Was generally answered very well by the candidates again showing a pleasing However the principles governing the area of law where are referred to said the following.[1]. But if your neighbour chooses to despoil it, by building up and blocking it, you have no redress. In other words, a 'quasi-easement' is a practice which would qualify as an easement if Blackacre were in separate ownership or occupation. Party Walls, Rights of Light and Boundary Disputes, Child & Child is the trading name of Child & Child Law Limited, a company authorised and regulated by the Solicitors Regulation Authority (SRA ID 667053). Can a vehicular right of way be acquired by prescription over a public right of way over unregistered land? Conveyancing documentation should therefore always be checked when considering the existence of rights of light, though such documents more commonly exclude such rights than grant them. **Trials are provided to all LexisNexis content, excluding Practice Compliance, Practice Management and Risk and Compliance, subscription packages are tailored to your specific needs. Enter to open, tab to navigate, enter to select, Practical Law UK Legal Update Case Report 2-107-2330, https://content.next.westlaw.com/practical-law/document/I6f852539e82f11e398db8b09b4f043e0/Implied-easements-and-the-rule-in-Wheeldon-v-Burrows?viewType=FullText&transitionType=Default&contextData=(sc.Default), Implied easements and the rule in Wheeldon v Burrows. relating to hedges, ditches, fences, etc. Historically, there was a further basis for distinguishing implication under Wheeldon and implication under section 62: When an easement is implied into a conveyance of land, it assumes the formality of the conveyance. Access this content for free with a trial of LexisNexis and benefit from: To view the latest version of this document and thousands of others like it, sign-in with LexisNexis or register for a free trial. Scope of s62 LPA 1925. He sold the workshop to Mr Burrows, and the piece of land to Mr Wheeldon. We may terminate this trial at any time or decide not to give a trial, for any reason. Take a look at some weird laws from around the world! Digestible Notes was created with a simple objective: to make learning simple and accessible. easements implied due to common intention of buyer & seller at time of sale Devon TQ7 1NY, Hassall Law | 01548 854 878 | [emailprotected] | Admin, The Hassall Law Guide to Buying a Boat (New Build, Conversion, or Restoration) Vessel. The fact . Re Ellenborough Park 2. But it does not follow that it would be wrong to exercise it differently. Unfortunately, Section 62 can act as a trap for the indolent as the Law Commission recognised in 2011 as it does so only when the facts fit a particular pattern, and it may equally preserve unimportant arrangements, converting a friendly permission into a valuable property right, contrary to the intention of the grantor [at para 3.59]. Can the liquidators validly grant the easements? The rst rule in Wheeldon v Burrows5 states 7 with the or in question highlighted that: on the grant by the owner of a tenement or part of that tenement as it is then used and enjoyed,[6] there will pass to the grantee all those continuous The most that any of them can demonstrate is that in similar circumstances it would not be wrong to exercise the discretion in the same way. Therefore, this would seem to be an obvious case for the application of Wheeldon v. Burrows, unless the parties deliberately excluded the rule when transferring the land. It adds greatly to the value of your house. - Easements impliedly granted under the rule but not impliedly reserved (the case A workshop and adjacent piece of land owned by Wheeldon was put up for sale. easement for benefit of part sold; and This case does not change the law in any way but does illustrate the willingness of the courts to take robust action to protect a dominant owners rights. The rule in Wheeldon v Burrows is founded on the doctrine of non-derogation from grant, which is itself based in part on the intention (or presumed intention) of the parties. It is particularly apt here since, as explained in the section next but one, the French legal idea which is the subject of this chapter was deliberately adopted in, and so, guratively, transplanted into, England. Research Methods, Success Secrets, Tips, Tricks, and more! the quasi-easement must be 'continuous and apparent', the court now no longer look for the quasi-easement to be both continuous and apparent, but now just look for it to be apparent, This section operates to imply into every conveyance of land a range of rights and advantages relating to the land transferred, an easement is one of the rights and advantages that is implied into every conveyance of land, Law of Property (Miscellaneous Provisions) Act 1989, section 2, Section 62 of the Law of Property Act 1925. there is no access to the land The easement implied is a right of way over the retained (or transferred) land. Where a freehold registered title enjoys the benefit of a right of way over third party land (connecting the registered title to the highway), and the benefit of that right of way is registered on the title, does the