

And when it didn’t work out (as inevitably happened at different times in my career), they encouraged me to apply again, sharing their own interview horror story or pointing out how many times other people had had to apply for this or that competitive appointment before finally getting it, and suggesting things I could do to improve my application before the next round. Over the years, I’ve tried to do the same for others, especially for women coming through the system.

There is no doubt that mentorship is invaluable, and it’s been critical for me. But I would like to pause here and raise a question. Looking to the future, is it enough? Should we also be thinking about how and when we can also do sponsorship?

Where mentoring is usually private and supportive, sponsorship is public and proactive. A sponsor is someone who not only gives advice behind the scenes but is also willing to use their position to advocate for you in rooms you’re not in, to mention your name as someone to watch, to recommend you to solicitors or push for you to be instructed on a particular case.

What might sponsorship look like at the Bar?

Senior barristers, if you have worked with a female junior who did excellent work for you, tell the solicitor. Don’t keep the information to yourself. Nominate her. Recommend her wherever you can. Be intentional and active about it.

Silks, set aside a section of the oral submissions for your female junior. The senior judiciary and the Supreme Court have issued guidance to encourage parties to give junior counsel this opportunity because of the relatively larger numbers of women at the less senior levels.

Solicitors, tell your clients that this is what is expected by the judiciary. It is happening more and more in the Supreme Court, and I can tell you that it works very well. From the judge’s perspective, after hearing from the same advocate for a few hours, a new voice can be refreshing and, in some cases, some submissions have landed better coming from a different voice. Judges, look out for talent, and when you see it, reach out to the barrister and talk about her where and when it matters.

These are just a few examples. You will have more.

Now, I recognise that sponsorship can be a challenge. To be a sponsor, you must have knowledge and experience of the sponsee’s professional ability. You may have to risk your own reputation to back the sponsee, and not everyone feels comfortable doing this. This makes the barrier to sponsorship higher, especially in under represented groups where the necessary relationships may not already exist. Of course, the risks of mentorship are lower, and it is correspondingly easier to find a mentor, not least because there are now a lot of formal schemes in place. But perhaps sponsorship can be a natural evolution of mentorship. The same person who guides you to the right room is also the person who talks about how excellent you are in that room.

Baroness Hale once said: “Equality is not a women’s issue. It’s a justice issue.”

Her words are a reminder that this is not about favour, it’s about fairness and recognising that the legal profession belongs to all who are capable of being in it.

So, to all of you here tonight, whether you’re in your early years of practice or well into silk, let’s think seriously about how and who gets seen in court, who gets backed, and who gets talked about. If we want a legal profession that truly reflects the society it serves, we must be intentional about both mentoring and sponsoring those whose potential has not always been given the chance to flourish. The pipeline doesn’t fix itself. We fix it by reaching back as we move forward.

When I joined the Supreme Court, it was, of course, a moment of deep personal honour. But more than that, I hoped it would stand as another signal to women at the Bar: you do belong at the highest level, and we need you there.

Tonight is a fantastic opportunity to make new connections, ask each other questions, share experiences and offer support. There is such power in the community that makes up the Inns of Court Alliance for Women. Welcome to you all, and let’s begin!

The Rt Hon Lady Simler DBE

WEDDINGS

Mieke Van Vlaanderen and Edward Cronan, 5 July 2025 © Faye Cornhill

Lewis Croft and Hannah Rumball, 26 October 2024 © Oliver Holder Photography

Rachel Sullivan and Fahd Baig, 21 September 2024 © Rahul Khona

Isabella Tee and Finley Judge, 28 June 2025 © D&A Photography

Rosie Sells and Michael Evans, 11 April 2025 © Anne Schwarz

Florence Binks and Robert Lakin, May 2025 © nickray.pic-time.com

LITERATURE AND CHRONICLES: HIGHLIGHTS OF THE LIBRARY’S MANUSCRIPT AND RARE BOOK COLLECTIONS

By the Assistant Librarian

In addition to the ‘working’ Law Library, the Inn possesses an impressive collection of rare printed books and manuscripts, many on non-legal subjects, which are regrettably only rarely seen. Among visiting scholars, it is indeed the literary and historical works that tend to elicit most interest. There follows a brief account of some of the books and manuscripts within these categories. The choice is entirely subjective!

THE ROMANCE OF BRUT

This begins: “En la noble citee de graunt Troie, il y avoit un noble chiualer…”

The Roman de Brut was composed about 1150 by the AngloNorman poet and chronicler, Wace, who based his work on Geoffrey of Monmouth’s (Latin) History of the Kings of Britain It describes the career of Brutus, a descendant of Aeneas, who comes with a party of companions to the British Isles and, finding them uninhabited, takes possession. The legend of Britain’s descent from ancient Troy was widely accepted in pre-Conquest times.

The Roman de Brut is a verse chronicle of some 1500 lines in octo-syllabic couplets. An English version with further extensive additions was made by the Middle English poet, Layamon of Worcestershire. This is of interest as it gives for the first time not only the story of Arthur, but also that of Lear and Cymbeline. The Inn’s manuscript copy (Petyt MS 511.19) is of the late 14th or early 15th century.

ROGER DE HOVEDEN’S CHRONICA

Roger de Hoveden (that is, of Howden in East Yorkshire) served as a clerk at the court of Henry II from about 1173 until after the King’s death in 1189. After leaving royal service, probably by 1192, he began writing his Historia Anglorum or Chronica, a history of England from the time of Bede. Like many historical writings of that period, it consisted largely of compilations from earlier manuscripts, though the fourth and final part is Roger’s own original work, incorporating many contemporary documents. It is believed that he died in 1201, since his chronicle ends somewhat abruptly in that year. Possibly written in the Durham scriptorium, and known to have been in the possession of the Abbey of Rievaulx early in the 13th century, our copy (Petyt MS 511.2) is one of the earliest surviving manuscripts of Hoveden’s work.

The printed book (Polycronycon of 1527) has a part-engraved title-page in red and black, showing the device of John Reynes, who bore the cost of the printing: St George slaying the dragon.

RANULF HIGDEN’S POLYCHRONICON

The Inn is fortunate to own this work both in manuscript form and as an early printed book.

Ranulf Higden (d 1364) was a Benedictine monk at St Werburgh’s Abbey, Chester, which became Chester Cathedral after the Dissolution. His fame rests on his Polychronicon, which is a universal history down to his own time. It was the most exhaustive history that had yet appeared, and it enjoyed great popularity for nearly two centuries. There are said to be over a hundred manuscripts extant. (Some of these are described in the prefaces of the edition of the Polychronicon in the Rolls Series, Vol 41, 1–10).

This manuscript passed through the hands of seven identified owners before reaching the Inn. J Conway Davies’s catalogue of Inner Temple Library manuscripts states somewhat drily that “The volume is written in two columns throughout. The hand is moderate, the parchment reasonable and the ink satisfactory for its period.” Remnants of the original catalogue entry from the Library of William Petyt can be seen on one of the flyleaves.

The printed book (Polycronycon of 1527) has a part-engraved title-page in red and black, showing the device of John Reynes, who bore the cost of the printing: St George slaying the dragon. The same leaf bears the signature of John Theyer (1634). The colophon reads, in full: “Imprented in Southwerke: By my Peter Treueris at ye expences of Iohn Reynes boke seller at the sygne of saynt George in Poules chyrchyarde, The yere of our lorde god MCCCCC. xxvii. the. xvi. daye of Maye.”

THOMAS NASHE’S THE CHOISE OF VALENTINES

The Choise of Valentines, Or the Merie Ballad of Nash His Dildo, thought to have been composed in 1592–1593, recounts in the first person a sexual encounter between a man and his female lover in a brothel on Valentine’s Day. The poem includes the first known use in English of the word ‘dildo’ and describes the item in detail. This manuscript copy is one of only three extant, the other two being in the Bodleian Library and the Folger Shakespeare Library (Washington, DC) respectively. The poem was never printed during Nashe’s lifetime.

The Choise of Valentines, or the Merie Ballad of Nash His Dildo, thought to have been composed in 1592–1593, recounts in the first person a sexual encounter between a man and his female lover in a brothel on Valentine’s Day.

PETRARCH’S THE TRIUMPH OF DEATH

Translated by Mary Sidney, Countess of Pembroke (1561–1621)

Sidney’s translation of Petrarch’s Trionfo della Morte, or The Triumph of Death, has been frequently acknowledged by scholars as one of the most accurate translations of the poem into English. Sidney translates Petrarch’s Italian into English almost exactly word for word, and retains the poem’s original terza rima rhyme scheme meticulously. This copy, which was originally sent to Lucy Russell, Countess of Bedford (1580–1627), by Sir John Harington (1561–1612), is the only one known to exist. Not surprisingly, then, this is one of the most popular items in the collection among visiting scholars.

Sidney translates Petrarch’s Italian into English almost exactly word for word, and retains the poem’s original terza rima rhyme scheme meticulously.

CERVANTES’S DON QUIXOTE

The first English translation, 1612

This year marks the 420th anniversary of the publication of El Ingenioso Hidalgo Don Quixote de la Mancha, by Miguel de Cervantes Saavedra (1547–1616). Considered by many to be among the greatest novels ever written, it was first published in two parts: part one in 1605 and part two in 1615.

This first English translation of part one, by Thomas Shelton (fl 1598–1629), was published in 1612. Despite some occasional signs of haste (Shelton claimed to have completed his translation in only 40 days), it is regarded as a good translation, benefiting from Shelton’s knowledge of contemporary Spain and reproducing in a lively style the spirit of the original. Few good copies, of which The Inner Temple’s is one, have survived.

LE MORTE DARTHUR

with illustrations by Aubrey Beardsley

Aubrey Beardsley (1872–1898) was commissioned by the publisher Dent to illustrate this edition of Thomas Malory’s Le Morte Darthur when he was only 21 years old, in 1893. It is said that, although Beardsley was initially glad of the work, he became disenchanted with the (very onerous) project, which involved a good deal of near-repetition of similar motifs, aside from the set-piece, full-page scenes. No doubt he turned with relish to his next commission, in 1894: the illustrations for Oscar Wilde’s French play, Salomé, which brought him widespread notoriety. The Inn’s copy is from the second printing of 1909, a limited edition of 1,500 copies (1,000 for the United Kingdom and 500 for America), on completion of which the type was dispersed.

It was William Caxton who produced the first printed edition of Le Morte Darthur in 1485, about 15 years after its composition by Sir Thomas Malory. The text here is that of Caxton’s edition, with modernised spellings.

It is a matter for regret that material from ‘special collections’ is not more visible, largely for space reasons. That said, Library users will be pleased to note that we hope, fairly soon, to have the facilities to display items from the manuscript and rare books collections on a rotating basis.

