To what extent can the conduct of the British government be conceptualised as complicity in genocide against the Palestinian population, through the lens of state crime scholarship?
Essay by: Hashir Hussain, ISCI Researcher and Master of Laws student at Queen Mary University of London
1. Introduction
Allegations that Palestinians are facing genocidal violence have become increasingly prominent in global discourse. International organisations, legal experts, and UN officials have described the scale and nature of harm in Gaza reaching the threshold of genocide.[1] Alongside this, attention has turned to the role of international actors in enabling or failing to prevent these harms. The United Kingdom, given its ongoing military, diplomatic, and political ties with Israel, faces growing scrutiny for its possible complicity.[2]
This essay explores the potential complicity of the British government in genocidal violence against the Palestinian population by drawing on state crime scholarship. It adopts an analytical framework focused on harm, enablement, omission, and the governance of knowledge to assess how responsibility for mass violence is produced and sustained. While legal frameworks offer essential standards for adjudicating genocide and state responsibility, they are not always designed to capture the broader political and institutional conditions through which atrocity is made possible.
A state crime lens allows for a fuller account of how liberal democracies may participate in extreme violence by sustaining the political, material, and discursive conditions under which such violence can occur and persist.
This essay argues that the United Kingdom’s conduct constitutes complicity in genocide insofar as its material support, diplomatic protection, and discursive management of responsibility have sustained the political and military conditions under which genocidal violence against Palestinians has been able to occur without effective restraint or prevention.
The essay proceeds in four stages. First, it briefly sets out the theory used in the analysis, outlining legal and criminological understandings of genocide, key concepts from state crime theory, and Stanley Cohen’s framework of denial. Second, it assesses whether the violence against Palestinians meets criminological indicators of genocidal harm and intent. Third, it examines the United Kingdom’s conduct, focusing on material and political enabling of genocidal conduct. Finally, it analyses how British political discourse has managed knowledge of harm in ways that limit responsibility and suspend duties of prevention.
2. Tools for Analysis
2.1 What is Genocide?
The UN Genocide Convention defines genocide as acts committed with intent to destroy, in whole or in part, a national, ethnical, racial, or religious group.[3] These acts include killing members of the group, causing serious bodily or mental harm, and deliberately inflicting conditions to bring about physical destruction. This definition remains the authoritative legal framework for determining genocide under international law.
However, the legal framework is constrained by the requirement to prove specific intent and the need for formal judicial processes.[4] These limits often delay recognition and response until after large-scale harm has occurred. For example, despite extensive evidence of mass killing, displacement, and destruction targeting the Rohingya population in Myanmar, no legal finding of genocide has been reached years after the violence began. During this period, states continued to maintain arms sales and diplomatic relations with Myanmar, without facing legal consequences under the Genocide Convention.[5]
Criminological approaches respond to these limitations by focusing on patterns of harm and responsibility rather than definitive legal findings. State crime scholarship defines genocide as the systematic, one-sided mass killing of individuals based on group identity. Drawing on this framework, this essay assesses genocidal violence through scale, targeting, and foreseeability.[6] This approach allows for the analysis of both direct perpetrators and external actors that facilitate or tolerate mass violence.
Accordingly, this essay adopts a hybrid approach. While the legal definition of genocide remains relevant, a criminological framework is necessary to evaluate ongoing harm and to examine how third-party states may contribute to genocidal violence through indirect but foreseeable involvement.
2.2 State Crime and Cohen’s Culture of Denial
This essay draws on the criminological frameworks of state crime and Cohen’s theory of denial to analyse the United Kingdom’s potential role in enabling genocidal violence. These approaches focus on the production of harm and the management of responsibility, offering tools to examine how states contribute to mass atrocity through action, inaction, or discourse.
Green and Ward define state crime as “state organisational deviance that involves the violation of human rights.” [7] This definition shifts attention away from formal legal rules and towards the institutional and policy-driven practices through which states cause or permit serious harm. In this essay, state crime theory provides a framework for assessing genocidal complicity by analysing how states contribute to mass violence through political and material enabling practices, as well as systemic support, even when they are not direct perpetrators.
