Authored By: Kavisha Puthuvlakan
Artificial intelligence (AI) has altered the way digital content is created, shared and consumed. As a result, highly realistic images, videos and audio recordings can now be generated, making it increasingly difficult to distinguish between authentic and manipulated content. One of the most significant developments in AI is the emergence of deepfakes, which are digitally fabricated or modified forms of media capable of falsely portraying individuals.[1] Although the technology has legitimate uses, its growing accessibility has also facilitated fraud, non-consensual intimate image abuse, political misinformation and identity theft.[2] Consequently, deepfakes raise considerable legal and societal concerns.[3]
The United Kingdom (UK) has introduced several legislative reforms to address the harms posed by deepfakes.[4] Nonetheless, there is no single legal framework specifically regulating their misuse. Instead, Parliament has adapted existing legislation to respond to the challenges created by this technology.[5] This article argues that, although recent reforms represent substantial progress, the current approach remains fragmented and reactive. It examines the strengths and limitations of the existing legal regulation and considers whether further legislative reform is necessary.
The Rise of Deepfakes
Deepfakes have become increasingly prominent in recent years, offering a range of legitimate benefits across different sectors. For instance, they have been used to support medical research, improve accessibility for individuals with disabilities, enhance film production, recreate historical figures for educational purposes and preserve the voices of those with speech disorders.[6] Nevertheless, the technology itself is not inherently unlawful or harmful. The main issue lies in the increasing accessibility of deepfakes, allowing sophisticated content to be used to deceive and manipulate individuals.[7] Thus, the challenge for lawmakers lies in regulating misuse without unnecessarily restricting technological innovation, a balance that has proven increasingly difficult as deepfake technology continues to evolve.[8]
Many have become victims of deepfakes, from businesses being affected by AI-generated voice cloning, identity theft and financial fraud to individuals whose privacy has been invaded, resulting in significant reputational, emotional and psychological harm.[9] According to Reuters, approximately eight million deepfakes were shared globally in 2025, compared with around 500,000 in 2023, demonstrating the rapid development of the technology and the growing extent of its misuse.[10] Ofcom has similarly recognised the growing use of deepfakes to deceive, defraud and spread misinformation, illustrating the wider risks they pose to individuals and society.[11] Furthermore, deepfakes no longer represent isolated incidents of online abuse but have become an increasingly widespread problem, raising concerns surrounding privacy, security and public trust in digital media.
Unlike the traditional methods of creating manipulated media, such as digitally edited photographs and manually altered video or audio recordings, deepfakes typically do not require specialist skills to create, largely due to advances in generative AI. Realistic deepfakes can now be produced rapidly, efficiently and inexpensively with minimal technical expertise, enabling almost anyone to create and distribute convincing AI-generated content.[12] As the technology continues to develop, the law has struggled to keep pace, leaving the existing body of law limited in its ability to prevent misuse and provide effective remedies for victims. This highlights the need for legal responses capable of addressing the unique challenges posed by AI-generated content.[13]
Deepfakes often engage several areas of law simultaneously, yet they are not regulated by one piece of legislation. Concurrently, a single deepfake may invade an individual’s privacy, enable fraud, involve the unlawful use of personal data, infringe copyright and damage their reputation. As such, victims may be required to rely upon a combination of criminal and civil remedies rather than one comprehensive legal regime.[14] Whilst this demonstrates the flexibility of existing legal principles, it also exposes the fragmented nature of the current legal framework, leaving uncertainty as to whether it can effectively respond to the challenges posed by deepfakes.
