THE PROFESSIONALIZATION OF COMMUNITY INTERPRETING
Originally published in Global Vision, Proceedings of the 37th Annual Conference of the American Translators Association, Muriel M. Jérôme-O’Keefe, ed., John Benjamins, pub., 1996.

by Holly Mikkelson
Monterey Institute of International Studies

Keywords: Community Interpreting, Court Interpreting, Medical Interpreting, Professionalization, Professional Associations, Client Education, Interpreter Training, Working Conditions

Abstract: Community interpreting, which includes court and medical interpreting, is following the typical pattern of a profession in its infancy. In the beginning it is characterized by a lack of standards for training and practice, disorganization and disunity among practitioners, a lack of recognition of the profession among clients and the public, and poor working conditions. These circumstances improve as practitioners unite and form professional associations to impose discipline and standardization and to achieve recognition through education, legislation and public relations. This paper will define the terms "community interpreting" and "profession," present a comparative analysis of community interpreting and other professions, and recommend a course of action to promote the profession in the medium and long terms.

1. DEFINITION OF TERMS

1.1 Community Interpreting

Community interpreting has been defined in a variety of ways, ranging from the kind of interpreting that takes place informally in neighborhoods and community agencies, and is performed by amateurs or ad hoc interpreters (Ref. 1, p. 29), to a more formal occupation involving practitioners with some training in medical, legal, or social service interpreting (Ref. 2). Roda Roberts (Ref. 3) provides a more detailed discussion of these definitions. This paper employs the definition found in the announcement of the First International Conference on Interpreting in Legal, Health and Social Service Settings:

Community Interpreting enables people who are not fluent speakers of the official language(s) of the country to communicate with the providers of public services so as to facilitate full and equal access to legal, health, education, government, and social services (Ref. 4).

Thus, community interpreting is distinguished from other types of interpreting, such as conference or escort interpreting, in that the services are provided to the residents of the community in which the interpreting takes place, not to conference delegates, diplomats, or professionals traveling abroad to conduct business. Other distinctions that set community interpreting apart from conference interpreting are identified by Roberts (Ref. 3): 1) Community interpreters primarily serve to ensure access to public services, and are therefore likely to work in institutional settings; 2) they are more apt to be interpreting dialogue-like interactions than speeches; 3) they routinely interpret into and out of both or all of their working languages; 4) the presence of the community interpreter is much more noticeable in the communication process than is that of the conference interpreter; 5) a great many languages, many of them minority languages that are not the language of government in any country, are interpreted at the community level, unlike the limited number of languages of international diplomacy and commerce handled by conference and escort interpreters; and 6) community interpreters are often viewed as advocates or "cultural brokers" who go beyond the traditional neutral role of the interpreter.

Other terms have been used to describe this activity. In the United Kingdom, for example, "public service interpreting" is the preferred term; while in Canada, "cultural interpreting" is often used. Other designations include "dialogue interpreting" and "ad hoc interpreting." "Community interpreting" seems to be the term most widely accepted in the literature, however (Ref. 3).

1.2 Profession

The American Heritage Dictionary of the English Language defines the term "profession" as "1) an occupation or vocation requiring training in the liberal arts or the sciences and advanced study in a specialized field; 2) the body of qualified persons of one specific occupation or field." The term has been used in a variety of contexts throughout history, beginning with the religious connotation of taking vows or expressing a belief. The sense of an occupation or calling came along later. In modern times, medicine, law, and the ministry have been considered the original "learned professions" (jokes about the "first profession" notwithstanding), and are regarded as models for others to emulate (Ref. 5, p. 13). This is especially true of medicine, which has reached the pinnacle of prestige and power in the United States. Sociologists, in particular, have studied the process whereby an occupation becomes a profession and thus enhances the social status of its practitioners.

This discussion of professionalization centers on the work of Joseph Tseng (Ref. 5), who has written a comprehensive review of the literature on professionalism and developed his own model based on conference interpreting in Taiwan. After presenting Tseng's findings and conclusions, I will apply his model to community interpreting in the United States.

2. PROFESSIONALIZATION

Tseng reviews the writings of a number of scholars who have examined the process whereby an occupation becomes a profession. He identifies two schools of thought, those who accept the "trait theory" of professionalization and those who uphold the "theory of control."

