Landlord and tenant update March 2010

Citation

Dowden, M. (2010), "Landlord and tenant update March 2010", Journal of Property Investment & Finance, Vol. 28 No. 4. https://doi.org/10.1108/jpif.2010.11228dab.001

Landlord and tenant update March 2010

Article Type: Law briefing From: Journal of Property Investment & Finance, Volume 28, Issue 4

Guarantors and AGAs – the final word?

In Good Harvest v. Centaur Services [2010] EWHC 330 (Ch) the High Court confirmed that an agreement requiring a tenant’s guarantor to give or join in an authorised guarantee agreement (“AGA”) in respect of an assignee is void. It runs into the anti-avoidance provisions in Landlord and Tenant (Covenants) Act 1995, s 25. That conclusion was unsurprising in the context of a clause that said:

[…] the Tenant making the application for licence to assign and its guarantor (if any but not someone who has already given an authorised guarantee agreement) shall enter into an authorised guarantee agreement.

However, the judge went on to rule that a guarantee actually given pursuant to that agreement was itself void. That further conclusion overturns a significant strand of commentary on the anti-avoidance provisions, which distinguished between executory agreements (i.e. agreements that remained to be performed) and executed agreements. Counsel for the landlord in Good Harvest argued that once actually given by the outgoing tenant’s guarantor, a new guarantee of the assignee’s obligations did not “exclude, modify or otherwise frustrate” the operation of the 1995 Act. The guarantor would be undertaking new obligations, not reviving obligations released on assignment. The judge rejected the argument, saying: “Had Parliament intended a tenant’s guarantor to be able to guarantee obligations of an assignee, it could have been expected to say so explicitly”.

Good Harvest leaves a number of questions open, and will not put an end to landlords’ attempts to retain the benefit of a guarantor’s covenant where the covenant strength of the outgoing tenant is poor. Approaches that have not been conclusively barred by Good Harvest include:

• •

  Guarantor becomes tenant: An early response to the 1995 Act anti-avoidance provisions was to include a condition precedent requiring the tenant to assign first to its guarantor. The guarantor became tenant and so could be called upon to give an AGA in respect of the third party assignee. Unless Good Harvest is successfully appealed, this approach is likely to see a resurgence. The landlord and tenant are entitled, under s 19(1A) to agree conditions precedent to the tenant’s ability to assign. Once the guarantor has become tenant, it can meet the criteria in s 16 for a valid AGA. However, the risk of challenge is increased by comments in Avonridge v. Mashru [2005] UKHL 70 that s 25 was enacted as “a comprehensive anti-avoidance provision”, and one that must be “interpreted generously, so as to ensure that the operation of the 1995 Act is not frustrated either directly or indirectly”.

• •

  Guarantee extends to tenant’s obligations under any AGA: The release from obligations provided by the 1995 Act relates to “tenant covenants” of the tenancy. The guarantor’s release under s 24(2) is “to the same extent” as the tenant. It was argued that new covenants given by a former tenant in an AGA could not be classed as “tenant covenants”. Consequently, if the original guarantee was written to apply to tenant covenants while the lease remained vested in the tenant, and also to the former tenant’s obligations under an AGA, it would fall outside the release provided by s 24(2). In that scheme, the guarantor is not being called on to give a new or direct guarantee in respect of the assignee. Although doubting that any form of “sub-guarantee” would survive the anti-avoidance provisions, the judge in Good Harvest said: In any case, even if a guarantor could sub-guarantee a tenant’s obligations under an AGA, it would not necessarily follow that he should be able to give a direct guarantee for an assignee. In short, I do not think it helps to try to answer the question whether a guarantor can give a sub-guarantee.

• •

  Consent withheld unless the guarantor gives a new guarantee: Another drafting response to the 1995 Act was to include a s 19(1A) circumstance, allowing the landlord to withhold consent unless the guarantor entered into a new guarantee in respect of the assignee’s performance (or, more conservatively, of the former tenant’s obligations under its AGA). The reasoning was that there was no agreement requiring the guarantor to provide a fresh guarantee, merely a facility for the landlord to withhold consent and retain the existing covenant strength if no such guarantee was forthcoming. This approach runs into the judge’s conclusion in Good Harvest that the executed guarantee, and not just the executory agreement to give it, was void.