Cohen’s theory complements this by examining how states and societies construct denial in response to mass harm.[8] He identifies different modes of denial, including literal, interpretive, and implicatory, which shape how knowledge is acknowledged, reframed, or displaced. These mechanisms are active strategies that allow states to continue their involvement while avoiding political or legal accountability. This framework is used to assess how British political discourse responds to allegations of genocide and how it enables continued support for policies that produce or sustain harm.
These frameworks form the basis for examining whether the violence against Palestinians meets the indicators of genocidal harm and intent as explored in the next section.
3. Assessing Genocidal Violence and Intent in Palestine
Before the United Kingdom’s conduct can be assessed, it is necessary to determine whether genocidal violence constitutes an analytically valid framework for understanding the acts against Palestinians, independent of any final determination by an international court. Applying the criminological approach set out in Section 2, this section assesses whether the violence in Palestine exhibits patterns of scale, targeting, and foreseeability associated with genocidal harm and intent.[9]It argues that these indicators are present and that genocidal violence therefore provides an appropriate analytical framework for assessing potential third-party complicity.
3.1 Scale of Harm
Genocide scholarship conceptualises scale as central to identifying genocidal violence because group destruction requires cumulative harm, over or incidental civilian suffering.[10] The violence in Palestine meets this threshold. More than 52,000 Palestinians have been killed and over 117,000 injured. In 36 documented attacks, all those killed were women and children, indicating extensive civilian harm.[11] The magnitude of death and injury demonstrates violence operating at a level that affects the population as a whole.
Scale is further evidenced through the systematic destruction of conditions essential to life. Thirty-one of Gaza’s thirty-six hospitals have been bombed, and approximately 89 per cent of water and sanitation infrastructure has been damaged.[12]These actions have dismantled the basic conditions necessary for survival, exposing civilians to life-threatening health crises. The cumulative effect of mass killing and the collapse of critical infrastructure demonstrates violence operating at a scale capable of producing group destruction.
3.2 Targeting of the Group
Similarly, targeting is used in genocide scholarship to analyse whether violence is directed at a group, as genocide is defined by the patterned exposure of a defined population to lethal or life-destroying conditions on the basis of identity.[13] In Palestine, patterns of violence reveal sustained harm directed at the Palestinian civilian population rather than at discrete military objectives. The repeated killing of women and children, combined with attacks on hospitals, schools, refugee camps, and residential areas, demonstrates that violence has been consistently directed at civilian life.[14]
The recurrence of attacks on such locations indicates that the harm is neither incidental nor accidental. Hence, the patterns observed in Palestine demonstrate targeting that operates at the level of the group.
3.3 Foreseeability and Inference of Intent
Within genocide scholarship, intent may be inferred where mass harm is foreseeable and sustained despite repeated warnings.[15] Intent is inferred where harmful conduct persists in the face of foreseeable group destruction. Throughout the conflict, humanitarian organisations repeatedly identified the civilian consequences of destroying hospitals, water systems, and shelters. These warnings rendered the resulting harm foreseeable.[16]
Despite this, similar sites continued to be targeted. The continuation of these practices indicates that the impact on civilians was anticipated and accepted. Official rhetoric reinforces this inference. Statements by senior Israeli officials referring to Palestinians as “human animals,” declaring a “complete siege,” and denying distinctions between civilians and Hamas frame the population as a collective threat.[17] This discourse legitimises violence against the group and normalises practices that are intended to produce group-based harm.
Taken together, the scale of harm inflicted upon Palestinians, the consistent targeting of civilian life, and the continuation of these practices despite foreseeable consequences, reinforced by dehumanising official rhetoric, establish a coherent pattern of violence directed at Palestinians as a group. These elements satisfy the indicators of genocidal harm and intent identified in state crime scholarship.[18] Genocidal violence therefore constitutes an analytically appropriate framework for assessing whether the conduct of external states, including the United Kingdom, may amount to complicity in sustaining or enabling such violence.
4. Assessing the UK’s Conduct
Having established genocidal violence as the appropriate framework for understanding the situation in Palestine, this section examines how the United Kingdom has contributed to sustaining that harm. It focuses on two interconnected forms of enabling: material support, through arms exports; and political support, through diplomatic protection. The analysis considers how these actions have reinforced the perpetrating state’s capacity to carry out large-scale violence, and how the UK’s failure to take available preventative measures has allowed that violence to continue. Together, these forms of support constitute meaningful involvement in the production and maintenance of genocidal violence.