The Current UK Legal Framework
Legal regulation of deepfakes in the UK has developed incrementally, with Parliament adapting both existing and newly enacted legislation to address the harms arising from AI-generated content.[15] Rather than being governed by a standalone Deepfake Act, the current legislation is dispersed across a range of legislative provisions.[16]
The Online Safety Act 2023 is one of the most prominent legislative developments in the UK’s response to online harm.[17] Whilst it does not regulate deepfakes directly, the Act imposes statutory duties on online platforms, obligating them to identify, assess and mitigate the risks faced by individuals who encounter illegal content.[18] These duties are particularly relevant where deepfakes are used for fraud or the sharing of non-consensual intimate images.[19] This is overseen by Ofcom,[20] which has been granted enforcement powers to investigate regulated services, require information, issue enforcement notices and impose substantial financial penalties where necessary.[21] This represents a notable shift in regulation because it recognises that tackling harmful online content should not be limited to those who create it but should also extend to the platforms through which it is disseminated.[22]
Furthermore, the regulation of sexually explicit deepfakes has been strengthened through amendments to the Sexual Offences Act 2003, [23] introduced by the Data (Use and Access) Act 2025.[24] These reforms were prompted by the increasing prevalence of non-consensual sexually explicit deepfakes, a form of abuse which the Government recognises as disproportionately affecting women and girls.[25] The 2025 Act amended the Sexual Offences Act 2003[26] by introducing new offences which criminalise the intentional creation, commissioning, requesting and profiting from non-consensual sexually explicit deepfakes.[27] Unlike previous legislation, which focused on the distribution of intimate images, these reforms also criminalise the creation of sexually explicit deepfakes, reflecting Parliament’s recognition that serious harm may arise before the content is distributed.[28]
In addition to strengthening protection for adult victims, Parliament has also extended legal protection for children through amendments to the Protection of Children Act 1978.[29] The law recognises that although no real child may have been involved in the creation of AI-generated images,[30] the increasing ability of AI to produce realistic child sexual abuse material (CSAM) has raised serious safeguarding concerns.[31] As such, the Protection of Children Act 1978 was amended by the Crime and Policing Act 2026, expanding existing CSAM offences to include AI-generated pictures which accurately portray children.[32] Individuals who produce, possess or disseminate AI-generated CSAM may now face the same legal repercussions as those dealing with traditional CSAM,[33] acknowledging that its potential for exploitation and harm exists irrespective of whether a real child was involved in its creation.[34]
Financial fraud is another area in which deepfakes have become particularly problematic, enabling offenders to impersonate individuals and deceive victims into transferring money or disclosing sensitive information.[35] Despite the Fraud Act 2006 predating the emergence of generative AI, its provisions are sufficiently broad to cover many forms of fraud involving deepfakes.[36] Individuals may commit an offence under the Act where they dishonestly use deepfakes to make false representations for financial gain. This includes schemes involving voice cloning, CEO fraud, and other forms of impersonation designed to induce victims into transferring money or disclosing private information.[37]
Whilst criminal legislation provides important protection against many forms of deepfake misuse, it does not provide a remedy for every case. Victims may also rely on civil remedies, supported by the Human Rights Act 1998, to protect their privacy, reputation and intellectual property rights.[38] The Human Rights Act 1998 is critical as courts must consider conflicting rights when determining disputes involving deepfakes.[39] While Article 10 safeguards the right to freedom of expression,[40] Article 8 protects an individual’s right to respect for their private and family life.[41] In a democratic society, freedom of expression is crucial, but it is not absolute and may be limited in cases where publication unjustly infringes the privacy or reputation of another individual.[42]
The significance of striking a balance between these conflicting rights is highlighted by Bloomberg LP v ZXC (2022),[43] where the Supreme Court affirmed that individuals generally have a legitimate expectation of privacy in relation to information concerning an ongoing criminal investigation.[44] Whilst the case did not involve deepfakes, it illustrated the balancing exercise that judges must do between Articles 8[45] and 10[46] when establishing whether an individual’s privacy should take precedence over the public interest in publication.[47] These principles are similarly relevant where deepfakes interfere with an individual’s private life whilst also engaging the competing right to freedom of expression.[48]
Depending on the type of harm sustained, victims may also seek civil remedies where criminal prosecution is unavailable or inappropriate.[49] Where deepfakes reveal or invent details about an individual’s personal life, claims for misuse of private information may arise.[50] In McKennitt v Ash (2006), the Court of Appeal affirmed that information may attract protection because it is private, rather than because it is true.[51] Accordingly, even AI-generated content which falsely represents an individual’s private life may interfere with the protections afforded by Article 8.[52]