Good Harvest is highly unlikely to be the last word in a debate that has been rumbling on since the 1995 Act was fast-tracked through Parliament. Covenant strength remains an essential element in the value of the landlord’s interest. On the initial grant of a lease, the covenant strength of the tenant frequently requires the support of a parent company guarantee. On assignment, particularly if it occurs relatively soon after the initial grant, landlords are legitimately concerned to minimise dilution of the covenant strength that remains available. If the tenant was not strong to begin with its worth as guarantor for the assignee it has introduced to the landlord is necessarily limited. Landlords will undoubtedly still try to hold on to the strongest covenant.

Landlord’s costs and damages depended on s 146 proceedings

In Agricullo v. Yorkshire Housing [2010] EWCA civ 229 a tenant had been in breach of its obligations to repair premises, including the roof and roofspace which also provided cover and protection to commercial premises retained for letting by the landlord.

The landlord had served a s 146 notice in due form, advising the tenant of its right to claim the benefit of the Leasehold Property (Repairs) Act 1938. The tenant served a counter-notice claiming the benefit of the Act. Once that counter notice was served, the landlord could not forfeit the lease or recover damages without leave of the court. Nonetheless, the landlord considered that the s 146 notice and the prospect of court proceedings gave it some leverage for discussion with the tenant. That view seemed to have been vindicated when, after protracted and difficult negotiations, the tenant carried out the works.

The landlord subsequently claimed the costs that it had incurred in connection with those negotiations, plus damages for loss of rent in respect of other premises in the building that had been adversely affected by the disrepair.

The court rejected the landlord’s claim for damages and costs. The claim was based on a lease clause that allowed recovery of costs “in contemplation of or in relation to any proceedings under s 146 or 147 of the Law of Property Act 1925 or the Leasehold Property (Repairs) Act 1938, including the preparation and service of all notices, and even if forfeiture is avoided (unless it is avoided by relief granted by the court)”.

The tenant successfully argued that nothing was recoverable under that clause. Once the counter-notice had been served invoking the protection of the 1938 Act the landlord could have pursued a forfeiture claim based on its s 146 notice only with leave of the court. It made no application for that leave so there were no relevant proceedings “in contemplation” or in existence.

The court found that the landlord had elected to proceed by negotiation rather than availing itself of the legal remedies provided for by the lease. The landlord could have applied for leave under the 1938 Act, or it could have gone into the premises to carry out the works itself, relying on a Jervis v. Harris clause that would have allowed it to recover its costs and expenses as a debt. Settling the matter by negotiation took the landlord’s costs outside the scope of the contractual clause.

Faced with this decision, landlords must now ensure that new leases contain a clause providing for the recovery of costs incurred in enforcing or seeking to enforce tenant covenants by whatever means (i.e. not limited to s 146, 147 or 1938 Act proceedings).

However, clauses similar to that in Agricullo are common in existing leases, and many draftsmen have taken the view that (as argued by Counsel for the landlord) the terms “in contemplation of” and “in relation to” were broad enough to include circumstances where the s 146 notice and the possibility of further proceedings was being used as leverage to bring the tenant to the negotiating table. In those cases, landlords must now consider:

• •

  going directly to court to make an application for leave under the 1938 Act; and

• •

  relying on a Jervis v. Harris clause which would allow them to enter the premises, carry out the works and recover its costs as a debt without engaging the 1938 Act.

Neither course is attractive.

Where a tenant serves a counter-notice invoking the protection of the 1938 Act Agricullo suggests that any leverage achieved by serving the s 146 notice is lost, and that the landlord is at risk on costs unless it resorts to litigation. The ruling arguably undermines the landlord’s ability to achieve a satisfactory settlement through negotiation and requires a “protective” application to the court. The landlord would be advised to issue court proceedings and then to make Part 36 offers to seek to settle the matter, bringing automatic costs liability into play in the event that the tenant accepts the terms – albeit on the standard basis. However, even if a landlord takes this course, the tenant’s adviser might well be tempted to argue that the costs of negotiating an agreement and supervising works fall outside the Court proceedings and ought to be irrecoverable in the absence of a sufficiently clear contractual obligation.

