Attorney General’s Guidelines on Disclosure (2005)
These Guidelines are issued by the Attorney General for investigators,
prosecutors and defence practitioners on the application of the disclosure
regime contained in the Criminal Procedure and Investigations Act 1996
(CPIA).
Foreword by Lord Goldsmith
Disclosure is one of the most important issues in the criminal justice system
and the application of proper and fair disclosure is a vital component of a fair
criminal justice system. The “golden rule” is that fairness requires full
disclosure should be made of all material held by the prosecution that
weakens its case or strengthens that of the defence.
This amounts to no more and no less than a proper application of the Criminal
Procedure and Investigations Act 1996 (CPIA) recently amended by the
Criminal Justice Act 2003. The amendments in the Criminal Justice Act 2003
abolished the concept of “primary” and “secondary” disclosure, and introduced
an amalgamated test for disclosure of material that “might reasonably be
considered capable of undermining the prosecution case or assisting the case
for accused”. It also introduced a new Code of Practice. In the light of these,
other new provisions and case law I conducted a review of the Attorney
General's Guidelines issued in November 2000.
Concerns had previously been expressed about the operation of the then
existing provisions by judges, prosecutors, and defence practitioners. It seems
to me that we must all make a concerted effort to comply with the CPIA
disclosure regime robustly in a consistent way in order to regain the trust and
confidence of all those involved in the criminal justice system. The House of
Lords in R vH & C made it clear that so long as the current disclosure system
was operated with scrupulous attention, in accordance with the law and with
proper regard to the interests of the defendant, it was entirely compatible with
Article 6 of the European Convention on Human Rights. It is vital that
everybody in the criminal justice system operates these procedures properly
and fairly to ensure we protect the integrity of the criminal justice system
whilst at the same time ensuring that a just and fair disclosure process is not
abused so that it becomes unwieldy, bureaucratic and effectively unworkable.
This means that all those involved must play their role. Investigators must
provide detailed and proper schedules. Prosecutors must not abrogate their
duties under the CPIA by making wholesale disclosure in order to avoid
carrying out the disclosure exercise themselves. Likewise, defence
practitioners should avoid fishing expeditions and where disclosure is not
provided using this as an excuse for an abuse of process application. I hope
also that the courts will apply the legal regime set out under the CPIA rather
than ordering disclosure because either it is easier or it would not “do any
harm’.
This disclosure regime must be made to work and it can only work if there is
trust and confidence in the system and everyone plays their role in it. If this is
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Attorney General's Guidelines on Disclosure (2005)
achieved applications for a stay of proceedings on the grounds of non
disclosure will only be made exceedingly sparingly and never on a speculative
basis. Likewise such applications are only likely to succeed in extreme cases
and certainly not where the alleged disclosure is in relation to speculative
requests for material.
I have therefore revised the Guidelines to take account of developments and
to start the process of ensuring that everyone works to achieve consistency of
approach to CPIA disclosure. The amalgamated test should introduce a more
streamlined process which is more objective and should therefore deal with
some of the concerns about inconsistency in the application of the disclosure
regime by prosecutors. A draft set of these revised Guidelines went out for
consultation, and resulted in many thoughtful and detailed responses from
practitioners, including members of the judiciary, who have to work with the
scheme on a daily basis. The Group that was established to advise me on the
revision of the Guidelines has taken account of the results of the consultation
exercise. I give my warm thanks to all who have offered responses on the
consultation and assisted in the revision of these Guidelines.
I am publishing today the revised Guidelines that, if properly, applied will
contribute to ensuring that the disclosure regime operates effectively, fairly
and justly - which is vitally important to the integrity of the criminal justice
system and the way in which it is perceived by the general public.
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Introduction: disclosure of unused material in criminal proceedings
1.
Every accused person has a right to a fair trial, a right long embodied in
our law and guaranteed under Article 6 of the European Convention on
Human Rights (ECHR). A fair trial is the proper object and expectation
of all participants in the trial process. Fair disclosure to an accused is
an inseparable part of a fair trial.