4.1 Material Enabling through Arms Trade
UK arms export licensing decisions materially enabled Israel’s capacity to conduct military operations during a period of foreseeable mass civilian harm in Gaza as these decisions sustained the operational conditions under which widespread destruction and civilian killing continued.
Following the escalation of violence in October 2023, the UK government conducted multiple reviews of existing and pending arms export licences and repeatedly declined to suspend or revoke them.[19] Parliamentary evidence confirms that these licences covered components for combat aircraft, drones, armoured vehicles, naval systems, and targeting equipment. Several of these items were internally identified as most likely to be used in offensive operations in Gaza.[20]By maintaining these licences, the UK preserved an ongoing supply relationship at a time when Israeli military activity was intensifying.
Arms transfers facilitate harm by reinforcing a recipient state’s capacity to sustain military action over time. Within state crime scholarship, regulatory and administrative decisions, such as export licensing, can function as mechanisms of complicity by enabling harmful outcomes through lawful governance processes.[21] As Stavrianakis explains, arms exports embed supplier states within the material architecture of warfare by sustaining military capability rather than merely transferring individual weapons.[22] The UK’s continued authorisation of exports therefore contributed to the persistence of military operations that produced extensive civilian harm.
The foreseeability of this harm was well established when these decisions were taken. As demonstrated in Section 3, by late 2023 there was extensive and credible reporting of mass civilian casualties, destruction of essential infrastructure, and patterns of conduct raising serious concerns under international humanitarian law.[23] Government assessments acknowledged these risks while concluding that Israel remained broadly committed to compliance.[24] Foreseeability is central to assessing responsibility, because the decision to continue military support in the face of known mass harm signals acceptance of its consequences; where the harm is systemic and sustained, complicity arises from maintaining the enabling conditions, even without tracing individual exported items to specific attacks.
The UK government has defended its position by emphasising the formal legality of its export control regime and the absence of a definitive legal determination of wrongdoing. This position was reflected in R (Al‑Haq) v Secretary of State for International Trade, where the High Court declined to intervene, deferring to executive assessments and treating aspects of the licensing framework as non‑justiciable.[25] Rather than resolving the substantive issue, the case illustrates a core critique in state crime scholarship: that procedural compliance and internal risk assessments allow states to present harmful decisions as lawful and controlled, thereby obscuring how those decisions materially enable mass violence.[26]
Accordingly, the UK’s continued authorisation of arms exports during a period of foreseeable civilian destruction sustained Israel’s military capacity and contributed to the conditions under which genocidal violence persisted. On this basis, arms export policy constitutes a material form of complicity, notwithstanding the absence of formal legal attribution.
4.2 Political Enabling through Diplomatic Shielding
Similarly, UK’s diplomatic conduct during the Gaza conflict politically enabled genocidal violence by shaping an international environment in which mass violence could continue without meaningful constraint. Unlike material support, which sustains physical capacity, diplomatic enabling involves limiting political consequences and weakening mechanisms of accountability. As Cohen explains, state responses that deny, minimise, or reframe harm, function to neutralise accountability, reducing restraint on continued violence even in the absence of direct material support.[27]
The UK’s abstentions in the UN Security Council illustrate this dynamic. As a permanent member, the UK holds significant institutional power to influence international responses. During multiple votes in 2023 and 2024, the UK declined to support resolutions calling for an immediate ceasefire, opting instead for language centred on humanitarian pauses.[28] These abstentions, although not vetoes, contributed to the Council’s inability to impose binding limits on Israeli military operations. While abstaining does not indicate active opposition, it signals a refusal to endorse enforcement. From an enabling perspective, this failure to support meaningful constraint allowed violence to escalate in the absence of coordinated international pressure.
This pattern reflects broader theories on patron–client dynamics in atrocity contexts. Nanlohy’s analysis shows that external patrons can enable violence by signalling impunity through silence or inaction.[29] Diplomatic behaviour that avoids criticism or declines to impose costs creates an “opportunity structure” where violence is politically feasible. The UK’s conduct aligns with this model, as it withheld pressure that could have altered the calculus of continued military operations.
The UK’s response to the International Court of Justice’s ruling in South Africa v Israel (2024) further demonstrates this effect.[30] Although the Court issued provisional measures citing a plausible risk of genocide, the UK did not recalibrate its diplomatic stance. Public statements acknowledged the Court’s authority but stressed that a ceasefire was not mandated, and no new diplomatic measures were proposed.[31] This response neutralised the judgment’s practical significance, limiting its impact as a tool for restraint.
