Appendix 1 – Review of detention policy and practices 2004–2014


1.1 Overview  

During the period between 2004 and 2014, all Australian governments maintained a legal and policy framework that supported the mandatory detention of asylum seekers who arrive in Australia without a valid visa.

Despite this bipartisan support for mandatory detention, the past decade also heralded the introduction of a number of positive changes to the legal and policy framework governing detention in Australia.

This chapter includes a review of these detention policies and practices and highlights the most significant changes over the ten year period from 2004 to 2014.

Most significantly, in 2005 amendments to the Migration Act introduced a non-compellable, non-delegable power for the Minister to issue a bridging visa or to approve the placement of individuals in residence determination arrangements in the community while their claims for protection are assessed. Another important development in 2005 was the introduction of a provision into the Migration Act which affirms the principle that a minor should only be detained as a ‘measure of last resort’.[630]

In 2008, a new set of immigration detention values were introduced outlining that children and where possible families were no longer to be held in immigration detention centres.[631]

In 2010 the government began to release significant numbers of families and children into community based alternatives to detention.

The Australian Human Rights Commission acknowledges there has been an unprecedented increase in the number of asylum seekers arriving in Australia by boat in recent years. Nevertheless, the Commission is concerned that despite the revised legal and policy framework since 2004, there continues to be significant numbers of children in locked detention and the average period of detention continues to increase.[632]

1.2 Key findings and recommendations from A last resort?

In 2004, the Commission (the then Human Rights and Equal Opportunity Commission) published its key report focused on children in Australia’s immigration detention system, A last resort?[633] The report made a series of findings and recommendations related to Australia’s immigration detention system ‘as it applied to children who arrived in Australia without a visa (unauthorised arrivals) over the period 1999 to 2002’.[634]

The report made three major findings:

  1. Australia’s immigration detention law and policy framework created a detention system which was ‘fundamentally inconsistent’ with the Convention on the Rights of the Child.
  2. Children in detention were prevented from being able to enjoy many of the rights articulated in the Convention on the Rights of the Child.
  3. Children are at high risk of serious mental harm and the Commonwealth’s failure to remove certain children from detention with their parents as recommended by mental health professionals amounted to cruel, inhuman and degrading treatment.[635]

A last resort? made five recommendations for change:

  1. That children and their parents in closed immigration detention facilities be released at the earliest possible opportunity.
  2. That the law be changed, in particular to create a presumption against the detention of children for immigration purposes, to provide independent assessment within 72 hours of the need to detain children, and to provide for prompt and periodic judicial review of detention after that.
  3. That an independent guardian be appointed for all unaccompanied children.
  4. That minimum standards for detention of children be codified in law.
  5. That there be a review of the use of ‘excised offshore places’ and the ‘Pacific Solution’ relating to their particular impact on children.

1.3 Key legislative and policy changes

(a) Migration Act 1958 (Cth)

The most significant legislative reforms to detention in the last decade have been the introduction of a suite of changes to the Migration Act introduced through the Migration Amendment (Detention Arrangements) Act 2005 (Cth). These changes provided new Ministerial powers that allowed for ‘children, families and people with special needs to be placed in detention in the community, rather than in a secure immigration detention centre’.[636]

Three key changes were introduced through this Act:

  • Section 197AB – Residence Determination
    The introduction of section 197AB of the Migration Act provides a ‘non-compellable, non-delegable ministerial power to make a residence determination (to permit a person in immigration detention to live in the community rather than a detention facility) under the scheme more commonly known as community detention’,[637] where the Minister thinks that is in the public interest to do so. This amendment enabled asylum seekers who had arrived in Australia by boat to be given the opportunity to reside in the community at a particular address, whilst being treated as if they were being kept in immigration detention in accordance with section 189 of the Migration Act.[638]
     
  • Section 195A – Bridging Visa E
    The introduction of section 195A of the Migration Act also provides the Minister with discretion to grant a visa (including a bridging visa) to an individual in immigration detention when the Minister deems it in the public interest to do so. For the first time, section 195A introduced the option of Bridging Visa E to asylum seekers who had arrived in Australia by boat, providing them temporary lawful status to reside in the community whilst their immigration status was resolved.[639]
  • Section 4AA – A measure of last resort
    An additional and complementary change to the Migration Act was implemented through the introduction of section 4AA, which affirmed the principle that ‘a minor shall only be detained as a measure of last resort’.