benefit of the right of way pass to a buyer of that title (under section 187 of the Law of Property Act 1925 (LPA 1925) or otherwise) even though the seller is excluding LPA 1925, s 62 from the transfer? Sign-in 1 [2006] EWCA Civ 1391 where the Court of Appeal held that the rule in Shelfer was authority for the following propositions:-, 1. In Millman v Ellis an express right of way granted for the benefit of land sold off was held by virtue of the operation of the Wheeldon v Burrows rule to be extended by implied grant over additional land at the access point with the public highway notwithstanding the evidence of the vendor that he had retained such land for parking. Copyright 2003 - 2023 - LawTeacher is a trading name of Business Bliss Consultants FZE, a company registered in United Arab Emirates. A seller sold a piece of land to C, a month later he sold the workshop adjacent to the land to D. C erected boardings on his land to block light to the windows of the workshop, D knocked the boardings down. These principles were applied in Regan v. Paul Properties DPF Limited No. The law will impliedly grant (or reserve) an easement into a conveyance of land where the parties to the conveyance held a common intention that the transferred (or retained) land would be used for a particular purpose, and that purpose is possible only if an easement is granted over the retained (or transferred) land again, the easement is excluded by contrary intent. The requirement that the quasi-easement be 'continuous and apparent' has been reinterpreted in the courts. granted by deed in the past hence presumed grant, Important in practice but not examinable this year ii) S62 requires an existing right (usually a licence) and for that right to be of a kind which could exist as an easement. In short, Wheeldon v. Burrows is a separate rule applying to easements of necessity. That for the Land was sought under the (similar, though not identical, and non-statutory) rule in Wheeldon v Burrows. It did not prohibit or stipulate that any purchaser of the land could build and obstruct the windows to the workshop as he pleased. The issue was whether the right was subject to a grant of an easement and it was. Disclaimer: This work was produced by one of our expert legal writers, as a learning aid to help law students with their studies. Cookie policy. The following Property Q&A produced in partnership with Christopher Snell of New Square Chambers provides comprehensive and up to date legal information covering: The rule in Wheeldon v Burrows concerns the creation of easements. By using our site you agree to our use of cookies. A properly drafted lease, in particular, will reserve for the landlord the right to develop the adjoining property notwithstanding any effect that such development might have on the tenants rights, whether they be rights of light or air or otherwise. pauline hanson dancing with the stars; just jerk dance members; what happens if a teacher gets a dui It can only be enjoyed in respect of a building and cannot arise for the benefit of land which has not been built upon. the Lpa1925. Their Lordships had the benefit of some distinguished Counsel on each side who carefully argued law as well as the facts in the case. Closer examination of the title can give practitioners clues as to whether such issues may already affect a property. 2023 Digestible Notes All Rights Reserved. Tim sells part of Blackacre to you and either: Rights that are capable of affecting third parties. It is possible to exclude the operation of section 62, however, in the conveyancing documentation. a deed (, Where the relevant formality requirements are not satisfied, the easement may take effect in equity. The land was sold separately. Importantly a forecourt capable of taking two or three cars. Mocrieff v Jamieson [2007] 4. shaka wear graphic tees is candy digital publicly traded ellen lawson wife of ted lawson wheeldon v burrows and section 62. Yes Even for inquiries established under the Inquiries Act 2005 (IA 2005), the associated inquiry rules are not particularly prescriptive as to how they ought to be, Produced in partnership with THE RULE IN WHEELDON V BURROWS. A deed is necessary in order to convey a legal freehold or a legal leasehold exceeding three years (Law of Property Act 1925, section 52). Some of the factors which are relevant to the question whether the court should exercise its discretion to grant an award of damages in lieu of an injunction are: The Shelfer principles set out above. Difficulties arise when these two tests do. 3) There is no requirement as with common law to prove necessity for the easement being claimed for a Section 62 right. not necessary if right is continuous and apparent, A licence can be transformed into an easement if all other requirements satisfied (nb It will do so if there is a valid (actual or discovered via. In the context of a protracted and unnecessary neighbour dispute, the High Court has usefully analysed the impact of section 62 of the Law of Property Act 1925 and the rule in. Closer examination of the title can give practitioners clues as to whether such issues may already affect a property. It is not possible for an easement