What must be clear is that a fair trial consists of an examination not just
of all the evidence the parties wish to rely on but also all other relevant
subject matter. A fair trial should not require consideration of irrelevant
material and should not involve spurious applications or arguments
which serve to divert the trial process from examining the real issues
before the court.
The scheme set out in the Criminal Procedure and Investigations Act
1996 (as amended) (the Act) is designed to ensure that there is fair
disclosure of material which may be relevant to an investigation and
which does not form part of the prosecution case. Disclosure under the
Act should assist the accused in the timely preparation and
presentation of their case and assist the court to focus on all the
relevant issues in the trial. Disclosure which does not meet these
objectives risks preventing a fair trial taking place.
This means that the disclosure regime set out in the Act must be
scrupulously followed. These Guidelines build upon the existing law to
help to ensure that the legislation is operated more effectively,
consistently and fairly.
Disclosure must not be an open ended trawl of unused material. A
critical element to fair and proper disclosure is that the defence play
their role to ensure that the prosecution are directed to material which
might reasonably be considered capable of undermining the
prosecution case or assisting the case for the accused. This process is
key to ensuring prosecutors make informed determinations about
disclosure of unused material.
Fairness does recognise that there are other interests that need to be
protected, including those of victims and witnesses who might
otherwise be exposed to harm. The scheme of the Act protects those
interests. It should also ensure that material is not disclosed which
overburdens the participants in the trial process, diverts attention from
the relevant issues, leads to unjustifiable delay, and is wasteful of
resources.
Whilst it is acknowledged that these Guidelines have been drafted with
a focus on Crown Court proceedings the spirit of the Guidelines must
be followed where they apply to proceedings in the magistrates’ court.
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General principles
8. Disclosure refers to providing the defence with copies of, or access to,
any material which might reasonably be considered capable of
undermining the case for the prosecution against the accused, or of
assisting the case for the accused, and which has not previously been
disclosed.
9. Prosecutors will only be expected to anticipate what material might
weaken their case or strengthen the defence in the light of information
available at the time of the disclosure decision, and this may include
information revealed during questioning.
10. Generally, material which can reasonably be considered capable of
undermining the prosecution case against the accused or assisting the
defence case will include anything that tends to show a fact
inconsistent with the elements of the case that must be proved by the
prosecution. Material can fulfil the disclosure test:
(a) by the use to be made of it in cross-examination;
(b) by its capacity to support submissions that could lead to:
(i) the exclusion of evidence;
(ii) a stay of proceedings; or,
(iii) a court or tribunal finding that any public authority
had acted incompatibly with the accused ’s rights
under the ECHR; or,
(c) by its capacity to suggest an explanation or partial explanation of
the accused's actions.
11.In deciding whether material may fall to be disclosed under paragraph
10, especially (b)(ii), prosecutors must consider whether disclosure is
required in order for a proper application to be made. The purpose of
this paragraph is not to allow enquiries to support speculative
arguments or for the manufacture of defences.
12. Examples of material that might reasonably be considered capable of
undermining the prosecution case or of assisting the case for the
accused are:
i. Any material casting doubt upon the accuracy of any
prosecution evidence;
ii. Any material which may point to another person, whether
charged or not (including a co-accused) having involvement in
the commission of the offence;
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iii. Any material which may cast doubt upon the reliability of a
confession;
iv. Any material that might go to the credibility of a prosecution
witness;
v. Any material that might support a defence that is either raised by
the defence or apparent from the prosecution papers; or,
vi. Any material which may have a bearing on the admissibility of
any prosecution evidence.
13. It should also be borne in mind that while items of material viewed in
isolation may not be reasonably considered to be capable of
undermining the prosecution case or assisting the accused, several
items together can have that effect.
14. Material relating to the accused’s mental or physical health, intellectual
capacity, or to any ill treatment which the accused may have suffered
when in the investigator's custody is likely to fall within the test for
disclosure set out in paragraph 8 above.