1.4 New Directions in Detention policy

On 29 July 2008, the then Minister for Immigration and Citizenship, Senator Chris Evans announced the New Directions in Detention policy,[640] which he stated would ‘fundamentally change the premise underlying detention policy’.[641] The New Directions in Detention policy introduced a set of seven immigration detention values by which the Australian Government was to be guided. These principles were:

  1. Mandatory detention is an essential component of strong border control.
  2. To support the integrity of Australia’s immigration program, three groups will be subject to mandatory detention:
    • all unauthorised arrivals, for management of health, identity and security risks to the community;
    • unlawful non-citizens who present unacceptable risks to the community; and
    • unlawful non-citizens who have repeatedly refused to comply with their visa conditions.
  3. Children, including juvenile foreign fishers and, where possible, their families, will not be detained in an immigration detention centre.
  4. Detention that is indefinite or otherwise arbitrary is not acceptable and the length and conditions of detention, including the appropriateness of both the accommodation and the services provided, would be subject to regular review.
  5. Detention in immigration detention centres is only to be used as a last resort and for the shortest practicable time.
  6. People in detention will be treated fairly and reasonably within the law.
  7. Conditions of detention will ensure the inherent dignity of the human person.

Under the New Directions in Detention policy, immigration detention was to be used as a last resort and for the shortest practicable period, and there was a presumption that people would be permitted to reside in the community unless they pose an unacceptable risk.[642]

As the New Directions in Detention policy was never enshrined in legislation, it has now been overtaken by alternative policy positions which have resulted in significant numbers of asylum seekers remaining in immigration detention facilities rather than in community arrangements while they await the resolution of their immigration status.[643]

1.5 Third country processing

In the decade from 2004 to 2014, political support for the policy of third country processing has varied. Since 2012, however, third country processing has received bipartisan support from both Labor and Coalition Governments.

On 28 June 2012, former Prime Minister Julia Gillard announced the appointment of the Expert Panel on Asylum Seekers (the Expert Panel) to provide advice and recommendations to the Australian Government on policy options to prevent asylum seekers risking their lives on dangerous boat journeys to Australia.[644]

Following the release of the report by the Expert Panel on 13 August 2012, the former Labor Government introduced a system of third country processing for asylum seekers arriving by boat.[645] The third country processing regime applied to all asylum seekers arriving by boat after 13 August 2012 unless the Minister for Immigration determined otherwise. Transfers commenced to Nauru in September 2012 and to Manus Island, Papua New Guinea in November of the same year.[646] Although these people were processed in another country, at this time it was possible that those determined to be refugees could be resettled in Australia.

In August 2012, the Labor Government adopted the Expert Panel’s recommendation to apply a ‘no advantage’ principle which stipulated that refugees arriving by boat should not receive an ‘advantage’ over refugees overseas who are waiting to be resettled.

The Government’s implementation of the ‘no advantage’ principle resulted in suspension of the processing for asylum seekers who had arrived by boat on or after 13 August 2012.[647] The suspension of processing has had a profound impact on the times that people have waited to have their refugee claims assessed. It has also prolonged the detention of children detained in onshore and offshore locked detention facilities.

On 19 July 2013, former Prime Minister Kevin Rudd announced a new regional resettlement policy that asylum seekers who arrived by boat after that date would never be resettled in Australia.[648] This policy has been adopted by the current Coalition Government. This means that asylum seekers who arrived by boat after 19 July 2013 will not only be processed offshore but settled offshore as well.

1.6 Indefinite detention on Christmas Island

Most asylum seekers on Christmas Island arrived after 19 July 2013, but before the federal election on 7 September 2013. These people are subject to third country processing and are ineligible for resettlement in Australia.

The asylum seekers on Christmas Island have now been detained for over one year on average. They are not able to be transferred offshore because there are limits to the capacity of the third country processing centres. Some asylum seekers are not being transferred because they have complex medical conditions, including infectious diseases that make offshore transfers problematic. Some families have babies that were born in Australia and these babies are part of a test case that is due to be heard in October 2014.[649] The test case will decide whether a child who is born in Australia is entitled to apply for refugee status if the child’s parents came here by boat.[650]

1.7 Rapid offshore processing after September election 2013

Asylum seekers who arrived in Australia by boat following the federal election on 7 September 2013 were sent offshore, many within 48 hours as per the new Coalition Government’s policy.[651] Rapid processing occurred on Christmas Island, with children and their families moved to Nauru and single adult men to Manus Island, Papua New Guinea.