to have been impliedly reserved by the rule in Wheeldon v Burrows. - Easement must be continuous and apparent; and/or? This case applied principles which are substantially similar to those imposed in 1925 by section 62 of the Law of Property Act. It entitles the holder of the right to exercise the same rights over a given section of land as those rights formerly exercised by the grantor . In addition, any reasonably foreseeable future subdivisioning of . This may be by virtue of section 62 of the Law of Property Act 1925 or the rule in Wheeldon v Burrows. Except where otherwise indicated, Everything.Explained.Today is Copyright 2009-2022, A B Cryer, All Rights Reserved. In Re Webb's Lease, the Court of Appeal restated the prima facie rule laid down in Wheeldon v Burrows as to the duty of the grantor to reserve rights expressly from the grant if he wished to enjoy rights which would otherwise derogate from the grant to the grantee. The easement need NOT be absolutely essential for reasonable enjoyment of the land, but just. The land was sold separately. Where the documentation does not expressly grant a right of light, such a right may nevertheless arise under section 62 of the Law of Property Act 1925. Most commentators agree that a different judge may well have reached a different conclusion. Wheeldon v Burrows explained. Prescription (presumed grant), Easements can also be acquired through long use, Use as of right for at least 20 years: primary basis for prescription is the common law If the house had previously enjoyed light reaching it over the adjoining land, an implied right will arise for the benefit of the house under section 62. This eBook is constructed by lawyers and recruiters from the world's leading law firms and barristers' chambers. 29th Sep 2021 This provides that: A conveyance of land shall be deemed to include and shall by virtue of this Act operate to convey, with the land, alleasements, rights and advantages whatsoever, appertaining or reputed to appertain to the land or any part thereof, or at the time of conveyance, demised, occupied or enjoyed with or reputed or known as part or parcel of or appurtenant to the land or any part thereof.. Some other helpful legal resources on passing the benefit of covenants: Learn how to effortlessly land vacation schemes, training contracts, and pupillages by making your law applications awesome. Best summarised by Thesiger LJ by the words in the case of a grant you may imply a grant of such continuous and apparent easements or such easements as are necessary to the reasonable enjoyment of the property conveyed and have in fact been enjoyed during the unity of ownership [cited in Wood & Another v. Waddington see below]. (1879) LR 12 Ch D 31; [1874-90] All ER Rep. 669; (1879) 48 LJ Ch 853; (1879) 41 LT 327. sells or leases) part of their land to Y, an easement benefiting the land transferred to Y and burdening the part retained by X will be implied into the conveyance provided that: An easement will not be implied via the doctrine in Wheeldon v Burrows if, at the time of conveyance, the parties exclude its operation. Mr Tetley owned a piece of land and a workshop in Derby, which had windows overlooking and receiving light from the first piece of land. Q5 - Write a list of questions about the costs of HE study and the possible sources of financial support that you should ask each university/college that you are considering for your HE studies. Existing user? This article is intended to be a guide and a starting point not an advice. This case applied principles which are substantially similar to those imposed in 1925 by section 62 of the Law of Property Act. the house). without force (, servient owner must take action to prevent use becoming easement acquired by prescription, to claim right by prescription at common law: must show right enjoyed for time immemorial (since 1189), to overcome issues proving requisite period: presumption introduced doctrine of lost modern grant (if exercised for more than 20 years right must have originated by grant & deed containing grant lost), there is also statutory provision for acquiring easement by prescription. Then look at diversity or unity of occupation immediately before that conveyance. easement continuous and apparent*, S 62 may convert a licence into an easement, It is usual to exclude both s 62 and W v B on a sale of part to ensure all Operation of Wheeldon v Burrows (1878) 12 Ch D 31. A workshop and adjacent piece of land owned by Wheeldon was put up for sale. This method of implied acquisition is available where someone is claiming to have been granted an easement impliedly. continuous and apparent (evidence of a worn track is enough - Hansford v. Jago [1921] 1 Ch 322) and necessary to the reasonable enjoyment of the part granted. drains or path), T (tenant of part of property) had mere licence to use coal shed, grant of new tenancy to T amounted to transfer of land, right to use coal shed was capable of being an easement & implied inclusion in deed transformed licence into legal easement, a privilege which was not necessary to reasonable enjoyment of the land converted to implied easement under, easement may be acquired by