Government justifications have emphasised the value of strategic alliances, balanced engagement, and the preservation of diplomatic access, on the basis that sustained dialogue promotes stability and moderates conduct.[32] This rationale assumes that engagement retains restraining capacity even where no conditions or consequences are attached. In contexts of sustained and well-documented mass civilian harm, however, unconditioned engagement operates differently. It prioritises diplomatic continuity over accountability and signals that the costs of continued violence are limited. Where a state maintains alliances without recalibrating support or imposing restraint, engagement functions as a source of political protection, allowing harmful conduct to proceed without jeopardising legitimacy or strategic relationships. In this way, strategic alliance ceases to be neutral diplomacy and becomes a mechanism through which impunity is preserved.
Ultimately, diplomatic tolerance in this context operates as tacit approval through its effects rather than its stated intent. Repeated abstentions from ceasefire resolutions, the refusal to support enforcement mechanisms, and the narrowing of the political significance of ICJ provisional measures collectively reduced the likelihood of external restraint. These practices communicated that Israeli military conduct would not generate meaningful diplomatic consequences, either bilaterally or multilaterally.
Accordingly, UK diplomatic conduct constitutes political enabling of genocide as it preserved the international conditions in which widespread civilian harm in Gaza was allowed to continue, reinforcing the broader architecture of complicity analysed in this essay.
5. Managing Knowledge and Responsibility
The United Kingdom’s material and political enabling of violence in Gaza have been sustained through the strategic governance of knowledge and responsibility. This section argues that official discourse has functioned as a form of enabling action, shaping the interpretation of harm and deflecting the obligations it generates. By controlling the political meaning of civilian suffering and systematically deferring responsibility, UK discourse has preserved the aforementioned permissive conditions under which genocidal violence persisted. Drawing on Cohen’s theory of denial this analysis demonstrates how interpretive and implicatory denial operate as a governance practice that enables complicity.
UK official responses display a pattern of acknowledgement neutered by strategic restraint. Government statements recognise the humanitarian catastrophe and affirm international legal authorities, including the ICJ’s provisional measures in South Africa v Israel (2024).[33] These acknowledgements, however, are systematically voided of corrective force: the ICJ ruling is narrowed to a non-mandate for a ceasefire; and Israel’s right to self-defence is repeatedly underscored.[34] In practice, this translates into abstaining from binding ceasefire resolutions while supporting humanitarian pauses. The government defends this as measured, lawful statecraft, arguing that quiet diplomacy and procedural respect are the most effective ways to influence an ally and secure stability.
This defence is an illustration of interpretive denial. Civilian harm is acknowledged yet reframed, from potential evidence of a coordinated campaign to tragic inevitable outcomes of war. As Dunkelberg shows, atrocities are often obscured through legalistic fragmentation.[35] By treating genocide solely as a matter for future judicial determination, UK discourse actively postpones the point at which facts compel preventative action. The government’s proceduralism is thus the very mechanism of this denial, converting a duty to prevent into a duty to await verification.
This leads to implicatory denial, which manages responsibility. The UK positions itself as a concerned but constrained actor, displacing the obligation to act onto courts, multilateral bodies, or the parties themselves. This constructs an identity of a passive observer, even as material and diplomatic support continues. As Pervez’s analysis of institutional bystandership argues, such framing presents omission as procedural necessity and restraint as responsible diplomacy.[36]The pragmatic rationale, therefore, functions to organise irresponsibility, acknowledging violence while evading the costly actions that acknowledgment should trigger.
These denials are active instruments of governance that enable continued violence. They stabilise the architecture of complicity by preventing acknowledged harm from generating political contradiction. Once arms exports and diplomatic shielding were in place, this governance of knowledge ensured they could continue without appearing inconsistent with professed values. By narrowing the meaning of genocide, deferring to slow judicial process, and reframing inaction as prudence, the UK maintained an environment where violence faced diminished constraint.