Michael Frost Assistant Librarian

LGBTQ+ SOCIETY: PRIDE IN PRACTICE

A speech by Master Barbara Mills, with an introduction by Master Jeremy Richardson

Master Jeremy Richardson

INTRODUCTION

By Master Jeremy Richardson

In celebration of Pride Month, The Inner Temple was proud to host an event in June on behalf of the four Inns, the Bar Council and The Law Society, honouring the contributions and presence of LGBTQ+ members across the legal profession. It was a powerful moment of reflection, solidarity and shared commitment to ensuring the Bar is a place where all individuals can belong, thrive and be respected. As Chair of the Inn’s Equality, Diversity and Inclusivity Sub-Committee, Master of our LGBTQ+ Society and as President of the Association of UK LGBTQ+ Judges (and as Recorder of Sheffield in my ‘day job’), I was delighted to welcome a full Hall of guests to this important inaugural event on behalf of the Treasurer, who could not be present.

I reflected on how very different times were when I was called to the Bar almost 45 years ago to the day. Then, it would have been unimaginable for an event of this kind to take place. Times have changed for the better, and we are fortunate to live in a country where such celebrations are possible, though we remain mindful that many in other parts of the world do not enjoy the same freedoms. This made the evening not only a joyful and vibrant occasion – indeed, I remarked that the Inn had not looked so colourful in years – but also a moment of pride and significance.

I had the pleasure of introducing Barbara Mills KC, Chair of the Bar Council of England and Wales, followed by Ian Jeffery, Chief Executive of the Law Society, and His Honour Judge Edward Connell, a member of the Judicial Diversity Committee and a committee member in the LGBTQ+ Judges Association, to deliver addresses. As both a leader of the profession and a Bencher of the Inn, Master Mills brought warmth, clarity and purpose to her remarks, which reaffirmed the Bar’s collective responsibility to uphold justice, not just in our courts, but within our professional culture. At a time when the principles of equality and inclusion are facing renewed scrutiny and challenge, Master Mills’ remarks stand as a timely and necessary reminder of what it means for the Bar to be not only open to all but committed to the wellbeing and dignity of all its members.

His Honour Judge Jeremy Richardson KC

The Recorder of Sheffield Chair of the Equality, Diversity & Inclusion Sub-Committee Master of the LGBTQ+ Society

PRIDE IN PRACTICE

Speech by Master Barbara Mills, Chair of the Bar, at the Pride in Practice Cross-Profession LGBTQ+ reception held on 26 June 2025, organised in collaboration with the Bar Council, Law Society and the Inns of Court.

I am so delighted to be here tonight, at my own Inn, celebrating Pride and the LGBTQ+ community in the legal profession.

We’re proud to be working with the Law Society, The Inner Temple, the other Inns and LGBTQ+ networks across the legal sector.

This is a very special event to mark Pride Month, and it is an opportunity to come together, to make friends and to reinforce our sense of community and support for each other.

I’m also very much looking forward to the entertainment…

But I cannot miss this opportunity to share some thoughts on where we are today, on the importance of inclusion in the legal profession, and to restate that, as a profession committed to justice, we must ensure that our workplaces, courtrooms and institutions remain inclusive and respectful for everyone.

Across the globe, we are witnessing a period of significant challenge to equality, diversity and inclusion (EDI).

At the Bar, we recognise that EDI is central to the integrity and effectiveness of our justice system. A diverse and inclusive legal profession is better equipped to serve the public, uphold the rights of all individuals and reflect the society it represents.

We are proud of the work being done by barristers, chambers and our institutions to promote inclusion, tackle discrimination and support underrepresented groups.

Efforts made by the judiciary, Law Society and Bar to widen access mean the diversity of those coming into the legal professions is better than ever. It is a source of great joy to me that young people now coming into chambers – and at the Employed Bar – can be open about their identities.

But we must also acknowledge that progress is uneven and that complacency is not an option.

BULLYING, HARASSMENT AND SEXUAL HARASSMENT REVIEW

Successive results from our Barristers’ Working Lives surveys tell us that bullying and harassment have become an intractable problem for our profession. In our 2023 survey, 38 per cent of LGBTQ+ barristers had experienced bullying or harassment, compared with 28 per cent of straight barristers.

Bullying and harassment directly impact our collective work on equality, diversity and inclusion. I have said repeatedly that it’s not enough to attract and encourage people to the Bar from underrepresented groups; we must have the conditions in place so that those people can not only stay but truly thrive in our profession. Experiencing or witnessing bullying, harassment or discrimination is intrinsically linked to personal wellbeing, how we each feel about our role and our worth at the Bar.

The Harman review has just been published, which reports on bullying and harassment at the Bar. The review presents a great opportunity for us to finally shift the dial on unacceptable behaviours. How we collectively and individually respond to Harriet’s recommendations when they are published will set our course in tackling these issues for the next generation.

The Pink Singers © The Inner Temple

Barbara Mills KC giving her speech at the Pride in Practice event © The Inner Temple

UK SUPREME COURT

I recognise it is important that I acknowledge the Supreme Court’s recent decision and recognise – as I do – that such judgments can have profound social implications.

I want to acknowledge genuine concerns raised by members of the profession and the wider public. It is essential that we engage with these issues thoughtfully, respectfully and with a commitment to the rule of law and human dignity.

I was in Brussels on Monday of this week at a reception to celebrate the Council of Europe’s Convention for the Protection of the Profession of Lawyer.

The Convention was adopted on 12 March 2025 and is the first international treaty creating specific obligations relating to the protection of lawyers and Bar associations. It opened for signature on 13 May 2025 and has had 17 signatures, including the United Kingdom. We were told that the Ministry of Justice is working at pace to ensure that it is ratified within a year.

The Convention’s stated purpose is “to strengthen the protection of the profession of lawyer and the right to practise this profession with independence and without discrimination, improper hindrance or interference, or being subjected to attacks, threats, harassment or intimidation.”

It covers a broad range of matters including: setting out the critical rights that lawyers must be able to exercise in their professional duties, including confidentiality and the right to meet with clients (including detained persons); demanding independent and objective standards for admission to the profession and disciplinary matters (Art 5, Art 8); requiring states to ensure that lawyers can do their work “without being the target of any form of physical attack, threat, harassment or intimidation; or any improper hindrance or interference” (Art 9).

At a time when many are rowing back from EDI, the Convention is a timely reminder of the reason the Bar Council remains as committed as it has ever been to promote equality and inclusion.

What is significant for the purposes of today is the fact that the role of Bar associations is expressly recognised in the Convention, which states that one of their responsibilities is “to promote the welfare of lawyers”. The explanatory notes elaborate on this:

“The role of promoting the welfare of lawyers falls within the competence of the professional associations, with Parties not hindering their action. This concerns the promotion of a better work-family balance and acting against sexual harassment and other disrespectful conduct on the part of lawyers themselves…”

At a time when many are rowing back from EDI, the Convention is a timely reminder of the reason the Bar Council remains as committed as it has ever been to promote equality and inclusion.

We will continue to support our LGBTQ+ colleagues and clients – as we will continue to support all those at the Bar –including those who have experienced vulnerabilities in terms of sex and race, to name just two of our protected characteristics.

The legal profession must be a place where difficult conversations can happen with integrity, compassion and a shared commitment to justice. It must be a place where everyone can thrive, be respected and contribute fully.

As the African proverb says: “Home is not where we live. Home is where we belong.”

The Bar Council will continue its focused attention and work to ensure that the Bar remains open to all and provides a safe and secure professional home to all who get here. We all belong here. Enjoy your evening.

Barbara Mills KC Chair of the Bar

The Sub-Treasurer and Ian Jeffrey, CEO of the Law Society © The Inner Temple

Drink and dine at the Pegasus Bar & Restaurant

Open for drinks and dining fi ve days a week, the Pegasus is the perfect spot to recharge or relax away from the bustling streets of London.

From pastries and co ee to dinner, our seasonal menus and fine selection of beverages o er something for everyone.

Alternatively, celebrate all your special occasions with exclusive hire available on weekends between 11am-11pm. Just moments from Temple Church, the Pegasus is a convenient location for pre or post church gatherings and concerts too. 020 7797 8230 | venuehire@innertemple.org.uk | innertemplevenuehire.co.uk

Standing events: Up to 50 guests

Seated events: Up to 28 guests

CELEBRATE THE LIVES

HER HONOUR SHIRLEY ANWYL KC

10 December 1940–15 February 2025

Master Anwyl was born and brought up in South Africa during the apartheid years. Discussing the foremost influences on her life in 100 Years of Women at the Bar, Master Anwyl describes “Both my parents were in the minority of the white population and believed in the equality of all people. It was my mother who had the greatest influence on my life, in the early years demonstrating by example tolerance of, courtesy towards and interest in all with whom she came into contact”.

At the age of ten, Master Anwyl wanted to become an actress and was sent to speech and drama classes on the condition that, when she left school, she would go to university before making a final decision about her career. She took courses in Latin and Roman Law and went on to become the first woman to complete an LLB at Rhodes University, and the first woman to be called to the Bar in the Eastern Cape Province of South Africa in 1963.

Master Anwyl was called to the Bar of England and Wales in 1966. In 1979, she became the 16th woman to take Silk. Her judicial career included serving as a Recorder from 1981 to 1995 and as a Deputy High Court Judge in the Family Division from 1981 to 1999. She was also appointed a Circuit Judge in 1995 and served as Resident Judge at Woolwich Crown Court from 1999 to 2007. She served as Chair of the Barristers’ Benevolent Association from 1989 to 1995, and she was a Fellow of the Royal Society of Arts from 1989.

Master Anwyl was granted the Freedom of the City of London in 1994 and became a Liveryman of the Fruiterers’ Company in 1996. In 1985, Master Anwyl was elected as a Governing Bencher of the Inn. Her two sons survive her.

RICHARD CLEGG KC

28 June 1938–7 August 2024

Master Clegg was called to the Bar in 1960, took Silk in 1979 and served as a Recorder of the Crown Court from 1978 to 1993. He also served as Chair of the Northwest section of the Bow Group from 1964 to 1966 and was Vice Chair of the Group during the same period. He also chaired the Winston Circle from 1965 to 1966 and was President of the Heywood and Royton Conservative Association from 1965 to 1968.

Master Clegg wrote several publications including Forged by Fire (2009), a memoir of personal reflections. He also published poetry, including The Secret Room (2013), Give Me a Vision (2014), Shadow Across the Moon (2014), and The Curlew Cries (2015).

Master Clegg was elected as a Bencher of the Inn in 1985. Beloved husband of Veronica, and much-loved father and grandfather, he died suddenly at home, aged 86 years.

Richard Clegg KC

Her Honour Shirley Anwyl KC

SIR BRIAN JENKINS GBE

3 December 1935–25 November 2024

Master Jenkins was born in 1935 in Beckenham, Kent. During the Second World War, his family were evacuated to Scarborough with his father serving as a Major in the Royal Artillery.

Between school and Trinity College, Oxford, he was commissioned into the Royal Artillery in Gibraltar for his National Service.

Master Jenkins was a retired English chartered accountant and businessman who served as President

of the Institute of Chartered Accountants in England and Wales in 1985–86; Lord Mayor of the City of London in 1991–92; Chairman of Woolwich PLC between 1995–2000; Deputy Chairman of Barclays Bank PLC between 2000–04 and Prior of the Order of St John and Chairman of St John Ambulance between 2004–10.

Master Jenkins was elected as an Honorary Bencher of the Inn in 1991.

