Return of the Chagos to Mauritius

Media Coverage

Subsequent to the announcement there has been intensive worldwide press coverage which has frequently involved gross inaccuracies, misinformation, ill-informed comment and wild speculation. Whilst unreliable media output has become an increasingly common feature in today’s world the worrying aspect on this occasion is that some hitherto respectable and trusted media organisations also seem to be unable to provide objective and accurate reporting.

A particular example is that of The Times Newspaper, published in London. This has carried a number of recent articles:

·        “PM defies US to cede Chagos”, Oct 4;

·        “Giving up Chagos islands puts UK security at risk, say Tories”, Oct 8

and Editorials:

·        “Cast Away”, Oct 5

·        “Fiasco”, Oct 8

All of which contained inaccuracies and falsehoods highly likely to mislead the readership. Most worrying is that the Editorials have carried what can only be called irresponsible journalism. The source facts are sufficiently accessible to anyone yet little attempt appears to have been made to ascertain these.

The following critique illustrates and corrects examples of those errors. 

Articles and Editorials

The front-page story in The Times on Friday 4 October headlined that:

“PM defies US to cede Chagos – The islands have been handed to Mauritius in a deal allies warned could benefit China”.

It claimed that Sir Keir Starmer had “renounced sovereignty of the Chagos Islands” and mentioned unattributable warnings from the US and British officials that China could establish listening posts on other islands in the archipelago. As regards the historical status of the Chagos it simply stated that “The islands were administered as part of the colony of Mauritius”.

The following day the Letters Section of The Times contained criticism of the use of the unattributable and unsubstantiated warnings about China[1] [2].

On the same day, Saturday 5 October, The Times Editorial (“Cast Away”) launched a critical assault on the agreement, accusing the British Government, inter alia:

·        “In ceding the Chagos …. the government has …. surrendered sovereignty over a precious strategic asset”

·        “the certainty of sovereignty will be replaced by a 99-year British lease of Diego Garcia”

·        “In surrendering sovereignty, the government has bowed to a spurious claim driven by anti-colonialist sentiment in the UN”.

·        “Mauritius is 1,400 miles from BIOT and has no substantive links with it. The Mauritian claim is based wholly on the fact that the Chagos islands were administered from Mauritius when the latter was a British possession.”

The Editorial went on: “This [detachment] argued the [Mauritian] government in Port Louis violated the UN principle that colonial territories should not be divided before independence”. And it then cited examples of Pitcairn and Mayotte where it claimed that this had been done before, as if Britain’s actions in 1965 had been acceptable and despite the fact that neither were valid comparisons and were inaccurately reported.

Letter submitted criticising the Editorial

Several of those involved for decades with the Chagos from diplomatic, legal and political spheres sought to challenge the Editorial by a letter submitted to The Times on Sunday 6 October. The Times declined to publish, saying that it was “too long and Richard Dunne [one of the 4 authors] was on the letters page the previous day, so I'm afraid we simply didn't have space for it …. I think the moment has now passed, but doubtless the subject will crop up again.”

[1] Richard Dunne, 5 October, Letter

[2] Further on the China ‘threat’ see the discussion in: https://thediplomat.com/2023/09/why-boris-johnson-is-wrong-about-the-british-indian-ocean-territory/

Further articles and Editorials by The Times 8 October

Following an Oral Statement to the House of Commons on Monday 7 October by the Foreign Secretary, David Lammy, and a subsequent debate, The Times published a further article on Tuesday 8 October titled “Giving up Chagos islands puts UK security at risk, say Tories”, and another even more critical Editorial, (“Fiasco – David Lammy has sold out not only an entire people but Britain’s national interest”).

The article erroneously described the UK/US base on Diego Garcia as an “RAF base”. It reiterated the claims that the agreement would “hand China a strategic advantage”.

The increasingly vitriolic Editorial commenced with an analogy of a landowner surrendering his land to an interloper, implying that Mauritius was no more than a “distant neighbour” with “no history of practical involvement” with the Chagos, and that the government had agreed to “cede ownership of the Chagos”, “surrendering sovereignty … to a country that flirts openly with China.”

