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Despite the availability of effective vaccines against COVID-19, booster vaccinations are needed to maintain vaccine-induced protection against variant strains and breakthrough infections. This study aimed to investigate the efficacy, safety, and immunogenicity of the Ad26.COV2.S vaccine (Janssen) as primary vaccination plus a booster dose.ENSEMBLE2 is a randomised, double-blind, placebo-controlled, phase 3 trial including crossover vaccination after emergency authorisation of COVID-19 vaccines. Adults aged at least 18 years without previous COVID-19 vaccination at public and private medical practices and hospitals in Belgium, Brazil, Colombia, France, Germany, the Philippines, South Africa, Spain, the UK, and the USA were randomly assigned 1:1 via a computer algorithm to receive intramuscularly administered Ad26.COV2.S as a primary dose plus a booster dose at 2 months or two placebo injections 2 months apart. The primary endpoint was vaccine efficacy against the first occurrence of molecularly confirmed moderate to severe-critical COVID-19 with onset at least 14 days after booster vaccination, which was assessed in participants who received two doses of vaccine or placebo, were negative for SARS-CoV-2 by PCR at baseline and on serology at baseline and day 71, had no major protocol deviations, and were at risk of COVID-19 (ie, had no PCR-positive result or discontinued the study before day 71). Safety was assessed in all participants; reactogenicity, in terms of solicited local and systemic adverse events, was assessed as a secondary endpoint in a safety subset (approximately 6000 randomly selected participants). The trial is registered with ClinicalTrials.gov, NCT04614948, and is ongoing.Enrolment began on Nov 16, 2020, and the primary analysis data cutoff was June 25, 2021. From 34 571 participants screened, the double-blind phase enrolled 31 300 participants, 14 492 of whom received two doses (7484 in the Ad26.COV2.S group and 7008 in the placebo group) and 11 639 of whom were eligible for inclusion in the assessment of the primary endpoint (6024 in the Ad26.COV2.S group and 5615 in the placebo group). The median (IQR) follow-up post-booster vaccination was 36·0 (15·0-62·0) days. Vaccine efficacy was 75·2% (adjusted 95% CI 54·6-87·3) against moderate to severe-critical COVID-19 (14 cases in the Ad26.COV2.S group and 52 cases in the placebo group). Most cases were due to the variants alpha (B.1.1.7) and mu (B.1.621); endpoints for the primary analysis accrued from Nov 16, 2020, to June 25, 2021, before the global dominance of delta (B.1.617.2) or omicron (B.1.1.529). The booster vaccine exhibited an acceptable safety profile. The overall frequencies of solicited local and systemic adverse events (evaluated in the safety subset, n=6067) were higher among vaccine recipients than placebo recipients after the primary and booster doses. The frequency of solicited adverse events in the Ad26.COV2.S group were similar following the primary and booster vaccinations (local adverse events, 1676 [55·6%] of 3015 vs 896 [57·5%] of 1559, respectively; systemic adverse events, 1764 [58·5%] of 3015 vs 821 [52·7%] of 1559, respectively). Solicited adverse events were transient and mostly grade 1-2 in severity.A homologous Ad26.COV2.S booster administered 2 months after primary single-dose vaccination in adults had an acceptable safety profile and was efficacious against moderate to severe-critical COVID-19. Studies assessing efficacy against newer variants and with longer follow-up are needed.Janssen ResearchDevelopment.