Furthermore, this also reflects a historical pattern examined in works like Britain and Genocide, wherein British involvement in mass violence is sustained through strategic legalism and reputational insulation.[37] Within state crime theory, such denial is a core technique of neutralisation, allowing states to facilitate harm while negating responsibility.[38]
In conclusion, the UK’s complicity in Gaza has been actively governed through knowledge. Here, interpretive and implicatory operated as enabling mechanisms that protected material and political support from disruption. By controlling how harm was recognised and what responsibilities followed, UK discourse lessened international constraints on Israel’s campaign and reduced the political cost of its own enabling actions. The government’s defence of proceduralism exemplifies it by demonstrating how denial is institutionalised. This governance of knowledge therefore constitutes the third pillar of the complicity analysed in this essay.
6. Conclusion
This essay has examined UK complicity through a state crime lens to determine how a liberal democracy can become functionally integrated into genocide without direct perpetration. By analysing arms exports as material reinforcement, diplomatic shielding as political enablement, and discursive denial as a mechanism of responsibility evasion, the evidence affirms that the UK’s role has been active, patterned, and facilitative.
The analysis demonstrates that UK conduct satisfies the criminological criteria of complicity within state crime scholarship. The continuation of arms transfers despite foreseeability of mass harm, abstentions from binding international restraint, and the strategic reframing of harm through interpretive and implicatory denial collectively constitute an architecture of enablement. This structure is institutionalised, operating through routine instruments of statecraft: trade agreements, alliance diplomacy, and public justification.
The significance of this finding extends beyond the UK–Israel case. It shows how liberal democracies, through proceduralized and rationalised means, can sustain atrocity while maintaining plausible deniability. This exposes a central dilemma in international atrocity prevention: that the mechanisms of enablement legal arms sales, UN abstention, technical adherence to process are often the same mechanisms through which states signal legitimacy and responsibility. In effect, complicity becomes bureaucratised, obscured within the everyday functions of government.
Therefore, the British government’s conduct is not merely diplomatically supportive but structurally complicit. It has materially fuelled, politically protected, and discursively obscured genocidal violence, embedding itself within the conditions of its continuation. This confirms a core proposition of state crime theory: that responsibility for mass atrocity cannot be confined to the principal perpetrator but must be traced to the wider networks of material, political, and epistemic support that render such violence possible and permissible.
Bibliography
Table of Cases:
International
Application of the Convention on the Prevention and Punishment of the Crime of Genocide (South Africa v Israel), Provisional Measures (Order) [2024] ICJ Rep (26 January 2024)
UK
R (Al-Haq) v Secretary of State for International Trade [2025] EWHC 1615 (Admin)
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Amnesty International UK, ‘Global Complicity, UK Involvement: Profiting from Atrocity and Enabling Israel’s Genocide and Apartheid – New Briefing’ (Press Release, 18 September 2025) https://www.amnesty.org.uk/press-releases/global-complicity-uk-involvement-profiting-atrocity-and-enabling-israels-genocide accessed 9 December 2025
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Cohen S, States of Denial: Knowing about Atrocities and Suffering (Polity 2001) ch 1
Convention on the Prevention and Punishment of the Crime of Genocide (adopted 9 December 1948, entered into force 12 January 1951) 78 UNTS 277
Fichtelberg A, ‘Justice and Genocide’ (2018) 12(2) Genocide Studies International 227
Green P and Ward T, State Crime: Governments, Violence and Corruption (Pluto Press 2004) 166
Gurmendi Dunkelberg A, ‘How to Hide a Genocide: Modern/Colonial International Law and the Construction of Impunity’ (2025) Journal of Genocide Research 1–24
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[1] Francesca Albanese, Genocide as Colonial Erasure: Report of the UN Special Rapporteur on the Situation of Human Rights in the Palestinian Territories Occupied since 1967 (1 October 2024) https://www.un.org/unispal/document/genocide-as-colonial-erasure-report-francesca-albanese-01oct24/ accessed 9 December 2025.
[2] Amnesty International UK, ‘Global Complicity, UK Involvement: Profiting from Atrocity and Enabling Israel’s Genocide and Apartheid – New Briefing’ (Press Release, 18 September 2025) https://www.amnesty.org.uk/press-releases/global-complicity-uk-involvement-profiting-atrocity-and-enabling-israels-genocide accessed 9 December 2025.
[3] Convention on the Prevention and Punishment of the Crime of Genocide (adopted 9 December 1948, entered into force 12 January 1951) 78 UNTS 277.