SIR NEIL BUTTERFIELD

28 September 1942–8 April 2025

Master Butterfield was called to the Bar of England and Wales in 1965. He was appointed Queen’s Counsel in 1985 and served as a Recorder from 1978–95. He led the Western Circuit from 1992–95 and served as its Presiding Judge from 1997–2000. He was appointed a Judge of the High Court of Justice, Queen’s Bench Division, in 1995, and was knighted that same year.

Master Butterfield served on the bench until his retirement in 2012. Following his judicial career, he continued to serve in several public roles, including as a member of the Parole Board from 2003–15 (Vice Chairman from 2005), and as a Board Member of the Independent Parliamentary Standards Authority from 2013–16. He also served as a Trustee of the Roman Catholic Diocese of Plymouth from 2014. In recognition of his service to the Church, he was appointed a Knight of St Gregory in 2017.

Master Butterfield was elected a Governing Bencher of the Inn in 1992.

Sir Neil Butterfield

Sir Brian Jenkins GBE

ROBIN DE WILDE KC

12 July 1945–13 March 2025

Born on 12 July 1945, Robin De Wilde was called to the Bar in 1971, appointed Queen’s Counsel in 1993 and elected a Bencher in 1996. He was a leading Silk in professional negligence, particularly personal injury and clinical negligence, including cerebral palsy and product liability. He chaired the Professional Negligence Bar Association from 1995–97, becoming Honorary Vice President in 1998. He sat as a Recorder between 2000–04. Master De Wilde was Chairman of the Ogden Working Party, 2003–17, and was responsible for the 5th, 6th and 7th editions of the Ogden Tables, in collaboration with actuaries from the Government Actuary’s Department. Master de Wilde also worked with the actuarial

profession in his professional practice and was a strong advocate for co-operation between actuaries and the legal profession, shaping the practice of the courts in this field. He was appointed an Honorary Fellow of the Institute of Actuaries in 2016.

From 2001–07, Master de Wilde was Master of the Yearbook, later serving on the Inn’s Investment Sub-Committee and Archives Committee. In a collaboration with Dr Johnson’s House Trust, he was instrumental in the Inn publishing in 2010 a series of essays by Lord Bingham entitled Dr Johnson and the Law Master De Wilde is survived by his wife, Patricia, and their three sons.

HIS HONOUR DENIS ORDE

28 August 1932–28 December 2024

Master Orde was a former army officer and Crown Court judge. After serving in the Army from 1950–52 he continued in the Territorial Army from 1952–64, becoming a Captain in 1958. He was called to the Bar in 1956 and was awarded the Profumo Price in 1959. He served as a Deputy High Court Judge (Civil) from 1983–2005 and as resident Judge at Durham Crown Court from 1986–2001. He chaired the Criminal Justice Liaison Committee for Northumberland, Tyne and Wear, and Durham (1995–2000), the Criminal Justice Strategy Committee for Durham County (2000–01) and served as President of the Mental Health Review Tribunal for Restricted Cases from 2001 to 2005.

Master Orde authored Nelson’s Mediterranean Command (1997, repr. 2014) and In the Shadow of Nelson: The Life of Admiral Lord Collingwood (2008, repr. 2019). He also contributed to the Oxford Dictionary of National Biography. Master Orde’s article, Nelson goes to Law, can be read in the 2014–15 edition of the Yearbook.

Master Orde was elected a Bencher of the Inn in 1998. He is survived by his daughters Georgina, also a member of this Inn, and Philippa.

SIR JEFFERY BOWMAN FCA

3 April 1925–18 February 2025

Master Bowman was educated at Winchester College and Trinity Hall, Cambridge, where he earned a First-Class Honours degree in Law. After serving in the Royal Horse Guards from 1953–55, he began a long and influential career at Price Waterhouse, eventually becoming Senior Partner and Joint Chairman of the Price Waterhouse World Firm. Further to this, he served as Chairman of the MidEssex Hospital Services NHS Trust and Masthead Insurance Underwriting PLC, and for more than 20 years he acted as Auditor to the Duchy of Cornwall.

He was Chairman of the Court of Appeal Civil Division Review from 1996–97, and of the Crown Office Review from 1999–2000. He was a Trustee of the Royal Botanic Gardens, Kew and a Governor of Brentwood School. He was Knighted in 1991.

Master Bowman was elected as an Honorary Bencher of the Inn in 1998. An active member of the Inn, he sat on the Inn’s Executive Committee from 2002–09 bringing to the Inn his extensive experience from the financial world.

Sir Jeffery Bowman FCA

Robin De Wilde KC

His Honour Denis Orde

DR PEHR GYLLENHAMMAR

28 April 1935–21 November 2024

Master Gyllenhammar was born in April 1935. He completed his military service from 1954–55 and became a sergeant. He then went on to graduate from Lund University with a degree in law in 1959 and worked an assistant lawyer at law firm Mannheimer & Zetterlöf in Gothenburg and then, in 1960, at Haight, Gardner, Poor & Havens in New York City. He studied maritime law in the United States and from 1968 aspects of Industrialism at the Centre d’Etudes Industrielles in Geneva.

Master Gyllenhammar was Chief Executive Officer and Volvo Chair between 1970–94. After Volvo, Master Gyllenhammar joined the boards of numerous companies, including Swedish investment company Kinnevik AB, the news agency Reuters,

Rothschild Europe, and insurance company Commercial Union (now Aviva), becoming Chair in 1998. He was also a senior advisor of Lazard Frères & Co LLC in New York City.

A key figure in equestrian sports, he founded the Fédération Equestre Internationale (FEI) Jumping World Cup series and championed Volvo’s sponsoring of global competitions.

Master Gyllenhammar was made Commander of the Ordre National du Mérite in 1980 and, in 1987, he was awarded the Légion d’honneur. In 2001, he was elected an Honorary Bencher of the Inn. He is survived by his third wife, Lee, whom he married in 2013, and by his five children.

TERENCE COGHLAN KC

17 August 1945–18 November 2024

Master Coghlan was called to the Bar in 1968 and took Silk in 1993. Highly regarded in Silk, Terence Coghlan focused his time on legal problems arising from medical matters, in particular clinical negligence. He was experienced in handling landmark cases for defendants as well as acting on behalf of health authorities, trusts, practitioners and health defence organisations.

Master Coghlan was appointed as a Bencher of the Inn in 2004 and served in numerous key roles – including as Chair of the Temple Church Committee, where he fostered collaboration between the Inns and encouraged continued amity and commitment to the Inns’ mutual

goals. As a Trustee and Director of the Temple Music Foundation, he was active in supplementing the Church’s ecclesiastical work with world-class programmes of music, which he and his wife, Angie, regularly attended.

An active scholarship interviewer, he ensured that the best and brightest new members of the Inn, regardless of their background, have the financial means to access the profession. As Master of the Cellar, he shared his expertise in wine, enhancing many of the Inn’s dinners over the years. During his time on the Archive Committee, a number of Book Prize Awards, of which Master HRH The Princess Royal is Patron, were organised.

Terence Coghlan KC

Dr Pehr Gyllenhammar

SIR BRIAN WILLIAMSON CBE MA

16 February 1945–17 October 2024

Master Williamson started his career in the mid-1970s trading futures for Gerrard and National in Chicago. He became a pivotal figure in London’s financial sector, serving twice as Chairman of the London International Financial Futures Exchange (Liffe), where he introduced the American ‘open outcry’ trading system to the City in 1982.

Knighted in 2000, Master Williamson was appointed as an Honorary Bencher of the Inn in 2005 and served as a member of the Investment Sub-Committee from 2006. In 2007, he was inducted in the Futures Industry Association’s Hall of Fame to commemorate his contribution to the global futures and options industry. Famed equally for an adventurous spirit, his interests included tobogganing and high-altitude ballooning.

JAMES TURNER KC

23 November 1952–21 February 2025

Born in 1952, James Turner’s first experience of the law was accompanying his widowed mother to the Temple, where counsel advised in relation to the settlement of the fatal accident claim following his father’s tragic death in the Hither Green train crash in 1967. This profound experience fired his interest in the law and a desire to, as described by his son, “fight injustice wherever it raises its ugly head.”

Called to the Bar in 1976, James Turner practised from 1 King’s Bench Walk, initially becoming known for his detailed knowledge of the technical elements of criminal law. He was a contributing editor of Archbold: Criminal Pleading, Evidence and Practice from 1992–2018.

After taking Silk in 1998, his practice became more focused on family law. Throughout his career, Master Turner was involved in many of the landmark family law cases of the past two decades.

Elected as a Barrister Governing Bencher of the Inn in 2006, Master Turner served as a member of the Executive Committee from 2009–2011. As described by Alexander Chandler KC, Master Turner was “kind, personable, with an unrivalled store of funny legal stories and – remarkably for a man of such talent – not a hint of arrogance.” He is survived by his widow Simone, his children, and eleven grandchildren.

THE RIGHT HONOURABLE LORD JUSTICE WILLIAM DAVIS 20 June 1954–7 June 2025

Master Davis was called to the Bar in 1975 and practised in Birmingham where his work consisted primarily of criminal and personal injury cases. He was appointed as an Assistant Recorder in 1992, a Recorder in 1995 and took Silk in 1998. He was Head of St Philips Chambers from 2004–08, when he was appointed a Circuit Judge, later becoming Resident Judge at Birmingham Crown Court.

Master Davis joined the High Court Bench in 2014 and served as Presiding Judge of the Northern Circuit from 2016–19. In 2021, he was appointed a Lord Justice

of Appeal and held a number of senior judicial roles, including Judicial Lead on Youth Justice (2014–22), Director of Criminal Training at the Judicial College (2014–19), and Chair of the Sentencing Council from 2022 until his death.

Master Davis was elected a Governing Bencher of the Inn in 2007 and served as a member of the Scholarships Committee between 2009 and 2010. In recent years he was a regular attender at Call Nights.

Sir William Davis died suddenly at home in Warwickshire on 7 June, leaving his wife Ginny and children, Rosie and Ralph.

James Turner KC

The Right Honourable Lord Justice William Davis

Sir Brian Williamson CBE MA

PROFESSOR THE HONOURABLE GEORGE HAMPEL AM KC

4 October 1933–8 October 2024

Master Hampel was born before the Second World War and escaped with his immediate family from Poland to Russia when the Germans invaded Poland. Many of his extended family did not survive the Holocaust. Towards the end of the war, he and his mother escaped from Russia to Paris and then to Australia.

After studying in Melbourne, he was called to the Bar in Victoria in 1954. His early practice focused on criminal law, extending from the Magistrates’ Court to the Supreme Court; he was later admitted to the Bars of several states and the Bar of England and Wales.

He defended John Stonehouse in his extradition proceedings in 1975 and came to London to represent him at

a successful bail application in the Hight Court. He was a Justice of the Supreme Court of Victoria from 1983–2000.

He is best known for his contribution to advocacy training; he was the first professor of advocacy to be appointed worldwide. The ‘Hampel Method’ was adopted by many common law countries for the teaching of advocacy and was introduced by him to the four Inns when he led a series of ‘train the trainer’ events here in the 1980’s. He was a strong supporter of advocacy training within the Inn and was elected as an Academic Bencher in 2013. He and his wife, Academic Bencher Master Felicity Hampel, also an advocacy trainer, trained war crime prosecutors at the Hague.

