By Barry Goldson

This article analytically excavates youth justice reform (in England and Wales) by situating it in historical context, critically reviewing the competing rationales that underpin it and exploring the overarching social, economic, and political conditions within which it is framed. It advances an argument that the foundations of a recognisably modern youth justice system had been laid by the opening decade of the 20th Century and that youth justice reform in the post-Second World War period has broadly been structured over four key phases. The core contention is that historical mapping facilitates an understanding of the unreconciled rationales and incoherent nature of youth justice reform to date, while also providing a speculative sense of future prospects.

Howard Journal of Criminal Justice 59(3): 317-334, 2020

By Aaron Brown and Nina Vaswani

The Glasgow Youth Court is a judicially-led initiative which has been supported by Glasgow City Health and Social Care Partnership (GCHSCP) and which has been operational since June 2021. Functioning within the Glasgow Sheriff Court, it operates on a problem-solving basis, covering those aged between 16 and 24-years-old. Where the presiding Sheriff is satisfied, the Glasgow Youth Court caters for the use of Structured Deferred Sentencing (SDS), which combines multi-disciplinary intervention and support in the community, with regular court reviews to monitor and encourage young people’s progress. The Children and Young People’s Centre for Justice (CYCJ) was commissioned by GCHSCP in late 2021 to undertake research into the Glasgow Youth Court, with the purpose of: 

Documenting the implementation, design and operation of the Youth Court; Evaluating data relating to Youth Court outcomes; Evidencing how the Youth Court is experienced by a range of key stakeholders. 

This report, through examination of the above themes, provides insight into how the Youth Court has been operationalised, how it has been experienced, and its key outcomes.    

Glasgow: Children and Young People's Centre for Justice,  2023. 56p.

By Tim Bateman 

The National Association for Youth Justice (NAYJ) campaigns for the rights of, and justice for, children in trouble. It seeks to promote the welfare of children in the youth justice system and to advocate for child friendly responses where children infringe the law (NAYJ, 2019). The Association has, more recently, endorsed the Youth Justice Board’s adoption of a ‘child first’ model, first articulated in its Strategic Plan, published in 2018 (Youth Justice Board, 2018). The subsequent revised edition of National Standards for children in the youth justice system, published in 2019, is intended to provide a framework to support agencies in delivering a child first provision, by ensuring that they: • ‘Prioritise the best interests of children, recognising their needs, capacities, rights and potential; • Build on children’s individual strengths and capabilities as a means of developing a prosocial identity for sustainable desistance from crime. This leads to safer communities and fewer victims. All work is constructive and future-focused, built on supportive relationships that empower children to fulfil their potential and make positive contributions to society; • Encourage children’s active participation, engagement and wider social inclusion. All work is a meaningful collaboration with children and their carers • Promote a childhood removed from the justice system, using prevention, diversion and minimal intervention. All work minimises criminogenic stigma from contact with the system’ 

London: Ministry of Justice/Youth Justice Board, 2019: 6)

By Holly Maclean, Fiona Dyer, Nina Vaswani, Deena Haydon, Maria Galli, Anthony Charles, Tim Bateman, & Ursula Kilkelly 

In 2021, in light of the commitment made by the Scottish Government to incorporate UNCRC into Scots Law, CYCJ convened a group of children’s rights experts from across England, Ireland, Jersey, Northern Ireland, Scotland and Wales to consider the implications and challenges of UNCRC incorporation across their separate jurisdictions. 

‘Rights Respecting Justice for Children in Conflict with the Law’ shines a light on the discussions that took place within this forum. This briefing paper provides an overview of talking points within the group across the period May 2021 – September 2023, highlighting both the most pressing concerns for children’s rights across the nations, and the similarities and differences in policy and practice.

Glasgow: Children and Young People's Centre for Justice, 2024. 17p.