[4] Aaron Fichtelberg, ‘Justice and Genocide’ (2018) 12(2) Genocide Studies International 227.
[5] Ashley S Kinseth, ‘The Trouble of Proving “Genocidal Intent”: The Modern Rohingya Crisis in Historical and Political Context’ (2019) 51 Journal of International Law & Policy Online Forum 1.
[6] Penny Green and Tony Ward, State Crime: Governments, Violence and Corruption (Pluto Press 2004) 166.
[7] Green and Ward (n 6) 2.
[8] Stanley Cohen, States of Denial: Knowing about Atrocities and Suffering (Polity 2001) ch 1.
[9] See section 2.1
[10] Martin Shaw, What Is Genocide? (Polity Press 2007) 132.
[11] UN Office for the Coordination of Humanitarian Affairs – Occupied Palestinian Territory, Casualties (OCHAoPt) https://www.ochaopt.org/data/casualties accessed 19 December 2025.
[12] Gaza war infrastructure damage and destruction” Statista https://www.statista.com/statistics/1616491/gaza-war-infrastructure-damage-destruction/ accessed 21 December 2025.
[13] Shaw (n 10) 132
[14] UN Office (n 9) and Statista (n 10).
[15] Shaw (n 10) 85
[16] United Nations Office of the High Commissioner for Human Rights, Attacks on hospitals during the escalation of hostilities in Gaza (OHCHR, 31 December 2024) 21.
[17] United States Congress, Congressional Record, vol 170, no 49 (20 March 2024) S2479 (statement quoting remarks of Israeli Defence Minister Yoav Gallant).
[18] See Section 2.1
[19] Louisa Brooke-Holland, UK Arms Exports to Israel (House of Commons Library Research Briefing No 09964, 8 January 2025).
[20] ibid.
[21] Green and Ward (n 6) 204-206.
[22] Anna Stavrianakis, ‘When “Peace and Security” Means Arming Genocide’ (2025) 96 Political Quarterly 610–618.
[23] See Section 3.3
[24] Goddy U Osimen, Valerie E Okpere, John Ehiabhi Anegbode and Mohadapwa H Wonosikou, ‘An Assessment of the Impact of UK Arms Export in the Israel–Hamas Conflict and the Complicit in War Crimes’ (2025) 9(4) Wukari International Studies Journal 263–276.
[25] [2025] EWHC 1615
[26] Stavrianakis (n 17).
[27] Cohen (n 8).
[28] UN Security Council, Security Council fails to adopt draft resolution on Gaza due to veto by permanent member (Press Release, SC/15450, 18 October 2023); UN Security Council, Security Council fails to adopt resolution demanding immediate humanitarian ceasefire in Gaza (Press Release, SC/15519, 8 December 2023); UN Security Council, Security Council fails to adopt draft resolution demanding immediate ceasefire in Gaza (Press Release, SC/15595, 20 February 2024).
[29] Sascha Nanlohy, ‘Geopolitics and Genocide: Patron Interests, Client Crises, and Realpolitik’ (2024) 9(1) Journal of Global Security Studies ogad 023.
[30] Application of the Convention on the Prevention and Punishment of the Crime of Genocide (South Africa v Israel), Provisional Measures (Order) [2024] ICJ Rep (26 January 2024).
[31] UK Foreign, Commonwealth and Development Office, Statement on the interim ICJ ruling in South Africa v Israel (26 January 2024).
[32] Dame Barbara Woodward, ‘A diplomatic solution is in the interests of all concerned. Even now, it is not out of reach’: UK statement at the UN Security Council (Statement at emergency UN Security Council meeting on Iran, 20 June 2025).
[33] South Africa v Isreal (n 25).
[34] UKFCDO (n 26).
[35] Alonso Gurmendi Dunkelberg, ‘How to Hide a Genocide: Modern/Colonial International Law and the Construction of Impunity’ (2025) Journal of Genocide Research 1–24.
[36] Aneeza Pervez, ‘Witnessing Silence: The Palestinian Genocide, Institutional Complicity, and the Politics of Knowledge’ (2025) Globalisation, Societies and Education 1–18.
[37] Martin Shaw, ‘Britain and Genocide: Historical and Contemporary Parameters of National Responsibility’ (2011) 37(5) Review of International Studies 2417–2438.
[38] Green and Ward (n 6) 178-181.