Emerging SARS-CoV-2 variants and evidence of waning vaccine efficacy present substantial obstacles towards controlling the COVID-19 pandemic. Booster doses of SARS-CoV-2 vaccines might address these concerns by amplifying and broadening the immune responses seen with initial vaccination regimens. We aimed to assess the immunogenicity and safety of a homologous booster dose of a SARS-CoV-2 recombinant spike protein vaccine (NVX-CoV2373).This secondary analysis of a phase 2, randomised study assessed a single booster dose of a SARS-CoV-2 recombinant spike protein vaccine with Matrix-M adjuvant (NVX-CoV2373) in healthy adults aged 18-84 years, recruited from 17 clinical centres in the USA and Australia. Eligible participants had a BMI of 17-35 kg/msup2/supand, for women, were heterosexually inactive or using contraception. Participants who had a history of SARS-CoV or SARS-CoV-2, confirmed diagnosis of COVID-19, serious chronic medical conditions, or were pregnant or breastfeeding were excluded. Approximately 6 months following their primary two-dose vaccination series (administered day 0 and day 21), participants who received placebo for their primary vaccination series received a placebo booster (group A) and participants who received NVX-CoV2373 for their primary vaccination series (group B) were randomly assigned (1:1) again, via centralised interactive response technology system, to receive either placebo (group B1) or a single booster dose of NVX-CoV2373 (5 μg SARS-CoV-2 rS with 50 μg Matrix-M adjuvant; group B2) via intramuscular injection; randomisation was stratified by age and study site. Vaccinations were administered by designated site personnel who were masked to treatment assignment, and participants and other site staff were also masked. Administration personnel also assessed the outcome. The primary endpoints are safety (unsolicited adverse events) and reactogenicity (solicited local and systemic) events and immunogenicity (serum IgG antibody concentrations for the SARS-CoV-2 rS protein antigen) assessed 14 days after the primary vaccination series (day 35) and 28 days following booster (day 217). Safety was analysed in all participants in groups A, B1, and B2, according to the treatment received; immunogenicity was analysed in the per-protocol population (ie, participants in groups A, B1, and B2) who received all assigned doses and who did not test SARS-CoV-2-positive or received an authorised vaccine, analysed according to treatment assignment). This trial is registered with ClinicalTrials.gov, NCT04368988.1610 participants were screened from Aug 24, 2020, to Sept 25, 2020. 1282 participants were enrolled, of whom 173 were assigned again to placebo (group A), 106 were re-randomised to NVX-CoV2373-placebo (group B1), and 104 were re-randomised to NVX-CoV2373-NVX-CoV2373 (group B2); after accounting for exclusions and incorrect administration, 172 participants in group A, 102 in group B1, and 105 in group B2 were analysed for safety. Following the active booster, the proportion of participants with available data reporting local (80 [82%] of 97 participants had any adverse event; 13 [13%] had a grade ≥3 event) and systemic (75 [77%] of 98 participants had any adverse event; 15 [15%] had a grade ≥3 event) reactions was higher than after primary vaccination (175 [70%] of 250 participants had any local adverse event, 13 [5%] had a grade ≥3 event; 132 [53%] of 250 had any systemic adverse event, 14 [6%] had a grade ≥3 event). Local and systemic events were transient in nature (median duration 1·0-2·5 days). In the per-protocol immunogenicity population at day 217 (167 participants in group A, 101 participants in group B1, 101 participants in group B2), IgG geometric mean titres (GMT) had increased by 4·7-fold and MNsub50/subGMT by 4·1-fold for the ancestral SARS-CoV-2 strain compared with the day 35 titres.Administration of a booster dose of NVX-CoV2373 resulted in an incremental increase in reactogenicity. For both the prototype strain and all variants evaluated, immune responses following the booster were similar to or higher than those associated with high levels of efficacy in phase 3 studies of the vaccine. These data support the use of NVX-CoV2373 in booster programmes.Novavax and the Coalition for Epidemic Preparedness Innovations.

This paper examines the law on good character evidence in criminal trials through a discussion of the important but under-analysed case of Hunter, in which a five-judge Court of Appeal sought to clarify the law on good character directions to the jury. However, it is argued here that the judgment conflicts with the leading House of Lords decision in Aziz. The paper considers how the court misinterpreted the law and, in particular, the defeasible nature of the rule in Aziz and the impact of the Criminal Justice Act 2003. As a result, the circumstances in which a good character direction will be provided have diminished significantly. It is argued that this has important implications for the right to a fair trial, as good character directions act as a ‘backstop’ against miscarriages of justice. They also form a vital part of the ‘framework of fairness’ considered necessary, in lieu of reasoned jury verdicts, by the Grand Chamber of the European Court of Human Rights in Taxquet v Belgium. Accordingly, it is contended that Aziz rather than Hunter should be followed so that, where there is evidence of good character, a direction is normally provided as a matter of law.