By  Laceé N. Pappas &  Amy L. Dent 

By Amber Krushas , Zachary Hamilton, Alex Kigerl , Xiaohan Mei  

Purpose: While risk instruments are consistently used to aid classification and supervision decisions, needs as sessments guide intervention efforts for individuals under supervision. At the core of the Risk-Needs-Responsivity (RNR) model and the General Personality and Cognitive Social Learning (GPCSL) theory, dynamic needs scoring allows agencies to identify change in needs over time. Yet, few studies have assessed the potential impact of changes among needs items. To overcome this limitation, the current study assesses how needs score change may influence recidivism propensity among youth. Methods: Using multi-level frailty models, the current study examines how changes in youth needs assessment scores influence time-to-recidivism among a large (N = 42,922), multi-state sample of justice-involved youth assessed with the Modified Positive Achievement Change Tool (MPACT). Results: Findings demonstrate that youth with increased needs scores and those that remained the same at reassessment had a greater propensity for recidivism, compared to those that decreased scores. Conclusions: Policy implications identify the effectiveness of the MPACT in measuring youth change, its utility for case management, and the needs domains most associated with recidivism reductions.   

Journal of Criminal Justice 90 (2024) 102146 

By Carlene Firmin, et al.

During adolescence, young people are exposed to a range of risks beyond their family homes including sexual and criminal exploitation, peer-on-peer abuse and gang-related violence. However, it has only been over the past two decades that the critical safeguarding implications of these harms have started to be recognised. Social care organisations are increasingly experimenting with new approaches but continue to experience challenges in supporting affected young people and their families. This book analyses the results of the first rapid evidence assessment of social care organisations’ responses to risks and harms outside the home across 10 countries. The authors highlight key areas for service development, give insights into how these risks and harms can be understood, and consider wider implications for policy and practice.

Bristol, UK: Bristol University Press, 2022. 146p.

By Colleen Sbeglia, Imani Randolph, Caitlin Cavanagh, and Elizabeth Cauffman

When youth commit crimes, their parents may be held legally responsible for their actions. Parental legal culpability laws were developed to ensure justice for victims of crime but also deter juvenile delinquency. However, it is unclear if parental culpability has these desired effects or if it instead contributes to disparities that already exist in the justice system. This review provides a psychological perspective on parental legal culpability, highlighting the different types of offenses that parents may be held responsible for, including vicarious tort liability, status offenses, and criminal responsibility. Given the significant public discourse around certain types of crime, we also include focused discussions about parental culpability for youth violence and cybercrimes. We then consider the unintended consequences that may arise as a result of parental sanctions, from exacerbating racial and ethnic inequalities to imposing financial burdens that may put families at risk for further justice involvement. Finally, we discuss challenges to the efficacy of parental culpability laws, with recommendations for areas of continued research.

Annual Review of Criminology, Volume 7, Page 403 - 416

By Wren Collective

 Sixty years ago, the Supreme Court held that Clarence Earl Gideon, a man accused of a felony, had the right to an attorney, despite not being able to afford one. Since then, the constitutional right to counsel has continued to expand—to those facing incarceration for any criminal offense, to children facing delinquency charges, and to all critical stages of representation. As part of our research into whether, across the country, we are meeting Gideon's lofty promise, the Wren Collective examined the provision of indigent defense in Cuyahoga County. We chose to specifically focus on the representation Cuyahoga’s children were receiving for two reasons. First, the juvenile court and its assignment of counsel received media attention in early 2023, highlighting a unique characteristic about the county’s public defender. Unlike many offices across the country, the public defender was seeking more, rather than fewer, cases. Instead of an “overworked and underpaid” office, Cuyahoga appeared to have a reasonably compensated, skilled set of attorneys who wanted to provide representation to more kids. Second, throughout our initial interviews, we heard concerns about the representation children receive, especially when it comes to bindovers—transfers of juvenile cases to adult court. Cuyahoga sends more kids to adult court than any other county in Ohio, and the overwhelming majority of those kids are Black. As we looked closer at the system, we learned that the concerns people shared were justified. Cuyahoga’s juvenile court judges are under utilizing the county public defender, an office of trained and dedicated attorneys, social workers, investigators, paralegals, and clerks. Though the office can take more cases and is set up to provide the robust support that children often need, judges assign private attorneys over public defenders to the majority of the cases in the county. But those private attorneys are generally not providing similarly robust representation, and many do not appear to be qualified to take on the most serious cases in the county. That means that the majority of kids in Cuyahoga are losing out on representation that would likely serve them better. We also found that Cuyahoga’s assigned counsel system suffers both from too much interference and not enough oversight. Judges routinely pick attorneys to assign to cases, yet the court does little to ensure that those attorneys are meeting state education and experience requirements to serve as appointed counsel in those cases. The good news is Cuyahoga can fix these problems. We recommend that the Cuyahoga County Juvenile Court appoint the public defender to represent all children facing delinquency charges, and that the public defender, rather than the court, determine when assigned counsel is needed. We also recommend the county establish an independent assignment process that adheres to a rotary system for attorney assignments, and that the attorneys who are on the assignment list be trained and their qualifications verified. We recognize our recommendations will take effort, political will, and commitment from multiple stakeholders to implement, but we are confident this is a place that is up to the challenge. Cuyahoga County bursts with possibility. It has the potential to do what seems impossible in other places—make real and lasting change. We hope that this report, with its focus on key problems and specific ways to solve them, will help it do so.   