It went on to describe as “an archaic principle of international law” the requirement that colonial territories should not be divided before independence. This was clearly a reference to UN Resolution 1514(XV) adopted by the General Assembly on 14 December 1960 (and still in force), entitled “Declaration on the Granting of Independence to Colonial Countries and Peoples” which so as to prevent dismemberment of non-self-governing territories (such as Mauritius and Chagos), provides that:

“Any attempt aimed at the partial or total disruption of the national unity and the territorial integrity of a country is incompatible with the purposes and principles of the Charter of the United Nations” [paragraph 6, resolution 1514 (XV)]

Repeating what had been said in the earlier 5 October Editorial, it was again claimed that “Mauritius’s only connection with Chagos, 1.400 miles away, was as host of the regional British administration” describing this as a “flimsy pretext for a Mauritian claim”. It concluded: “a lease [over Diego Garcia] is no substitute for sovereignty” and “British territory is being surrendered to lawfare”.

Inaccuracies in the Articles and Editorials

Mauritius’s historical claim to Chagos

The articles and Editorials variously described Mauritius relationship with the Chagos Archipelago as:

·       “The islands were administered as part of the colony of Mauritius” [4 Oct]

·      “Mauritius is 1,400 miles from BIOT and has no substantive links with it. The Mauritian claim is based wholly on the fact that the Chagos islands were administered from Mauritius when the latter was a British possession.” [Editorial 5 Oct]

·        Mauritius a “distant neighbour” with “no history of practical involvement” with the Chagos [Editorial 8 Oct]

·      “Mauritius’s only connection with Chagos, 1.400 miles away, was as host of the regional British administration” describing this as a “flimsy pretext for a Mauritian claim” [Editorial 8 Oct]

The use of a distance (1,400 miles from Mauritius) to somehow imply the lack of any connection is disingenuous. The Chagos Archipelago is remote from other landmasses. Its nearest neighbours are the Maldives (~400 miles), India and Sri Lanka (~1,000 miles), and Seychelles (~1,200 miles). Is there a suggestion that one of these closer neighbours has a better claim to sovereignty? Or perhaps the UK, a mere 6,000 miles distant is the best candidate!

And what are the facts of the link between Mauritius and the Chagos during the days of British colonial rule over its former colony between 1814 and 1965? Both Mauritius and Britain had ample opportunity to present evidence of this to the International Court of Justice (ICJ) and did so in their written and oral submissions. These are freely accessible on the ICJ website [1].

Britain[2] maintained that Chagos was administered “purely as a matter of convenience- as a Dependency of Mauritius”[3] and emphasised that this was “very loosely” so; that contact between Mauritius and Chagos was “minimal”; “the islands were privately owned” and had “no economic relevance to Mauritius”. It admitted however that under the Mauritius (Constitution) Order 1964 which British officials had drawn up, “Mauritius included its Dependencies which included the Chagos Archipelago”[4].

In creating the British Indian Ocean Territory in 1965, the UK also admitted that it had relied upon the Colonial Boundaries Act 1895[5], a British Act of Parliament used to alter the boundaries of its colonies[6].

Mauritius argued[7] with a long list of examples, that:

“The historical and colonial record clearly demonstrates that the Chagos Archipelago has been an integral part of Mauritius. Under French colonial occupation and then throughout more than 150 years of British rule, Mauritius and the Chagos Archipelago were governed as part of the same, indivisible unit. The U.N. and the international community have recognised that the Chagos Archipelago has always been an integral part of Mauritius. Judges in the U.K.’s highest court, at the European Court of Human Rights and in international arbitral proceedings have consistently expressed the view that the Chagos Archipelago has been part of the colony of Mauritius. There is no legal or judicial authority of which Mauritius is aware in support of a contrary position. The conduct and practice of British authorities in particular, including statements by U.K. officials and representatives at the highest levels, are incompatible with a view which does not recognise that the main Island of Mauritius and the Chagos Archipelago have always been treated in law and in fact as part of the same territory”[8].

In response, the UK[9] claimed that “Mauritius’ narrative of the events is not based on a fair or accurate portrayal of the facts”[10]. Once again it emphasised the remoteness, the looseness of the administration, and insignificant ties, claiming that “In the British context, dependencies could be, and often were, detached or attached as between one colony and another by exercise of the Royal Prerogative”[11] giving as an example the detachment of the Seychelles in 1903. It even attempted to draw support from the words of the Premier of Mauritius who in 1983 had described the Chagos as “islands very remote” and a “portion of our territory of which very few people knew”[12] [underlining added] unappreciative of the fact that these actually undermined its case.

