Gender Recognition Reform (Scotland) Bill: consultation analysis

This report presents the analysis of responses to our consultation on the draft Gender Recognition Reform (Scotland) Bill.

This document is part of a collection

7. Impact Assessments

7.1 The fifth and final question covered the draft Impact Assessments. In line with its usual practice, the Scottish Government would produce final versions of these impact assessments for the Bill once it is introduced into Parliament.

7.2 The draft impact assessments that have been produced are:

  • Business and Regulatory Impact Assessment (BRIA);
  • Child Rights and Wellbeing Impact Assessment (CRWIA);
  • Fairer Scotland Duty Assessment (FSDA);
  • Data Protection Impact Assessment (DPIA); and
  • Equality Impact Assessment (EQIA).

Q5: Do you have any other comments on the provisions of the draft Impact Assessments?

7.3 Around 8,600 respondents made a comment at Question 5.

7.4 It should be noted that some respondents submitted extensive and detailed answers at Question 5 and that these can only be summarised briefly in a report of this nature. However, all responses are available in their entirety to the policy team at the Scottish Government.

7.5 Most respondents either made broad, general observations about the impact of the proposals or on the suite of assessments. More specific comments tended to be focused either on the EQIA and/or the CRWIA, or the impacts on people with characteristics covered by those assessments.

General observations

Those broadly in support of a statutory declaration-based system

7.6 The comments of those who broadly supported a statutory declaration-based system tended to be brief, often simply expressing the view that allowing trans people to obtain a GRC more easily would not affect any other person or groups of people.

7.7 This was sometimes connected with general statements that they agreed with the draft impact assessments or that they considered them to be good and/or comprehensive.

Those broadly opposed to a statutory declaration-based system

7.8 Many respondents who were broadly opposed to a statutory declaration-based system argued that the impact assessments are not thorough, comprehensive or evidence-based and that they are inadequate and not fit-for-purpose.

7.9 Concerns were raised in respect of evidence that the Scottish Government has failed to consider during the impact assessment process. This was sometimes voiced in terms of specific information that respondents felt had been overlooked or excluded, and sometimes a more general sense that one side of the debate is being listened to while the other is not.

7.10 Specific suggestions were that the Scottish Government is:

  • Not listening to Women's Groups that have voiced specific concerns with respect to proposed reforms to the 2004 Act.
  • Relying on the opinions of a small number of women's sector charities to inform policy.
  • Failing to consider differing views within the trans community.

7.11 It was suggested that the impact assessments include a large number of studies referencing groups that are supportive of GRA reform, without similar weight being given to studies offering alternative perspectives. On a related point it was argued there is no acknowledgment that much of the academic literature arises from the work of researchers who support self-declaration in principle, while funding opportunities for work coming from other perspectives are much more limited. It was also suggested that the Scottish Government should commission independent research into trans issues.

7.12 Specifically, it was suggested the EQIA overlooks evidence produced by grassroots women's groups, documenting the fears of women who have experienced domestic and sexual violence at the hands of men, about sharing space with trans women, and the potential for women's self-exclusion from women-only spaces that include trans women.

7.13 One Women's Group respondent reported an FOI request which showed that, although a literature search carried out by the Scottish Government Library listed a number of their own publications under a heading 'The following results may be particularly relevant', none of these were quoted in the EQIA or listed in the references.

7.14 Other evidence that respondents thought had been overlooked included:

  • Contributions of a former prison governor with respect to the presence of trans women in women's prisons.
  • Cases in Scotland, the UK and elsewhere in the world where self-identified trans women who retain male anatomy have sought to abuse single-sex spaces.

7.15 The nature of some of the research that is cited in the impact assessments was also highlighted, with two papers suggested to draw analogies that many found to be offensive.[34] In addition, a paper addressing harm done to female survivors of male violence when they are denied a female-only therapeutic environment was argued to have been misrepresented.


Those broadly in support of a statutory declaration-based system

7.16 Those broadly supporting a statutory declaration-based system tended not to make wider observations on the EQIA beyond those made about the impact assessments overall; they sometimes suggested that the EQIA is good, comprehensive and correctly identifies that the proposals will not have a detrimental impact on anyone's rights.

7.17 It was also reported that, according to the Equality and Human Rights Commission, the regulatory body responsible for enforcing the Equality Act, the proposed changes will not affect the operation of the Equality Act 2010, including in relation to single-sex and separate-sex services (discussed further below).

