CATCHWORDS TRADE PRACTICES - Consumer protection - Game of lotto - Coupon not validated in time for inclusion in draw - Coupon marked to select six winning numbers - Advertisements as to closing time of game - Whether advertisements misleading or deceptive or likely to mislead or deceive - Measure of damages - Loss of a chance. ° Trade Practices Act 1974 (Cth), s.52 Lotteries (Control) Act 1954 (W.A.), s.4(1) Lotto Act 1981 (W.A.) KERRY ELAINE TAYLOR & ANOR v. LOTTERIES COMMISSION No. WA G 55 of 1985 Neaves J. 29 July 1987 Canberra IN THE FEDERAL COURT OF AUSTRALIA ) ) WESTERN AUSTRALIA DISTRICT REGISTRY ) No. WA G 55 of 1985 ) ) GENERAL DIVISION BETWEEN : KERRY ELAINE TAYLOR and VERNON BARRY TAYLOR Applicants AND: LOTTERIES COMMISSION Respondent MINUTE OF ORDER JUDGE MAKING ORDER : Neaves J. DATE OF ORDER : 29 July 1987 WHERE MADE : Canberra THE COURT ORDERS THAT: 1. The application be dismissed. 2. The applicants pay the respondent's costs of the application. Note: Settlement and entry of orders is dealt with in Order 36 of the Federal Court Rules. ame eel ——— mere : oer seb IN THE FEDERAL COURT OF AUSTRALIA WESTERN AUSTRALIA DISTRICT REGISTRY No. WA G 55 of 1985 wee ww GENERAL DIVISION BETWEEN : KERRY ELAINE TAYLOR and VERNON BARRY TAYLOR Applicants AND: LOTTERIES COMMISSION Respondent CORAM: Neaves J. DATE: 29 July 1987 REASONS FOR JUDGMENT The game of lotto, as conducted in Western Australia in May 1984 by the Lotteries Commission ("the Commission") pursuant to the Lotto Act 1981 (W.A.) ("the Lotto Act"), provides the setting for this claim for damages under the Trade Practices Act 1974 (Cth) ("the Trade Practices Act"). The claim is brought by Kerry Elaine Taylor and her husband, Vernon Barry Taylor, ("the applicants") and is based on an allegation that the Commission, in trade or commerce, engaged in conduct that was misleading or deceptive or likely to mislead or deceive contrary to s.52 of the Trade Practices Act. The applicants claim that, by reason of that conduct on the part of the Commission, they were denied the opportunity to havea lotto coupon which had been prepared by Mrs Taylor on the morning of Thursday, 24 May 1984, included in those entitled to participate in the draw which took place on the night of ere ear cS oan ' Mey ' en yw a ee _ Vee a en ae wy gt crs tere cae, - - TOTTI npr rg 2. Saturday, 26 May 1984. The significance of being denied that opportunity arises from the circumstance that the six numbers selected in one of the ten games on the relevant coupon corresponded with the winning numbers drawn on that night. Before proceeding further, it is desirable to refer to the relevant statutory provisions under which the game of lotto was conducted in Western Australia at the relevant time. The Commission is, and was in 1984, constituted by s.5 of the Lotteries (Control) Act 1954 (W.A.) ("the Lotteries Act") as a body corporate. By s.4(1) of the Lotto Act, the Commission was authorised, subject to the Act, to conduct, promote, organize and operate games of lotto in order to raise money for charitable purposes as defined by the Lotteries Act. In the Lotto Act, a reference to a game of lotto was a reference to a form of game in which the subscribers to the game chose or attempted to forecast or select, from a group of numbers, a smaller group of numbers to be drawn on a random basis (s.3(3)). "Subscriber", in relation to a game of lotto, was defined to mean the person whose name appeared on the face of an entry in the space provided for the purpose (s.3(1)). "Entry form", in relation to a game of lotto, was defined to mean the entry form or coupon required by the rules to enable a person to enter or subscribe to the game of lotto (s.3(1)). For the purposes of conducting games of lotto, the Commission was empowered, with the approval of the Minister, to make arrangements with certain authorities of the other States and Territories of the Commonwealth for the joint conduct with paw any cee een wen Se eee ra eye eee ver . ' 3. those authorities of games of lotto and to conduct games of lotto jointly with those authorities (s.4(2)). Games of lotto were, in May 1984, conducted on a nation-wide basis pursuant to arrangements of that kind. By sub-s.4(3) the Commission was authorised to make rules relating to the conduct by itself of games of lotto. In evidence are the Lotto Rules revised April 1983 and these are said to be the rules which were in force in May 1984. It will become apparent, however, that in May 1984 the manner in which lotto was conducted differed somewhat from what was set out in the rules but nothing of significance turns on that in this case. For the purposes of the rules, lotto was described as a numbers game in which the subscriber was required to forecast or select six winning numbers from the numbers 1 to 40 inclusive (rules 1.2 and 2.3). Each lotto game was to be identified by a number (rule 2.2). The rules and the conditions on each lotto coupon were to apply to the drawing