2.1 Trait Theory

The trait theory states that an occupation becomes a profession by attaining certain characteristics, including adherence to a code of ethics, a body of theoretical knowledge, licensure or registration, and loyalty to colleagues. Proponents of the trait theory have devised checklists of attributes that can be ticked off to determine how far a given occupation has progressed toward the goal of professionalization (Ref. 6).

2.2 Theory of Control

The theory of control, on the other hand, goes beyond internal characteristics and looks at how the occupation relates to other components of the labor market and institutions in society. According to this view, the more control practitioners of an occupation are able to exert over the substance of their work and the market in which they operate, the more professionalized the occupation. Tseng notes that the theory of control views professions in terms of the amount of power they wield, and that professionalization is a collective effort rather than an individual one: "Powerful professions are characterized by powerful associations"(Ref. 5, p. 20). An occupational group can exert both internal control (over the body of knowledge and training required for entry into the field and the behavior or ethics of the practitioners) and external control (working conditions and relations with clients). The legal profession, for example, defines not only the curriculum of law schools and the content of bar exams, but also the standards for training and testing in related occupations (paralegals, court reporters, court clerks). As a result, these related occupations have comparatively little autonomy and are less likely to attain the degree of professionalization that lawyers and judges enjoy.

One element of prestigious professions that has often been remarked upon is the mystification of the specialized knowledge acquired by practitioners. Often the aura of mystique is created by using terms of art and jargon when "talking shop" with colleagues, thus excluding the uninitiated from the dialogue (Ref. 7, pp. 40-41). A profession that succeeds in mystifying its expertise is able to control the market by prohibiting interlopers from practicing the profession.

A corollary to the mystification principle is the notion that professions gain power by defining the needs of their clients rather than allowing the clients to set the agenda (Ref. 8). Thus, until recently it was virtually impossible to obtain a divorce without retaining an attorney, because it was impossible for a layperson to know what he needed to do to achieve the goal of legally severing marital bonds. It was not until a few reformers wrested that power away from attorneys by writing self-help books, complete with sample forms and detailed checklists, that it finally became possible to accomplish an uncontested divorce without retained counsel. (If any property or children are involved in the divorce, which is usually the case, it is still impossible to proceed without a lawyer.) If a client is able to come to a practitioner and say, "I know what I want, just help me with the technicalities," as in the case of an interior decorator or a hairdresser, the occupation does not have a great deal of autonomy or power. If the client is able to understand what the practitioner is doing to help him accomplish his goal, he maintains a certain amount of control over the transaction. On the other hand, if he consults a physician who performs a strange test on a mysterious machine, for example, he has no means of challenging or questioning the physician's judgment.

The theory of control also posits that powerful professions establish alliances with the state. If they are perceived as performing a service that benefits the public, the state will grant them special privileges and independence. They are more likely to be self-regulated than other occupations (consider the Bar Association's role in writing bar exam and disciplining its members, for example), and this autonomy, in turn, enhances the public's trust in the profession (Ref. 9).

Tseng concludes that the theory of control is more useful than the trait theory for understanding how an occupation becomes a profession, but it fails to provide guidelines for an occupation that aspires to achieve that objective. Consequently, he provides his own model of professionalization, which draws upon elements of trait and control theory and adds components based on his experience with conference interpreting.

2.3 Tseng Model

According to Tseng, the first phase in the process of professionalization is market disorder. This period is characterized by fierce competition among the practitioners of an occupation:

Practitioners in the market cannot keep outsiders from entering practice. They themselves may have started practice as outsiders or quacks. Recipients of the service either have very little understanding of what practitioners do or very little confidence in the services they receive. It is very likely that the public simply does not care about the quality of the services. Hence, distrust and misunderstanding permeate the market. What matters more to clients, in the absence of quality control, is usually price. Whoever demands the lowest fees gets the job. .... When the clients need services, they simply call upon anyone who is around and asking a reasonable fee. Clients who demand quality services are usually troubled by the fact that they do not know where to get qualified practitioners for services (Ref. 5, pp. 44-45).

Unlike doctors or lawyers, who are able to mystify their occupations, interpreters deal with clients who think they know what interpreters do (and think it is very simple), but in fact do not. Furthermore, in many cases (especially in community interpreting settings) the professionals who work with interpreters do not value the interpreting service nearly as much as a patient values his health or a legal client his freedom. The upshot is that interpreting is not mystified by the client's ignorance, but merely devalued.