CATHERINE CALLAGHAN KC

23 July 1971–13 August 2025

Master Callaghan was called to the Bar by The Inner Temple in November 1999 and joined Blackstone Chambers where she practised for 26 years in public and regulatory law, civil liberties and employment law, taking Silk in 2018. She served as a member of the Attorney General’s A Panel of Counsel from 2013–18 and was the Chair of the Constitutional and Administrative Law Bar Association (ALBA) from 2022–23.

Master Callaghan was elected a Governing Bencher of the Inn in 2018. She was a member of the Scholarships Committee, served on the Executive Committee from 2021, and latterly she was a Trustee of the Temple Church Trust.

She is survived by her husband, Andreas Gledhill KC.

Catherine Callaghan KC

Professor The Honourable George Hampel AM KC

LAWYERS AS PEACEMAKERS

By Master Rachael Field

The legal profession professes a commitment to the rule of law which provides a foundation for civic systems of law and government, serving society by ensuring personal freedoms and supporting social stability and order, as well as peace, freedom and decency. The legal profession is therefore more than a commercial industry driven by a market ideology of maximising individual gain through the provision of services for profit. As Justice Kiefel of the Australian High Court has said: “Practising lawyers do not just run a business, selling their skills and services to clients in return for fees. The practice of law is a profession and this sets it apart from other, commercial, enterprises”.

Nevertheless, the practice of law is simultaneously both a profit making business and a profession, and it is therefore influenced, if not driven, by the reality of market forces. It could be said that the legitimacy of the legal profession is upheld by a social bargain: lawyers provide ethical and altruistic service in exchange for a level of status and privilege. However, while the social bargain struck by the legal profession is not a simple or straightforward one, and while professions may well be criticised in modern society for being part of a neoliberalist privileging of the rationality and logic of the market, the social and political significance of the legal profession, both historically and in contemporary society, cannot be denied.

Admission to the legal profession requires a person to be of good character. To endure and succeed in the profession, lawyers need a moral compass and to abide by the customs and character of the community. Admission to the profession requires lawyers to swear, or declare and affirm, that they “will truly and honestly conduct” themselves and that they “will faithfully serve in the administration of the laws according to the best of (their) knowledge, skill and ability”.

Traditionally, lawyering has been broadly divided into transactional work (focused on managing business related transactions) and dispute resolution work. In both transactional and dispute resolution roles, lawyers are engaged as expert advisers, representatives and advocates who negotiate persuasively on behalf of their clients, assisting them to develop options, make informed choices and decisions and take control of positive or problematic personal and commercial situations.

Dispute resolution expertise is particularly central to the contemporary real world of lawyering. Communication skills are critical to all the work that lawyers do, and negotiation skills are used on a daily basis. Transactional lawyering can also be seen as a part of the dispute resolution matrix because effective transactional practice can operate to prevent disputes arising. In effect, transactional lawyering is a form of preventative law, for which dispute resolution expertise is essential. With regard to the dispute resolution aspect of legal practice, contemporary lawyering involves an expansive matrix of dispute resolution process options, many of them conducted away from the court system.

It is positive that lawyers are now much more aware of the benefits of non-adversarial approaches to helping people resolve or manage disputes. Perhaps more importantly, users of legal services are also demanding more seriously that their legal advisors help them find ways to resolve legal problems and disputes without the cost, delay and disruption of adversarial approaches and court proceedings. Increasingly also, processes such as negotiation, mediation and conciliation are being institutionalised through recognition in government policy and inclusion in the statute book at both state and federal levels. More and more, civil procedure legislation expects or mandates that parties to legal disputes engage in a non-litigation process and take genuine steps to resolve their dispute, before they are able to file proceedings in a court. Further, once a matter does reach court, judges at all levels of the Australian court hierarchy have wide ranging powers to refer matters to court connected dispute resolution processes.

The result of these developments is that non-adversarial dispute resolution processes and approaches have become embedded in Australian legal practice and are an inherent part of the day to day work of lawyering, even in matters where litigation is also being considered. A practical indication of this is found in the trend in law firms to rename their litigation sections with reference to dispute resolution and barristers increasingly include assistance with mediation and conciliation processes among the legal services they offer. Contrary to popular belief, therefore, lawyers are in effect peacemakers.

In both transactional and dispute resolution roles, lawyers are engaged as expert advisers, representatives and advocates who negotiate persuasively on behalf of their clients, assisting them to develop options, make informed choices and decisions and take control of positive or problematic personal and commercial situations.

Professor Rachael Field Professor of Law, Bond University

LAW AND BORDERS: AN INTERVIEW WITH THE MASTER OF THE GARDEN 10 YEARS ON

Patricia Robertson KC, Master of the Garden, has a walk around the Garden chatting with Head Gardener Sean Harkin, reflecting on her almost ten years in the role.

S: It will soon be ten years since you took over as Master of the Garden. Can you remember taking on the role?

At the time, I was newly liberated from six years on the Bar Standards Board, the last three of those as Vice Chair of that Board. That had involved a great deal of time in various committees as well as the Board itself, each with daunting amounts of paper to digest. When I had to negotiate a tricky regulatory issue, I would often invite the relevant person to join me for laps of The Inner Temple Garden to talk it through in an environment that fosters calm and civility.

Before becoming Master, I had been Assistant Master to the previous Master of the Garden, Master Sells, who had taught me the ropes and whose enthusiasm for everything related to the Garden was, and still is, unbounded. One of the many pleasures of being Master of the Garden is that it’s all about talking through what’s being done or what’s planned, often whilst in front of the plants in question or in an informal chat over Zoom, with only the necessary minimum of paperwork and formal meetings.

S: Have you always been passionate about gardens and plants?

Yes! I remember plants I have met going back to childhood, such as the first Ceanothus I encountered in a garden on my way to school, which seemed to me a miraculous colour to meet on a grey Edinburgh street. My grandad propagated so many fuchsias – his favourite plant – that in winter, when all the pots were brought into the lobby of his flat on the east coast of Scotland, you could barely get through to the front door. I designed a garden for my parents with a lot more enthusiasm than know-how decades ago, and my idea of the perfect Sunday is to spend it hands-on with plants – weeding, potting up, pruning.

S: Can you talk us through how you feel the Garden has evolved over your time?

Andrea had already moved the Garden a long way away from the ‘London Park’ style of planting, using succession planting to create constantly evolving displays full of contrasting textures in the high border and King’s Bench border, as well as an area devoted to drought tolerant plants, many of them from South Africa, around the steps.

Since you took over, as well as extending the beds around the west side of the lawn to add more interest and creating a garden room around the pond (both a great success), the emphasis has been on developing a romantic look that works with nature and enhances the biodiversity of the garden. This has included extending the meadow and the tree circle planting, creating dead wood areas for insects, allowing more self-seeding and letting seed heads stand into the autumn, and replacing the liriope under the plane trees with a much more diverse ecosystem of plants. Your success in creating a much-needed oasis for wildlife in the city has been recognised with numerous awards.

This approach to gardening involves a particularly delicate balancing act between letting nature have its way and exercising control. At certain points in the cycle of the year, we might have to tolerate some dishevelment in a few areas of the garden if we are going to create a rich and complex habitat, whilst at the same time we need to make sure that there are always other areas looking their best so that the garden remains a spectacular venue for events and a delightful refuge for those who live and work around it. The (rare) miner bees have given these developments a big thumbs up by colonising the meadow!

Master Robertson and Sean in the Pond Garden

Ferula communis, Giant Fennel encouraged to gently self seed

S: Some may not be aware that you also run an iris nursery in Umbria and are developing a garden there in your spare time. How did you come to be propagating iris, and can you describe the garden?

My husband is an art historian whose work is mainly based in Italy, and so we acquired a small farm in Umbria as a base. It’s an ‘agriturismo’, which means a mix of holiday rentals and agriculture. We make our own olive oil and, on finding that the local plant nurseries were often quite limited in the range of plants on offer, I decided to create Umbria’s first (and only) specialist iris nursery.

We started with irises because they grow well in the local conditions, are drought tolerant (increasingly important), enthusiasts will seek them out online and we can send them out bare root in the early autumn to anywhere in Europe (with the season for that work coinciding with the legal vacation). This means our market is not limited to those who happen to pass by our little nursery. Over time, I hope to make some crosses from our irises to create new cultivars and to start propagating day lilies, roses, herbaceous geraniums and grasses from our extensive collections here. However, that will need to wait for some future moment when I can devote more time to it!

In order to market our irises and also create a venue for events, I created a display garden with panoramic views over the valley below. Visitors can see some 850 cultivars of bearded irises as well as roses, peonies and a wide range of grasses and herbaceous perennials. The plants we use have to be able to cope with temperatures ranging from around -8C in winter to 39°C in summer. Water has a key role in the garden, with a central pond (for the water irises), a cascade and a formal water feature inspired by the hundred fountains at Tivoli (but achieved using very simple materials and without the benefit of a Cardinal’s budget). However, as water is a precious resource, all of this recirculates rainwater captured from the hillside above and is powered by photovoltaic panels. We open the gardens in May, when the irises are in flower, and for the rest of the year, they are a resource for our rental guests and a venue for weddings and events.

S: Where do you find your inspiration, and can you use three words to describe your gardening style?

I don’t think I have any one particular gardening style that I follow. I borrow like a magpie from all sorts of influences. One advantage of having a lot of space to create a garden (which is a luxury I have in Italy) is that you really can adopt the ‘right plant, right place’ philosophy because there will be a boggy patch somewhere for the moisture lovers and a sun-baked spot elsewhere. This is harder to achieve in my heavily overshadowed North London garden, when it is difficult to resist the temptation to include things I love that just won’t thrive there, like hostas, which are immediately shredded by the thriving slug population.

I don’t think I have any one particular gardening style that I follow. I borrow like a magpie from all sorts of influences.

However, I suppose the constants are an emphasis on texture, scent and light. I like plants that make you want to touch them, or which introduce movement, such as silky grasses. Perfume is indispensable to a garden, and roses, irises, peonies and scented geraniums are all generous in that regard. The play of light and the way light changes over a day and over the year is the fourth dimension of gardening; the same iris will be transformed depending on whether the light falls on it or comes from behind, while tiny sparks of light catch the tips of a transparent screen of Stipa gigantea and ripples of light animate the pond, brightening even a wintry day.

I try to think about each of these aspects when planning –but also remember that gardens rarely respect one’s plans –and to allow for an element of serendipity.

Master Robertson’s Iris Nursery, Umbria

S: Do you have a favourite garden or landscape that you would recommend?