Additional civil remedies may also be available under the Defamation Act 2013, where legal action may be taken if a deepfake causes serious harm to someone’s reputation.[53] Similarly, AI-generated endorsements involving celebrities or public figures may give rise to actions in passing off.[54] In Irvine v Talksport Ltd (2002), the High Court recognised that a false commercial endorsement could amount to passing off.[55] The same principle is applicable where deepfakes falsely imply sponsorship of a product or service,[56] thereby illustrating that established commercial torts remain capable of addressing emerging forms of AI misuse.[57] Additionally, where AI systems reproduce copyrighted works without permission, creators may also benefit from protection under copyright law.[58]
Collectively, these laws and civil remedies highlight that the UK has a broad legal response which can deal with several types of deepfake abuse.[59] Nevertheless, the framework remains scattered across several legal mechanisms, requiring victims to rely on multiple areas of law instead of a single piece of legislation specifically created to regulate deepfakes.[60]
Strengths of the Current Framework
Despite criticism of the current legislation, the existing regime provides several noteworthy advantages.[61] Rather than waiting to enact an entirely new Deepfake Act, Parliament has demonstrated a willingness to amend existing legislation in response to emerging threats posed by artificial intelligence.[62] Recent reforms introduced by the Crime and Policing Act 2026[63] and the Data (Use and Access) Act 2025 illustrate that the law can adapt to keep pace with technological developments.[64] This gradual approach has enabled the Government to address specific harms more swiftly than may have been possible through the lengthy process of introducing entirely new legislation.[65] As a result, victims now benefit from greater legal protection than was available only a few years ago.[66]
The current legal framework is also highly adaptable, in that although many of the principal pieces of legislation predate generative AI, they remain sufficiently flexible to address new forms of misconduct.[67] For instance, voice cloning scams and other forms of financial fraud may be prosecuted under the Fraud Act 2006, without it requiring AI-specific legislation.[68] Likewise, where deepfakes compromise an individual’s privacy, reputation or commercial interests, civil remedies such as misuse of private information, passing off and defamation continue to provide protection.[69] Due to this adaptability, established legal principles can remain relevant despite rapid technological developments, reducing the need for entirely new legislation whenever technology evolves.[70]
Moreover, the fact that victims are protected against both perpetrators and the online platforms through which deepfake harm is shared is another significant advantage.[71] Under the Online Safety Act 2023, online platforms are subject to proactive duties, requiring them to identify and mitigate the risks associated with illegal content, with compliance overseen by Ofcom’s enforcement powers.[72] These protections also extend to victims of non-consensual intimate deepfakes and AI-generated CSAM.[73] The Government has also reported a 380% increase in organisations developing deepfake detection technology, indicating that technological innovation is increasingly supporting legislative efforts to tackle AI-generated harm.[74] As such, this reflects a broader regulatory strategy which recognises that effective protection requires both preventative measures and legal remedies once harm has occurred.[75]
These developments indicate that the UK has made considerable progress in responding to the legal challenges posed by deepfakes.[76] Through a combination of criminal offences, civil remedies and platform regulation, the current framework provides a vast range of protection for victims of AI-generated harm.[77] Nonetheless, these strengths should not overshadow the shortcomings of the existing legislative framework.[78] Although recent reforms have strengthened legal protection significantly, substantial loopholes remain, raising concerns as to whether the existing protections can address the long-term challenges posed by rapidly evolving technology.[79]
Weaknesses of the Current Framework
One of the biggest shortcomings of the current system of regulation governing deepfakes is that there is no single piece of legislation specifically designed to protect victims.[80] This becomes problematic because liability is often dependent on whether the content falls within an existing criminal offence or a civil cause of action.[81] Additionally, similar cases may produce different legal outcomes because they are governed by multiple areas of law.[82] This creates uncertainty for victims, as deepfakes may be regulated differently depending on whether they are considered sexually explicit, fraudulent, defamatory or an invasion of privacy.[83] Victims must first identify the appropriate legal route despite the harm arising from the same underlying technology, a process which may be time-consuming, expensive and distressing.[84] Furthermore, harmful content may go unreported because many victims are unaware of the legal remedies available or the existing elements cannot be easily established.[85] As a result, the current legislative approach remains fragmented rather than providing a clear, consistent response to the creation or distribution of deceptive AI-generated media.[86]
Another weakness of the current legal regime is that it remains largely reactive, having developed in response to specific incidents.[87] Although the recent reforms are undoubtedly important in tackling sexually explicit deepfakes and CSAM, they were introduced only after the technology had become widely accessible.[88] According to Ofcom, four in ten UK adults encountered misinformation or deepfake content in 2024, illustrating how widespread the issue has become.[89] This is reinforced by the Government’s recognition of the increasing use of deepfakes, suggesting that harmful content may circulate extensively before legislative or regulatory action is taken.[90] Ultimately, the law continues to follow technological developments rather than keeping pace with them, making it difficult to respond to future forms of misuse.[91]