This article explores similarities between the permutational processes in sound poetry and process music, suggesting models for new music which supports audience comprehension of processual languag...

Background Provision of care and support for people with dementia and family carers is complex, given variation in how dementia manifests, progresses and affects people, co-morbidities associated with ageing, as well as individual preferences, needs, and circumstances. The traditional service-led approach, where individual needs are assessed against current service provision, has been recognised as unfit to meet such complexity. As a result, people with dementia and family members often fail to receive adequate support, with needs remaining unmet. Current research lacks a conceptual framework for explaining variation in satisfaction of care needs. This work develops a conceptual framework mapped onto the care delivery process to explain variations in whether, when and why care needs of people with dementia are met and to expose individual-, service-, system-level factors that enable or hinder needs satisfaction. Methods Data collected through 24 in-depth interviews and two focus groups (10 participants) with people with dementia and family carers living in the North East of England (UK) were analysed thematically to develop a typology of care needs. The need most frequently reported for people with dementia (i.e. for support to go out and about) was analysed using themes stemming from the conceptual framework which combined candidacy and discrepancy theories. Results The operationalisation of the framework showed that satisfaction of the need to go out was first determined at the point of service access, affected by issues about navigation, adjudication, permeability, users’ resistance to offers, users’ appearance, and systems-level operating conditions, and, subsequently, at the point of service use, when factors related to service structure and care process determined (dis)satisfaction with service and, hence, further contributed to met or unmet need. Conclusion The conceptual framework pinpoints causes of variations in satisfaction of care needs which can be addressed when designing interventions and service improvements.

We report viscosities of liquid hexadecane measured at temperatures between 323 K and 673 K and at pressures up to 4.0 MPa. This study significantly extends the temperature range over which viscosity data for hexadecane are available. The experiments were carried out using a dual-capillary viscometer that measures the ratio of the viscosity at the temperature in question to that at a reference temperature, 298.15 K in this work, at which the viscosity is well known. Absolute viscosities were then obtained with an estimated expanded relative uncertainty of about 3% at 95% confidence. An empirical function was developed to correlate the viscosity ratio with the density ratio and this fitted the experimental data within about 1%. The results were found to agree well with the existing literature data.

This chapter is concerned with the potential impact on prosecutions under the Fraud Act 2006 of the Court of Appeal’s judgment in Hunter Hunter [2015] 1 WLR 5367. This purported to provide greater clarity in the law on good character. However, it is argued here that there is an unresolved conflict between the judgment in Hunter Hunter and that of the leading case of Aziz Aziz [1996] AC 41 which, with respect, the Court of Appeal appears to have misinterpreted and misconstrued. It is argued here that as proving guilt for offences under the Fraud Act 2006 often hinges on the uncertain concept of dishonesty, to which the defendant’s good character can be of central importance, the consequences of the changes to the law brought about by Hunter Hunter will be especially significant for Fraud Act 2006 defendants.

IntroductionPatients with long-term conditions consistently report a lack of information around services and support available to them. This unmet need for information is significant among people with dementia and family carers. A quality improvement intervention is being carried out to tackle this issue as part of a co-creation initiative in the North East of England (UK). The intervention consists of the dissemination (via the local Community Mental Health Services for Older People) of a leaflet about services available to people with dementia and their family carers in the study site. This protocol is reported in accordance with the Standards for Reporting Implementation Studies.Methods and analysisThis effectiveness–implementation hybrid type 2 study aims at understanding (1) the unfolding and outcomes of the implementation strategy, (2) the outcomes of the intervention (for people with dementia and family carers, staff implementing the intervention and local service providers) and (3) the contribution of co-creation to the design and implementation of the intervention and its outcomes. The prospective theory of change of the intervention articulated by local stakeholders is used as a reference framework against which to assess the implementation and outcomes of the intervention. Evaluation data will be collected through in-depth interviews with people with dementia and family carers receiving the intervention, staff implementing the intervention and managers from local service providers. Referral data from local service providers will be collected to triangulate the interview data. A focus group with key stakeholders will support the sense-making of findings. The realist configuration of mechanism–context–outcome, operationalised using an information behaviour model, will inform data analysis and interpretation.Ethics and disseminationEthical and research governance approvals have been obtained from the West Midlands—South Birmingham Research Ethics Committee. The results of the study will be submitted for publication in peer-reviewed journals and disseminated through conferences.