In such a situation, practitioners have little incentive to obtain specialized training. As competition increases, however, they may view training as a means of obtaining a competitive edge. Ironically, Tseng views training as a source of both cohesion and disturbance of the market. He explains that initially, "training schools vary considerably in admission standards, duration of training, curricula and the qualifications of graduates and instructors." Training institutions may end up competing for students to stay afloat, and as a consequence, they "may oversupply the market with excessive numbers of practitioners." The increased competition makes it difficult for practitioners to convince clients "to respect their job descriptions and consequently their control over the working conditions." The result is a vicious cycle of unprofessional behavior and mistrust of practitioners by their clients (Ref. 5, p. 46).

Eventually, though, training institutions do have a positive impact, because the most highly-trained practitioners become dissatisfied with the status quo. The graduates of the most prestigious schools

are likely to nurture and cultivate the same vision for the market, so that when the number of such graduates reaches a certain proportion of the practitioners in the market, the consensus that the occupation should be organized to protect clients from malpractice and themselves from outsiders comes naturally among such practitioners (Ref. 5, p. 48).

Thus begins Phase II, the consolidation of the profession and the development of a consensus about practitioners' aspirations. Training institutions must adapt to an increased demand for quality services. They also support the emergence of professional associations as a means of enhancing the prestige of their graduates. Tseng views the professional association as a critical factor in professionalization. In this third stage,

professionals can really work collectively with their colleagues to exert their influence over their job description and the behavior of their collegauges, control admission into their circle and appeal to clients and the public for recognition of the profession. The power and achievements of the association strengthen the commitment of members to the course they are pursuing (Ref. 5, pp. 48-49).

The next step is for the professional association(s) to formulate ethical standards. "The enforcement of the code of ethics is crucial," Tseng points out, "because it functions externally as one of the bargaining chips to earn public trust and internally as an indispensable tool for internal control" (Ref. 5, p. 49). He also emphasizes the interdependence of the code of ethics and the professional association: As professional associations become more influential, their codes of ethics become more sophisticated and are more strictly enforced; but if enforcement is weak, the associations cannot be powerful or function properly.

Another factor in increasing professionalization is control of admission to the profession. A strong association can require all practitioners to be members in good standing in order to practice legally. It may also play a role in accreditation of practitioners, although that function is often reserved to the government. In the United States, three related professional organizations exemplify this transitional stage. On one end of the continuum is the American Translators Association, which has made accreditation a condition for active membership but has not managed to obtain any legal recognition for this status; in the middle is the court interpreting profession, represented by a number of organizations that have at best an advisory role in government-run certification programs; and at the other extreme is the Registry of Interpreters for the Deaf, which administers its own legally-recognized and enforced certification program.

As professional associations gain strength, they are able to exert more influence on the public through publicity campaigns. "With publicity measures," says Tseng, "the association tries to convince the clientele and the public to accept its definition of the professional content of work and working conditions. In other words, the purpose is to achieve market control" (Ref. 5, p. 51). If the public relations campaign is successful, the professional association can then try to influence political and legal authorities through lobbying campaigns with a view to achieving legislative recognition and licensure. This marks the final phase of Tseng's model, at which point the profession has managed to ensure its own protection and autonomy.

The transition from Phase I to Phase IV is not a smooth or quick progression, Tseng warns. "It is not a peaceful evolution, but rather a process involving conflicts and a power struggle at each stage." In particular, evolving from Phase I to Phase III

depends on the resilience of the practitioners aspiring for professionalization in holding out against unqualified competitors and market encroachers. The consensus and commitment reached at the second stage are fragile, because practitioners may change their occupation if better job alternatives are available or making a living becomes too demoralizing, thus shrinking the population and reducing the force of the professional aspirants (Ref. 5, p. 53).

Tseng makes it clear that the professional association is a sine qua non for professionalization, but that even with an association in place, dissent among the members can weaken its effectiveness. A key factor is enforcement of the code of ethics:

The effectiveness of the professional association in projecting the collective image of the profession to the public and legal authorities rests upon the extent to which it can control and develop the expertise and enforce the code of ethics. It is impossible to overemphasize its importance and relevance to the overall development of the profession (Ref. 5, p. 54).