and to be binding on all the subscribers (rule 2.5). The rules were to be displayed at the office of the Commission, at any branch offices and at the place of business of all accredited agents. They might be made public by any other means (rule 2.6). An accredited agent was defined as a person authorised to accept and validate lotto coupons for the purpose of forwarding them to the Commission (rule 1.12). What was described as an "ordinary coupon" was a form containing 8 numbered blocks (games) each consisting of 40 squares numbered pars eee age oe ee ' ns eee ae mcr ens . . > le iat ell allie belerete es from 1 to 40 (rule 1.3). It is to be noted that the form of coupon used at the relevant time did not comply with this rule. The form used consisted of 10 such blocks. A subscriber was to make his forecast by marking the numbers of his choice with an "X" (rules 1.3 and 3.1). Each place of business at which coupons were sold was to have a machine for validating coupons. A coupon was validated by inserting the coupon in the machine which marked the coupon with the agent's identification number, the coupon number and the lotto game number (rule 1.8). Each coupon comprised three parts. After the coupon had been validated, the original part was to he forwarded to the Commission, the second part retained by the agent and the third part returned to the subscriber as evidence of his entry (rules 1.6 and 3.3). . Rule 7.1 provided as follows: "7.1 A Lotto coupon shall be accepted fora particular drawing if it arrives at the offices of the Commission within the time set out in Rule 12 of these Rules so as to enable amicrofilm of the original part to be made prior to the drawing of that particular Lotto. Once accepted, the coupon cannot be altered or withdrawn." All coupons accepted for a particular drawing were to he microfilmed under supervision and the microfilm delivered to the State Auditor-General's representative prior to the draw taking place (rule 7.2). A lotto coupon not completed and forwarded in accordance with the rules, or not microfilmed prior to the draw, was to be excluded from the drawing. A a ee oes waaay se wet owe pee + tL rt ee eee ny ee oe eee sot coupon lodged with an agent which was not head office of subsequently received was to be placed in the next available draw (rule 7.3) "7. 6 the Commission by the time aforesaid but - Rule 7.6 provided: Acceptance of the Lotto coupon shall not be deemed to have been effected until the original part of the coupon has been received at the head office of the Commission within the time provided under Rule 12 and clearly showing complete details of the imprint of the validating machine as provided in Rule 1.8." Rule 12 was in the following terms: "Time 12.1 12.2 12.3 Limits: Lotto coupons shall reach the offices of the Commission in sufficient time to permit a microfilm of the original part of the coupon to be made and complete Csici such formalities as may be required by the Auditor General's representative prior to the drawing of that particular Lotto. Lotto coupons shall be delivered to the office of the Commission by the prescribed time which shall be determined by the Commission from time to time and announced through the normal advertising and communication channels. Subscribers mailing Lotto coupons directly to the offices of the Commission shall do so in accordance with Rule 12.1." received at the ~— aint -_ mer core The rules provided' (rule 1.9) for the drawing to be made by the use of an electronically operated machine such that it would randomly select numbers from the numbers 1 to 40 inclusive. The first six numbers drawn were referred to ae a a 6. as the winning numbers (rule 8.1). In each lotto there were to be five prize winning divisions identified by the numbers 1 to 5 inclusive (rule 8.2). It is only necessary to refer for present purposes to the first of those divisions. The prize pool was to be 60% of the subscriptions received for each lotto and was to be distributed as to 30% to Division 1 (rule 9.1). To participate in the Division 1 prize pool, a subscriber was required to have selected the six winning numbers in one game (rule 8.2). Statistically his chance of doing so was one in 3.8 million. In 1984 the Commission operated its lotto business through its own branch office in the basement of a department store in Perth and through ~ a large number of accredited agents throughout the State. The evidence was that there were 275 such agents. The agents received from members of the public lotto coupons together with the subscriptions payable and validated the coupons in the manner to which reference has already been made. The agent was required, having balanced the coupons with the amount of subscriptions received and having ensured that the coupons were properly validated, to have the coupons delivered to the Commission's head office in Perth. Agents were informed by memorandum from the Commission that the validated coupons for week-end lotto