Defence statements
15.A defence statement must comply with the requirements of section 6A
of the Act. A comprehensive defence statement assists the participants
in the trial to ensure that it is fair. The trial process is not well served if
the defence make general and unspecified allegations and then seek
far-reaching disclosure in the hope that material may turn up to make
them good. The more detail a defence statement contains the more
likely it is that the prosecutor will make an informed decision about
whether any remaining undisclosed material might reasonably be
considered capable of undermining the prosecution case or of assisting
the case for the accused, or whether to advise the investigator to
undertake further enquiries. It also helps in the management of the trial
by narrowing down and focussing on the issues in dispute. It may result
in the prosecution discontinuing the case. Defence practitioners should
be aware of these considerations when advising their clients.
16. Whenever a defence solicitor provides a defence statement on behalf
of the accused it will be deemed to be given with the authority of the
solicitor’s client.
Continuing duty of prosecutor to disclose
17.Section 7A of the Act imposes a continuing duty upon the prosecutor to
keep under review at all times the question of whether there is any
unused material which might reasonably be considered capable of
undermining the prosecution case against the accused or assisting the
case for the accused and which has not previously been disclosed.
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This duty arises after the prosecutor has complied with the duty of
initial disclosure or purported to comply with it and before the accused
is acquitted or convicted or the prosecutor decides not to proceed with
the case. If such material is identified, then the prosecutor must
disclose it to the accused as soon as is reasonably practicable.
18.As part of their continuing duty of disclosure, prosecutors should be
open, alert and promptly responsive to requests for disclosure of
material supported by a comprehensive defence statement.
Conversely, if no defence statement has been served or if the
prosecutor considers that the defence statement is lacking specificity or
otherwise does not meet the requirements of section 6A of the Act, a
letter should be sent to the defence indicating this. If the position is not
resolved satisfactorily, the prosecutor should consider raising the issue
at a hearing for directions to enable the court to give a warning or
appropriate directions.
19.When defence practitioners are dissatisfied with disclosure decisions
by the prosecution and consider that they are entitled to further
disclosure, applications to the court should be made pursuant to
section 8 of the Act and in accordance with the procedures set out in
the Criminal Procedure Rules. Applications for further disclosure should
not be made as ad hoc applications but dealt with under the proper
procedures.
Applications for non-disclosure in the public interest
20. Before making an application to the court to withhold material which
would otherwise fall to be disclosed, on the basis that to disclose would
give rise to a real risk of serious prejudice to an important public
interest, prosecutors should aim to disclose as much of the material as
they properly can (for example, by giving the defence redacted or
edited copies or summaries). Neutral material or material damaging to
the defendant need not be disclosed and must not be brought to the
attention of the court. It is only in truly borderline cases that the
prosecution should seek a judicial ruling on the disclosability of material
in its possession.
21.Prior to or at the hearing, the court must be provided with full and
accurate information. Prior to the hearing the prosecutor and the
prosecution advocate must examine all material, which is the subject
matter of the application and make any necessary enquiries of the
investigator. The prosecutor (or representative) and/or investigator
should attend such applications.
22. The principles set out at paragraph 36 of RvH & C should be
rigorously applied firstly by the prosecutor and then by the court
considering the material. It is essential that these principles are
scrupulously attended to ensure that the procedure for examination of
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material in the absence of the accused is compliant with Article 6 of
ECHR.
Responsibilities: investigators and disclosure officers
23. Investigators and disclosure officers must be fair and objective and
must work together with prosecutors to ensure that disclosure
obligations are met. A failure to take action leading to inadequate
disclosure may result in a wrongful conviction. It may alternatively lead
to a successful abuse of process argument, an acquittal against the
weight of the evidence or the appellate courts may find that a
conviction is unsafe and quash it.
24. Officers appointed as disclosure officers must have the requisite
experience, skills, competence and resources to undertake their vital
role. In discharging their obligations under the Act, code, common law
and any operational instructions, investigators should always err on the
side of recording and retaining material where they have any doubt as
to whether it may be relevant.
25.An individual must not be appointed as disclosure officer, or continue in
that role, if that is likely to result in a conflict of interest, for instance, if
the disclosure officer is the victim of the alleged crime which is the
subject of investigation. The advice of a more senior investigator must
always be sought if there is doubt as to whether a conflict of interest
precludes an individual acting as the disclosure officer. If thereafter a
doubt remains, the advice of a prosecutor should be sought.