The UK again presented its argument concerning the relationship at the hearing of the ICJ on 3 September 2018[13] claiming that Chagos was merely “attached” and not an integral part of Mauritius.

What did the Court make of these arguments? It clearly rejected the arguments of the UK and concluded that[14]:

28. Between 1814 and 1965, the Chagos Archipelago was administered by the United Kingdom as a dependency of the colony of Mauritius. From as early as 1826, the islands of the Chagos Archipelago were listed by Governor Lowry-Cole as dependencies of Mauritius. The islands were also described in several ordinances, including those made by Governors of Mauritius in 1852 and 1872, as dependencies of Mauritius. The Mauritius Constitution Order of 26 February 1964 (hereinafter the “1964 Mauritius Constitution Order”), promulgated by the United Kingdom Government, defined the colony of Mauritius in section 90 (1) as “the island of Mauritius and the Dependencies of Mauritius”.

29. In accordance with General Assembly resolution 66 (I) of 14 December 1946, the United Kingdom as the administering Power regularly transmitted information to the General Assembly under Article 73 (e) of the Charter of the United Nations concerning Mauritius as a nonself-governing territory. The information submitted by the United Kingdom was included in several reports of the Fourth Committee (Special Political and Decolonization Committee) of the General Assembly. In many of these reports, the islands of the Chagos Archipelago, and sometimes the Chagos Archipelago itself, are referred to as dependencies of Mauritius. In its 1947 Report, Mauritius is described as comprising the island of Mauritius and its dependencies among which are mentioned the island of Rodriguez and the Oil Islands group of which the principal island is Diego Garcia. The Report of 1948 collectively referred to all of the islands as “Mauritius”. The Report of 1949 states that “there are dependent upon Mauritius a number of islands scattered over the Indian Ocean, of which the most important is Rodriguez . . . Other dependencies are: Chagos Archipelago . . . Agalega and Cargados Charajos”.

On the basis of the parties’ evidence to the ICJ and the Court’s summary of these facts it is therefore entirely untrue to characterise Mauritius’s claim to the islands in the manner presented by The Times in its partisan reporting, revealing only gross ignorance of the facts. Moreover, the use of terms such as “flimsy pretext” border on the offensive.

If we look into the historical records, at the time of the detachment of the islands in 1965, Britain clearly recognised that they were an integral part of Mauritius, viz:

·        the necessity to use powers under the Colonial Boundaries Act 1895 to alter the boundaries of the colony of Mauritius;

·        in defining them as “the Chagos Archipelago, being islands which immediately before the date of this Order were included in the Dependencies of Mauritius” in the British Indian Ocean Territory Order 1965;

·        in SECRET government documents from 1965 which record that “The Chagos Archipelago   .. belongs to Mauritius” and that it would be necessary in consequence to amend the Mauritius (Constitution) Order in Council 1964[15].

If this was not enough, Britain in committing to “return” the Chagos to Mauritius “if the need for the facilities on the islands disappeared” in an undertaking in the 1965 Lancaster House Agreement which has since been ruled to be binding[16] further illustrates a recognition by all concerned that Mauritius was entitld to consider the Chagos part of its territory at the time.

From 1965 for the next 15 years the UK was true to the original wording of this undertaking. For example, on 21 October 1975 Mr Ennals [Minister of State for Foreign and Commonwealth Affairs] said that £3m was granted to Mauritius 'as compensation for the loss of sovereignty over the Chagos Archipelago'. The BIOT Commissioner was later (in 1983) to write[17]: “This was, and is, a potentially embarrassing statement”. On 23 March 1976 a UK Minister wrote to the Mauritian High Commissioner in London explicitly using the word “returned”[18] and on 11 July 1980 Margaret Thatcher, the British Prime Minister, informed Parliament that “in the event of the islands [Chagos] no longer being required for defence purposes, they should revert to Mauritius. This remains the policy of Her Majesty’s Government”[19].

By 1980 however, moves were afoot within the Foreign and Commonwealth Office to alter the use of “return” to “cede” as reflected by a 1983 briefing by the BIOT Commissioner to UKMIS in New York and British High Commissioners in New Delhi and Mauritius[20]: “We are of course keen to avoid any suggestion that Mauritius has sovereignty. We also maintain that Mauritius never did have sovereignty”. Referring to earlier use of “return” and “revert”, the Commissioner rather tellingly admitted that: “If reminded of the 1975 answer, we should probably have to say something to the effect that all that Mauritius was being compensated for was not receiving the sovereignty it would otherwise have acquired on independence” a clear acknowledgment that Mauritius had been deprived of sovereignty in 1968.