By Marian Gewirtz and  Bosco Villavicencio, Jr

This report describes the processing of 16- and 17-year-old arrestees during the third year of New York State’s Raise the Age (RTA) Law. The law, which went into effect for 16-year-olds on October 1, 2018, and for 17-year-olds on October 1, 2019, raised the age of criminal responsibility in the State and changed how these Adolescent Offenders (AOs) are processed. Arrests from October 2020 through September 2021 are compared with arrests from October 2019 through September 2020 (year 2), October 2018 through September 2019 (year 1, the first year of the implementation of RTA for 16-year-olds and the year prior to implementation for 17-year-olds. Data is also presented for October 2017 through September 2018 (pre-RTA). RTA Arrests ● There were 1,364 arrests of 16-year-olds and 2,002 arrests of 17-year-olds in the third year of RTA. The number of arrests was lower in year 3 than in year 2, especially for 16-yearolds. ● The volume of arrests of 16- and 17-year-olds decreased markedly when they became eligible for RTA. The number of arrests continued to decline for both age groups and for VFO (violent felony offenses), non-VFO felony offenses and especially for misdemeanors. Prosecution ● The percentage of felony arrests prosecuted as felonies declined for both age groups and both VFO and non-VFO charges since implementation of RTA. However, the decrease was greater for 16-year-olds and for cases with non-VFO charges. ● There were far fewer cases for 16- and 17-year-olds prosecuted in adult court with felony charges after RTA was implemented. The decrease was steeper for 16-year-olds than for 17-year-olds. The number decreased from 1,111 in year 1 to 863 in year 2 and 668 in year 3 for 16-year-olds but declined from a high of 992 down to 894 for 17-year-olds. Arraignment ● About half of AO cases were removed to Family Court at arraignment in year 3, up from 44% for both age groups in year 2 and only 25% at arraignments for 16-year-olds in year 1 (17-year-olds were not yet eligible). The rate of removal was higher for cases with nonVFO charges than for those with VFO offenses. ● In the third year of RTA, youths were released at arraignment (ROR, under supervision or with other non-monetary conditions) in more than nine of every ten non-VFO cases but in little more than seven of every ten VFO cases. Adult Court Outcomes ● Most RTA case for both ages were removed to Family Court (84% to 90% across the ages and time periods), but the rates were higher for non-VFO cases (91% to 97%) than for cases with VFO charges (79% to 86%). ● In year 3, more than six of every ten VFO cases were removed at arraignment or the following day as were nearly nine of every ten non-VFO cases. Yet a month or more elapsed from arraignment to removal for one in ten AO cases.  Sentencing ● More than half of the sentences in AO cases included jail or prison time (55%) ranging from time already served pretrial (6% of sentences) to four years or more (10% of sentences).  

New York: New York City Criminal Justice Agency 2023. 44p.

By Keith Finlay, Michael Mueller-Smith, Brittany Stree

Children’s indirect exposure to the justice system through biological parents or coresident adults is both a marker of their own vulnerability and a measure of the justice system’s expansive reach in society. Estimating the size of this population for the United States has historically been hampered by inadequate data resources, including the inability to observe nonincarceration events, follow children throughout their childhood, and measure adult nonbiological parent cohabitants. To overcome these challenges, we leverage billions of restricted administrative and survey records linked with Criminal Justice Administrative Records System data and find substantially larger exposure rates than previously reported: prison, 9% of children born between 1999–2005; felony conviction, 18%; and any criminal charge, 39%. Charge exposure rates exceed 60% for Black, American Indian, and low-income children. While broader definitions reach a more expansive population, strong and consistently negative correlations with childhood well-being suggest that these remain valuable predictors of vulnerability. Finally, we document substantial geographic variation in exposure, which we leverage in a movers design to estimate the effect of living in a high-exposure county during childhood. We find that children moving into high-exposure counties are more likely to experience post-move exposure events and exhibit significantly worse outcomes by age 26 on multiple dimensions (earnings, criminal activity, teen parenthood, mortality); effects are strongest for those who moved at earlier ages