26. There may be a number of disclosure officers, especially in large and
complex cases. However, there must be a lead disclosure officer who
is the focus for enquiries and whose responsibility it is to ensure that
the investigator's disclosure obligations are complied with. Disclosure
officers, or their deputies, must inspect, view or listen to all relevant
material that has been retained by the investigator, and the disclosure
officer must provide a personal declaration to the effect that this task
has been undertaken.
27. Generally this will mean that such material must be examined in detail
by the disclosure officer or the deputy, but exceptionally the extent and
manner of inspecting, viewing or listening will depend on the nature of
material and its form. For example, it might be reasonable to examine
digital material by using software search tools, or to establish the
contents of large volumes of material by dip sampling. If such material
is not examined in detail, it must nonetheless be described on the
disclosure schedules accurately and as clearly as possible. The extent
and manner of its examination must also be described together with
justification for such action.
28. Investigators must retain material that may be relevant to the
investigation. However, it may become apparent to the investigator that
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some material obtained in the course of an investigation because it was
considered potentially relevant, is in fact incapable of impact. It need
not then be retained or dealt with in accordance with these Guidelines,
although the investigator should err on the side of caution in coming to
this conclusion and seek the advice of the prosecutor as appropriate.
29.In meeting the obligations in paragraph 6.9 and 8.1 of the Code, it is
crucial that descriptions by disclosure officers in non-sensitive
schedules are detailed, clear and accurate. The descriptions may
require a summary of the contents of the retained material to assist the
prosecutor to make an informed decision on disclosure. Sensitive
schedules must contain sufficient information to enable the prosecutor
to make an informed decision as to whether or not the material itself
should be viewed, to the extent possible without compromising the
confidentiality of the information.
30. Disclosure officers must specifically draw material to the attention of
the prosecutor for consideration where they have any doubt as to
whether it might reasonably be considered capable of undermining the
prosecution case or of assisting the case for the accused.
31. Disclosure officers must seek the advice and assistance of prosecutors
when in doubt as to their responsibility as early as possible. They must
deal expeditiously with requests by the prosecutor for further
information on material, which may lead to disclosure.
Prosecutors
32.Prosecutors must do all that they can to facilitate proper disclosure, as
part of their general and personal professional responsibility to act fairly
and impartially, in the interests of justice and in accordance with the
law. Prosecutors must also be alert to the need to provide advice to,
and where necessary probe actions taken by, disclosure officers to
ensure that disclosure obligations are met.
33.Prosecutors must review schedules prepared by disclosure officers
thoroughly and must be alert to the possibility that relevant material
may exist which has not been revealed to them or material included
which should not have been. If no schedules have been provided, or
there are apparent omissions from the schedules, or documents or
other items are inadequately described or are unclear, the prosecutor
must at once take action to obtain properly completed schedules.
Likewise schedules should be returned for amendment if irrelevant
items are included. If prosecutors remain dissatisfied with the quality or
content of the schedules they must raise the matter with a senior
investigator, and if necessary, persist, with a view to resolving the
matter satisfactorily.
34. Where prosecutors have reason to believe that the disclosure officer
has not discharged the obligation in paragraph 26 to inspect, view or
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listen to relevant material, they must at once raise the matter with the
disclosure officer and, if it is believed that the officer has not inspected,
viewed or listened to the material, request that it be done.
35.When prosecutors or disclosure officers believe that material might
reasonably be considered capable of undermining the prosecution case
or assisting the case for the accused, prosecutors must always inspect,
view or listen to the material and satisfy themselves that the
prosecution can properly be continued having regard to the
disclosability of the material reviewed. Their judgement as to what
other material to inspect, view or listen to will depend on the
circumstances of each case.
36. Prosecutors should copy the defence statement to the disclosure
officer and investigator as soon as reasonably practicable and
prosecutors should advise the investigator if, in their view, reasonable
and relevant lines of further enquiry should be pursued.