Those broadly opposed to a statutory declaration-based system

7.18 However, those broadly opposed to a statutory declaration-based system raised particular concerns about the assessment of impact on the protected characteristics of sex and sexual orientation in respect of women and girls, with many respondents disputing the EQIA's conclusion that women will not be affected negatively by the proposed changes. In addition to women's physical and psychological safety, it was argued that privacy and dignity must also be protected.

7.19 It was suggested that the EQIA does not engage systematically with questions on the implications of reform of the 2004 Act for operation of the Equality Act and does not clearly set out the evidence that the Scottish Government has considered in coming to the conclusion that there is no negative impact on women's equality and rights.

7.20 One perspective was that in the absence of the further information set out in Chapter 5 of the consultation paper, the draft EQIA would be insufficient.


Those broadly in support of a statutory declaration-based system

7.21 Very much in line with more general observations that the reforms would not have a negative impact on any groups of people, many respondents who broadly supported a statutory declaration-based system expressly stated that they did not believe the proposed changes would have a negative impact on women and girls. This was sometimes connected with welcoming the conclusion of the draft EQIA that the policy is not expected to impact on men and women in different ways.

7.22 Some of those taking this view highlighted that they were women, sometimes also commenting that they were feminists, cis women, lesbians, or mothers for example, and that they had no concerns that the proposals would have a negative impact on them. They sometimes referred specifically to not being concerned with regard to single-sex spaces, including having no concerns that trans women in single-sex spaces would present a threat to their safety. Some referred to their own experiences of having shared workplaces, changing rooms or public toilets with trans women, and having never felt anything other than comfortable. It was suggested that any suggestion that trans people, and trans women in particular, are a threat to cis women is absurd and not supported by robust evidence.

7.23 Further comments on access to single-sex spaces and facilities, such as toilets, changing rooms, and women-only services, included that nobody is currently required to show a birth certificate to prove their eligibility for these spaces or services. It was suggested that this will not change and that much of the women's sector in Scotland has been including trans women in their women's services for a decade, with no reported difficulties. It was reported that these services operate under what is, in effect, a self-identification model and have stated that the proposed reforms will not mean they have to alter their services.

7.24 It was also noted that the Equality Act 2010 allows organisations to apply exemptions from their services on the grounds of 'proportionate risk' to these services. Risks that women and children's safety might be compromised, for example, could continue to be addressed using Equality Act exemption provisions, where these organisations consider it necessary.

7.25 The Scottish Government's commitment to develop guidelines for policymakers and service providers to ensure that the rights of women and trans people can be collectively realised was welcomed. It was requested that guidance should be provided on how to comply with the Equality Act 2010, and how to apply the exemption rule in practical terms on the day-to-day running of services. One suggestion was that the expertise of women's organisations is used to develop and lead on guidance and information dissemination on the application of the Gender Recognition Act and Equality Act provisions in creating safe spaces for children and women, using the model of self-identification that has worked effectively for many years.

7.26 Finally, and reflecting the views expressed at Question 4, it was considered that there will be a significant negative impact on non-binary people if they are not covered by the reforms.

Those broadly opposed to a statutory declaration-based system

7.27 Those broadly opposed to a statutory declaration-based system tended very strongly to a different view. With respect to sex in particular it was suggested that the draft EQIA:

  • Fails to produce any evidence to support the Scottish Government's view that the proposed changes will not have a negative impact on women and girls, women-only spaces and services. If the Scottish Government wishes to weaken existing protections for single-sex spaces and services, it was argued that the burden of proof is on the Government to produce robust evidence that the change will not reduce privacy, dignity and safety for women.
  • Fails to analyse potential impacts arising from the likelihood that a GRC will enhance a person's legal rights of access to single-sex provision and the likely increase in both the number and the range of people who have a GRC.
  • Fails to consider psychological harm perpetrated on women by the presence of someone who is male-bodied.
  • Fails to consider impacts on lesbians and gay men, including by the erosion of understandings and provisions based on same-sex, not same-gender, attraction.