Since the early 1980s the UK has consistently avoided repeating the undertaking in the terms originally agreed as if doing so will somehow alter its original promise.

However, even in the repetition of the promise in terms of “ceding” the Chagos to Mauritius, Britain was admitting that Mauritius alone, and no other State, had any claim to the islands. Indeed, the exclusivity of Mauritius had already been assured in 1965 when the British Governor of Mauritius, Sir John Rennie, informed the Colonial Secretary[21] that:

Council of Ministers today confirmed agreement to the detachment of the Chagos Archipelago on conditions enumerated, on the understanding that

……

(2) As regards (vii) undertaking[22] to Legislative Assembly excludes

(a) sale or transfer by H.M.G. to third party or

(b) any payment or financial obligation by Mauritius as condition of return.

On 19 November 1965 the Colonial Secretary confirmed that “as regards point (vii) the assurance can be given provided it is made clear that a decision about the need to retain the islands must rest entirely with the United Kingdom Government …..”.[23]

Both the ICJ proceedings and these historical documents illustrate just how poorly informed The Times Editorial of 8 October was on this point.

Sovereignty over the Chagos since 1965.

The words used by The Times consistently suggest that Britain is now ‘ceding’ or ‘surrendering’ sovereignty over the Chagos:

·        “PM defies US to cede Chagos” [Oct 4]

·        “Sir Keir Starmer has renounced sovereignty of the Chagos” [Oct 4]

·        “In ceding the Chagos …. the government has …. surrendered sovereignty over a precious strategic asset” [Editorial 5 Oct]

·        “Britain is to surrender sovereignty of the Chagos archipelago to Mauritius” [Editorial 5 Oct]

·        “the certainty of sovereignty will be replaced by a 99-year British lease of Diego Garcia” [Editorial 5 Oct]

·        “In surrendering sovereignty, the government has bowed to a spurious claim driven by anti-colonialist sentiment in the UN”. [Editorial 5 Oct]

·        “cede ownership of the Chagos” [Editorial 8 Oct]

·        “surrendering sovereignty … to a country that flirts openly with China.” [Editorial 8 Oct]

·        “British territory is being surrendered to lawfare”. [Editorial 8 Oct]

Such terminology presumes that Britain still retains sovereignty over the Chagos, but is this so?

Britain exercised sovereignty over its colony of Mauritius following cession by the French in the Treaty of Paris in 1814 and this continued to be so until 1965. The aim of detaching the islands from Mauritius to form a new colony of the British Indian Ocean Territory (BIOT) was to preserve British sovereignty into the future and avoid the islands becoming part of Mauritius. At the time of this detachment, Mauritius was progressing towards self-governance from Britain like many other colonies at the time, a process known as decolonisation. Independence was completed 3 years later in 1968.

Following WWII, State practice on decolonisation evolved under the auspices of the United Nations. Over time, certain features governing the process have become embedded in customary international law and in so doing these bind all nation States.

Members of the UN who administered colonies, such as Britain, that had not attained a full measure of self-government were required under Article 73 of the UN Charter[24] “as a sacred trust …. to promote to the utmost…. the well-being of the inhabitants” and were obliged to “develop self-government” of those peoples.

In 1960 a defining moment in State practice of decolonisation was the adoption of UNGA Resolution 1514(XV)[25]. This clarified the content and scope of the right of peoples of a colony to “self-determination” to determine their own destiny. The resolution also provided for “the transfer of power without any conditions or reservations, in accordance with the freely expressed will and desire [of the people]” and stated that “Any attempt aimed at the partial or total disruption of the national unity and the territorial integrity of a country is incompatible with the purposes and principles of the Charter of the United Nations”.

To refer to such important rules of State practice in relation to decolonisation as “an archaic principle of international law” (The Times Editorial 8 Oct) displays only ignorance and is irresponsible. For a newspaper which in the words of its former editor, John Witherow, “is an authoritative, credible, responsible and trusted part of the nation’s cultural heritage”[26] (reiterated by the present editor[27]) it represents a particularly important failure. It is inconceivable that The Times would advance a similar argument were the UK to attempt to ignore the wishes of the people of the Falkland Islands or to detach part of that colony (now called a “British Overseas Territory”).