37.Prosecutors cannot comment upon, or invite inferences to be drawn
from, failures in defence disclosure otherwise than in accordance with
section 11 of the Act. Prosecutors may cross-examine the accused on
differences between the defence case put at trial and that set out in his
or her defence statement. In doing so, it may be appropriate to apply to
the judge under section 6E of the Act for copies of the statement to be
given to a jury, edited if necessary to remove inadmissible material.
Prosecutors should examine the defence statement to see whether it
points to other lines of enquiry. If the defence statement does point to
other reasonable lines of inquiry further investigation is required and
evidence obtained as a result of these enquiries may be used as part of
the prosecution case or to rebut the defence.
38. Once initial disclosure is completed and a defence statement has been
served requests for disclosure should ordinarily only be answered if the
request is in accordance with and relevant to the defence statement. If
it is not, then a further or amended defence statement should be
sought and obtained before considering the request for further
disclosure.
39. Prosecutors must ensure that they record in writing all actions and
decisions they make in discharging their disclosure responsibilities, and
this information is to be made available to the prosecution advocate if
requested or if relevant to an issue.
40. If the material does not fulfil the disclosure test there is no requirement
to disclose it. For this purpose, the parties’ respective cases should not
be restrictively analysed but must be carefully analysed to ascertain the
specific facts the prosecution seek to establish and the specific
grounds on which the charges are resisted. Neutral material or material
damaging to the defendant need not be disclosed and must not be
brought to the attention of the court. Only in truly borderline cases
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should the prosecution seek a judicial ruling on the disclosability of
material in its hands.
4
. If prosecutors are satisfied that a fair trial cannot take place where
material which satisfies the disclosure test cannot be disclosed, and
that this cannot or will not be remedied including by, for example,
making formal admissions, amending the charges or presenting the
case in a different way so as to ensure fairness or in other ways, they
must not continue with the case.
Prosecution advocates
42. Prosecution advocates should ensure that all material that ought to be
disclosed under the Act is disclosed to the defence. However,
prosecution advocates cannot be expected to disclose material if they
are not aware of its existence. As far as is possible, prosecution
advocates must place themselves in a fully informed position to enable
them to make decisions on disclosure.
43. Upon receipt of instructions, prosecution advocates should consider as
a priority all the information provided regarding disclosure of material.
Prosecution advocates should consider, in every case, whether they
can be satisfied that they are in possession of all relevant
documentation and that they have been instructed fully regarding
disclosure matters. Decisions already made regarding disclosure
should be reviewed. If as a result, the advocate considers that further
information or action is required, written advice should be promptly
provided setting out the aspects that need clarification or action.
Prosecution advocates must advise on disclosure in accordance with
the Act. If necessary and where appropriate a conference should be
held to determine what is required.
44. The prosecution advocate must keep decisions regarding disclosure
under review until the conclusion of the trial. The prosecution advocate
must in every case specifically consider whether he or she can
satisfactorily discharge the duty of continuing review on the basis of the
material supplied already, or whether it is necessary to inspect further
material or to reconsider material already inspected. Prosecution
advocates must not abrogate their responsibility under the Act by
disclosing material which could not be considered capable of
undermining the prosecution case or of assisting the case for the
accused.
45. Prior to the commencement of a trial, the prosecuting advocate should
always make decisions on disclosure in consultation with those
instructing him or her and the disclosure officer. After a trial has started,
it is recognised that in practice consultation on disclosure issues may
not be practicable; it continues to be desirable, however, whenever this
can be achieved without affecting unduly the conduct of the trial.
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46. There is no basis in law or practice for disclosure on a “counsel to
counsel” basis.
Involvement of other agencies
Material held by Government departments or other Crown bodies
47.Where it appears to an investigator, disclosure officer or prosecutor
that a Government department or other Crown body has material that
may be relevant to an issue in the case, reasonable steps should be
taken to identify and consider such material. Although what is
reasonable will vary from case to case, the prosecution should inform
the department or other body of the nature of its case and of relevant
issues in the case in respect of which the department or body might
possess material, and ask whether it has any such material.