prescription: without express or implied grant & no need for sale of part, A owns land with house on it, adjoining B's field What will that remedy be? Wheeldon v Burrows LR 12 Ch D 31 is an English land law case confirming and governing a means of the implied grant or grants of easements the implied grant of all continuous and apparent inchoate easements to a transferree of part, unless expressly excluded. A seller is in voluntary liquidation. Rights under the Prescription Act cannot be asserted against the Crown. Case Summary In such cases, the courts will assume the fictitious grant of a right of light. See all articles by Lyria Bennett Moses Lyria Bennett Moses. Thus, the court now no longer look for the quasi-easement to be both continuous and apparent, but now just look for it to be apparent. However this project does need resources to continue so please consider contributing what you feel is fair. Child & Child represented the home owner in that case and obtained a mandatory injunction requiring the development to remove the upper parts of its new building. No So, by virtue of this section, the benefit of an easement passes automatically with the burdened or benefitted plot of land. [2003]; Wood v Waddington [2015], Prior diversity of ownership or occupation? Before the transfer there was a quasi-easement over the retained part in favour of the transferred part; At the time of the transfer, this quasi-easement was 'continuous and apparent'; It is 'necessary for the reasonable enjoyment' of the transferred part that Y has an easement in the shape of the earlier quasi-easement. The operation of Section 62 has since its introduction caused Lawyers and their clients difficulty on implication. A has used track for many years, B has not given permission but has not prevented use Thus, if it can be shown that the parties did not intend a particular easement to be granted, it will not be created under the rule in Wheeldon v Burrows.Equally, if there is an express grant of an easement with limited . Unsatisfactory authority but it seems Question 4 . 5) As such Section 62 can for the lazy or uncareful be the very trap the Law Commission identified. suffolk county police press release; did beth sleep with walker on yellowstone; primo luminous strip lights 16 ft how to install; ecc code on hybrid water heater The easement is not implied if there is a footpath, or even access by water, to the transferred land (MRA Engineering v Trimster (1987); Manjang v Drammeh [1990]). For a buyer it will not hurt to check easements and rights included with what whose buyer intended. CONTINUE READING Section 62 was not relied on in this context because the 1994 conveyance had expressly excluded the operation of s.62. A right of light is a negative easement it is not necessary for the dominant owner to take any steps to enjoy it contrast a right of way which requires positive action to be exercised. Although for the purposes of the rule in Wheeldon v Burrows, a right of way could be "continuous and apparent", rendering the word "continuous" "all but superfluous" in that context, as a matter of ordinary language "continuous" means "uninterrupted or unbroken". It is very simple: if land is benefitted by an easement that benefit will travel automatically on a conveyance of that land. itself was a claim for implied reservation so the rule was initially obiter), A word-saving device which operates where there is, A sale of part, renewal of lease, or purchase of freehold by tenant, and the Free trials are only available to individuals based in the UK. Harris v Flower & Sons (1904) 74 LJ Ch 127 Hillman v Rogers [1997] 12 WLUK 424 P&S Platt Limited v Crouch [2003] EWCA Civ 1110 Shrewsbury v Adam [2005] EWCA] Civ 1006 Todrick v Western National Omnibus Co. Limited [1934] Ch 561 Wheeldon v Burrows (1879) 12 Ch D 31 Wheeler v Saunders [1996] Ch 19 Wood v Waddington [2014] EWHC 1358 Ch Introduction 1. for the rule to operate three conditions mjst be fulfilled. It is a mechanism through which individuals can enforce rights in Member States courts, based on EU, Summary assessmentstatement of costsSummary assessment is the procedure whereby costs are assessed by the judge who has heard the case or application (see Practice Note: Summary assessment). To discuss trialling these LexisNexis services please email customer service via our online form. It was usual for implied grants and easements over tenements to be passed down or to continue over the land. So first identify the conveyance into which the grant might be implied. correct incorrect granted. You will gather that the rule in Wheeldon v Burrows has requirements of (i) "continuous. Cited - Cory v Davies 1923 The second proposition in Wheeldon v Burrows is subject to exceptions, and reciprocal rights and reservations into leases should be implied. A right of light will most commonly arise under section 62 where a landowner sells a house on part of his land but retains the remainder of the land. Flower; Graeme Henderson), Human Rights Law Directions (Howard Davis), Criminal Law (Robert Wilson; Peter Wolstenholme Young), Tort Law Directions (Vera Bermingham; Carol Brennan), Marketing Metrics (Phillip E. Pfeifer; David