This chapter discusses the corroboration rule and the practice of suspect witness warnings. It covers the meaning and function of corroboration; the fact that there is no general requirement for corroboration at common law and that a conviction or judgment may be based on the evidence of a single witness; where corroboration is required as a matter of law; the abolition of the rule of practice requiring the judge to direct the jury to exercise caution before convicting in the absence of corroboration; the development of suspect witness warnings; cases in which a suspect witness warning is required; and suspect witness warnings and confirming evidence.

This chapter discusses the statutory exceptions to the inadmissibility of hearsay evidence in criminal cases that were created by the Criminal Justice Act 2003. The impact of the Human Rights Act 1998 on the admissibility of hearsay evidence is discussed, including the important cases of Horncastle and Al-Khawaja and Tahery v United Kingdom, where the Supreme Court and the European Court of Human Rights came into conflict over whether an accused may be convicted where the ‘sole and decisive’ evidence against him is hearsay. The common law exceptions preserved by the Criminal Justice Act 2003 are then considered—res gestae. The chapter ends with discussion of the abolition of hearsay in civil proceedings by the Civil Evidence Act 1995.

This chapter examines cases in which a court will, or may, find facts in issue or relevant facts established without requiring proof by means of evidence. Specifically, it considers cases in which: (a) facts are formally admitted for the purpose of the proceedings, i.e. are taken to be proved without the need for evidence; (b) notorious or readily demonstrable facts are noticed judicially by the court, i.e. are facts of which the court will acknowledge the truth without the necessity for proof; and (c) facts are presumed in favour of the party asserting them, i.e. where a party proves one fact (the primary fact) and a second fact (the presumed fact) will also be taken to have been proved, in the absence of evidence to the contrary.

Cross-examination is the process of challenging the evidence of a witness called on behalf of another party, and was described by Wigmore as ‘the greatest legal engine ever invented for the discovery of truth’. Any witness who has taken the oath becomes liable to cross-examination by any other party. This chapter discusses the general principles of cross-examination (including the effect of an omission to cross-examine, and restrictions and limitations), cross-examination as to credit and an explanation of what constitutes collateral matters, and cross-examination on documents (and the potential effect of this on the admissibility of those documents). The re-examination of witnesses that may follow cross-examination is also considered along with the calling of evidence in rebuttal and a judge’s power to call witnesses.

A privilege is a rule of law that permits a witness to refuse to answer a question, or a party to refuse to produce certain materials. This chapter discusses the privilege against self-incrimination. Legal professional privilege, consisting of legal advice and litigation privilege, is explained along with the exceptions and the importance of the ‘dominant purpose’ rule in litigation privilege and the limitation of litigation privilege to adversarial, and not investigative or inquisitorial, proceedings. Other privileges, in particular the ‘without prejudice’ rule in civil cases, and the protection of sources of information contained in publications under the Contempt of Court Act 1981, s. 10, are also examined.

This chapter provides an overview of the law of evidence. It discusses the definition of evidence and how the law of evidence differs from the science or philosophy of evidence; the characteristics of the judicial trial that demand a particular legal approach to the presentation and use of evidence including, on occasion, its exclusion; the development of the rules of evidence in the common law system and the factors that influenced this; the classification of the rules of evidence; and the impact of the European Convention on Human Rights, in particular the provisions relating to the right to a fair trial.