It is very difficult to choose, so I will cheat and give you more than one. Just over a year ago, I visited the Western Cape area of South Africa. Kirstenbosch seemed to me the most beautiful botanical garden I had ever seen. The position below Table Mountain is both a spectacular setting and responsible for creating a special microclimate for the garden. The planting is managed in a way that is breathtaking, whilst at the same time illustrating the different groupings within this extraordinarily diverse plant kingdom. From there, we went down to the coast just to the east of the Cape, to an eco-resort whose mission is to preserve an unspoilt section of South Africa’s fynbos. From a distance, the hills might just look to be covered by a sea of green bushes (or that was my husband’s perspective), but when you get up close, this apparent uniformity turns out to be an illusion. There are more different species per square metre than in practically any other environment on Earth, including rainforest. The Proteas may be the most spectacular of these, but some of the least imposing have the most amazing scent and, in combination, the fynbos has a unique and memorable perfume. It was humbling to see what a spectacular, selfbalancing garden nature had created for itself, sustaining a vast range of wildlife from sunbirds to leopards.

My other long-standing favourite is the Gardens of Ninfa, south of Rome. Here, again, the position is unique: the gardens were created amidst the ruins of a medieval town and are nourished by crystal clear, cold waters running from the massive mountain behind the site. The head gardener told me that the trees here grow much faster than the normal rate because of the conditions. The style is full-on dreamy romantic, with roses tumbling over the frescoed walls of ruined churches, and mosses and ferns colonising trees growing through the middle of abandoned watchtowers.

S: What do you see as the challenges facing The Inner Temple Garden going forward, and is there anything you would like to see through during your time?

The most immediate challenge, which is also an opportunity, is to plan the greening of some areas of the car park, in conjunction with the work of resurfacing. I confess, I have nursed territorial ambitions in respect of the car park since I first became an Assistant Master of the Garden, so this has been a very long time in coming to fruition, but plans are now being actively developed within the Estates Committee.

As you know, the aim of the Garden team, which we hope others will support, is to use discrete areas of planting to enhance the car park whilst protecting the roots of trees, and reducing water run-off by providing planting beds in key areas where flooding in heavy rain can otherwise create problems. We also hope to improve the relationship between the Treasury Building and the Garden. Whilst there will, of course, be a continued need for car parking, the number of cars needing to be accommodated is on a downward trajectory. At the same time, there is greater awareness of the need to ensure that the Inn attracts and retains its tenants by offering an environment in which people are positively enthusiastic about living and working. Ultimately, the Inn’s ability to fulfil its wider mission depends on maintaining its revenue base.

I hope that I can see this through to completion of the planning phase. Just as the overhaul of the planting in Hare Court transformed it into a calm and welcoming space, I would hope we can create green oases within the current car park that welcome you into the grounds of the Inn, rather than confront you with a sea of parked cars to navigate through. More broadly, like all gardeners, the Garden team will need to work out what aspects of their approach need to be changed or adapted to respond to the challenges of climate change and to support the Garden’s objectives of greater sustainability. This has, rightly, been a particular focus in recent five-year plans.

The Pond Garden © Claire Takacs

Master Robertson and Sean in the Pond Garden

Snowdrops with Crosus in February

S: Lastly, what is the best thing about being Master of the Garden?

The biggest pleasure has been the opportunity to talk endlessly about plants with you on circuits of the Garden and to chat to the team about the tasks in hand! However, I do think it’s quite important that people reading this understand what being Master of the Garden doesn’t involve, because all too often I am given credit I don’t deserve. Just because I am an enthusiastic gardener doesn’t mean I have anything like the depth of expertise that you and the Garden team bring to bear. Decisions about the development of the Garden are firmly yours and not mine, as is all the hard work that goes into realising that vision.

The role of Master of the Garden is not to second-guess that expertise or impose their own ideas. Rather, it includes providing a sounding board for ideas, occasional constructive suggestions advanced in the spirit of a critical friend, guidance on the budgeting and planning process, and advocacy for the Garden within and outside the Inn. Above all, the Master of the Garden is a crucial interface, in governance terms, between the Garden team and the wider objectives and concerns of the Inn.

That takes me to another of the best things about the role, which is the fact that the Inn is enormously supportive of the Garden, so when we are an agenda item in any of the Committees, including the Finance Committee, there is a great reserve of good will and understanding of what we are trying to achieve and how much we contribute to the life of the Inn. This makes it much easier to negotiate for the things the Garden needs. Equally, in recent years, we have had to modify some of our ambitions because the Inn needed to find savings and we, as a team, had to find ways to contribute to that. Happily, of all of life’s pleasures, plants represent the most bang for your buck. A particular triumph was persuading the Inn to finance our investment in snowdrops in what was a difficult year financially – a modest initial investment which is now paying dividends every February!

Andrena-cineraria bee which ground nests in the meadows

Hare Court

Master Robertson in the Garden

Meadow with Liriodendron trees in background © Paul Debois

Patricia Robertson KC Master of the Garden Fountain Court Chambers

Sean Harkin Head Gardener

MUSIC IN THE TEMPLE CHURCH: AN OPPORTUNITY FOR ALL

By the Director of Music

Any organisation must adapt to its surroundings to survive, and this has never been more relevant and important in church music. Temple Church’s choir and musical tradition stretches back to the twelfth century, just after the church was built, and continues to flourish in a lively and varied programme today. Our current music programme encompasses a chorister programme for girls and boys aged 8–13; a youth choir for teenagers aged 14–21; an expanding singing outreach programme to primary schools; a choral scholarship scheme for emerging professional singers; and a weekly international organ recital series encompassing student showcase opportunities. Our ethos is to have entry points for participation at every age level from age six to professional musician.

The choristers of the Temple Church attend a range of schools in London and come to the church for a rehearsal at 4.30pm most weekdays. Many collegiate style choirs require children to attend particular schools but, at the Temple Church, we pride ourselves on this opportunity being open to anyone who can reach the church for rehearsals. We currently have children from 14 different schools, so the choir is a unique team of individuals. The daily musical training they receive is designed to enable them to thrive in a professional choir for their performances here and, equally as important, to equip them with musical skills for life.

During 2024, the choirs performed a range of major services and concerts, including a landmark performance of Handel’s Messiah at Christmas, and concerts on the theme of ‘Song of songs’ and ‘Lamentations’, Vivaldi’s Gloria and Purcell’s Come ye Sons of Art with period orchestras, Britten’s Ceremony of Carols and premiere performances by contemporary composers Cecilia McDowall and Anna Semple. The choir also performed alongside the choir of Hampton Court, and recorded a track for the Cathedral Music Trust’s Christmas card.

EQUAL OPPORTUNITIES

In September 2024, the choir welcomed its first girl choristers, which created an exciting new direction for the choir. Quite simply, the girl choristers have been integrated into the treble line alongside other new juniors in school year 4, joining the team of existing boys. The transition has been very smooth on account of the pre-existing culture of support, pastoral care, positive encouragement, and first-rate teaching in the pursuit of musical excellence. The choristers went on a residential choir camp to Norfolk in May, joining with Norwich Cathedral Choir for a service, as well as spending time together doing team building activities. The atmosphere of mutual respect and encouragement across the age range is similar to that of a well-run football team. In fact, a chorister football match is quite a spectacle, especially as the Temple Church choristers train with a tennis ball in their breaks along the South side of the church!

MUSICAL APPRENTICESHIP

The music profession has always relied on training and a sense of musical apprenticeship with an exchange of skills. This sense of mentoring has come to fruition with our choral scholarship scheme, now in its fifth year. The female choral scholar scheme has enabled four singers each year to work alongside the professional singers of the Temple Church Choir. Developing this further, in 2025, we will offer an opportunity to four postgraduate singers (soprano, alto, tenor and bass) at the start of their professional journeys. The choral scholars will sing alongside our professional singers and receive bespoke training and mentoring from the music department. Above all, we recognise the importance of encouraging young musicians and helping them to develop their confidence, resilience, and widest possible range of skills. To survive in the profession today, musicians need to be able to turn their hand to different skills and to fit into a variety of ensembles and settings throughout their careers.

Temple choristers at Norwich cathedral

Choir camp – Tom Allery overseeing a game of pool

LOOKING BACK, LOOKING FORWARD

2025 sees the 70th anniversary of the reforming of the choir after the 1950’s post-war restoration. A number of original members of the choir are working alongside us to organise a special choir reunion on Sunday 26th October 2025 for former choir members and scholars of all generations. Former members of the choir will join forces with the current choir in singing parts of the service of choral Mattins that morning.

‘SING OUT’

In 2022, I led an initial pilot project, called ‘Sing Out’, to primary schools in London. Working with a team of colleagues from the choir, we delivered free sessions to year 3 and 4 classes, preparing them for a celebration concert in the church with two or three schools. This project has become an annual fixture in the church, and we are expanding our network across London, meeting new partners and link organisations each year. Most of the children we work with have not heard a professional singer perform live, have never heard the church organ or even set foot in a building as old as the Temple Church.

Sessions in schools last typically an hour, and link to the core music skills we teach in the choir. Beginning with a warm up of the body and the voice, we get straight into how to make the children’s voices project and connect naturally with their speaking voice and supported breathing. We then learn a range of songs, typically folk songs and rounds, and immediately start to relate this to school curricula, reading, storytelling, emotions, acting and history. The concert typically ends with two songs by contemporary composer Jonathan Dove from his Seasons and Charms

Each year we have worked with around 150 children, and we plan to increase this in the future. In early 2025, we made a new appointment, a Head of Choral Education and Outreach who will work in the music department and take a lead on developing our engagement work, developing partnerships, continuing to build a talent pipeline of young singers for choristership, and establishing a junior choir. We have been delighted to appoint Yvette Murphy, who has previously run the schools outreach programme for the Diocese of Westminster and who will continue to build our community engagement projects across a range of ages, encompassing both singing and the organ.

AN OPPORTUNITY FOR ALL

Above all, our work at the church is about proudly building on our heritage but making sure there are no barriers preventing participation. We are proud of the excellence on which we build, and aspire for this level of musical quality and opportunity to be available to all. We seek to ensure that our resources are shared widely with our neighbours, and that, above all, we make our musical offerings in liturgies and concerts relevant to modern day London. Every new venture is ultimately about investing in the future of our music programme, and making it relevant for the future. We seek to work through the lens of tradition but with the confidence to adapt, react, and innovate with purpose. In this way, the next steps on our journey as an institution are defined by their relevance and engagement in London today. Temple Church’s history and music have a unique way of opening the doors to this ancient place, whatever your story.

Thomas Allery Director of Music

Temple choristers at Norwich Cathedral School

Probationers at Temple Church Nativity Play

‘Sing Out’ at Temple Church

RAISING THE BAR ON

Conference and Meeting spaces

Book a meeting room or conference space at The Inner Temple and you will have everything you need for a successful day.

All rooms feature high-tech integrated AV, with interactive Clevertouch screens, cameras for room capture, recording and streaming, allowing you to reach audiences near and far and to revisit your meetings when needed.

There is also a spacious shared breakout space for attendees to take time out, with access to the viewing balcony which overlooks the award-winning garden and the surrounding areas.