The Quarterly Journal of Economics, Volume 138, Issue 4, November 2023, Pages 2181–2224, https://doi.org/10.1093/qje/qjad021

By Pamela D Schulz

The language in media stories surrounding the high drama of juvenile and youth crime is very alarmist and continues to fuel political debates and demands for tougher penalties rather than the proverbial slap on the wrist for young offenders. Further there are fear discourse elements that suggest that for some politicians cited in the daily news cycle as being “out of control”. In opposition to this fear and alarmist discourse in the notion that the media news cycle highlights youth crime for its sensationalist perspectives and poor reporting of youth courts and their judgments in such matters. A comprehensive discourse analysis of youth crime reporting may suggest that media must take the blame for some of the inappropriate focus on youth crime as being selective. This yearlong study suggests that the public need more information to see for themselves whether the current moves and political debates need to be reviewed and refreshed. In addition, family supports are a signal to consider as presented by expert authorities involved in decision making and reporting.

Children and Teenagers, Vol. 6, No. 4, 2023, http://dx.doi.org/10.22158/ct.v6n4p1

By The Sentencing Project

For a decade, incarceration disparities between Tribal and white youth have remained stubbornly high. As of 2021, Tribal youth were 3.7 times as likely to be detained or committed in juvenile facilities as their white peers, according to nationwide data collected in October 2021 and recently released. This ratio is essentially unchanged from 2011.1 There are 11 states with at least 8,000 Tribal youths (a cutoff that allows for meaningful comparisons), and Tribal youth are more likely than their white peers to be in custody in eight of these states. For the purposes of this fact sheet, all “Tribal youth” are by definition non-Hispanic/Latinx. (The underlying dataset labels them as American Indian.2 ) Juvenile facilities, including 1,323 detention centers, residential treatment centers, group homes, and youth prisons3 held 24,894 youths as of October 2021. These data do not include the 291 people under 18 in adult prisons at year-end 20214 or the estimated 2,000 people under 18 in adult jails at midyear 2021.5 Nationally, the youth placement rate was 74 per 100,000 in 2021. The Tribal youth placement rate was 181 per 100,000, compared to the white youth placement rate of 49 per 100,000. Between 2011 and 2021, overall juvenile placements fell 59%. In the 11 states with at least 8,000 Tribal youths between the ages of 10 and 17, between 2011 and 2021, disparities grew by at least 50% in two and decreased by at least 50% in two

Washington, DC: The Sentencing Project, 2023. 3p.

By The Sentencing Project

For a decade, incarceration disparities between Latinx and white youth have fallen, though disparities still remain. As of 2021, Latinx youth were 16% more likely to be placed (i.e., detained or committed) in juvenile facilities as their white peers, according to nationwide data collected in October 2021 and recently released. These data reveal a sharp decline in Latinx-white youth incarceration disparities since 2011; that year, Latinx youth were 76% more likely to be in placement than white youth.1 Juvenile facilities, including 1,323 detention centers, residential treatment centers, group homes, and youth prisons2 held 24,894 youths as of October 2021. (These data do not include the 291 people under 18 in adult prisons at year-end 20213 or the estimated 2,000 people under 18 in adult jails at midyear 2021.4 ) Nationally, the youth placement rate was 74 per 100,000 youth in 2021. The Latinx youth placement rate was 57 per 100,000, compared to the white youth placement rate of 49 per 100,000. A total of 20% of youths in placement are Latinx, and Latinx youth comprise 25% of all youth across the United States.5 Latinx youth are more likely to be in custody than white youth in half of states with at least 8,000 Latinx youth (between the ages of 10 and 17), a cutoff that allows for meaningful comparisons Between 2011 and 2021, juvenile placements fell by 59%. During these years, Latinx youth placements declined slightly faster than white youth placements (a 65% decline vs. 57%), resulting in a smaller but still considerable disparity.

Washington, DC: The Sentencing Project, 2023. 3p.