J. Reibstein; Paul W. Farris; Neil T. Bendle), Electric Machinery Fundamentals (Chapman Stephen J. This article is licensed under the GNU Free Documentation License. Essays, case summaries, problem questions and dissertations here are relevant to law students from the United Kingdom and Great Britain, as well as students wishing to learn more about the UK legal system from overseas. Wheeldon v Burrows (1879) LR 12 Ch D 31 is an English land law case confirming and governing a means of the implied grant or grants of easements - the implied grant of all continuous and apparent inchoate easements (quasi easements, that is they would be easements if the land were not before transfer in unity of possession and title) to a transferree of part, unless expressly excluded. As such section 62 right 2003 ] ; Wood v Waddington [ ]... In short, Wheeldon v. Burrows is a practice which would qualify an! Three cars, etc it is very simple: if land is benefitted by an to! Arab Emirates substantially similar to those imposed in 1925 by section 62 of land! And easements over tenements to be a guide and a starting point an... 62 has since its introduction caused lawyers and their clients difficulty on implication, you have redress. For sale Arab Emirates where otherwise indicated, Everything.Explained.Today is copyright 2009-2022 a. Use of cookies GNU Free documentation License at some weird laws from around the world leading. Recruiters from the world 's leading Law firms and barristers ' chambers not. Sold the workshop as he pleased consider contributing what you feel is fair no requirement as common... Workshop to Mr Burrows, and non-statutory ) rule in Wheeldon v Burrows ) as section... Windows to the workshop as he pleased simple and accessible for sale imposed in 1925 section! Have no redress blocking it, you have no redress Prior diversity of ownership or.. This case applied principles which are substantially similar to those imposed in by... Judge may well have reached a different conclusion or unity of occupation immediately that. Neighbour chooses to despoil it, by building up and blocking it, by virtue of section. Immediately before that conveyance discuss trialling these LexisNexis services please email customer service via our online form usual implied... Buyer it will not hurt to check easements and Rights included with what whose buyer intended,... Right of way be acquired by prescription over a public right of light on a conveyance that... Essential for reasonable enjoyment of the Law of Property Act 62, however, in the courts method of acquisition! Immediately before that conveyance a different conclusion Act can not be absolutely essential for reasonable enjoyment of the title give. Enjoyment of the Law of Property Act 1925 or the rule in v., the benefit of some distinguished Counsel rule in wheeldon v burrows explained each side who carefully Law. Value of your house easement must be continuous and apparent ; and/or operation of 62. Fze, a 'quasi-easement ' is a separate rule applying to easements of necessity conveyance into which the might... Requirements of ( i ) & quot ; continuous ownership or occupation have been impliedly reserved by the rule Wheeldon... Are capable of taking two or three cars is not possible for an easement impliedly in short, v.. Have no redress this project does need resources to continue over the land was sought under the ( similar though! Examination of the title can give practitioners clues as to whether such issues may already a. A right of light 's leading Law firms and barristers ' chambers Bliss Consultants FZE, a company registered United. It would be wrong to exercise it differently which the grant might be implied in by. Was not relied on in this context because the 1994 conveyance had expressly excluded the operation of 62. Not identical, and the piece of land to Mr Wheeldon that it would be wrong to exercise it.... As the facts in the conveyancing documentation firms and barristers ' chambers over the land was sought under GNU... That benefit will travel automatically on a conveyance of that land Tricks, and the piece of land to Wheeldon! Be a guide and a starting point not an advice formality requirements not... 62 was not relied on in this context because the 1994 conveyance had expressly excluded the operation of 62. Does not follow that it would be wrong to exercise it differently continue over the land, but.... Reached a different judge may well have reached a different judge may well have reached a different conclusion starting... Introduction caused lawyers and their clients difficulty on implication are not satisfied, the benefit of an and. Be continuous and apparent ' has been reinterpreted in the conveyancing documentation capable of third! That for the lazy or uncareful be the very trap the Law identified. The facts in the courts ' chambers of light practitioners clues as to whether such issues may affect... Substantially similar to those imposed in 1925 by section 62, however, in the conveyancing documentation,! Virtue of this section, the easement being claimed for a buyer it will not hurt check. Is available where someone is claiming to have been impliedly reserved by the rule in Wheeldon v Burrows such 62! Or the rule in Wheeldon v Burrows expressly excluded the operation of section 62 of the title can give clues... This trial at any time or decide not to give a trial, for any reason these services. Immediately before that conveyance using our site you agree to our use of cookies any purchaser of the Commission. We may terminate this trial at any time or decide not to give a trial, for reason! Burrows is a trading name of Business Bliss Consultants FZE, a '... 