Tseng stresses that professionalization is a circular process, with each phase providing feedback and reinforcement to the previous phase. It is also important to look at the social context in which an emerging profession exists, he notes. If other, more powerful professions oppose the recognition of the occupation in question as a profession, it will have a more difficult time emerging. For example, Ruth Morris (Ref. 10) has shown that the legal profession feels threatened by autonomy or independent thinking on the part of a court interpreter, fearing that the judge's role of interpreting the law and the attorney's role of presenting evidence will be usurped by the interpreter. The legal profession has tight control of the body of knowledge required for practicing law, and it will not easily relinquish that control to an allied profession. In her research, she has found

negative judicial views of the interpreting process and of those who perform it, in the traduttore traditore tradition, spanning the gamut from annoyance to venom, with almost no understanding of the linguistic issues and dilemmas involved. Legal practitioners, whose own performance, like that of translators and interpreters, relies on the effective use and manipulation of language, were found to deny interpreters the same latitude in understanding and expressing concepts that they themselves enjoy. Thus they firmly state that, when rendering meaning from one language to another, court interpreters are not to interpret--this being an activity which ony lawyers are to perform, but to translate--a term which is defined, sometimes expressly and sometimes by implication, as rendering the speaker's words verbatim.

The law continues to proscribe precisely those aspects of the interpreting process which enable it to be performed with greater accuracy because they have two undesirable side effects from the legal point of view: one is to highlight the interpreter's presence and contribution, the other is to challenge and potentially undermine the performance of the judicial participants in forensic activities (Ref. 10, p. 26).

Another factor identified by Tseng in his review of the literature on professionalization is public perception that the occupation is

important and connected to the well-being of the people. ... When a particular service of a rising profession is not in demand, the public is not likely to recognize its importance and relevance to their lives. As a result, actions taken to persuade the public to support the professionalization of a particular occupation cannot be effective (Ref. 5, pp. 56-58).

Once again, the court interpreting profession provides a pertinent example of the role of public perception in the recognition of an occupation. Because foreigners and foreign languages are not viewed favorably in courts of law (Ref. 11), and because of the anti-immigrant, anti-criminal-defendant sentiment prevailing in many societies today, anyone associated with immigrants in the courts is regarded as undesirable. Consequently, providing qualified interpreters for litigants who do not speak English is a low priority. Morris sums up the issue uniquivocally:

The law's denigratory attitude to foreigners, and its related distaste at having to deal with problems which arise from their presence in the host country, exclude its making proper interpreting arrangements for its dealings with them. In this way, its dire fears about defective communication become self-fulfilling (Ref. 10, pp. 28-29).

The same can be said of other areas of community interpreting, in which the interpreter is often seen as a crutch that enables an immigrant who ought to have learned English to draw public benefits of some sort.

After presenting his model of professionalization, Tseng discusses numerous obstacles to professionalization. The first one is "confusion of the professional title" (Ref. 5, p. 63). It is well known to translators and interpreters that the lay public does not understand the difference between translating and interpreting, and often misuses the terms. Furthermore, Morris (Ref. 12) has written extensively on the legal profession's attitudes toward court interpreters, and she emphasizes the need to distinguish between interpreting as an "intralingual" process that is performed by judges and that involves "determining the 'true' meaning of a written document," and the "interlingual" process involving the transfer of messages from one language to another (Ref. 10, p. 25).

Another obstacle to professionalization cited by Tseng is the lack of a systematic body of knowledge exclusive to the profession. It is a source of great frustration to translation and interpretation professionals that anyone who who has any familiarity, no matter how rudimentary, of a foreign language thinks he can interpret and translate. Thus, knowledge of languages, the basic foundation of the profession's body of knowledge (and the only aspect visible to the lay public) is not exclusively held by its practitioners. Tseng points out that little serious research has been conducted on interpreting, and there is still no consensus about whether interpreting is an art or a science (Ref. 5, p. 68). A corollary to this obstacle, then, is public misconceptions about the profession. Tseng notes that clients do not know how to recruit qualified interpreters, thereby enabling unqualified interpreters to survive in the market, provided they can maintain good relations with the clients (Ref. 5, p. 70). Paradoxically, he also points out that because of the common misconception that interpreting "is an effortless activity that can be done by any bilinguals" and that interpreters are "machines that do code-switching automatically from one language to another," clients think that it is easy to evaluate the quality of the interpreting services they are receiving. He concludes that "only when clients have no clue on which to base their evaluation of the interpretation can interpretation evoke any sense of awe among clients. This is detrimental to professionalization" (Ref. 5, pp. 70-74).