020 7797 8230 | venuehire@innertemple.org.uk | innertemplevenuehire.co.uk

Lecture: Up to 120

Meeting: Up to 24

Classroom: Up to 28

IN MEMORIAM

Remembering members who have died in the past year:

Richard Clegg KC* 07/08/2024

Martha Knowlden 15/08/2024

Professor the Honourable George Hampel AM KC* 08/10/2024

Owen Daniel Esq 15/10/2024

Margaret Pine-Coffin 15/10/2024

Sir Brian Williamson CBE* 16/10/2024

Judge Doyle 27/10/2024

Terence Coghlan KC* 18/11/2024

Dr Pehr Gyllenhammar* 21/11/2024

Sir Brian Jenkins GBE* 25/11/2024

The Rt Hon The Lord Lloyd of Berwick DL** 08/12/2024

Sebastian Ukegheson 12/12/2024

His Honour William Monro Davies KC 30/12/2024

His Honour Denis Orde* 30/12/2024 The Rt Hon Sir Anthony May** 30/12/2024

Frances Heaton 05/01/2025

Derrick Pears 09/01/2025

James Turner KC* 21/01/2025

Charles Holland 09/02/2025

Her Honour Shirley Anwyl KC* 15/02/2025

Sir Jeffery Bowman FCA* 18/02/2025

Robin De Wilde KC* 13/03/2025

Nicholas George 08/04/2025

Sir Neil Butterfield* 08/04/2025

Shabrina Ali 10/04/2025

The Rt Hon Lord Justice William Davis* 07/06/2025

Sir James Watson Bt 14/06/2025

Lola-Rose Avery 15/06/2025

Andrew Watson 15/06/2025

Sir Colin Corness 25/06/2025

Patrick Lynch 12/08/2025

Catherine Callaghan KC* 13/08/2025

© Paul Debois

ARTIFICIAL INTELLIGENCE AND PROFESSIONAL ETHICS

An extract from the speech delivered by the Treasurer, Richard Salter KC, at the Singapore Litigation Conference on 29 April 2025.

It is natural for lawyers – especially lawyers of my generation – to be nervous, even to be afraid of Artificial Intelligence. Some of us (though I am sure, no one in this room) are still not adept at using computers for word processing and diary keeping, much less at using them for anything more complicated.

One of my predecessors as Treasurer still kept his diary in a small book that he carried around with him: and I am currently a member of an arbitral panel where the presiding arbitrator is only just getting to grips with MS Word and has had to leave the formatting of the Award entirely to me.

The reality though is that, as a profession, we have no real choice about whether we should embrace AI. We will have to.

First, because the industrial, financial and consumer sectors that are served by lawyers and the legal system are themselves already using AI at every level, and will expect lawyers and judges both to understand AI (with all its advantages and limitations) and to use it.

Second, because there will be work to be had in future in claims relating to the non-use and the misuse of AI.

But third, and most importantly, because of all the things that AI can do even now to help lawyers and the legal system to provide a better, quicker and cheaper service to our clients and other users.

The real question for us in the legal profession worldwide is not what deleterious effects AI will have – whether it will make us all redundant – but what beneficial effect it can have on the service that we provide to our clients.

The UK was among the first jurisdictions to provide, in December 2023, formal Guidance for Judicial Office Holders on the use of AI. This was revised and re-issued on 15 April 2025, partly to take account of the fact that a closed AI system is now available to the judiciary of England and Wales.

There are three ethical and practical themes in that guidance, which apply as much to lawyers as to judges.

First, before using AI, whether as a lawyer or as a judge, you need to understand both what it does and what it does not do.

This is the first, and most important, rule. AI can be a good tool but, to use it effectively, you absolutely have to understand it, and to understand it well.

At present, most of the available Large Language Models are simply trained to predict the most likely combination of words from a mass of data. Unless you are using a dedicated and specially written AI program, the model will not check its responses by reference to an authoritative database. It will sometimes ‘hallucinate’ and invent authorities.

You will no doubt be aware of the story of Steven Schwartz, who included six fictitious cases suggested by ChatGPT in his submissions in the case of Mata v Avianca Inc [Civil Action No: 22 Civ 1461] in New York. The affidavit which he filed in order to explain his conduct to Judge P Kevin Castel included screenshots showing that he had specifically asked the AI whether one of the cases that it had given him was a ‘real’ case, and had been reassured by the AI that it was. It even provided an apparently authentic case citation. 1

Even the best programs are also likely to have a number of inbuilt biases, which lawyers must be alert to – let us not forget that human decision-making can be biased too – and, while AI can certainly invent, you cannot expect it to develop the law. It has a natural tendency to look backwards. It may contain the words of great judicial innovators like Lord Eldon and Lord Denning, but it does not yet have anything like their vision of what the law could and should look like.

Nevertheless, as Chief Justice Menon rightly reminded the inaugural India-Singapore Conference on Technology in April last year, AI technology is changing and developing at an incredible pace. To borrow the wise words of Professor Richard Susskind, today’s AI systems are “the worst [they] will ever be”.

Tomorrow’s AI systems may have different and better abilities and different risks and limitations inherent in them.

Professional ethics and competence will require us to use those systems: but, to use them, we must understand them and must keep pace with the technological changes.

The second and third themes in the UK Judicial Guidance come from the limitations on what AI can do at the moment.

The second theme is that, you must avoid inputting confidential information into public LLMs, because doing so makes the information available to the world. Some AI models even now claim to be limited to accredited databases and to preserve confidentiality: but the ethical principle of preserving confidentiality must always be paramount, and is the individual responsibility of the lawyer using the AI, not of the system.

The third theme is that it is not the AI, but the judge or lawyer using it, that is responsible for the output.

These three themes find a clear echo in the four general rules provided in the Chartered Institute of Arbitrators’ Guideline on the use of AI in arbitration, which was published as recently as 9 March 2025.

These four ethical rules are said to be applicable both to parties and to arbitrators. First, all participants should make reasonable enquiries to understand a proposed tool. Second, all participants should weigh up the risks against the benefits of use. Third, all participants should make enquiries about the applicable laws and regulations governing the use of the tool.

Fourth, unless expressly agreed in writing by the tribunal and parties (and subject to any mandatory rule), the use of an AI tool by any participant will not diminish their responsibility and accountability.

As the guidance which the English Bar Council put out in January 2024 says, “Generative AI LLMs can therefore complement and augment human processes to improve efficiency but should not be a substitute for the exercise of professional judgment, quality legal analysis and the expertise which clients, courts and society expect from barristers”.

This idea, that human oversight and responsibility is always necessary in the legal and judicial process is built into the thinking behind the European Union’s recent AI Act (Regulation (EU) 2024/1689 of the European Parliament and of the Council of 13 June 2024 laying down harmonised rules on artificial intelligence). This Regulation characterises AI systems concerned with the administration of justice as “High Risk AI systems”. They are not banned, but they must be closely monitored.

1 The judgment of the Divisional Court of the King’s Bench Division (Dame Victoria Sharp P and Johnson J) in the cases of Ayinde v LB Haringey and Al-Harou v Quatar National Bank [2025] EWHC 1383 (decided not long after this speech was delivered) contains (at [6] – [8], per Dame Victoria Sharp P) a vivid description of the current limitations of AI for legal research: “[6} In the context of legal research, the risks of using artificial intelligence are now well known. Freely available generative artificial intelligence tools, trained on a large language model such as ChatGPT are not capable of conducting reliable legal research. Such tools can produce apparently coherent and plausible responses to prompts, but those coherent and plausible responses may turn out to be entirely incorrect. The responses may make confident assertions that are simply untrue. They may cite sources that do not exist. They may purport to quote passages from a genuine source that do not appear in that source. [7] Those who use artificial intelligence to conduct legal research

The decision of the Court of Justice of the European Union in OQ v Land Hessen (SCHUFA Holding) (Case C-634/21) (a case concerning automated credit-scoring) suggests that Article 22 2 of the EU’s General Data Protection Regulation 3 (which still, in slightly amended form to takwe account of Brexit, is part of English law) may also prohibit automated decision making more generally, even outside the legal system.

However, as the UK’s senior civil judge, Sir Geoffrey Vos MR, said in the lecture which he gave at the LawTech UK Generative AI Event in February this year, in a world in which machines are becoming so much more capable than humans, it may become simply too time-consuming and expensive for anyone to check the integrity of every decision that machines recommend humans to make.

For example, there are many small cases which it is presently simply too expensive for private litigants to take to England’s lowest civil court, the County Court. The UK’s out-of-court consumer redress systems – we call them ‘Ombudsmen’ –are also labour-intensive, and their cost is a significant drain which is generally either recovered from the relevant business or industry sector or paid out of general taxation by the state. Might it be better, even at the cost of some imperfect decision-making and ‘rough’ justice, to automate the resolution of such claims? Might that not be better than leaving so many people without any practically effective legal remedy?

In his Blackstone lecture in November 2024, Sir Geoffrey Vos MR gave the question of whether a child should be removed from its parents as an example of a decision that it is inconceivable that society would accept as being made by a machine. In his February 2025 lecture, however, he noted that some of the distinguished Oxford academics who were present at that lecture questioned his assumption, and suggested that emotive decisions of that kind would be just the type of decision-making that parents would really prefer to be taken out of human hands.

The Legal Community will need, as technology develops, to decide what kinds of advice and decision-making should, and which should not, be undertaken by a machine.

I look forward to hearing and learning from the contributions which others will make to this Workshop. AI will inevitably make profound changes to the way in which we, as lawyers and judges, go about our business. How best to respond to the ethical and practical challenges which we face is a subject about which we can all learn and profit from the experience and collective wisdom of other jurisdictions.

Richard Salter KC Treasurer 2025

notwithstanding these risks have a professional duty therefore to check the accuracy of such research by reference to authoritative sources, before using it in the course of their professional work (to advise clients or before a court, for example). [8] This duty rests on lawyers who use artificial intelligence to conduct research themselves or rely on the work of others who have done so. This is no different from the responsibility of a lawyer who relies on the work of a trainee solicitor or a pupil barrister for example, or on information obtained from an internet search”. The judgment also contains in an Appendix a list of similar cases involving the misuse of AI from all over the world, including several examples from England, the first dating from 2023.

2 Which (in the UK version) provides that “(1) The data subject shall have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly

affects him or her. (2) Paragraph 1 shall not apply if the decision: (a) is necessary for entering into, or performance of, a contract between the data subject and a data controller; (b) is required or authorised by domestic law which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests; or (c) is based on the data subject’s explicit consent. (3) In the cases referred to in points (a) and (c) of paragraph 2, the data controller shall implement suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view and to contest the decision”.

3 Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data,

AFTER 1925: REFLECTING ON 100 YEARS OF PROPERTY LEGISLATION

By Master Judith Bourne

1925 saw an ‘explosion’ of property legislation which aimed to ‘simplify’ and ‘make certain’ all transactions in land. The legislation also sought to reduce the number of estates in land and make transactions more affordable. Six bills received the Royal Assent on 9 April 1925 (many have been repealed or replaced):

• Law of Property Act

• Administration of Estates Act

• Settled Land Act

• Trustee Act

• Land Charges Act

• Land Registration Act

The new Acts did not attempt to revolutionise the law relating to property but rather attempted to do what had never been done before: codify and consolidate large parts of the existing common law and statute in relation to property in land.