Political deepfakes also remain a significant gap within the existing legal system.[92] Whilst the Online Safety Act 2023 may apply where election-related content amounts to an existing criminal offence,[93] deceptive political deepfakes do not always fall within the scope of existing offences.[94] This means that speeches, videos or images which falsely portray politicians or seek to manipulate public opinion may not necessarily be unlawful. This further suggests that the legislative response is not yet fully equipped to regulate the evolving risks posed by deepfakes.[95]
Even where legal protection exists, enforcing the law can still be difficult.[96] Deepfakes can be created anonymously or by individuals who are located outside of the UK, making it complicated to identify those responsible and enforce existing legislation.[97] Harmful content may also be copied and distributed across multiple online platforms before its removal, reducing the effectiveness of legal remedies.[98] Although the Online Safety Act 2023 places greater responsibility on online platforms,[99] enforcement alone cannot prevent every instance of deepfake misuse, particularly where those responsible cannot be identified or are located overseas.[100]
Taken together, these weaknesses indicate that the current law is not yet equipped to address the wide range of harms posed by deepfakes.[101] Although existing legislation provides valuable protection in many circumstances, significant gaps remain, particularly where emerging forms of misuse fall outside the scope of existing offences or where enforcement proves difficult.[102] This raises the question of whether further legislative reform is necessary to create a more coherent and effective legal framework.
The Future of Deepfake Regulation
Rather than continuing to amend multiple pieces of legislation whenever a new problem arises, Parliament should move towards a more comprehensive system of regulation, providing greater clarity for victims, online platforms and AI developers.[103] This does not necessarily require Parliament to abandon the existing legal position. Many of the existing offences remain effective and should continue to apply where appropriate.[104] However, as Mishcon de Reya observe, the current approach still lacks clear personality rights and digital replica rights.[105] Addressing this gap would provide individuals with better control over the unauthorised AI-generated use of their likeness whilst complementing existing criminal and civil protections.[106] Without a more coordinated regulatory approach, Parliament risks remaining in a continual cycle of reacting to technological developments rather than anticipating them.[107] This concern is reinforced by Gartner’s prediction that, by 2026, 30% of enterprises will no longer consider identity verification fully reliable, due to deepfakes becoming substantially sophisticated, exhibiting how the challenges posed by AI are likely to continue developing alongside the technology.[108]
For instance, future reforms could introduce clearer responsibilities for AI developers and providers to reduce the likelihood of harmful deepfakes prior to their circulation.[109] Similarly, clearer regulation of political deepfakes would also address one of the most prominent gaps in the legislative response, helping to reduce the spread of AI-generated misinformation during election campaigns and other democratic processes.[110] Measures encouraging the identification of AI-generated content, including watermarking or clear labelling where appropriate, can also assist individuals in recognising manipulated media, improving transparency without unnecessarily restricting legitimate uses of artificial intelligence.[111] This reflects Ofcom’s view that greater transparency can help users to distinguish authentic content from AI material, reducing the risk of deception without preventing the development of legitimate AI technologies.[112]
Despite this, any future reform must avoid unnecessarily restricting technological innovation or freedom of expression.[113] Deepfake technology has many legitimate uses across healthcare, education, entertainment and accessibility. Reforms should also be careful to remain proportionate, target the harmful misuse, whilst encouraging beneficial innovation.[114]
Conclusion
In summary, the UK has made considerable progress in responding to the harms arising from deepfakes through recent legislative reform and the continued application of established legal principles.[115] Although the current legislation provides valuable protection, it remains fragmented and reactive. Further targeted reform is therefore necessary to strengthen existing protections and ensure the law continues to respond effectively to the evolving challenges posed by artificial intelligence.[116]
Bibliography
Table of Cases
Bloomberg LP v ZXC [2022] AC 1158, [2022] UKSC 5
Irvine v Talksport Ltd [2002] EWHC 367 (Ch), [2002] 1 WLR 2355
McKennitt v Ash [2006] EWCA Civ 1714
Table of Legislation
Crime and Policing Act 2026
Data (Use and Access) Act 2025
Defamation Act 2013
European Convention on Human Rights 1950
Fraud Act 2006
Human Rights Act 1998
Online Safety Act 2023
Protection of Children Act 1978
Sexual Offences Act 2003
Secondary Sources
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[1] Oliver Lock, ‘Deepfakes’ (Lexis Practical Guidance, 2026) <https://plus.lexis.com/api/permalink/e1c3b3a9-72c4-4463-8c54-cda69a6e155a/?context=1001073&federationidp=G9DTRN66797> accessed 17 July 2026.
