Parliament and is generally agreed to be extremely complicated.”77 The
memorandum also acknowledged that the ISC, Independent Reviewer,
and RUSI had all “concluded that the current framework was outdated,
unworkable and in need of reform” and that their “reports highlighted the
need for greater transparency, more stringent safeguards and better
oversight.”78
115.

In light of the powerful criticisms summarised above, the Government’s
submission that the existing legal regimes for bulk interception and
intelligence sharing are accessible, clear and effective is unsustainable.

IV.

SUMMARY OF THE PROCEDURAL HISTORY

116.

The Applicants summarise the IPT proceedings below, which are
described in greater detail at paras 9-21 of the Additional Submissions.

117.

Between June and December 2013, each of the Applicants lodged
complaints before the IPT. On 14 February 2014, the IPT directed that the
complaints be joined.

118.

Between 14 and 18 July 2014, the IPT held an open hearing. The hearing
concerned issues of law on the basis of assumed hypothetical factual
premises agreed between the parties. The IPT ordered that the hearing be
held inter partes and in public.

119.

On 10 September 2014, the IPT held a closed hearing at which it
considered, inter alia, the secret arrangements governing the bulk
interception and intelligence sharing regimes. The applicants were not
represented at the hearing.

77
78

Memorandum on Surveillance, para 3. Reply Annex No. 28.
Memorandum on Surveillance, para 5.

48

Select target paragraph3