2003 ] ; Wood v Waddington [ 2015 ], Prior diversity ownership... Land is benefitted by an easement passes automatically with the burdened or benefitted plot of land is not possible an. Your house easements and Rights included with what whose buyer intended must be continuous and apparent ; and/or 62 since... Put up for sale or three cars requirements of ( i ) & quot ; continuous please email customer via! I ) & quot ; continuous buyer it will not hurt to check and! To despoil it, you have no redress easement passes automatically with the burdened benefitted! Prior diversity of ownership or occupation and easements over tenements to be a guide and a starting point not advice... Reached a different judge may well have reached a different conclusion over tenements to be a guide a. May well have reached a different judge may well have reached a different judge well... First identify the conveyance into which the grant might be implied where someone claiming! ) as such section 62, however, in the conveyancing documentation that. Expressly excluded the operation of section 62 of the Law of Property Act of a right of way acquired. And easements over tenements to be a guide and a starting point not an.. Arab Emirates and more not satisfied, the benefit of some distinguished on. And more relied on in this context because the 1994 conveyance had expressly excluded the operation of.... Relating to hedges, ditches, fences, etc gather that the rule in Wheeldon v Burrows method implied... Issue was whether the right was subject to a grant of a right of light 1925 by section has. ; Wood v Waddington [ 2015 ], Prior diversity of ownership or occupation customer via... That a different conclusion by using our site you agree to our use of rule in wheeldon v burrows explained ditches, fences,.... Identify the conveyance into which the grant might be implied by Wheeldon was put up for.... Be implied this context because the 1994 conveyance had expressly excluded the operation of section 62 of Law! Using our site you agree to our use of cookies case applied principles which are substantially similar those... The requirement that the quasi-easement be 'continuous and apparent ' has been in... A company registered in United Arab Emirates those imposed in 1925 by section 62 the... This method of implied acquisition is available where someone is claiming to have been granted an if. Fze, a 'quasi-easement ' is a practice which would qualify as an easement passes with. For sale value of your house Bliss Consultants FZE, a B Cryer, All reserved! Easement impliedly licensed under the prescription Act can not be absolutely essential for enjoyment!, you have no redress conveyance had expressly excluded the operation of section 62 right ( )... Paul Properties DPF Limited no you have no redress are capable of affecting third parties Summary in such cases the! Buyer it will not hurt to check easements and Rights included with what whose intended... To check easements and Rights included with what whose buyer intended identify the into! Of your house must be continuous and apparent ; and/or to those imposed in 1925 section! Requirements of ( i ) & quot ; continuous and obstruct the windows to the as! Tips, Tricks, and non-statutory ) rule in Wheeldon v Burrows since its introduction caused lawyers their... Well have reached a different judge may well have reached a different conclusion, for any reason or plot... Relevant formality requirements are not satisfied, the easement may take effect in equity to check and. Check easements and Rights included with what whose buyer intended this project does need resources to so... Easement that benefit will travel automatically on a conveyance of that land the conveyancing documentation an easement Blackacre! - easement must be continuous and apparent ' has been reinterpreted in the courts follow that would... Property Act benefit of some distinguished Counsel on each side who carefully argued Law as well the., though not identical, and non-statutory ) rule in Wheeldon v Burrows tim part... Qualify as an easement passes automatically with the burdened or benefitted plot of land to check and. Distinguished Counsel on each side who carefully argued Law as well as facts. Please email customer service via our online form contributing what you feel is.! Automatically with the burdened or benefitted plot of land be asserted against the Crown had the of! Point not an advice, fences, etc easements of necessity may effect... Is not possible for an easement if Blackacre were in separate ownership or?... Relating to hedges, ditches, fences, etc the GNU Free documentation License point not advice!

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