[2] UNICEF, ‘Deepfake abuse is abuse’ (4 February 2026) <https://www.unicef.org/press-releases/deepfake-abuse-is-abuse> accessed 17 July 2026.
[3] Ofcom, ‘A deep dive into deepfakes that demean, defraud and disinform’ (23 July 2024) <https://www.ofcom.org.uk/online-safety/illegal-and-harmful-content/deepfakes-demean-defraud-disinform> accessed 17 July 2026.
[4] Alex Davies Jones, ‘Government crackdown on explicit deepfakes’ (GOV.UK, 7 January 2025) <https://www.gov.uk/government/news/government-crackdown-on-explicit-deepfakes> accessed 17 July 2026.
[5] Jon Baines, Katie Iveson, Nina O’Sullivan, Isabella Piasecka and Anne Rose, ‘When AI impersonates – taking action against deepfakes in the UK’ (Mishcon de Reya, 10 October 2025) <https://www.mishcon.com/news/when-ai-impersonates-taking-action-against-deepfakes-in-the-uk> accessed 17 July 2026.
[6] Ibid (note 1).
[7] Ibid (note 3).
[8] Ibid (note 5).
[9] Ibid (note 2).
[10] Reuters, ‘Britain to work with Microsoft to build deepfake detection system’ (5 February 2026) <https://www.reuters.com/world/uk/britain-work-with-microsoft-build-deepfake-detection-system-2026-02-05/> accessed 17 July 2026.
[11] Ofcom, ‘Four in ten UK adults encounter misinformation’ (27 November 2024) <https://www.ofcom.org.uk/media-use-and-attitudes/attitudes-to-news/four-in-10-uk-adults-encounter-misinformation> accessed 17 July 2026.
[12] Gartner, ‘Gartner Predicts 30% of Enterprises Will Consider Identity Verification and Authentication Solutions Unreliable in Isolation Due to AI-Generated Deepfakes by 2026’ (1 February 2024) <https://www.gartner.com/en/newsroom/press-releases/2024-02-01-gartner-predicts-30-percent-of-enterprises-will-consider-identity-verification-and-authentication-solutions-unreliable-in-isolation-due-to-deepfakes-by-2026> accessed 17 July 2026.
[13] Ibid (note 5).
[14] Ibid (note 1).
[15] Ibid (note 4).
[16] Ibid (note 1).
[17] Online Safety Act 2023.
[18] Ofcom, ‘How can tech firms help users spot deepfakes?’ (11 July 2025) <https://www.ofcom.org.uk/online-safety/illegal-and-harmful-content/how-can-tech-firms-help-users-spot-deepfakes> accessed 17 July 2026.
[19] Ibid (note 3).
[20] Department for Science, Innovation and Technology, ‘Online Safety Act’ (GOV.UK, 24 July 2025) <https://www.gov.uk/government/collections/online-safety-act> accessed 17 July 2026.
[21] Ibid (note 18).
[22] Ibid (note 1).
[23] Sexual Offences Act 2003.
[24] Data (Use and Access) Act 2025.
[25] Ibid (note 4).
[26] Ibid (note 23).
[27] Ibid (note 24).
[28] Danielle Reece-Greenhalgh, ‘Deepfakes and the criminal law: addressing the rise of AI-generated sexual material’ (Solicitors Journal, 16 May 2025) <https://www.solicitorsjournal.com/sjarticle/deepfakes-and-the-criminal-law-addressing-the-rise-of-ai-generated-sexual-material?category=Feature> accessed 17 July 2026.
[29] Protection of Children Act 1978.
[30] Home Office, The Rt Hon Liz Kendall MP and Jess Phillips MP, ‘Government leads global fight against deepfake threats’ (GOV.UK, 5 February 2026) <https://www.gov.uk/government/news/government-leads-global-fight-against-deepfake-threats> accessed 17 July 2026.
[31] Ibid (note 2).
[32] Crime and Policing Act 2026.
[33] Ibid (note 28).