7.28 The Scottish Government's view that there is lack of evidence that including trans women in women-only services and spaces has negative impacts was challenged. Points raised included that:

  • There is a lack of any evidence around the actual experienced impacts of trans inclusion in services.
  • Absence of evidence is taken to mean evidence of absence and there is no acknowledgement that data is not gathered in a way which would allow the issues it raises to be examined.
  • The suggestion that 'lack of evidence around the actual experienced impacts of trans inclusion' is supported by the Gottschalk paper mentioned in the EQIA was disputed since, it was suggested, the author draws the opposite conclusion to that reached by the Scottish Government. [35]

7.29 With respect to crime and the potential impact on the prison system it was argued that, since any crimes committed by trans women are now recorded as women's crime, it is impossible to find evidence within available data that trans women still pose a male level of risk towards women and girls. Under a declaration-based system, it was suggested crimes committed by non-trans men masquerading as being trans would also be recorded as women's crime.

7.30 It was argued that the EQIA:

  • Offers no evidence to support the assertion that trans women who have undergone no physical changes depart from male pattern offending.
  • Fails to reference a large-scale Swedish study that compares levels of criminal convictions, including for violent offending, for women, men, fully surgically transitioned trans women and fully surgically transitioned trans men.
  • Overlooks cases in Scotland, the UK and elsewhere where males have self-identified as women and sought to abuse single-sex spaces. Several specific examples were cited.
  • Ignores the contributions of a former prison governor, as noted above.

7.31 With respect to operation of the single-sex exemptions available under paragraph 28 of schedule 3 of the Equality Act it was argued that, once a person has changed their birth certificate, there is no way for an organisation to distinguish between those who were or were not born female. Further, it was suggested that organisations may worry about their right to ask if a person holds a GRC, and it was noted that it will not be an offence for a person to make a misleading statement about their own GRC status.

7.32 A requirement that organisations in receipt of Government funding (for example through the Equally Safe Fund) must have trans inclusion policies in place was suggested to have implications in that:

  • It may fetter the discretion of funding recipients to invoke single-sex exceptions under the Equality Act 2010.
  • A requirement to provide evidence of trans inclusion policies does not require corresponding evidence of how providers will seek to implement those policies without harming female service users.

7.33 It was also argued that the EQIA should include evidence from both front-line workers and users of women's facilities - such as rape crisis centres – not just from those who run such services.

7.34 There was a concern that leaving the decision on admission to women's refuges to an individual operator to 'risk assess' risks failing to protect vulnerable women.

7.35 There was also a concern that evidence from several Women's Organisations about the potential for women's self-exclusion from specialist and mainstream women-only spaces and services, should they include trans women, has been overlooked. While it was acknowledged that the type of survey approach used to gather this evidence is not statistically representative, the same point was made with respect to Government consultations.

7.36 A number of examples were given of situations where women may self-exclude rather than share a space with a male bodied person. These included:

  • Female survivors of male sexual violence who feel forced to self-exclude when a rape crisis service cannot guarantee a female-only therapeutic environment.
  • Effects on minority groups – for example Muslim women who do not feel comfortable in certain spaces where biological males are present.
  • Self-exclusion from gyms and from lesbian groups.

7.37 Difficulties in using disaggregated data to distinguish offences committed by women and trans women were noted above. It was also noted that the EQIA makes no mention of other potential consequences of collecting gender-sensitive sex-disaggregated data, including with reference to the gender pay gap.

7.38 Given that the Scottish Government has established a working group on sex and gender in data, it was suggested the remit of that group and any relevant findings should have been published before consulting on gender recognition.


Those broadly in support of a statutory declaration-based system

7.39 Some of the comments relating to the protected characteristic of age focused on older people, including welcoming the EQIA's conclusion that the proposals will advance equality of opportunity for older people, in particular those who have been living in their acquired gender for a longer period and may not have access to the evidence required to apply to the GRP. Specifically, it was reported that people who transitioned before the 2004 Act was passed may not have kept records of their medical treatment and so would not be able to provide the record of diagnosis of gender dysphoria required under the current system.

7.40 Other comments included that trans people who are approaching end of life may wish to obtain legal gender recognition to ensure their gender is correctly recorded on their death certificate and this could be considered to be of particular benefit to older trans people.

7.41 Issues that were raised with specific reference to the EQIA included that younger people, in particular 16-18 year olds, may face particular barriers when applying for legal gender recognition because they feel constrained by their engagement with the education system.

7.42 Also in relation to younger people, and as covered at Question 3, there were calls to extend legal gender recognition to under 16s.