48. It should be remembered that investigators, disclosure officers and
prosecutors cannot be regarded to be in constructive possession of
material held by Government departments or Crown bodies simply by
virtue of their status as Government departments or Crown bodies.
49. Departments in England and Wales should have identified personnel
as established Enquiry Points to deal with issues concerning the
disclosure of information in criminal proceedings.
50. Where, after reasonable steps have been taken to secure access to
such material, access is denied the investigator, disclosure officer or
prosecutor should consider what if any further steps might be taken to
obtain the material or inform the defence.
Material held by other agencies
51.There may be cases where the investigator, disclosure officer or
prosecutor believes that a third party (for example, a local authority, a
social services department, a hospital, a doctor, a school, a provider of
forensic services) has material or information which might be relevant
to the prosecution case. In such cases, if the material or information
might reasonably be considered capable of undermining the
prosecution case or of assisting the case for the accused prosecutors
should take what steps they regard as appropriate in the particular
case to obtain it.
52. If the investigator, disclosure officer or prosecutor seeks access to the
material or information but the third party declines or refuses to allow
access to it, the matter should not be left. If despite any reasons
offered by the third party it is still believed that it is reasonable to seek
production of the material or information, and the requirements of
section 2 of the Criminal Procedure (Attendance of Witnesses) Act
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1965 or as appropriate section 97 of the Magistrates Courts Act 1980'
are satisfied, then the prosecutor or investigator should apply for a
witness summons causing a representative of the third party to produce
the material to the Court.
53. Relevant information which comes to the knowledge of investigators or
prosecutors as a result of liaison with third parties should be recorded
by the investigator or prosecutor in a durable or retrievable form (for
example potentially relevant information revealed in discussions at a
child protection conference attended by police officers).
54. Where information comes into the possession of the prosecution in the
circumstances set out in paragraphs 51-53 above, consultation with the
other agency should take place before disclosure is made: there may
be public interest reasons which justify withholding disclosure and
which would require the issue of disclosure of the information to be
placed before the court.
Other disclosure
Disclosure prior to initial disclosure
55. Investigators must always be alive to the potential need to reveal and
prosecutors to the potential need to disclose material, in the interests of
justice and fairness in the particular circumstances of any case, after
the commencement of proceedings but before their duty arises under
the Act. For instance, disclosure ought to be made of significant
information that might affect a bail decision or that might enable the
defence to contest the committal proceedings.
56. Where the need for such disclosure is not apparent to the prosecutor,
any disclosure will depend on what the accused chooses to reveal
about the defence. Clearly, such disclosure will not exceed that which
is obtainable after the statutory duties of disclosure arise.
Summary trial
57. The prosecutor should, in addition to complying with the obligations
under the Act, provide to the defence all evidence upon which the
Crown proposes to rely in a summary trial. Such provision should allow
the accused and their legal advisers sufficient time properly to consider
the evidence before it is called.
‘The equivalent legislation in Norther Ireland is section 51A of the Judicature (Northern
Ireland) Act 1978 and Article 118 of the Magistrates’ Courts (Northern Ireland) Order 1981.
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Material relevant to sentence
58.In all cases the prosecutor must consider disclosing in the interests of
justice any material, which is relevant to sentence (e.g. information
which might mitigate the seriousness of the offence or assist the
accused to lay blame in part upon a co-accused or another person).
Post-conviction
59. The interests of justice will also mean that where material comes to
light after the conclusion of the proceedings, which might cast doubt
upon the safety of the conviction, there is a duty to consider disclosure.
Any such material should be brought immediately to the attention of
line management.
60. Disclosure of any material that is made outside the ambit of Act will
attract confidentiality by virtue of Taylor v SFO [1999] 2 AC 177.
Applicability of these Guidelines
61. Although the relevant obligations in relation to unused material and
disclosure imposed on the prosecutor and the accused are determined
by the date on which the investigation began, these Guidelines should
be adopted with immediate effect in relation to all cases submitted to
the prosecuting authorities in receipt of these Guidelines save where
they specifically refer to the statutory or Code provisions of the Criminal
Justice Act 2003 that do not yet apply to the particular case.
Issued in April 2005
Reformatted on 29 November 2012
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