[34] Ibid (note 1).
[35] Ibid (note 5).
[36] Fraud Act 2006.
[37] Ibid (note 1).
[38] Human Rights Act 1998.
[39] Ibid (note 38).
[40] European Convention on Human Rights 1950, art 10.
[41] European Convention on Human Rights 1950, art 8.
[42] Bloomberg LP v ZXC [2022] UKSC 5.
[43] Ibid (note 42).
[44] Bloomberg LP v ZXC [2022] AC 1158.
[45] Ibid (note 41).
[46] Ibid (note 40).
[47] Ibid (note 42).
[48] Ibid (note 1).
[49] Ibid (note 5).
[50] Ibid (note 38).
[51] McKennitt v Ash [2006] EWCA Civ 1714.
[52] Ibid (note 41).
[53] Defamation Act 2013, s1.
[54] Ibid (note 5).
[55] Irvine v Talksport Ltd [2002] EWHC 367 (Ch), [2002] 1 WLR 2355.
[56] Ibid (note 55).
[57] Anat Lior, ‘Addressing AI-Related Harms Through Existing Tort Doctrines’ (Oxford Business Law Blog, 3 July 2024) <https://blogs.law.ox.ac.uk/oblb/blog-post/2024/07/addressing-ai-related-harms-through-existing-tort-doctrines> accessed 18 July 2026.
[58] Theo Lind, Michael Rubinger, Jim Holloway and Conrad Flaczyk, ‘Artificial Intelligence 2025’ (Lexology Panoramic Next, 23 October 2025) <https://plus.lexis.com/api/permalink/8e0a9dfe-c85a-49ba-8f41-da2deea941f5/?context=1001073&federationidp=G9DTRN66797> accessed 18 July 2026.
[59] Ibid (note 1).
[60] Ibid (note 5).
[61] Ibid (note 5).
[62] Ibid (note 4).
[63] Ibid (note 32).
[64] Data (Use and Access) Act 2025.
[65] Ibid (note 28).
[66] Ibid (note 1).
[67] Ibid (note 30).
[68] Fraud Act 2006.
[69] Ibid (note 1).
[70] Ibid (note 30).
[71] Ibid (note 3).
[72] Online Safety Act 2023.
[73] Ibid (note 64).
[74] Department for Science Innovation and Technology, ‘Deepfake detection technology’ (GOV.UK, 26 March 2026) <https://www.gov.uk/government/publications/deepfake-detection-technology/deepfake-detection-technology> accessed 18 July 2026.
[75] Ibid (note 30).
[76] Ibid (note 30).
[77] Ibid (note 1).
[78] Ibid (note 5).
[79] Ibid (note 1).
[80] Ibid (note 5).
[81] Ibid (note 1).
[82] Ibid (note 57).
[83] Ibid (note 2).
[84] Stephen Halloran, ‘What is the law on Explicit Deepfakes in the UK?’ (Lawtons Solicitors, 27 January 2026) <https://www.lawtonslaw.co.uk/resources/law-on-explicit-deepfakes-uk/> accessed 18 July 2026.
[85] Ibid (note 2).
[86] Ibid (note 58).
[87] Ibid (note 5).
[88] Ibid (note 4).
[89] Ibid (note 11).
[90] Ibid (note 30).
[91] Ibid (note 5).
[92] Ofcom, ‘TV loses its crown as main source for news’ (10 September 2024) <https://www.ofcom.org.uk/media-use-and-attitudes/attitudes-to-news/tv-loses-its-crown-as-main-source-for-news> accessed 18 July 2026.
[93] Ibid (note 17).
[94] Ibid (note 1).
[95] Ibid (note 92).
[96] Ibid (note 5).
[97] Ibid (note 58).
[98] Ibid (note 18).
[99] Ibid (note 72).
[100] Ibid (note 5).
[101] Ibid (note 58).
[102] Ibid (note 5).
[103] Ibid (note 1).
[104] Ibid (note 84).
[105] Ibid (note 5).
[106] Ibid (note 58).
[107] Ibid (note 28).
[108] Ibid (note 12).
[109] Ibid (note 30).
[110] Ibid (note 11).
[111] Ibid (note 18).
[112] Ibid (note 3).
[113] Ibid (note 40).
[114] Ibid (note 57).
[115] Ibid (note 84).
[116] Ibid (note 5).