It was a large logistical exercise to move people from Christmas Island to Nauru in 48 hours. It meant that Nauru needed to build more accommodation and staff had to be deployed to Christmas Island to assist with the ‘removal’ of people offshore.

1.8 Other policy decisions

(a) Department Community Support and Children’s Branch

In 2010, the government established a Children’s Unit in the immigration detention portfolio with particular responsibility for children’s issues. The original objective of the Unit was to ‘support the specific needs of children and families through a cohesive policy approach’.[652] The Department reports that the responsibility of the Unit has expanded into the Community Support and Children’s Branch. This Branch receives support from the Community Programmes and Children Division and covers matters relevant to children in detention.[653]

The Department has developed a specific chapter in its Procedures Advice Manual outlining a set of guiding principles to guide staff developed from Australia’s obligations under the Convention on the Rights of the Child.[654]

(b) Departmental communication policies and practices

In 2013, the current Minister for Immigration and Border Protection, the Hon Scott Morrison MP issued a directive requesting that Department employees and all service providers refer to asylum seekers who arrive by boat as ‘illegal maritime arrivals’ and ‘detainees’. People being sent to offshore processing centres on Nauru and Manus Island, Papua New Guinea are to be referred to as ‘transferees’.[655] This directive changed the terminology used by the previous government which was to describe asylum seekers who arrived by boat as ‘clients’ or ‘irregular maritime arrivals’ in recognition that neither Australian domestic law nor international law make it illegal to claim asylum.

1.9 Implementation of policy

(a) The use of community-based alternatives to detention

On 18 October 2010, the Australian Government announced that it would begin moving significant numbers of children and their families into Community Detention.[656] From the date of the announcement to 30 April 2014, a total of 8750 detainees had been approved for Community Detention, including 2771 children with their parents and 1813 unaccompanied children.[657]

A year later, on 25 November 2011, the government announced that, following initial health, security and identity checks, selected asylum seekers who arrive in Australia by boat would be placed into the community while their asylum claims were assessed.[658] This was to be achieved through extending the use of Community Detention to vulnerable individuals in addition to children and families. Bridging visas were granted for the first time to people who had arrived in Australia by boat.[659]

Since November 2011, successive Ministers have utilised their discretionary power to grant bridging visas to more than 29,000 asylum seekers who have arrived in Australia by boat.[660]

According to data provided by the Department of Immigration and Border Protection, 1,939 asylum seeker children were released from detention on bridging visas by 30 April 2014, including 48 babies who had been born in Australia.[661]

(b) Release of children under the age of 10

On 19 August 2014, the Minister for Immigration and Border Protection announced that the government would release all children under 10 and their families from detention into the community on bridging visas. This announcement only applies to asylum seekers on the Australian mainland who arrived prior to 19 July 2013. The Minister had said previously the arrangements in place for the protection and support for families with children under 10 was not sufficient and that this needed to be rectified before children were released into the community. The Minister told the Inquiry that he had already been releasing children over 10 from detention onto bridging visas.

1.10 Numbers and length of detention of children 2004 – 2014

In 2008 the number of asylum seekers arriving by boat began to steadily increase and between 2009 and 2013 the number of arrivals reached unprecedented numbers. Chart 60 shows the spike in arrivals from 2011 to 2013.

Chart 60: Number of people arriving by boat to Australia since 2004

 Number
of people arriving by boat from 2004-2008 was close to 0, the number peaked at over 20000
in 2013 before substantially decreasing in 2014.

Chart 60 description: Number of people arriving by boat from 2004-2008 was close to 0, the number peaked at over 20,000 in 2013 before substantially decreasing in 2014.

Source: J Phillips and H Spinks, Boat arrivals in Australia since 1976, Parliamentary Library Research Paper[662]

The Commission welcomes the government’s use of Community Detention and bridging visas to facilitate the removal of children and their families from locked detention facilities. However, the Commission is concerned that these mechanisms remain underutilised.