Faced with that prospect, landlords may well be inclined to take direct action under a Jervis v. Harris clause. However, the effectiveness of that approach was called into question by the ruling in Hammersmith v. Creska [1999] All ER (D) 644, where the landlord was refused access to the premises, and the court would not grant an injunction ordering the tenant to permit entry. The court was willing to award damages in lieu under s 50 Supreme Court Act 1981, but it is far from clear that those damages would amount to full recovery of the direct and consequential losses, and of the costs incurred by the landlord in seeking to remedy the breach.

Agricullo is a harsh ruling. In effect, the landlord was penalised for negotiating rather than litigating. The unfortunate lesson for landlords, even in the post-Woolf world, is that situations remain where litigation rather than negotiation cannot be avoided.

Rent is payable as an expense of administration

Rent is payable as an administration expense where the administrator occupies or uses any part of premises.

In Goldacre v. Nortel [2009] EWHC 3389 (Ch) administrators used part of premises “for the more efficient conduct of the administration”. They sought a ruling on whether rent was payable as an expense of the administration (conferring priority) and, if so, whether the court had discretion to order payment of a sum referable only to the floor space actually occupied. The judge held that there is no discretion to declare something to be or not to be a liquidation expense, and that the same principle applies to administrations. The whole of the rent due under the lease fell within Insolvency Rules 1986, r 2.67(1) and must be treated as an expense of the administration with priority over the administrator’s own fees.

However, a finding that rent is an administration expense does not determine the time at which that rent should be paid. The possibility of other claims having priority and of there being insufficient assets in an administration means that a landlord may have to wait and see whether payment is made. The landlord’s right is not to immediate payment, but to have the accruing rent treated as an expense having appropriate priority where the administrator continues to make use of the premises.

The judge considered that the matter was determined exclusively by the Rules, and that if rental liability fell within the Rules then it is payable (but not necessarily recoverable) as a matter of mandatory obligation, and not as a matter of discretion, either on the part of the administrators or of the court. In construing the rules, the judge applied the Lundy Granite principle, under which liquidators are liable to pay rent as a liquidation expense where they make use of or retain, for the benefit of the liquidation, possession of leasehold premises. Given the closeness of wording between rule 4.218(1)(a) considered by the House of Lords in Re Toshoku Finance UK [2002] 3 All ER 961 and that in rule 2.67(1)(a) the judge held that rent should be treated as an expense “properly incurred by the administrator in performing his functions in the administration of the company”.

The judge also said that he would regard rent as capable of falling within rule 2.67(1)(f), as a “necessary disbursement by the administrator in the course of the administration”. He stated that a payment would be “necessary” even if (as in Goldacre) the landlord had not made any threat to bring forfeiture proceedings. Where the Lundy Granite principle applies a payment is ’necessary’ because it is due.

The rent in Goldacre was payable quarterly in advance, so the whole sum for each quarter was due on the relevant quarter day. Apportionment Act 1870 does not apply to rent payable in advance, so the full instalment of rent falling due on a quarter day while the administrators were occupying or using the premises would be treated as an expense of the administration even if the administrators vacated during that quarter. Powdrill established that a liquidator electing to hold leasehold premises can do so only on the terms and conditions contained in the lease, and that any liability incurred while the lease is being enjoyed or retained for the benefit of the liquidation is payable in full as a liquidation expense. The judge held that the same principle applies in administrations.

Considering whether his conclusions were consistent with the “rescue culture” underpinning Insolvency Act 1986 and extended by subsequent legislation, the judge accepted that the Lundy Granite principle developed in a context where liquidators were in fact carrying on business for the purpose of the winding up in an endeavour to sell the business as a going concern.

The judge, with the agreement of the parties, reached his decision on the basis that he was not bound by the Court of Appeal ruling in Sunberry to exercise a discretion to consider how much it would be fair for the administrators to pay. However, he indicated that if compelled to exercise that jurisdiction he would have considered the whole of the rent to be payable, even though the administrators occupied only part of the premises. That was based on evidence that the landlord could not realistically maximise the return of the property by re-letting part while the administrators were using part, and that their continued presence precluded redevelopment.

The judge also noted, without adverse comment, that sub-tenants occupied other parts of the premises and that those subtenants had been served with notice under Law of Distress Amendment Act 1908, s 6 which had the effect of transferring to the landlord the right of the company in administration to receive rent directly from those subtenants. The 1908 Act remains an extremely useful tool for landlords where intermediate tenants are affected by insolvency.