should reach the Commission's head office by 11.00 a.m. (10.00 a.m. when so called daylight saving time was operating in the eastern States) on the Friday preceding the draw. In the case of some agencies, particularly those in the metropolitan area of Perth, the en tre 7H 7. Commission in fact arranged to collect the coupons from the agent by courier service early on each Friday morning. In the case of other agencies, the agent delivered the coupons to the Commission's office. The latter was the practice followed by the South Perth Newsagency, an accredited agent of the Commission, to which reference will hereafter be made. Mr William James Hartley, Acting Secretary of the Commission, gave evidence that the time of 11.00 a.m. on Friday was notified to the agents as the time for the receipt of coupons on the basis that it would allow sufficient time for all coupons received for the week-end draw to be microfilmed and the requirements of the Auditor-General to he satisfied prior to the draw. It is apparent from his evidence, however, that validated coupons received after that time would, if time permitted, be microfilmed and allowed to participate in the draw. Mr Hartley also said that it was a matter for each agent, having regard to his obligation to have the coupons validated by him delivered to the Commission in good time, to determine for himself the time beyond which he would not accept coupons for validation. Advertising material was distributed by the Commission to its accredited agents. The Material so distributed included a poster to the effect "Lotto closes here ...." the agent being able to complete the blank space by inserting the appropriate day and time. wy eens mee meee penn tee ae me net 8. The expression "closing time" in relation to the conduct of the game of week-end lotto appears to have been used ina variety of senses. So far as the Commission itself was concerned, the expression referred to the time at which the microfilm of the participating coupons had been prepared and delivered to the representative of the State Auditor-General. That was the time at which each game of lotto could properly be said to close. So far as an accredited agent was concerned, it was the time before which the validated coupons were to be delivered to the Commission. So far as a subscriber to the game was concerned, the reference was to the time up to which the agent with which the subscriber proposed to deal would accept coupons for validation. 'That time would be fixed by the agent concerned. In country areas of the State it would, of necessity, be earlier than in the case of agencies in the metropolitan area of Perth so as to allow sufficient time for the coupons to be delivered to the head office of the Commission. But even within a particular part of the metropolitan area, different agents might accept coupons up to a different time. Thus, in the case of an agent who did not trade ona Thursday night, the "closing" time might be 5.30 p.m. In the case of agents trading late on Thursday night, the time might be 9.00 p.m. In the case of a very limited number of agencies, at the most, so far as the evidence goes, two or three, which were open twenty-four hours a day, the "closing" time might be an early hour on Friday morning. The Commission's own sub-branch in the Perth city area to which reference has already been made was ee .- iran ' pny t ar ae oe —-~———- Te a ai ata 9. also prepared to validate coupons for the week-end draw from the opening of business until 10.00 or 11.00 a.m. on a Priday. For some time prior to May 1984 the Commission had conducted each week games of lotto known as week-end and mid-week lotto and that practice continued during May 1984. Week-end lotto was drawn on a Saturday night, mid-week lotto on a Wednesday night. The Lotto Rules to which I have referred make no reference to mid-week lotto but they were subsequently amended to do so. The deficiencies in the rules in this regard appear to be of no significance for present purposes. The week-end and mid-week drawings of lotto were identified by a single consecutive series of numbers, the week-end draws being identified by an odd number and the mid-week draws by an even number. The game which was drawn on Saturday, 26 May 1984 was identified by the number 297. The draw conducted on 26 May 1984 resulted in the six winning numbers being 1, 8, 20, 23, 33 and 34. The total prize pool for that draw was $6,392,121.56, the Division 1 prize pool amounting to $1,918,849.31. It appears that there were, provisionally, seven coupons which correctly selected those six winning numbers, a prize of $274,121.33 being payable in respect of each of those coupons. The evidence does not establish whether that provisional situation was subsequently confirmed. If the Division 1 prize pool had had to be distributed so as to 10. take account of the coupon the subject of this proceeding, a prize of $239,856.16 would have been payable in respect of each of the eight