Those broadly opposed to a statutory declaration-based system

7.43 However, a concern was raised that the evidence cited in the EQIA (regarding a Swedish sample of six older trans people) is so small as to be unrepresentative and therefore unhelpful in informing large-scale policy decisions.

7.44 It was also that reported that figures show that trans men are over-represented in middle age and trans women are over-represented in younger age groups; there was a query as to why this is the case and whether any research is being carried out.

7.45 Also with regard to younger people, it was suggested that the EQIA does not consider:

  • Why high numbers of autistic girls are identifying as trans.
  • Why there has been a significant increase in the number of girls identifying as trans.
  • The relationship between age and detransition rates and why there is no information or research on this issue.

7.46 Finally, any suggestion that the proposed reforms will promote good relations among and between different age groups was seen as unconvincing.


7.47 A general comment was that the impact assessment has failed to make any reference to non-trans people with disabilities. The associated concern was that this means the impact on disability provision, for example if the reforms result in an increased user base of unisex disabled facilities such as changing rooms and public toilets, has been ignored.

Those broadly in support of a statutory declaration-based system

7.48 A number of the other disability-related comments focused on mental health and included support for the draft EQIA's recognition that having legal gender recognition with consistent documentation could have a positive impact on a trans person's mental health. An LGBT group respondent suggested that this is consistent with findings from their own research that trans people were disproportionately affected by mental health issues. It was suggested that, while the mental health inequalities faced by the trans population are not solely related to legal gender recognition, being able to access this without being subject to a distressing, humiliating process should boost wellbeing.

7.49 With regard to learning disabilities, the EQIA's reference to considering the need for clear and straightforward guidance for people with learning disabilities was welcomed and more generally it was suggested that the information given by the Registrar General should be made available in an accessible format for all applicants.

7.50 In relation to autism, the relevance of the evidence that has been cited in the EQIA with regards to the prevalence of autistic spectrum conditions within the trans population was questioned.

Those broadly opposed to a statutory declaration-based system

7.51 Other comments addressing mental health raised concerns or queries about the wider body of evidence available, or the coverage in the EQIA including that:

  • There are limited studies on mental health after transition. There was a query at why this is the case, and it was reported that a former member of staff from the Tavistock clinic has stated that the data and studies do not show that a child who transitions can expect higher levels of psychological health and life satisfaction.
  • Very much reflecting some of the concerns raised in relation to age, the 'data gaps identified' section does not cover the absence of evidence relating to young women and co-morbidities and specifically in relation to depression/anxiety, anorexia and autism.

7.52 Other comments about autism included that the coverage in the EQIA is not fit for purpose. It was suggested that the evidence reported seems thin, with weak conclusions being drawn from a lack of evidence, rather than leading to a conclusion that further research is needed.

7.53 There was a specific suggestion that the Gender Identity Development Service holds information on a higher prevalence of autistic spectrum conditions in clinically referred gender dysphoric adolescents than in the general adolescent population. This clinical observation was reported to have been reiterated in the wider international literature and it was argued to require further study.

Gender reassignment

There were relatively few comments which directly addressed the coverage of gender reassignment within the EQIA.

Those broadly in support of a statutory declaration-based system

7.54 Points raised in relation to the EQIA's coverage of gender reassignment included that:

  • As noted in relation to the protected characteristic of sex, non-binary people will continue to be unable to access legal recognition of their gender. As at Question 4, it was suggested that without their inclusion, the policy cannot be said to have a positive impact in advancing equality of opportunity for the whole trans community.
  • Similarly, and as covered at Question 3, there were calls to extend legal gender recognition to under 16s.

Those broadly opposed to a statutory declaration-based system

7.55 Those broadly opposed to a statutory declaration-based system tended to focus on regret and/or detransition.

7.56 There was a query as to the relevance of the evidence cited as to the level of regret associated with transitioning, particularly the evidence on regrets associated with medical interventions.

7.57 Others were concerned either about a lack of evidence, or that the evidence which is available has not been fully considered when developing the proposals. Issues raised were sometimes similar to those covered above in relation to mental health and included that the draft EQIA cites a large study in which 12% of transgender people who had undergone physical changes related to transitioning regretted them, while 43% regretted social changes they had made. It was also noted that suicide among transgender individuals is substantially elevated and regrets are a commonly cited reason for suicide.