2.4 Prescriptions for Professionalization

To overcome these obstacles, Tseng advocates the development of a strong professional association that represents the majority of practitioners. He points out that

an association cannot be expected to fully realize its power if it only represents a portion of competent practitioners. In a well-established profession, practitioners cannot operate without being members of a professional association. ... Therefore, the limited representation of interpreters' associations, in my opinion, is the major problem these associations are facing in the struggle to fully realize their potential (Ref. 5, p. 81).

Tseng concludes with this exhortation:

Interpreters worldwide must join hands with researchers and scholars to develop the body of knowledge on interpretation, and in the process to settle the confusion over the professional title. Interpreters should cooperate more closely with associations they belong to in campaigns for the promotion of the profession. The associations, though they have made considerable achievements, should not degenerate into inaction because of complacency, for their objectives have not yet been reached. On the other hand, the practitioners should not be discouraged at the inherent difficulty of professionalization for interpreting, because as long as the occupation is developing and the associations adopt appropriate strategies for development, and there is the possibility of favorable changes in the overall professional climate, interpreting may have a chance of growing into maturity (Ref. 5, pp. 147-48).

Roda Roberts (Ref. 3, pp. 133-136) presents guidelines for the professionalization of community interpreting that are remarkably similar to Tseng's prescriptions, and thus lend further support to his arguments. She advocates 1) clarification of terminology (i.e., settling on a clear definition and a universally recognized name for the occupation); 2) clarification of the role(s) of the community interpreter; 3) provision of training for community interpreters; 4) provision of training for trainers of community interpreters (a very important issue that Tseng does not address); 5) provision of training for professionals working with interpreters (a more formalized version of what Tseng terms "client education"); and 6) accreditation of community interpreters.

Tseng does not emphasize accreditation in his discussion of the conference interpreting profession in Taiwan, but he does indicate that a certification program lent more power to the interpreting profession in Australia (Ref. 5, p. 86). Roberts is a stronger advocate of accreditation:

The respect of other professionals for community interpreters will certainly increase if the latter's competency is guaranteed by a rigorous accreditation system. Indeed, it is not enough to evaluate a potential interpreter's abilities at the end of training; what is also required is national recognition of their interpreting skills by means of an accreditation procedure established by a professional body ... (Ref. 3, p. 136).

Morris cautions, however, that certification or accreditation alone does not guarantee professionalism (Ref. 10, p. 41).

3. COMMUNITY INTERPRETING IN THE UNITED STATES

Roberts asserts that community interpreting, though "the oldest form of interpreting in the world, has been the most neglected both by practising interpreters and by scholars" (Ref. 3, p. 127). Her description of community interpreting in general is an accurate depiction of the current situation in the United States. Whereas court interpreting is just beginning to emerge as a recognized profession in this country, albeit with obvious growing pains, other types of community interpreting are far behind. Two states, California and Washington, have attempted to implement certification programs governing certain aspects of medical interpreting, and fledgling medical interpreter associations have been founded in California, Washington, and Massachusetts.

In other institutions, such as social service agencies and school districts, Roberts' categorization of community interpreters, ranging from individuals engaged in interpreting as a full-time occupation to unpaid volunteers (Ref. 3, pp. 130-132), is apropos. In these settings, interpreting is rarely recognized as a separate occupation and is likely to be performed by employees as an adjunct to their normal duties, or in the case of languages of lesser diffusion (LLDs), by relatives of the non-English-speaking party, including children. These ad hoc interpreters receive no training whatsoever, and are not members of any relevant professional associations. As a result, they feel no sense of commitment to interpreting as a profession.

Thus we see a vicious circle similar to that described by Tseng: Practitioners receive little recognition and low pay, and therefore have no incentive to obtain specialized training; consequently, training programs are rare and not well-funded; the low prestige and limited earning potential makes community interpreting unattractive as a career option for talented, well-educated individuals with bilingual skills. As noted above, prevailing anti-immigrant attitudes in the United States contribute to the low prestige of community interpreting. Unlike conference interpreters, whose clients are powerful leaders of the business and political worlds, community interpreters serve powerless members of society.