winning coupons. Both Mr and Mrs Taylor gave evidence. I accept that for some considerable time prior to May 1984 they had been subscribing to lotto as conducted by the Commission and had done so on amore or less regular basis. They had so subscribed since they went to reside at Collie in 1982 and they continued to do so when they moved to an address in South Perth in 1984, prior to May of that year. During the period they resided at Collie, Mr Taylor usually marked and lodged the coupons for lotto though it was sometimes done by Mrs Taylor. For some period of time, three coupons were marked, one in the name of Mr Taylor, one in the name of Mrs Taylor and one in the name of their son, Ryan Taylor. Mrs Taylor was apparently informed that, as the son was a minor, a prize could not be paid to him and the practice was thereafter followed of adding either Mr or Mrs Taylor's name to the coupon intended to be for the benefit of the son. When the family came to Perth, the same procedure as had been adopted at Collie continued. Sometimes Mr Taylor marked and lodged the coupons. On other occasions this was done by Mrs Taylor. Mr Taylor, in fact, marked and lodged the coupons for the week-end draws on 31 March and 14 April 1984. Those coupons were validated at an agency known —anqreny Set aaaan sateen aimee sent rr re ar a ee ll. as "Fred's Lucky Lottery" at the Garden City Shopping Centre in the suburb of Booragoon. However, Mr Taylor was away from Perth - he was working at a camp near Argyle - during part of April and for the whole of May 1984. Where Mr Taylor was working there was no convenient agency at which lotto coupons might be lodged for validation and, in consequence, Mrs Taylor attended to the lodging of the coupons in Perth. It was her habit, she said, to lodge the coupons at the South Perth Newsagency, Mends Street, South Perth and todo so ona "Thursday night (late shopping night). She agreed that she visited the South Perth Newsagency a number of times a week and said that, on occasions, she may have lodged a lotto coupon on a day of the week other than Thursday. She said 'that, at that time, the family did not enter mid-week lotto. Mrs Taylor maintained a file of the duplicate copies of the lotto coupons lodged by herself or her husband. She produced the duplicate copy of the coupon lodged for each of the week-end draws between Saturday, 17 March 1984 (Draw 277) and Saturday, 19 May 1984 (inclusive) with the exception of Saturday, 28 April 1984 (Draw 289). A search conducted by the Commission of lotto coupons delivered to it by the South Perth Newsagency and the agency known as "Fred's Lucky Lottery" for the draw on 28 April 1984 was made without locating a coupon lodged by either Mr or Mrs Taylor. Both Mr and Mrs Taylor said that they believed they had entered lotto every week and neither could offer an explanation why there was no coupon for that draw. 12. It was put to Mrs Taylor in cross-examination that she had forgotten to put in the coupon for draw 297, the draw here in question just as, so it was suggested, she had forgotten to put ina coupon for draw 289. Mrs Taylor denied the suggestion. Both Mr and Mrs Taylor said they understood that, at Collie, lotto coupons had to be lodged with the local agency by 3.00 p.m. (Mr Taylor) or 3.30 p.m. (Mrs Taylor) on the Wednesday preceding the Saturday on which the draw was to take place. At the South Perth Newsagency, the time was 9.00 p.m. on the Thursday preceding the draw. It may be noted that Gregory Charles Armstrong, the manager of the newsagency in May 1984, said that the closing time was 8.30 p.m. However, I shall accept for present purposes that it was 9.00 p.m. Mr and Mrs Taylor said that they believed the earlier closing time at the agency at Collie was referable to the greater distance to be covered in having the coupons delivered to the Commission's head office in sufficient time to enable them to participate in the draw. Mrs Taylor said that the information she had about the closing time at the South Perth Newsagency had been obtained from the agency itself and from the Commission's advertisements on television and in the press. There is evidence that posters were displayed at the South Perth Agency to the effect that "Lotto closes here at 9 p.m. on Thursday". In evidence are advertisements inserted by the Lotteries Commission in the "Mid Week Times" newspaper. The —— Be ee ore ey ' B ate Fay we Pemeeeen pee pees = 13. advertisements appeared in the issues of the newspaper published on 2, 16, 23 and 30 May 1984. The advertisement published on 2 May 1984 included the statement "Saturday Lotto Draw 291 Closing Thursday". In the issue of 23 May 1984 the advertisement included the statement "Saturday Lotto Draw 297 On sale now Closes Thursday". The advertisement published on 30 May 1984 contained similar wording except that it referred to Draw 299. The advertisement published on 16 May 1984 contained no reference to the closing date of Saturday Lotto. Mrs