7.58 There was an associated concern that the draft EQIA gives minimal coverage to regret and detransition and that, as suggested previously, insufficient research has been done, including in relation to the impact a change to a statutory declaration-based system may have.

7.59 It was also suggested that there has been a lack of engagement with people who have detransitioned in the impact assessments and that their views should be acknowledged and considered.


7.60 Comments in relation to race were very limited but included that the provisions relating to being 'ordinarily resident' in Scotland in order to apply for legal gender recognition need to be considered in the context of race being a protected characteristic.

7.61 It was also noted that the 'data gaps identified' section is blank and that this seems surprising.

Pregnancy and maternity

7.62 The limited number of comments that were made tended to focus on the need to consider the impact of the proposals on pregnancy and maternity and a perception and concern that the Scottish Government has not done so.

Those broadly in support of a statutory declaration-based system

7.63 Further comments included the suggestion that the existing position of designating the birth parent as a 'mother' could have a negative impact on people originally assigned female. The associated concern was that they may delay attempting to gestate a child and / or applying for legal gender recognition due to the lack of opportunity to register as 'parent' instead of 'mother'.

7.64 It was suggested that the Cross-Party Group on Sexual Health and Blood Borne Viruses should be consulted, including with reference to recently carried out research into trans healthcare and reproductive health.

Those broadly opposed to a statutory declaration-based system

7.65 From an alternative perspective, there were concerns that a trend whereby female-to-male trans people are keeping their wombs and declaring themselves to be 'pregnant men', and campaigning to be recognised as 'fathers', could be enshrined in policy and legislation; this was seen as automatically opening the door to discrimination against pregnant women and mothers. It was also suggested that the proposals would be very likely to lead to public sector bodies in Scotland changing their language to talk of 'pregnant people' so as to avoid litigation from trans activists.

Religion or Belief

Those broadly opposed to a statutory declaration-based system

7.66 It was argued that the EQIA should include a more explicit statement in relation to the protection of religion in respect of (for example) the freedom of conscience of healthcare workers and the freedom of parents and of schools to teach in accordance with their religious and ethical views.

7.67 It was suggested that the Scottish Government's proposals would enshrine belief in a person's right to self-determination in the public sector, setting up conflict with anybody whose religion or belief opposes this.

7.68 This was sometimes connected with a perception that some protected characteristics are seen as more important than others, and that the views of many people of faith, and of faith groups, have been side-lined.

7.69 There was disappointment that fuller consideration has not been given to the effect of a declaration-based system on communities of faith, including the evangelical community who, it was reported, would not recognise the term 'gender identity' as it is used in the consultation.

7.70 It was suggested the EQIA fails to recognise the potential impacts in respect of:

  • Religious gatherings, meetings, trips and holidays that currently segregate on the basis of sex.
  • Ministers of religion and the administration of religious services and/or rites; and
  • The potential impact of these proposals upon the efficacy of existing religious exemptions.


7.71 Many of the comments relating specifically to the CRWIA covered similar themes to those already raised in relation to the EQIA, and in relation to the protected characteristics of sex, age, disability and gender reassignment in particular. Many of the comments also returned to issues already set out in the analysis at Question 3.

Those broadly in support of a statutory declaration-based system

7.72 Comments by those broadly supporting a statutory declaration-based system included that the evidence presented is robust and helpful and that the proposal to extend legal gender recognition to 16- and 17-year olds can be seen as a reasoned response to the available evidence.

7.73 Another theme, as at Question 3, was in relation to under 16s. Comments included that, based on the information included in the CRWIA, it is unclear why a decision to extend legal gender recognition to those under 16 has not been taken. Specifically, it was noted that:

  • In making the case for reducing the minimum age to 16, consideration is given to all of the relevant articles of the UNCRC that may be engaged by lowering the age at which trans young people can apply for a GRC; these rights based arguments apply equally to under 16s.
  • The current impact assessment references evidence within the partial CRWIA completed for the 2018 consultation, but this evidence largely focuses on whether children experiencing some incongruence with their assigned gender would continue to experience this into adulthood, rather than focusing on children and young people who are confident of their gender.

7.74 The assertion that, due to puberty, children and young people may not be 'clear' about gender or sexuality was challenged. It was noted, for example, that young people going through puberty are already able to make significant decisions under Scots Law including instructing a lawyer from age 12. Further, it was suggested that sexuality is not a factor that should be considered in relation to legal recognition of gender.