An added difficulty is that in many languages, there are few opportunities to work full-time as interpreters, and practitioners must engage in other occupations, such as tax preparation or real estate sales, which give them the flexibility to take occasional interpreting assignments. Because they do not specialize in interpreting, these practitioners do not have an opportunity to perfect their skills.

The market disorder described by Tseng also characterized community interpreting in the United States. Clients have no way of knowing which interpreters are competent, since there is no certification program in most areas and in most languages. Thus, they tend to accept the lowest bidder, which intensifies the competition among rival interpreters. The result is often unprofessional behavior, which further lowers the public's opinion of the occupation.

4. RECOMMENDATIONS

In conclusion, I subscribe wholeheartedly to Roberts' recommendations for the professionalization of community interpreting (Ref. 3, pp. 133-36). The practitioners of community interpreting must reach a consensus about their role and function, and must then educate their clients (both English-speaking service providers and non-English speakers). Following the sequence of steps outlined by Tseng, formal training programs should be instituted, which means that competent interpreter trainers must be identified and cultivated. As these training programs (which should be language-specific wherever possible) become established, professional associations should emerge to represent the interests of community interpreters and to enforce the code of ethics. In turn, as these associations grow stronger, they should strive to educate the public and potential clients about the role of the community interpreter and the importance of hiring a trained professional. They should also establish a good working relationship with the relevant legal authorities who may wish to regulate the profession. A credible certification program should be developed to encourage practitioners to obtain proper training and to instill public trust in the profession. As Tseng noted, this is not a linear process, but a circular or spiral progression, with each stage influencing both the preceding and succeeding ones.

As a result of this process, community interpreting will be a strong and respected profession with a recognized body of knowledge and credentialing process, a financially and intellectually rewarding occupation that will attract the most qualified practitioners. It will not be a smooth or easy process, but it will be well worth the effort.

5. REFERENCES

  1. Gonzalez, Roseann, Victoria Vazquez, and Holly Mikkelson. Fundamentals of Court Interpreting: Theory, Policy, and Practice. Durham, NC: Carolina Academic Press, 1991.
  2. Unattributed article, "Community interpreting: Affirmation of a new discipline" in Language International 7.4 (1995), pp. 14-15.
  3. Roberts, Roda. "Community Interpreting Today and Tomorrow," in Peter Krawutschke, ed. Proceedings of the 35th Annual Conference of the American Translators Association. Medford, NJ: Learned Information, 1994, pp. 127-138.
  4. Carr, Sylvana, Roda Roberts, Aideen Dufour, and Dini Steyn. The critical link: Interpreters in the community. Papers from the 1st International Conference on Interpreting in Legal, Health, and Social Service Settings, Geneva Park, Canada, June 1-4, 1995. Amsterdam, Philadelphia: John Benjamins Publishing, forthcoming.
  5. Tseng, Joseph. Interpreting as an Emerging Profession in Taiwan -- A Sociological Model. Unpublished Master's Thesis, Fu Jen Catholic University, Taiwan, 1992.
  6. Carter, M.J. and others. "Occupation to Profession Continuum--Status and Future of AAHPERD," Journal of Physical Education, Recreation and Dance, 61(3), 106-09, cited in Tseng, op. cit.
  7. Mellinkoff, David. The Language of the Law. Boston, Toronto: Little, Brown & Co. 1963.
  8. Freidson, E. Professional Powers: A Study of the Institutionalization of Formal Knowledge. Chicago: University of Chicago Press, 1986, cited in Tseng, op. cit.
  9. Wilding, P. Professional Power and Social Welfare, Routledge & Kegan Paul Ltd., 1982, cited in Tseng, op. cit.
  10. Morris, Ruth, "The Moral Dilemmas of Court Interpreting." The Translator, Vol. 1, No. 1, 1995, pp. 25-46.
  11. Morris, Ruth, "Pragmatism, Precept and Passions: The Attitudes of English-Language Legal Systems to Non-English Speakers" in Marshall Morris, ed. Translation and the Law. Amsterdam, Philadelphia: John Benjamins Publishing, 1995, pp. 263-79.
  12. Morris, Ruth. Images of the Interpreter: A Study of Language-Switching in the Legal Process. Ph.D. thesis, Lancaster University: Department of Law, 1993.

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