Taylor said she had seen advertisements similar to those in evidence but she was unable to identify any specific advertisement she had seen. Mrs Taylor also said that, when viewing the televised draw of week-end Iotto, she had heard advertisements referring to week-end lotto closing on Thursday or Thursday night. I an satisfied on the evidence that for a considerable time prior to May 1984 the advertisements used by the Commission in the Perth metropolitan area on radio and television and in the press stated that week-end Lotto closed on Thursday or Thursday night and did not specify any particular hour. It is true that for some time in 1981 the advertisements used by the Commission in the Perth metropolitan area did refer to the closing time as 9.00 p.m. on the Thursday night preceding the draw but I am satisfied that that had not been the form of advertising in use after 1981. Poy ts were g age sey ere r 14. It is convenient, at this point, to refer to the events of Thursday, 24 May 1984. At that time Mrs Taylor was employed as a part-time tutor at the Western Australian Institute of Technology at Bentley, another suburb of Perth. She normally worked a full day on Tuesday, half a day on Wednesday and at other times on request from the Institute. She was required to attend the Institute on Thursday, 24 May 1984, her expectation being that she would work from 8.30 p.m. to 4.30 p.m. Mrs Taylor's evidence was that she completed a lotto coupon at home before leaving for her place of employment intending to go shopping after work when she would lodge the coupon for validating at the South Perth Newsagency in accordance with her normal practice. Having selected and marked six numbers in 'each of the games contained on the coupon, she inserted in the space reserved for the name and address of the subscriber the words and figures "Barry and Ryan Taylor, 29 Hopetoun St., Sth. Perth". In the events which happened, Mrs Taylor was required to work until approximately 11.00 p.m. on that day without any break for an evening meal. In the expectation that she would leave her place of employment at about 4.30 pem., she had taken no steps to lodge the lotto coupon during the day. When she was required to work after that time she became concerned about lodging the coupon. She said that she was not aware of any agency in the vicinity of the Institute where she might have lodged the coupon but that, even if she had known of such an agency, it would have a > ' oO Cope se un- RO renee re See ee pe ng et ran ' t . . > ' - t an) * an wpe es 15. been of no assistance to her as she was unable to leave her employment at any time between 4.30 p.m. and 11.00 p.m. on that day. She further said that her understanding was that the closing time for the Saturday draw of lotto was 9.00 p.m. on Thursday night. She made no enquiries whether the coupon could be validated at a later hour on the Thursday or on the Friday and she took no steps to validate it. Subsequently she made enquiries in that regard and ascertained that a few agencies were open later than 9.00 p.m. ona Thursday and that one ina nearby suburb of Victoria Park was open for business 24 hours a day. The crucial question, of course, is not whether that agency was open after 9.00 p.m. on a Thursday but whether it would after that time accept for validatidn coupons for the Saturday draw. The evidence establishes that it would do so. It may be inferred that it would have done so on Thursday, 24 May 1984. Mrs Taylor said that, had she been aware that the agency at Victoria Park was open, she would have called there on her way home from her employment late on the Thursday night and validated the coupon. IT accept that it was Mrs Taylor's belief that, in order to have a coupon participate in the week-end draw, the coupon had to be validated by 9.00 p.m. on the Thursday preceding the draw. This is reflected in her evidence that once 9.00 p.m. came on Thursday, 24 May 1984, she gave up any idea of validating the coupon she had completed that morning. Her case is that she was led to that belief by the conduct of the Commission in advertising on television and weet eee trie mane re er ee es an am Plone an Ponte eens one ween eee en . 2 . onan ae ne ce eens see ee rs ee ne oe ero te wee 16. in the press the closing time of week-end lotto, conduct which is alleged to be misleading or deceptive or likely to Mislead or deceive. There was nothing misleading or desceptive in the advertising material displayed at the South Perth Newsagency. That material stated correctly that the closing time for week-end lotto at that agency was 9.00 p.m. on Thursday. It said mo more andno less. It gave no information as to the closing times of other agencies. It was not its concern to do so. The question then is whether the advertisements published on hbehaif of the Commission in the metropolitan area of Perth on television and in the press were misleading or deceptive or likely to misiead or deceive. I have already