Subjective intention does not prevent a tenancy

Leases (whether residential or commercial) give tenants a range of statutory protections. They include various forms of “security of tenure”, compensation for improvements and (in residential leases) protection from eviction and the regulation of costs such as service charges.

Licensees do not generally enjoy those protections. A licence might therefore seem to offer the owner of property a way to allow occupation and use on an “easy in, easy out” basis, without the need to follow complex statutory procedures. However, where there is any doubt about its legal effect the court will lean towards finding that an agreement is a lease rather than a licence so that the occupier has statutory rights and protections.

The court determines whether an agreement is a lease or a licence by looking at its substance, not the label attached to it by the parties. In Street v. Mountford [1985] AC 809 the House of Lords identified the hallmarks of a tenancy. They are:

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  exclusive possession;

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  of defined premises; and

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  for a term.

Payment of rent might also be an indication of a tenancy, but in fact rent is not required for a tenancy to exist. Crucially, the role of those hallmarks is to allow the court to infer the parties’ objective intentions. If an agreement includes those hallmarks, it does not matter that the parties have labelled it as a “licence”, or that one of the parties can show that his subjective intention differed.

In Lynch v. Kirby [2010] All ER (D) 114 (Mar), the defendant moved into a room in a flat owned by the claimant. The parties completed and signed a pre-tenancy determination form. On the same day, the defendant applied for housing benefit, which was granted on 24 February.

Subsequently, the claimant commenced possession proceedings. The defendant resisted, claiming that the arrangement had created a tenancy. The claimant argued that a tenancy was to have been created only if the defendant had obtained housing benefit.

The judge found that the defendant had entered into exclusive possession of the room from 20 February 1997. On that date, the defendant and the claimant completed and signed a pre-tenancy determination form. The judge accepted that the claimant had not intended to accept the defendant as a tenant unless he was awarded housing benefit. He also found that the claimant had permitted the defendant to take up occupation in the property until such time as his housing benefit was approved, because he was aware that the defendant had friends in the property. The judge made an order for possession. The defendant appealed.

He argued that the judge had misdirected himself in law in finding that the appellant had not been granted an assured tenancy. The Court of Appeal agreed, and allowed the appeal.

The court’s task is to review what the parties said and did, and from that material infer whether the parties’ objective intentions, as expressed to each other, were to enter into a mutually binding contract.

On all the evidence, there had been an intention on the part of the defendant and the claimant to create legal relations. That intention was evidenced by the signed pre-tenancy determination form and the exclusive possession granted by the claimant to the defendant.

In accordance with the agreement, the defendant had on the same day applied for housing benefit. The objective indications had been present. The judge had erred in taking account of the subjective intention of the claimant. The claimant had done no more than take a commercial risk in allowing the defendant to enter the property. Consequently, the defendant was granted an assured short-hold tenancy.

CRC energy efficiency scheme

The CRC Energy Efficiency Scheme (’CRC’) is a mandatory scheme in force on 1 April 2010. It directly affects public and large private sector organisations, and extends the “cap and trade” approach from energy intensive industries to commercial and mixed use property. Consequently, CRC indirectly affects a wide range of occupiers, and raises significant questions for landlords and tenants.

The Government decided not to permit landlords and tenants to opt to transfer responsibility for emissions to the tenant. It will not legislate for the apportionment of the costs and benefits of the CRC between landlords and tenants, considering this to be a matter of commercial negotiation between the parties. However, the Government is including a provision that requires the tenant to co-operate with the landlord organisation for the purpose of complying with CRC.

CRC may place greater emphasis on green leases in the future. Buyers and sellers of property will also have to consider how to deal with the CRC scheme on completion.

The CRC scheme includes a specific duty on the part of tenants, licensees and franchisees to cooperate with the building owner so that it can meet its compliance obligations under CRC. However, it seems that the duty to cooperate is intended mainly to require the provision of data and information. It does not in itself require any payment to be made by tenants, licensees or franchisees towards the cost of allowances or other compliance costs. Any entitlement to payment would be a matter for contractual provision.

How does CRC work?

Under CRC, once it is in full operation:

1. 1.

   the Government will auction a limited number of allowances each year;

2. 2.

   participants:

   • •

     will surrender allowances to the scheme administrator against each tonne of CO2 emitted during the scheme year; and

   • •

     either buy or sell allowances from one another, from registered traders or from the “safety valve” depending on their deficit or surplus of allowances at the end of the relevant trading periods.

