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in 1994, and a Law Commissioner for England and Wales from 1994 to 1999. His work as a Law Commissioner included co-authorship of the Law Commission's Report No. 242 (Privity of Contract: Contracts for the Benefit of Third Parties), published in 1996 under the chairmanship of Lady Arden of Heswall (then The Honourable Mrs Justice Arden, DBE). This led to the Contracts (Rights of Third Parties) Act 1999,

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