said that those advertisements relevantly were confined to a statement to the effect that week-end lotto closed on Thursday or on Thursday night. The references in the advertisements to lotto "closing" were clearly references to the situation obtaining at the agencies where intending subscribers might validate their coupons. The only respect in which the advertisements are said to be misleading or defective or to be likely to mislead or deceive is in their failure to state that the Commission's branch office and the two or three agencies which would do so would receive and validate coupons for the week-end draw for a period on the Friday morning preceding oe eaanaem etal wr a.tf fi me A ore, or : , tee ome ee aye eee woe 17. the draw. The advertisements could not be said to be misleading or deceptive in so far as those two or three agencies would receive and validate coupons up to midnight on the Thursday night. On the other hand, to have advertised, as the applicants suggested, that week-end lotto closed at 11.00 a.m. on Friday would clearly have been misleading. To have done so may well have resulted in many intending subscribers presenting their coupons at their local agency on Friday morning only to be told that, so far as that agency was concerned, week-end lotto had closed the previous day. The content of the advertisements must, I think, be looked at ina practical way. The Commission was concerned to have members of the public become subscribers to lotto and to exhort those who were already subscribers to continue to be such. The latter were enjoined to continue to subscribe lest they suffer the same experience as Mr and Mrs Taylor. The advertisements, in speaking of the closing time, were clearly intending to convey a general message to those to whom the advertisements were addressed. It would not be reasonable to expect the closing time at each individual agency to be stated. It would be equally unreal to say that, because it was not practicable to state the closing time at each agency, no reference should have been made at all to a closing time. Looking at the matter in its context, I am not satisfied that to advertise in the manner complained of by "4 on a ise pragae, 18. the applicants was to engage in conduct that was misleading or deceptive or likely to mislead or deceive andso in contravention of s.52 of the Trade Practices Act. I am also not satisfied on the evidence that Mrs Taylor's failure to have the coupon validated in time was due to her reliance upon the advertisements. Her evidence was that, had she been aware that the agency at Victoria Park was open, she would have called there on her way home from her employment late on the Thursday night. The real cause of her failing to have the coupon validated was her ignorance of the circumstance that the agency at Victoria Park was prepared to receive and validate coupons up to midnight on the Thursday night and beyond. I am unable to conclude that her ignorance in that regard was due in any way to the content of the advertising material published on behalf of the Commission. Had I reached a different conclusion upon the matters referred to above, a further difficulty would have stood in the way of the applicants. Clearly Mrs Taylor suffered no damage herself - she was not named as a subscriber on the coupon. Further, it would appear, on the evidence, that the coupon was intended to be for the benefit of Mr and Mrs Taylor's infant son but he is not joined asa party. Whether, in those circumstances, Mr Taylor could establish damage entitling him to an award is an open question which I need not now address. sree mene aye eg ey er . wo ' ' . oo te en oe ns in ams mite waht os 19. In the light of the conclusion to which [I have come, it is umnecessary to consider the measure of damages in a case such as this. I should, however, say that, in my view, the damages would not reflect the share of the Division 1 prize pool to which the coupon would have entitled the subscriber had it been included in the draw. Rather, the quantum of damages awarded would reflect the loss of the chance (statistically one in 3.8 million) to participate in the draw. Lest it be thought that the matter has been overlooked, I should add that it was not disputed at the hearing that the Commission was a trading corporation or that, in conducting the game of lotto, it was engaged in trade or commerce. In the result, the application is dismissed. The applicants must pay the Commission's costs of the application. I certify that this and the preceding 18 pages are a true copy of the Reasons for Judgment herein of the Honourable Mr Justice Neaves. Associate Dated: 29 July 1987 = ee wey eye mater ee rear ? v= I ee = me, Counsel for the applicants Solicitors for the applicants Counsel for the respondents Solicitors for the respondents Dates of hearing 20. Mr D.R. Clyne Paternoster & Chan Mr R.E. Birmingham Kennedy & Hyman 18, 19 May 1987 OTS ere mt pe ee Se wee = H rect ro TT aT ae oad : :