An allowance represents the right to emit the equivalent of one tonne of carbon dioxide.

CRC is designed to complement existing Government policies. Emissions that are already regulated by a Climate Change Agreement (CCA) or the EU Emissions Trading System (EUETS) are not targeted under CRC.

The scheme administrator is:

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  for England and Wales, the Environment Agency (EA);

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  for Scotland, the Scottish Environment Protection Agency (SEPA); and

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  for Northern Ireland, the Northern Ireland Environment Agency (NIEA).

The first phase of CRC will last for three years. Subsequent phases are for seven years, the first two of which are preparatory and overlap with the previous phase (the second phase begins on 1 April 2011, the third on 1 April 2016). Each phase has:

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  A qualification period for which organisations must assess whether they qualify to make an information disclosure or participate fully in CRC.

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  A registration period (the first expiring 30 September 2010).

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  A series of compliance years running from April to March.

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  A footprint year where participants must monitor their total emissions from energy supplies and determine what emissions must be included in CRC. This data must be reported to the administrator in a footprint report (the deadline for submitting the first report is 29 July 2011).

Who is affected?

A large private or public sector organisation qualifies as a participant if it:

• •

  has at least one half-hourly meter (HHM) bought on the half-hour electricity market; and

• •

  consumed over 6,000 megawatt-hours (MWh) in 2008.

If the organisation meets the first criterion but used below 6,000 MWh in 2008, it must make an “information disclosure” of the electricity consumption to the CRC registry.

Although participation is determined by electricity use, participants must measure and record their entire energy use (electricity, gas, fuel oil, coal, liquefied petroleum gas).

As well as those directly affected, CRC will potentially impact on tenants, licensees and franchisees that occupy buildings owned by a CRC participant.

Exemptions and de minimis thresholds

CRC does not cover:

• •

  emissions covered by Climate Change Agreements (CCAs);

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  organisations with more than 25 per cent of their energy use covered by CCAs;

• •

  direct emissions included in the EUETS; and

• •

  carbon dioxide emissions from transport.

Exemptions available to sectors covered by CCAs and the EUETS, will be based on emissions from the recent reporting year under those schemes, rather than for the CRC compliance year. They will also be exempt from providing a “footprint report”, which will ease the administrative burden for heavily regulated sectors such as the chemical sector.

Required actions

An organisation falling within CRC must:

• •

  register online;

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  measure and record the business’ energy use and calculate the carbon dioxide emissions annually;

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  provide annual energy date to the EA;

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  buy allowances;

• •

  submit an annual report of emissions to the EA; and

• •

  trade allowances with other businesses, depending on whether the organisation has excess or too few allowances.

Parents and subsidiaries

CRC uses the definition of “undertaking” in Companies Act 2006, expanded to include unincorporated associations. Responsibility for CRC registration and compliance lies with the highest parent organisation in the group with a place of business in the UK. Access to the compliance account is restricted to named individuals, and is subject to identity checks.

Before the Government’s response to consultation, subsidiaries would have participated as part of the holding companies group. Now subsidiaries that are “Significant Group Undertakings” and would qualify for the CRC in their own right can be “disaggregated” to participate in their own right, as long as separate registration does not take the parent group below the CRC threshold. This will be of interest to a number of sectors, including landlords of portfolios including large shopping centres, business parks, data centre operators, franchise businesses and the private equity and fund management sector.

Auctions, trading and caps

There will be a three-year introductory phase from April 2010, with fixed price sales of allowances. The first sale of allowances each year will be in 2011, with a fixed price of £12 per tonne of CO2.

Organisations can buy allowances for both 2010–2011 and 2011–2012. All subsequent sales and auctions will only be for the year ahead.

No trading will be allowed in the first year. From April 2013, there will be a sale of allowances each year via an auction. The Government will limit (cap) the total number of allowances available each year to ensure that overall emissions fall.

Dealing with allowances

Following the initial sale period (the first month of each reporting year) participants can:

• •

  buy or sell allowances by trading on the secondary market; and

• •

  buy allowances through the “safety valve”.