By The Sentencing Project

For a decade, incarceration disparities between Black and white youth have remained stubbornly high. As of 2021, Black youth were 4.7 times as likely to be placed (i.e., detained or committed) in juvenile facilities as their white peers, according to nationwide data collected in October 2021 and recently released. This disparity has hardly changed over the past decade.1 Juvenile facilities, including 1,323 detention centers, residential treatment centers, group homes, and youth prisons2 held 24,894 youths as of October 2021. (These data do not include the 291 people under 18 in adult prisons at year-end 20213 or the estimated 2,000 people under 18 in adult jails at midyear 2021.)4 Nationally, the youth placement rate was 74 per 100,000 in 2021. The Black youth placement rate was 228 per 100,000, compared to the white youth placement rate of 49 per 100,000. Forty-two percent of youths in placement are Black, even though Black Americans comprise only 15% of all youth across the United States.5 Among all states with a population of at least 8,000 Black youth, (between 10 and 17), a cutoff that allows for meaningful comparisons, Black youth are more likely to be in custody than white youth. Black and white youth have similar juvenile placement rates in the District of Columbia.

Washington, DC: The Sentencing Project, 2023. 3p.

By The Southern Poverty Law Center

Mississippi’s youth legal system is a study in extremes. While the state is currently experiencing its lowest youth arrest rate in decades, it simultaneously has markedly expanded its use of youth incarceration. Rather than being met with needed services and support, Mississippi students are being pushed out of the classroom at nation-leading rates and into the carceral system – a pipeline that has disproportionately impacted the state’s Black youth. Overall, Mississippi’s failure to invest in successful community-based programs that provide noncarceral alternatives for youth in need of rehabilitation leaves the state with incarceration as the first option for far too many young people. This overincarceration harms youth and their communities and is an expensive use of precious taxpayer funds. There is a better way. This report delves into the history and context behind Mississippi’s current youth legal system,  expands on its harmful impacts, and recommends policy  changes for reform.

Montgomery, AL: Southern Poverty Law Center, 2023

By The Southern Poverty Law Center

The impact of mass incarceration on children and families in Louisiana is significant. As the mass incarceration capital of the world, Louisiana has an estimated 94,0001 children with a parent who is behind bars. The devastating effects of incarceration on children and families are evidence that incarceration is a sentence that the entire family will serve. Parental incarceration is a growing epidemic. Nationally, one in 28 children experiences parental incarceration today, compared to one in 125 children in 1985.2 Black children are particularly affected by caregiver incarceration, as 11.4% of Black children experience parental incarceration, compared to 1.8% of their white peers.3 This is of little surprise, as Black people are disproportionately represented in the prison system, due to historic social and economic inequality.

Montgomery, AL: Southern Poverty Law Center.  2021. 16pg

By Maria Micaela Sviatschi

This paper provides evidence showing how deportation policies can backfire by disseminating not only ideas between countries but also criminal networks, spreading gangs, in this case, across Central America and spurring migration back to the US. In 1996, the US Illegal Immigration Responsibility Act drastically increased the number of criminal deportations. In particular, the members of large Salvadoran gangs that developed in Los Angeles were sent back to El Salvador. Using variation in criminal deportations over time and across cohorts combined with geographical variation in the location of gangs and their members’ place of birth, I find that criminal deportations led to a large increase in Salvadoran homicide rates and gang activity, such as extortion and drug trafficking, as well as an increase in gang recruitment of children. In particular, I find evidence that children in their early teens when the leaders arrived are more likely to be involved in gang-related crimes when they are adults. I also find evidence that these deportations, by increasing gang violence in El Salvador, increase child migration to the US–potentially leading to more deportations.

Princeton, NJ: Princeton University Working Paper, 2020. 52p.