The pre-1925 law had developed from Tudor times and more radical changes were made in the 19th century. Influenced by political and social changes, the first report from the Real Property Commissioners in 1829 began a process of legislative change that the 1925 legislators concluded. 1925 was the ideal time, due to change following the First World War. Public opinion was in favour of reform because land was expensive to convey and too slow. Large estates were being broken up, people aspired to home ownership, death duties were heavy, conveyancing was defective, and the law of primogeniture needed review. Lord Wolstenholme and Sir Benjamin Cherry began the legislative process in 1895, and the legislation received Royal Assent on 9 April 1925.

Just over 100 years later (10 April), a group of scholars and barristers met for a celebratory centenary workshop and to contemplate its next 100 years. The group were welcomed by Professor Judith Bourne Legal Academic Bencher at The Inner Temple, CILEX Law School and workshop organiser).

After 1925: Centenary Workshop

The plenary paper was delivered by Professor James Lee (Legal Academic Bencher at The Inner Temple and King’s College, London). Professor Lee’s paper reflected on the use made of equity by the legislature. His paper, Equity, Ancient and Modern, examined an article by HG Hanbury in 1929, entitled The Field of Modern Equity, which had reflected on “the very important Property Legislation of 1925” and its effect on the ‘province of equity’ and the resulting implications for teaching and research on the subject. Professor Lee described this article as Hanbury’s “sales pitch” for the book that would become Modern Equity, the first edition of which was published in 1935. 99 years later the Supreme Court heard a submission that section 53(1)(c) on dispositions of equitable interests should in fact be limited to such interests in land, rather than all property (as at least 50 years of case law had confirmed or assumed).

Professor Lee concluded that the Law Commission has identified a future project on reform, modernising trust law for a global Britain. In proposing that project, the Commission referred to trusts as an “outdated area of the law”, which “has not been comprehensively reviewed since 1925.” And yet, reviewing legislative developments in the field of trusts over the last 30 years, both here and abroad, showed that equity retains its dynamic role. We therefore needed to re-evaluate our thinking, pedagogy and scholarship in this field, as modern equity becomes ancient.

The Gratuitous Transfer Resulting Trust: Personal but not Real? was the title of the next paper delivered by Dr Matthew Stubbins (Director of Law at Canterbury Christ Church University). His paper examined two questions: whether section 60(3) of the Law of Property Act 1925 was a reforming section or merely a “word-saving” provision, and further, what was the correct interpretation of s60(3) and the position of gratuitous transfers of land.

The paper set out how, for the last 100 years, debate has simmered over the intended purpose behind some of the Law of Property Act (LPA) 1925’s provisions. He argued that this was encapsulated in s60(3), where notwithstanding its now century’s long existence, a categorical interpretation had yet to be formulated, in contrast to other sections such as section 53. The uncertainty regarding section 60(3) could be distilled into those two questions: was the LPA 1925 intended to actively reform property law, or was it merely a “word-saving” provision intended to simplify the convoluted pre-existing legislation?

Section 60(3) provides that “In a voluntary conveyance a resulting trust for the grantor shall not be implied merely by reason that the property is not expressed to be conveyed for the use or benefit of the grantee.” The literal interpretation, adopted in court judgments such as Lohia v Lohia and Ali v Kahn [2002] EWCA Civ 874, and by many in the academic community, has been to interpret section 60(3) as eliminating the presumption of resulting trust upon the gratuitous transfer of land. He argued that the judicial trend against the established literal interpretation was problematic. The two questions therefore remain unanswered a century after the LPA’s enactment.

David Sheldon (Lecturer in Law, University of Bristol) opened the next paper by describing the enactment Law of Property Act as, “a blockbuster event in the world of property law” which built on the Law of Property Act 1922. Mr Sheldon’s paper, Formalities, the Law of Property Act 1925 and the 21st Century provoked much discussion in his assessment of the formality requirements in the Law of Property Act 1925 and their fitness for purpose in the modern world of registered land.

He argued that the LPA 1925 was an ambitious recrafting and reorganisation of property law as we knew it. Within this recrafting, an attempt was made to simplify the law of real property to create a system where conveyancing became more efficient. Part of this clarification was successful in that the number of estates and interests in land were reduced significantly as well as creating a small number of formalities needing to be satisfied for the effective creation or transfer of legal estates.

Over the course of the next 100 years, the simplification of these formality requirements as well as their workings alongside other provisions within the LPA 1925 have been strained and stretched to their limits. Technological developments, judicial intervention and judicial creationism along with the enactment of further statutes such as Law of Property(Miscellaneous Provisions) Act 1989, Trust of Land and Appointment of Trustees Act 1996 (ToLATA) and the Land Registration Act 2002 have raised questions as to whether the time has finally arrived for the Law of Property Act 1925 to be replaced with a new statute fit for modern purposes.

After coffee, Dr Anton van Dellen (barrister at Fraser Chambers, Assistant Coroner in West London, Rhodes Scholar, Fellow at Christ Church and former neurosurgery registrar) considered both the present and future of the 1925 Property legislation with his paper on Cryptocurrency and Law of Property Act 1925 section 53(1)

His paper considered the trading of cryptocurrency and the application of section 53(1) Law of Property Act 1925. Section 53(1) states that a disposition of an equitable interest in land must be in writing; the writing must be signed by the person disposing of the interest, or by their agent or by will; and a declaration of trust must be in writing, signed by the person who can declare the trust, or by will. Ruscoe & Moore v Cryptopia Limited (in liquidation) [2020] NZHC 728 held, for the New Zealand equivalent of section 53(1), that cryptocurrencies were held on express trusts. The servers on which the cryptocurrencies were held had been hacked. The cryptocurrencies held were not segregated and were consequently held on trust for multiple co-owners. Section 53(1) applies to dispositions of equitable interests in cryptocurrencies that are held on trust for multiple coowners. However, the underlying issue is the certainty of subject matter in relation to the shares of an intangible asset.

In Re Goldcorp Exchange Limited (in receivership) [1995] 1 AC 74, the Privy Council held that a proportion of a fluctuating stock of gold was insufficiently identifiable to constitute the subject-matter of a trust. Goldcorp was distinguished on the basis that it was a Sale of Goods case in Hunter v Moss [1994] 1 WLR 452 which concerned a share of future shares and by Neuberger J (as he then was) in Re Harvard Securities Ltd [1998] BCC 567. Section 53(1), he felt, was overdue for reform as applicable to cryptocurrencies, which would enable Goldcorp to be over-ruled by statute.

Dr Sarah Egan (barrister of The Inner Temple, New Square Chambers) considered Co-ownership and Cohabitation after 1925: A Case for Reform? Her paper reviewed whether the 1925 legislation accomplished its objectives regarding coownership of property with a focus on cohabitation disputes in light of the social and technological changes which have occurred since the legislation was enacted and also in light of the reform of this area of law by subsequent legislation, such as the ToLATA and the Trustee Act 2000, in order to evaluate whether further reform is required.

Firstly, Dr Egan’s paper considered how the 1925 Acts codified the common law and modernised the legal principles relating to co-ownership of property to identify the objectives of the legislation within the prevailing social and historical context. Secondly, she looked at whether the objectives of the 1925 Acts had been accomplished in the context of cohabitation disputes with reference to the further reforms of the law of co-ownership of property by the ToLATA 1996 and the Trustee Act 2000. Her analysis included a review of the approach of the courts in the pertinent jurisprudence (such as Stack v Dowden [2007] UKHL 17 and Jones v Kernott [2011] UKSC 11) when interpreting the legislation to assist in the evaluation of whether there was a need for reform. In conclusion, she examined whether the law on co-ownership in the context of cohabitation disputes required further reform with proposals for how such reform may be achieved.

Professor Philipp Elliot-Wright (Head of the School of Law at the University of West London and non-practising barrister) took the workshop through the legal-historical events that led to the 1925 legislation. His paper, What came before: Attempts at reform prior to 1925 and the socio-economic factors driving reform considered the need for reform of English land law that had been recognised and articulated for centuries prior to the 1925 legislation. No less a person than Oliver Cromwell described land law in England as a “tortuous and ungodly jumble” He argued that it was straightforward to find numerous other jurists from that period onwards articulating similar sentiments. By the mid-19th century, the Liberal Party was articulating reforms that included registration of estates and the rationalisation of the conveyancing process. Yet, despite certain statutory initiatives, there were to be no substantive reforms until the dramatic platform of such in 1925.

There have been various theses put forward as to what drove reform from the 1860s onwards, be it a battle between Benthamite Liberals and ossified solicitors, and/or entrenched establishment interests, essentially a ‘goodie’ verses ‘baddie’ narrative. His paper focused on the respective socio-economic drivers, especially in the mid to late-19th century that drove calls for reform, and the opposition to such. This included entrenched social and economic interests of the traditional landed establishment, verses the ever-greater need for reform in an industrialising and urbanising society. Despite opposition to reform, from the 1870s onwards, there would be

tentative moves, such as the Land Transfer Act 1875 and the Settled Land Act 1882. Professor Elliot-Wright suggested that many of the key concepts underpinning the reforms of 1925 were already in place before the First World War, but that it would be the political aftermath of that event that was crucial to propel the process of reform to fruition.

The day concluded with a joint paper by Judges Michell (Principal Judge of the Land Registration Division of the First-tier Tribunal, Property Chamber) and Paton (First-tier Tribunal) with their paper, What’s the ‘matter’? – the growth of a specialist national property law tribunal. This paper highlighted that only nine of the 378 pages of the Law Commission’s 2001 report accompanying the draft Land Registration Bill were devoted to the creation of a new independent Adjudicator to HM Land Registry to “determine any contested application to the registrar that cannot be disposed of by agreement between the parties”. It was said that the Adjudicator would provide a “similar service” to the former Solicitor to HM Land Registry.

Whilst in the early days, there were those who thought that the Adjudicator would concern themselves only with strict land registration law and send most cases to the courts for determination, but what emerged, at first as the Adjudicator and then (since 2013) the First-Tier Tribunal, Property Chamber, Land Registration Division – was a specialist national tribunal and litigation forum in which substantive issues both of fact and English property law are determined. This Tribunal receives around 1,000 new cases each year, now dealt with by five salaried full-time judges, and nearly 40 part-time judges drawn from specialist practice, assisted by two legally qualified registrars and 21 full time Ministry of Justice staff. One or both parties are usually legally represented, and the Adjudicator/Tribunal has from the outset exercised a costs-shifting jurisdiction. The paper traced those developments, the “matters” with which the Tribunal deals, the jurisdictional and other challenges it faces, and its future role in property dispute resolution.

The workshop produced much discussion, and the group intends to publish a volume out of the papers delivered and from members of the audience. We were very grateful to the Honourable Society of The Inner Temple for hosting this event, in particular, the Archivist, Celia Pilkington.