The secondary market

The secondary market consists of other CRC participants plus registered traders. Prices will be agreed between buyer and seller, and Government will exercise no price control (other than indirectly through the safety valve). The CRC online registry will have a noticeboard trading facility to help participants find buyers and sellers for allowances. There may also be separate third party trading facilities. This is to enable participants with surplus allowances to sell them, and participants whose emissions exceed their allowances to purchase more.

Unlike allowances purchased directly from Government during the initial sale period, allowances purchased on the secondary market will be subject to VAT.

The “safety valve”

The “safety valve” mechanism is intended to protect against the price of allowances becoming too high. CRC participants can ask the scheme administrator to issue extra allowances throughout the year.

To meet participants’ request the scheme administrator must purchase allowances from the EU ETS market. The price of the additional CRC allowances will always be greater than allowances purchased during the initial sale period. Safety valve allowances will not be sold for less than £12 per tonne even if the EU ETS market were to fall below that level. Consequently, it is in the financial interests of participants to purchase allowances through the safety valve only if CRC allowances for sale on the secondary market are more expensive than EU ETS allowances (taking into account fees and charges).

Banking allowances

As an alternative to selling surplus allowances, a CRC organisation may bank them to cover emissions for future years. The only exception is the final year of the introductory phase, when all remaining allowances issued during that phase will be cancelled before the “capped phase” takes effect.

Issues for landlords and tenants

CRC operates at the participants’ group level. Consequently, it is unlikely that landlords will ’”ring-fence” allowances for use in respect of a particular building. However, the approach taken in most commentary on CRC, and by the industry working party established by the British Property Federation, assumes that landlords will seek to pass on to their tenants the costs allowances, whether through service charge or by means of direct covenants.

Where landlords take that approach, potential disputes include:

The cost of additional allowances

Tenants may object to paying the costs of allowances purchased on the secondary market or through the “safety valve”. Allowances purchased outside the initial Government sale will always be more expensive, and may be taken to indicate that the landlord’s initial assessment of the number of allowances required was defective. It is also conceivable that some landlords will be unaware of their obligations under CRC and will fail to register, requiring all of their allowances to be obtained on the secondary market.

Tenants may also object to the price agreed by its landlord for secondary market purchases, or to the timing of purchases via the “safety valve” if the landlord elects to make an application at a time when the price of EU ETS allowances is high.

From the landlord’s perspective, the need to purchase additional allowances may be attributable to the inadequate provision of data by a tenant or licensee. In those cases, the landlord may argue that the additional costs are a consequence of the tenant or licensee’s breach of its duty to cooperate under Article 65 of the CRC Energy Efficiency Scheme Order 2010, and that those costs ought to be recoverable.

The decision to sell

CRC allowances must be purchased, held and surrendered by participants against emissions for which they are responsible. However, where the participant is a landlord there is a strong likelihood that at least some of its allowances will have been funded by tenants or other occupiers. Consequently, tenants may:

• •

  object to the sale of surplus allowances, preferring them to be banked against future use; and

• •

  demand a share of the sale proceeds.

Calculation of the tenant’s entitlement is likely to be extremely complicated where the allowances relate to a large group structure, where the landlord’s portfolio includes buildings that it occupies for the purposes of its own business, or where its portfolio is mixed and includes tenants whose energy use is significantly more intense than others’.

Banking allowances

Issues may also arise where a landlord elects to bank allowances against future years. They include:

• •

  objections from tenants whose leases are coming to an end by expiry of exercise of a break clause who may argue that surplus allowances to which they have contributed funds should be sold and the proceeds distributed, rather than being held for the benefit of the landlord and future tenants; and

• •

  tenant demands that allowances to which they have contributed funds should be allocated specifically to their building rather than, for example being surrendered against the landlord’s own energy use.

Initial compliance costs for CRC amount to approximately £38,000 per annum for an organisation required to register as a full participant. However, that figure merely represents the cost of allowances at the threshold level. Those costs increase as an organisation’s energy use exceeds the threshold figure, and as administrative and other associated costs are factored in. CRC is intended to focus minds on the need for improved energy performance and for a move towards a low carbon economy. Consequently, unlike the requirement to display energy performance certificates (EPCs) in the private sector or display energy certificates (DECs) in the public sector, CRC was intended to introduce an appreciable financial incentive for improvement, and penalty for “business as usual”. When the cost of allowances becomes a live issue from April 2011, CRC will be a key element in landlord and tenant negotiations.Lexis PSL

Malcolm Dowden