There are still a concerning number of children detained in locked detention facilities. The number of children in locked detention has risen from a total of 68 children in July 2004 to 1022 children in January 2014. In January 2014 there were 939 with at least one parent and 83 unaccompanied children.[663] The increase in children in detention since 2010 is shown in Chart 61.

Chart 61: Number of children in detention; July 2004 to January 2014

 children
in detention was 100 or less from 2004 to 2009. There was then an increase in
the number of children peaking at over 1500 in July 2013 before decreasing in
2014.

Chart 61 description: Children in detention was 100 or less from 2004 to 2009. There was then an increase in the number of children peaking at over 1500 in July 2013 before decreasing in 2014.

Source: Data from the Department of Immigration and Border Protection[664]

While numbers of children in locked detention decreased since the peak of 1638 (1287 with at least one parent, 351 unaccompanied) in July 2013, Department data indicates that the average length in detention also rose significantly during the same period.[665]

In January 2013, children and adults had been in detention for four months (124 days) on average. At the time of writing this report, the average period of detention for children and adults is 413 days.

Notably, when the number of children in detention reached its highest levels in July 2013, the average detainee was spending 72 days in detention facilities, less than at any other time during the period between January 2013 and July 2014.[666]

These periods of immigration detention can be contrasted to much shorter periods in comparable countries. In 2011 the Department provided comparative data on average lengths of detention in the United States and Canada to the Senate Joint Select Committee on Australia’s Immigration Detention Network. According to those figures:[667]

  • In 2008-09, Canada detained 14,359 individuals in immigration detention for an average of 17 days. About 60 percent of these people were detained for less than 48 hours.
  • In 2009 the average time spent in immigration detention in the United States was 30 days.

The Commission is concerned by the underutilisation of community placement options and by the prolonged and indefinite detention of children in Australia.