It was in this context that Britain detached the Chagos and between 1967 and 1973 with US complicity compulsorily deported all the islanders, mainly to Mauritius but some to the Seychelles. In so doing Britain made no attempt to comply with Resolution 1514 (XV) and lied to the UN and the world concerning the status of the inhabitants.

The consequences of the detachment and failure to allow Mauritians (including Chagossians) to exercise the right to self-determination in 1965 was examined by the ICJ in its Advisory Opinion on 25 February 2019[28].

The ICJ considered that the 1960 Resolution 1514 (XV) had a declaratory character and by 1965 the right to self-determination had become a customary norm of international law, with the necessity for “the free and genuine will of the people concerned”[29] to be applied to “the entirety of a non-self-governing territory”[30], in other words in the case of Mauritius this also included the Chagos Islands.

As regards the detachment of the Chagos, the ICJ observed that:

“No example has been brought to the attention of the Court in which, following the adoption of resolution 1514 (XV), the General Assembly or any other organ of the United Nations has considered as lawful the detachment by the administering Power of part of a non-self-governing territory, for the purpose of maintaining it under its colonial rule.”[31]

“The Court considers that the peoples of non-self-governing territories are entitled to exercise their right to self-determination in relation to their territory as a whole, the integrity of which must be respected by the administering Power. It follows that any detachment by the administering Power of part of a non-self-governing territory, unless based on the freely expressed and genuine will of the people of the territory concerned, is contrary to the right to self-determination”.

The ICJ concluded that the breach of this customary norm of self-determination by Britain meant that the detachment had been unlawful. It follows that any claim by Britain to sovereignty over the Chagos after the detachment fails, and that following independence in 1968 the new state of Mauritius became sovereign over all of the former colony, including the Chagos Archipelago.

Immediately following the Advisory Opinion, the UK’s repeated response was that “An Advisory Opinion of the ICJ is advice provided to the United Nations General Assembly at its request; it is not a legally binding judgment”[32]. In so doing, however, it ignored the effect of the declaratory statement on the customary law of self-determination.

Indeed, as recently as 2023 other organisations[33] which attempt to lobby and influence Parliamentarians have similarly ignored the binding effect of the customary international law of decolonisation on all sovereign States.

Over time we may conclude that the official UK position softened and it has come to realise that to deny that the ICJ Advisory Opinion has any effect in international law is untenable. No doubt influenced by, inter alia:

·        UNGA Resolution 73/295 of 22 May 2019 which demanded that the UK withdraw its colonial administration from the Chagos within 6 months and where support for the UK in the UNGA crumbled (116 votes for the resolution, 6 against[34] and 56 abstentions).

·        a judgment of the International Tribunal for the Law of the Sea in the dispute between Mauritius and Maldives over the delimitation of the maritime boundary between the Chagos and Maldive islands [35], where the Tribunal ruled that the Advisory Opinion had decided the issue of Mauritian sovereignty over the Chagos and accordingly Mauritius was the coastal state for the purposes of the delimitation.

It is notable that until early 2022 the UK continued to claim sovereignty, repeatedly stating that it had “no doubt as to our sovereignty over BIOT, which we have held continuously since 1814”[36].

The language changed however and by December 2022 when challenged, it responded that it had commenced negotiations with Mauritius on the “exercise of sovereignty over the British Indian Ocean Territory/Chagos Archipelago”[37]. The certainty of its claim instantly evaporating by the change of terminology. The announcement of the negotiations had been made earlier on 3 November 2022 by the Foreign Secretary, James Cleverly[38] where he again had referred to these as concerning “the exercise of sovereignty”. Throughout the 2 year period of negotiations Britian has never used the term ‘cede’ nor any word or phrase suggesting it was surrendering or transferring sovereignty.

The words of the Foreign Secretary, David Lammy, on 7 October 2024[39] in Parliament represents the final recognition by the UK that any continuing claim to sovereignty is unsustainable:

“Since its creation, the territory and the joint UK-US military base on Diego Garcia have had a contested existence. In recent years, the threat has risen significantly. When we came into office, the status quo was clearly not sustainable. A binding judgment against the UK seemed inevitable, and it was just a matter of time before our only choices would have been abandoning the base altogether or breaking international law”.