By HM Inspectorate of Probation; Bob Smith, et al

Children who are remanded in youth detention are some of the most vulnerable in our communities. Numerically they are a small group, typically between 200 and 250 at any one time, and around 1,200 in a year. Many have experienced neglect, abuse and trauma. They have often missed out on schooling and diagnosis of learning needs and disabilities. Some have been victims of exploitation. For many of them, there have been missed opportunities to intervene earlier in their lives. The offences which the children in our sample group were suspected of committing were mostly serious, some involving life-changing injuries and loss of life. However, not all children in our sample needed to be remanded in custody. A quarter were released on bail before being sentenced, and inspectors judged that more of them could have been safely managed in the community. Children were bailed, often within a week of their initial remand, not because their risk had reduced but because a suitable bail programme with appropriate accommodation had become available which could safely manage those risks. Children’s services and youth justice services should work together more effectively to provide information and community remand options to the courts earlier. In this report, we set out a range of ways to achieve this, but it mostly involves good communication and clarity of responsibilities between professionals, who take a proactive approach. Children who are remanded comprise around 40 per cent of all children in custody. There is a gulf between the quality of care given in the three types of secure facilities used for children who are remanded in custody: secure children’s homes, secure training centres and young offender institutions. The quality of care is good in the secure children’s homes but less so in the others, where we identified many weaknesses in the management of remanded children. Children acquire child in care status as a result of their secure remand, and that is applied in widely different ways. The assistance they should receive is not consistently good enough, as a result of ineffective care planning and because their social workers lack knowledge of both the criminal justice system and secure estate processes. As a result, children do not always have timely access to basics such as pocket money to pay for phone calls (including to their social workers) and essential items. Families of sentenced children receive help with travel costs for visits from the secure estate, but families of remanded children rely on assistance from youth justice and children’s services, which is not always forthcoming. Social workers do not sufficiently implement the care planning regulations in the context of children’s circumstances when they are in the secure estate. As a result, the benefits of ‘in-care status’ are not realised to improve children’s circumstances. National standards and guidance are needed in this area. When the remand ends, some children return to their communities, and sometimes that return is unexpected. They do not always receive the support they need, and if they have reached 18 their case may need to transfer to the Probation Service. That does not always happen effectively. Underlying these shortcomings in remand are racial and ethnic disparities at many of the key decision points in the system, which result in black and mixed heritage children being over-represented in custody. This needs urgent attention. Our recommendations are designed to improve the quality of services across the whole remand process, to ensure that only those children who need to be detained are in custody and that those children receive a high-quality service that keeps the community safe but meets their needs, both when they are in custody and as they prepare to return to their communities.

Manchester, UK: The Inspectorate, 2023. 50p.

By David Foster

There is currently no general statutory obligation for individuals in England to report child abuse. Government statutory guidance on safeguarding, says “anyone who has concerns about a child’s welfare should make a referral to local authority children’s social care and should do so immediately if there is a concern that the child is suffering significant harm or is likely to do so.” While this does not impose a legislative requirement to report abuse, it creates an expectation that those working with children will comply with the guidance unless there are exceptional circumstances.

In addition, some individuals are required to report child safeguarding concerns under standards or codes of conduct set by their professional regulatory body. A failure to adhere to such standards may result in misconduct or fitness to practise proceedings against them.

Mandatory reporting duty

There have been calls for a mandatory duty to report known or suspected child abuse and neglect to be introduced for specific groups, such as social workers and teachers. Proponents argue that a mandatory reporting duty would offer greater protection to children. However, others fear it could create a ‘needle in the haystack’ effect and result in a ‘tick-box approach’.

Independent Inquiry into Child Sexual Abuse

The final report of the Independent Inquiry into Child Sexual Abuse, published in October 2022, said children had suffered as a result of “a marked absence of a cohesive set of laws and procedures in England and in Wales that require individuals working with children to report child sexual abuse”.

The report recommended the UK Government and the Welsh Government introduce legislation placing certain individuals – ‘mandated reporters’ – under a statutory duty to report child sexual abuse in prescribed circumstances (for example, where they observe recognised indicators of sexual abuse).

The report recommended it should be a criminal offence for mandated reporters to not report child sexual abuse when a child or perpetrator discloses it to them, or they witness a child being sexually abused.

Government commits to introducing mandatory reporting duty

In April 2023, the UK Government committed to introduce, subject to consultation, a mandatory reporting duty for those working or volunteering with children to report child sexual abuse.

Following on from an earlier call for evidence, on 2 November 2023, the Government launched a consultation setting out proposals for a mandatory reporting duty and seeking views on “a small but significant set of undecided policy questions.” The consultation closes on 30 November.

Following a previous consultation in 2016, the Government decided against introducing a mandatory reporting duty.

Research Briefing. London: UK Parliament, House of Commons Library, 2023. 23p.