7.75 Finally, it was suggested that the CRWIA does not sufficiently address the impact that lack of legal gender recognition will continue to have on under 16s. It was reported that children and young people sometimes have to present their birth certificate as proof of identification, and that being required to produce their unchanged birth certificate would mean they are placed at unnecessary risk of transphobic discrimination.

Those broadly opposed to a statutory declaration-based system

7.76 Additional issues raised by those broadly opposed to a statutory declaration-based system included that the CRWIA does not consider the impact of the proposals on children other than those seeking to change their gender legally. It was suggested that a study of the impact on all other children is required.

7.77 There were also queries as to the relevance of some of the research that has been cited. These included that:

  • Rebeca Robles et al "Removing transgender identity from the classification of mental disorders: a Mexican field study for ICD-11 is a study of adult transsexuals in Mexico City, mostly born male, mostly sex workers. It has no relevance to Scottish children who identify as trans, many of whom are female.
  • Dhejne C et al "Mental Health and gender dysphoria: A review of the literature (2016) is not a review of research about children or adolescents, it is about adults.

7.78 It was suggested that only research relevant to children and young people in Scotland should have been cited.

7.79 Other issues included that:

  • There seems to be an assumption that mental health issues are related to discrimination, but no evidence is presented to support this. More research is needed into the causes of mental health problems, especially among young people.
  • The CRWIA implies that puberty, rather than gender dysphoria, is a disorder. This needs to be corrected.
  • Accepting that there will not yet be a big pool of experience of those who have transitioned as children, it is nevertheless important to consider the impact on those who transitioned or began transitioning as children, and in particular the impact of medical and especially surgical treatment.

7.80 There were also concerns that the CRWIA downplays parental rights and that Gillick Competence[36] is not covered explicitly, which was seen as an omission.

7.81 The inclusion of references to Article 8 of the UNCRC, framed to suggest that the 'right to an identity' applies to the right to a gender identity, was considered highly controversial. It was reported to be clear that the original drafting (about name and nationality, religion, culture and language for example) had no such provision in mind.

Other assessments

7.82 There were only very limited comments about the other draft impact assessments.

7.83 On the draft FSDA, these included that it is welcome that the assessment recognises that the trans population may experience greater socio-economic disadvantage when compared with the general population, and that a reduction in the application fee would have a broadly positive impact. There was an associated recommendation that the Scottish Government should proceed with the option (Option A) for the Registrar General not to charge a fee.

7.84 The lack of robust data on trans people in the workplace in Scotland was noted, with the introduction of a 'trans status' question for the 2021 Census welcomed.[37] It was suggested that the Scottish Government should gather evidence on harassment and discrimination of trans people and transphobic hate crime.

7.85 Comments relating to the draft DPIA included that:

  • It is crucial that the privacy and dignity of trans people is protected and that such personal and sensitive information as an applicant's trans status and history is not compromised.
  • Section 22 exists to protect trans people's privacy and additional exceptions could jeopardise that privacy and could contravene ECHR Article 8 – the right to respect for a private and family life.

7.86 It was noted that the draft DPIA states that by removing the evidence requirements of the existing process, the new system of obtaining a GRC will not collect 'special category data' about applicants. A query was raised as to whether the fact that a person is trans, or that they have made an application for a GRC, may itself be considered 'special category data'. It was suggested that this issue is reviewed before the final DPIA is published.

7.87 Other suggestions included that:

  • Consideration should be given to research, since the relatively small numbers of trans people increases the potential identifiability of individuals following linkage of supposedly anonymous data sets. Under the 2004 Act, this could constitute non-permitted disclosure.
  • The draft Bill may be the only piece of legislation that removes a legal document - in this case a birth certificate - from the record. A process similar to that covering adoption should be followed, with a new certificate issued but the original retained and available to the appropriate authorities in future should they require it.
  • Given that awareness of the provisions of section 22 may be limited, practical guidance for employers, employees, public services and service users, in addition to prosecutors, may be useful.

7.88 With reference to the BRIA, it was reported that it does not discuss the cost of the current system.

7.89 It was noted that the BRIA says that a sheriff may revoke a GRC due to incapacity. This power was described as unnecessary and it was suggested that a GRC does not need to be revoked during a period of incapacity.



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