[630]Migration Act 1958 (Cth), ss 4AA, 195A, 197AB.
[631]See C Evans, New Directions in Detention – Restoring Integrity to Australia’s Immigration System (Speech delivered at the Centre for International and Public Law Seminar, Australian National University, Canberra, 29 July 2008), at http://pandora.nla.gov.au/pan/67564/20100913-1000/www.minister.immi.gov.au/media/speeches/2008/ce080729.html (viewed 15 September 2014).
[632]Department of Immigration and Border Protection, Correspondence to Australian Human Rights Commission in response to Notice to Produce (Graph – Average length of time in detention)
[633]Human Rights and Equal Opportunity Commission, A last resort? National Inquiry into Children in Immigration Detention (2004) (A last resort?) At www.humanrights.gov.au/human_rights/children_detention_report/index.html (viewed 1 September 2014).
[634]Human Rights and Equal Opportunity Commission, A last resort? National Inquiry into Children in Immigration Detention (2004) (A last resort?) p 5 At www.humanrights.gov.au/human_rights/children_detention_report/index.html (viewed 1 September 2014).
[635]Human Rights and Equal Opportunity Commission, A last resort? National Inquiry into Children in Immigration Detention (2004) (A last resort?) p 5. At www.humanrights.gov.au/human_rights/children_detention_report/index.html (viewed 1 September 2014)
[636]Department of Immigration and Border Protection, Submission No 45 to the National Inquiry into Children in Immigration Detention 2014, p 27. At https://www.humanrights.gov.au/sites/default/files/Submission%20No%2045%... (viewed 7 October 2014).
[637]Department of Immigration and Border Protection, Submission No 45 to the National Inquiry into Children in Immigration Detention 2014, p 27. At https://www.humanrights.gov.au/sites/default/files/Submission%20No%2045%20-%20Department%20of%20Immigration%20and%20Border%20Protection.pdf (viewed 7 October 2014).
[638]Department of Immigration and Border Protection, Submission 45 to the National Inquiry into Children in Immigration Detention 2014, p 27. At https://www.humanrights.gov.au/sites/default/files/Submission%20No%2045%20-%20Department%20of%20Immigration%20and%20Border%20Protection.pdf (viewed 7 October 2014).
[639]Department of Immigration and Border Protection, Submission No 45 to the National Inquiry into Children in Immigration Detention 2014, p 29. At https://www.humanrights.gov.au/sites/default/files/Submission%20No%2045%20-%20Department%20of%20Immigration%20and%20Border%20Protection.pdf (viewed 7 October 2014).
[640]See C Evans, New Directions in Detention – Restoring Integrity to Australia’s Immigration System (Speech delivered at the Centre for International and Public Law Seminar, Australian National University, Canberra, 29 July 2008). At http://pandora.nla.gov.au/pan/67564/20100913-1000/www.minister.immi.gov.au/media/speeches/2008/ce080729.html (viewed 15 September 2014).
[641]See C Evans, New Directions in Detention – Restoring Integrity to Australia’s Immigration System (Speech delivered at the Centre for International and Public Law Seminar, Australian National University, Canberra, 29 July 2008), at http://pandora.nla.gov.au/pan/67564/20100913-1000/www.minister.immi.gov.au/media/speeches/2008/ce080729.html (viewed 15 September 2014).
[642]See C Evans, New Directions in Detention – Restoring Integrity to Australia’s Immigration System (Speech delivered at the Centre for International and Public Law Seminar, Australian National University, Canberra, 29 July 2008), at http://pandora.nla.gov.au/pan/67564/20100913-1000/www.minister.immi.gov.au/media/speeches/2008/ce080729.html (viewed 15 September 2014).
[643]Department of Immigration and Border Protection, Historical data on children in detention 2004 - 2014, Item 25, Document 25.1, Schedule 2, First Notice to Produce, 31 March 2014; Australian Human Rights Commission, Community arrangements for asylum seekers, refugees and stateless persons. Observations from visits conducted by The Australian Human Rights Commission from December 2011 to May 2012 (2012), sect. 5.2.
[644]The Expert Panel is led by Air Chief Marshall Angus Houston AC AFC (retired), and also comprises
Mr Paris Aristotle AM, Director of the Victorian Foundation for the Survivors of Torture (‘Foundation House’) and Professor Michael L’Estrange AO, Director of the National Security College. The Terms of Reference for the Expert Panel are provided at http://expertpanelonasylumseekers.dpmc.gov.au/terms (viewed 30 September 2014).
[645]The Migration Legislation Amendment (Regional Processing and Other Measures) Bill 2012 (Cth).
[646]B Packham, ‘Labor to act quickly to reopen Nauru, PNG asylum-seeker processing centres’, The Australian, 13 August 2012 at http://www.theaustralian.com.au/national-affairs/immigration/labor-caucus-backs-expert-panel-on-asylum-policy/story-fn9hm1gu-1226449423972 (viewed 18 September 2014).
[647]B Hall, ‘No-benefits policy puts 20,000 in oblivion’, The Sydney Morning Herald, 28 May 2013 at http://www.smh.com.au/federal-politics/political-news/nobenefit-policy-puts-20000-in-oblivion-20130527-2n7kd.html (viewed 2 September 2014).
[648]The Hon K Rudd PM, ‘Australia and Papua New Guinea Regional Settlement Arrangement’, media statement (19 July 2013). At http://pandora.nla.gov.au/pan/79983/20130830-1433/www.pm.gov.au/press-office/australia-and-papua-new-guinea-regional-settlement-arrangement.html (viewed 15 September 2014).