So, by failing to allow Mauritius (including Chagossians) freely to exercise the right to self-determination at the relevant time, the detachment to create a new British colony (the British Indian Ocean Territory [BIOT]) was from the outset unlawful. The consequence is that Britain does not have and has not held sovereignty over the Chagos for the last 59 years. Since Britain does not have sovereignty, it follows that it cannot 'cede', ‘surrender’ or ‘renounce’ sovereignty over the islands to any other State. Commentators who continue to use these terms and to question the decision by the UK to recognise the status quo have clearly failed to appreciate the relevant facts, or in the alternative have chosen to ignore them. The Times falls into this category.

REFERENCES

[1] https://www.icj-cij.org/case/169

[2] Written Statement of the UK 15 February 2018

[3] Ibid para 2.17

[4] Ibid para 2.29

[5] Wrongly dated as 1890 in the UK’s statement

[6] Ibid para 2.31

[7] Written Statement of the Republic of Mauritius 1 March 2018

[8] Ibid para 2.48

[9] Written Comments of the UK 14 May 2018

[10] Ibid para 2.3

[11] Ibid para 2.9

[12] Ibid para 2.12

[13] Legal Consequences of the Separation of the Chagos Archipelago from Mauritius in 1965 Verbatim Record 3 September 2018 No 21 at paras 19-21

[14] Ibid, paras 28-29

[15] Anglo-US Strategic Interests in the Indian Ocean – Detachment of Islands. FCO 141/1422 National Archives, London. Folio 2.

[16] In the Matter of the Chagos Marine Protected Area, Award of the Arbitral Tribunal constituted under Annex VII of the UN Convention on the Law of the Sea. 18 March 2015. Tis Award was binding on the UK and Mauritius.

[17] National Archives, London, File FCO 31/3835 Folio 27. Letter dated 25 March 1983 from Mr Wenban-Smith to MJ Williams – “Mauritius – Claim to BIOT”.

[18] Arbitral Tribunal Award para 430(a).

[19] Parliamentary Question, House of Commons, Hansard Vol 988.

[20] National Archives, London, File FCO 31/3835 Folio 27. Letter dated 25 March 1983 from Mr Wenban-Smith to MJ Williams – “Mauritius – Claim to BIOT”.

[21] National Archives, London, File FO 371/184529 In Folio 24/181/G. Inward telegram from Sir J Rennie to Secretary of State for Colonies dated 5 November 1965.

[22] The undertaking to return the islands to Mauritius.

[23] National Archives, London, File FO 371/184529 In Folio 24/181/G. Telegram from Secretary of State for the Colonies to Sir J Rennie dated 19 November 1965.

[24] https://www.un.org/en/about-us/un-charter/chapter-11

[25] https://www.ohchr.org/en/instruments-mechanisms/instruments/declaration-granting-independence-colonial-countries-and-peoples

[26] https://www.northern-scot.co.uk/news/national/article/john-witherow-steps-down-as-times-editor-after-nine-years-59371/

[27] https://www.news.co.uk/our-brands/the-times/

[28] Legal Consequences of the Separation of the Chagos Archipelago from Mauritius in 1965. Advisory Opinion of the International Court of Justice. 25 February 2019. https://www.icj-cij.org/case/169/advisory-opinions

[29] Ibid para 157

[30] Ibid para 158

[31] Ibid para 160

[32] Answer to Parliamentary Question 259287 – 6 June 2019: https://questions-statements.parliament.uk/written-questions/detail/2019-06-03/259287

[33] For example the Policy Exchange (Sovereignty and Security in the Indian Ocean – Why the UK should not cede the Chagos Islands to Mauritius) 2023: https://policyexchange.org.uk/publication/sovereignty-and-security-in-the-indian-ocean/

[34] One of those voting in support of the UK , the Maldives, has since changed its mind.

[35] https://www.itlos.org/en/main/cases/list-of-cases/dispute-concerning-delimitation-of-the-maritime-boundary-between-mauritius-and-maldives-in-the-indian-ocean-mauritius/maldives/

[36] For example Parliamentary question 138065: https://questions-statements.parliament.uk/written-questions/detail/2022-03-10/138065/

[37] Parliamentary question 110650: https://questions-statements.parliament.uk/written-questions/detail/2022-12-14/110650

[38] House of Commons Written Statement HCWS354: https://questions-statements.parliament.uk/written-statements/detail/2022-11-03/hcws354

[39] https://hansard.parliament.uk/Commons/2024-10-07/debates/81AA365A-E64B-41C7-929A-38E8DD4FC72F/BritishIndianOceanTerritoryNegotiations