Professor Judith Bourne Dean of CILEX Law School

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Justice L Nageswara Rao (H)

Dr James Renwick AM CSC SC (H)

The Hon Mr Justice Richard Harrison (J)

Ms Errollyn Wallen CBE (H)

Brigadier General Malinda Dunn (H)

Her Honour Judge Boye (J)

His Honour Judge Julian Smith (J)

Stephen Akinsanya Esq (B)

Ms Grace Brown (B)

The Rt Hon The Lord Murray of Blidworth (B)

Ms Tamara Oppenheimer KC (B)

Ian Mullarkey Esq (B)

Mrs Hannah Smith (B)

His Honour Judge Grimshaw (J)

Baldip Singh Aulak Esq (B)

Miss Katherine Duncan (B)

KEY

(B) Barrister Governing Bencher

(H) Honorary Bencher

(J) Judicial Governing Bencher (A) Legal Academic

(O) Other Governing Bencher

(S) Senior Bencher

(U) Supernumerary Bencher

(V) Overseas Bencher

PEOPLE FINDER

TREASURY

Sub-Treasurer Greg Dorey CVO

Head of the Sub-Treasurer’s Office

Jennie Collis Price

Executive Assistant to the Sub-Treasurer Wanda Szwed

Director of the Treasury Office

Henrietta Amodio

Membership Registrar and Data Protection Lead Jude Hodgson

Records and Membership Assistant

Jacqueline Fenton

Member Events and Administration Manager Kate Peters

Member Events and Administration Assistant Rosy Humphrey

Communications & Social Media Co-ordinator Sandra Alvarez

Treasury Office Assistant Isabelle Keltie

Reception Supervisor – daytime (main entrance) Kushmanda Khetoo

020 7797 8250 enquiries@innertemple.org.uk

020 7797 8177 subtreasurer@innertemple.org.uk

020 7797 8177 jcollisprice@innertemple.org.uk

020 7797 8179 wszwed@innertemple.org.uk

020 7797 8182 hamodio@innertemple.org.uk

020 7797 8206 jhodgson@innertemple.org.uk

020 7797 8241 jfenton@innertemple.org.uk

020 7797 8183 kpeters@innertemple.org.uk

020 7797 8264 rhumphrey@innertemple.org.uk

020 7797 8227 salvarez@innertemple.org.uk

020 7797 8182 ikeltie@innetemple.org.uk

020 7797 8247 kkhetoo@innertemple.org.uk

Reception Supervisor – evening (main entrance) Maryam Khan 020 7797 8247 mkkhan@innertemple.org.uk

Director of Education Gail Fleming 020 7797 8214 gfleming@innertemple.org.uk

Head of Teaching and Learning

Karen Taylor 020 7797 8213 ktaylor@innertemple.org.uk

Education Programmes Manager (Pre-Pupillage) Julia Armfield

Education Programmes Officer (Pre-pupillage) Kerry Upham

020 7797 8207 jarmfield@innertemple.org.uk

020 7797 8189 kupham@innertemple.org.uk

Education Programmes Manager Vanessa Bennett 020 7797 8261 vbennett@innertemple.org.uk (Pupils & New Practitioners)

Education Co-ordinator Mercy Quaynor 020 7797 8253 mquaynor@innertemple.org.uk

Education Programme Manager David Miller 020 7797 8209 dmiller@innertemple.org.uk (Established Practitioners)

Education Operations & Projects Manager Richard Loveridge 020 7797 8212 rloveridge@innertemple.org.uk

Education Engagement Co-ordinator James Batterson 020 7797 8257 jbatterson@innertemple.org.uk

Education & Training Administrator Marianne Allen 020 7797 2386 mallen@innertemple.org.uk

Senior Manager (Scholarships & Outreach) Stephanie Baughen 020 7797 8262 sbaughen@innertemple.org.uk Outreach Co-ordinator Jess Brown

jbrown@innertemple.org.uk

(enquiries and cataloguing)

Michael Frost

020 7797 8178 mfrost@innertemple.org.uk

Assistant Librarian (enquiries and acquisitions) Sally McLaren 020 7797 8221 smclaren@innertemple.org.uk

Senior Library Assistant (enquiries and acquisitions)

Senior Library Assistant (enquiries and binding)

Graduate Trainee Librarian

Library Assistant

Enquiry Desk

Archivist

Simon Hindley

James Rowles

Jessie Leach

Karolina Laigonaite

Celia Pilkington

Assistant Archivist Umut Kav

020 7797 8222 shindley@innertemple.org.uk

020 7797 8223 jrowles@innertemple.org.uk

020 7797 8218 jleach@innertemple.org.uk

020 7797 8219 klaigonaite@innertemple.org.uk

020 7797 8217/8218

020 7797 8251 cpilkington@innertemple.org.uk

020 7797 8251 ukav@innertemple.org.uk

Director of Properties and Surveyor Richard Snowdon

Facilities Manager

Operations & Facilities Officer

Office Manager

Estates Officer

Mechanical and Electrical Engineer

Lukas Jelinek

Monika Kieller

surveyors@innertemple.org.uk

020 7797 8203 rsnowdon@innertemple.org.uk

020 7797 8199 ljelinek@innertemple.org.uk

020 7797 8192 mkieller@innertemple.org.uk (Maternity leave until Spring’ 26)

Rene Hicks

Albena Ahjem

Darren Readings

Works Supervisor Paul Simmonds

020 7797 8173 rhicks@innertemple.org.uk

020 7797 8202 aahjem@innertemple.org.uk

020 7797 8198 dreadings@innertemple.org.uk

020 7797 8190 psimmonds@innertemple.org.uk

Facilities Foreman Fausto Gonzalez (Julius Rutherfoord) 020 7797 8195 fgonzalez@innertemple.org.uk

Lead Electrician Ian Ward

020 7797 8197 iward@innertemple.org.uk

Lead Plumber Tony Baca 020 7797 8196 tbaca@innertemple.org.uk

Lead Carpenter

Head of Catering

Steve Hanks

Vicky Portinari

020 7797 8239 shanks@innertemple.org.uk

7797 8230 catering@innertemple.org.uk

020 7797 8231 vportinari@innertemple.org.uk

Deputy Head of Catering Priya Patel 020 7797 8233 ppatel@innertemple.org.uk

Executive Head Chef Robbie Lamb 020 7797 8232 rlamb@innertemple.org.uk

Sales and Marketing Manager

Senior Sales Executive

Senior Sales Executive

Stacey Barber

020 7797 8280 sbarber@innertemple.org.uk

Raeesah Rahman 020 7797 8246 rrahman@innertemple.org.uk

Katheryne Barros

020 7797 8194 kbarros @innertemple.org.uk

cfoley@innertemple.org.uk

chons@innertemple.org.uk

nsutton-smith@innertemple.org.uk

psteel@innertemple.org.uk

pottingshed@innertemple.org.uk

CHAIRS OF BENCH COMMITTEES & SUB-COMMITTEES

EXECUTIVE COMMITTEE

Master Treasurer

ADVOCACY TRAINING COMMITTEE

Master Sarah Clarke

ARCHIVES COMMITTEE

Master Julia Dias

BENCHER NOMINATION COMMITTEE

Master Reader

COMMUNICATIONS, INFORMATION TECHNOLOGY & ARTIFICAL INTELLIGENCE COMMITTEE

Master Tom Mitcheson

EDUCATION & TRAINING COMMITTEE

Master Simon Heptonstall

EMPLOYED BAR FORUM

Master Sara Lawson

EQUALITY, DIVERSITY & INCLUSIVITY SUB-COMMITTEE

Master Jeremy Richardson

ESTATES COMMITTEE

Master Roger Stewart

FINANCE SUB-COMMITTEE

Master Sonia Nolten (Senior Bench Auditor)

INTERNATIONAL COMMITTEE

Master Kieron Beal

INVESTMENT SUB-COMMITTEE

Master Matthew Reeve

LIBRARY COMMITTEE

Master James Dingemans

PEGASUS SCHOLARSHIP TRUST

Master Martin Goudie

QUALIFYING SESSIONS COMMITTEE

Master Henrietta Hill

SCHOLARSHIPS & OUTREACH COMMITTEE

Master Saira Kabir Sheikh

STUDENT ENGAGEMENT & SUPPORT COMMITTEE

Master Samantha Hillas

TREASURER NOMINATION COMMITTEE

Master Michael Soole

MASTERS OF THE CIRCUITS AND ASSISTANT MASTERS

INTERNATIONAL:

Master Joanna Korner

Master Kieron Beal

MIDLAND:

Master Paul Bleasdale

Master Michael Burrows

Master Elizabeth McGrath

NORTHERN CIRCUIT:

Master Joseph Hart

Master Nigel Bird

Master Samantha Hillas

Master Simon Gurney

NORTH EASTERN CIRCUIT:

Master Anne Richardson

Master Simon Mallett

Master Gillian Matthews

SOUTH EASTERN:

Master Fiona Jackson

Master Christine Agnew

Master Simon Oliver

Master Heidi Stonecliffe

WALES & CHESTER:

Master Rhys Taylor

Master Jonathan Rees

Master Catherine Heyworth

WESTERN:

Master Christopher Quinlan

Master James Patrick

Master James Townsend

TEMPLE CHURCH TRUST

Master Rory Phillips

MARSHALL HALL TRUST

Master Jonathan Waite

TEMPLE MUSIC FOUNDATION

Master Guy Beringer

INNER TEMPLE REPRESENTATIVES ON EXTERNAL BODIES

BAR COUNCIL

Master Saira Kabir Sheikh

Master Minka Braun

Simon Atkinson (BLC Rep)

BARRISTERS’ BENEVOLENT ASSOCIATION

Master Daniel Toledano

INNS OF COURT ALLIANCE FOR WOMEN

Master Leigh-Ann Mulcahy (Co-Convenor)

Master Jennifer Eady

BAR TRIBUNALS & ADJUDICATION SERVICE (BTAS)

INNS’ CONDUCT COMMITTEE

Master Tom Cosgrove

TRIBUNAL APPOINTMENTS BODY

Master Ingrid Simler (Chair)

Master Julia Dias

Master Ruby Sayed

COUNCIL OF THE INNS OF COURT (COIC)

COIC BOARD

Master Nicholas Green (President)

Master Jill Frances

Sub-Treasurer

COIC MATCHED FUNDED PUPILLAGE SCHEME

Master Ruby Sayed

INNS’ STRATEGIC ADVISORY GROUP

Master Treasurer

Master Reader

Master Jill Frances

Sub-Treasurer

INCORPORATED COUNCIL OF LAW REPORTING

Master Margaret Bowron

Master Mary Malecka

INNS OF COURT AND BAR EDUCATIONAL TRUST

Master Martin Griffiths

INNS OF COURT COLLEGE OF ADVOCACY (ICCA)

ICCA BOARD

Master Nicholas Green (COIC President)

Master Richard Honey

ICCA EDUCATION COMMITTEE

Master Sara Lawson

ICCA FINANCE AND OPERATIONS COMMITTEE

Master Richard Honey (Chair)

Master Christopher Bond

ICCA INTERNATIONAL COMMITTEE

Master Rehana Azib

Master Bibi Badejo

Master Sarah Clarke

Master Richard Honey

ICCA APPEALS COMMITTEE

Master Rebecca Bailey-Harris

ICCA MISCONDUCT PANEL

Master Peter Clark

INNS OF COURT LIBRARIES LIAISON COMMITTEE

Master James Dingemans

INSTITUTE OF ADVANCED LEGAL STUDIES (IALS)

Master Mark Havelock-Allan

SELDEN SOCIETY

Master Donald Cryan

Uncommon Scents

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