[649]P Taylor and P Maley, ‘Families and children face stay on Christmas Island as PNG transfers in doubt’, The Australian, 22 October 2013. At www.theaustralian.com.au/national-affairs/immigration/families-and-children-face-stay-on-christmas-island-as-png-transfers-in-doubt/story-fn9hm1gu-1226744122598 (viewed 31 August 2014).
[650]Maurice Blackburn Lawyers, ‘Court date sought to release Australian-born baby from detention’ 16 June 2014. At http://www.mauriceblackburn.com.au/about/media-centre/media-statements/2014/court-date-sought-to-release-australian-born-baby-from-detention/#sthash.oCBAB7B1.dpuf (viewed 17 September 2014).
[651]The Hon S Morrison MP, Operation Sovereign Borders Joint Agency Taskforce address, transcript, (23 September 2013) At http://newsroom.customs.gov.au/channels/transcripts-operation-sovereign-borders/releases/transcript-press-conference-operation-sovereign-borders-update-a (viewed 22 September 2014).
[652]Department of Immigration and Border Protection, Submission No 45 to the National Inquiry into Children in Immigration Detention 2014, p 41. At https://www.humanrights.gov.au/sites/default/files/Submission%20No%2045%20-%20Department%20of%20Immigration%20and%20Border%20Protection.pdf (viewed 7 October 2014).
[653]Department of Immigration and Border Protection, Submission No 45 to the National Inquiry into Children in Immigration Detention 2014, pp 41-42. At https://www.humanrights.gov.au/sites/default/files/Submission%20No%2045%20-%20Department%20of%20Immigration%20and%20Border%20Protection.pdf (viewed 7 October 2014).
[654]Department of Immigration and Border Protection, Submission No 45 to the National Inquiry into Children in Immigration Detention 2014, p 38. At https://www.humanrights.gov.au/sites/default/files/Submission%20No%2045%20-%20Department%20of%20Immigration%20and%20Border%20Protection.pdf (viewed 7 October 2014).
[655]B Hall, ‘Minister wants boat people called illegals’, The Sydney Morning Herald, 20 October 2013 at www.smh.com.au/federal-politics/political-news/minister-wants-boat-people-called-illegals-20131019-2vtl0.html (viewed 31 August 2014).
[656]Department of Immigration and Border Protection, Submission No 45 to the National Inquiry into Children in Immigration Detention 2014, p 27. At https://www.humanrights.gov.au/sites/default/files/Submission%20No%2045%20-%20Department%20of%20Immigration%20and%20Border%20Protection.pdf (viewed 7 October 2014).
[657]Department of Immigration and Border Protection, Submission No 45 to the National Inquiry into Children in Immigration Detention 2014, p 27. At https://www.humanrights.gov.au/sites/default/files/Submission%20No%2045%20-%20Department%20of%20Immigration%20and%20Border%20Protection.pdf (viewed 7 October 2014).
[658]Minister for Immigration and Citizenship, ‘Bridging visas to be issued for boat arrivals’ (Media Release, 25 November 2011), At http://www.chrisbowen.net/media-centre/media-releases.do?newsId=5240 (viewed 30 September 2014).
[659]Bridging visas have been used for many years to allow, among others, asylum seekers who arrive by plane to live lawfully in the Australian community. See Prime Minister of Australia and Minister for Immigration and Citizenship, ‘Asylum seekers; Malaysia agreement; Commonwealth Ombudsman’ (Joint Press Conference, 13 October 2011), At http://www.minister.immi.gov.au/media/cb/2011/cb179299.htm (viewed 10 July 2012).
[660]Department of Immigration and Border Protection, Submission No 45 to the National Inquiry into Children in Immigration Detention 2014, p 29. At https://www.humanrights.gov.au/sites/default/files/Submission%20No%2045%20-%20Department%20of%20Immigration%20and%20Border%20Protection.pdf (viewed 7 October 2014).
[661]Department of Immigration and Border Protection, Submission No 45 to the National Inquiry into Children in Immigration Detention 2014, p 29. At https://www.humanrights.gov.au/sites/default/files/Submission%20No%2045%20-%20Department%20of%20Immigration%20and%20Border%20Protection.pdf (viewed 7 October 2014).
[662]Based on J Phillips and H Spinks, Boat arrivals in Australia since 1976, Parliamentary Library Research Paper (2013), p 22. At http://www.aph.gov.au/About_Parliament/Parliamentary_Departments/Parliam... (viewed 2 October 2014).
[663]Department of Immigration and Border Protection, Historical data on children in detention 2004 - 2014, Item 25, Document 25.1, Schedule 2, First Notice to Produce 31 March 2014.
[664]Department of Immigration and Border Protection, Historical data on children in detention 2004 - 2014, Item 25, Document 25.1, Schedule 2, First Notice to Produce 31 March 2014.
[665]Department of Immigration and Border Protection, Historical data on children in detention 2004 - 2014, Item 25, Document 25.1, Schedule 2, First Notice to Produce 31 March 2014.
[666]Department of Immigration and Border Protection, Immigration Detention and Community Statistics Summary: 31 August 2014 (2014), p 3. At http://www.immi.gov.au/managing-australias-borders/detention/_pdf/immigration-detention-statistics-august2014.pdf (viewed 17 September 2014).
[667]Department of Immigration and Citizenship, Submission to the Joint Select Committee on Australia’s Immigration Detention Network (September 2011), pp 213 and 224. At http://www.aph.gov.au/DocumentStore.ashx?id=f47478f9-3792-4b5f-9346-0569382e1560 (viewed 22 September 2014).`