This first part of the chapter discusses the concept of burden of proof, covering the legal or persuasive burden of proof; the evidential burden; the effect of presumptions on the burden of proof; the legal burden of proof in civil cases; the evidential burden in civil cases; the burden of proof in criminal cases; defence burdens of proof before Lambert; defence burdens of proof after Lambert; and the burden of proof of secondary facts. The second part of the chapter discusses the standard of proof, covering standard of proof required of prosecution in criminal cases; standard of proof required of defence; standard of proof of secondary facts; the standard of proof in civil cases; and the standard of proof in matrimonial and family cases.

The common law adopted the position that previous judgments should not be admissible as evidence of the truth of the facts on which they are based, as against strangers to the judgment. However, given the evidential value of previous judgments, the following cases must be distinguished: (a) judgments as evidence of their own existence, content, and legal effect; (b) judgments as evidence of the truth of facts on which they are based, as between the parties to the proceedings in which the judgment was given, and their privies; and (c) judgments as evidence of the truth of facts on which they are based, as between strangers to the proceedings in which the judgment was given, or as between parties to the proceedings (or their privies) and strangers. This chapter discusses cases (a) and (c).

This chapter is divided into two parts. The first part discusses the law on witness competence and compatibility. The general rule of law in England and Wales is that all witnesses, including children, are competent (able to give evidence) and witnesses are also compellable (liable to be required to give evidence subject to sanction for contempt). Particular rules apply to children and persons under disability, the accused in a criminal case, and spouses and civil partners. The second part deals with oaths and affirmations, covering the requirement of sworn evidence; the effect of oaths and affirmations; and exceptions to the requirement of sworn evidence.

This chapter discusses the following: the basic terminology of the law of evidence and the often inconsistent use of these terms; the terminology of the qualities of evidence, including the difference between direct and circumstantial evidence; hearsay evidence; documentary evidence (both primary and secondary); real evidence, including material objects, demeanour, appearance, and views of the locus in quo; the terminology of the form of evidence (oral, documentary and real evidence); the terminology of facts to be proved; facts in issue; facts forming part of the res gestae; facts relevant to facts in issue; standards of comparison; and the terminology of admissibility and weight.

This chapter discusses the following: the general rule of common law that the opinion of a witness is inadmissible, and the exceptions for evidence of general reputation, the opinion of an expert witness within his area of expertise, and the opinion of any witness as a way of conveying facts within the competence of members of the public generally which do not call for specialized knowledge; principles of admissibility; competence; independence and objectivity; the weight of expert opinion evidence; the function of expert evidence; materials used by experts in forming their opinion; expert reports; common subjects of expert evidence; and the admissibility of non-expert opinion evidence. The developments since the Law Commission report on Expert Evidence (No. 325) are addressed, as are the impact of the Criminal Procedure Rules 2015 and the Criminal Practice Direction.

This chapter discusses the evidence of bad character in criminal cases since the abolition of the common law rules relating to it. It covers the definition of bad character under ss. 98 and 112 of the Criminal Justice Act 2003; evidence of bad character of accused and the admissible gateways under s. 101; evidence of bad character of persons other than accused under s. 100; safeguards in relation to evidence of bad character under s. 103; and other statutory provisions dealing with bad character, in particular those dealing with sexual history questioning: s. 41 of the Youth Justice and Criminal Evidence Act 1999.

Examination in chief is the process whereby a party, who has called a witness to give evidence on his behalf, elicits from that witness evidence relevant to the issues and favourable to the examiner’s case. This chapter discusses the following: the nature and conduct of examination in chief; memory-refreshing by the witness; previous consistent statements; identification evidence; the Turnbull Guidelines on identification; unfavourable and hostile witnesses; and presentation of evidence by non-traditional means. The courts make increasing use of ‘special measures’ to assist witnesses in giving evidence, for example, through the use of intermediaries, live links and Achieving Best Evidence interviews.

hcmf// continued its tradition of Monday's concerts being free and consisting of shorter concerts resulting from a competitive selection process. Many of the concerts had full audiences, and it is an achievement of the festival that these ‘shorts’ are seen as concerts on a par with their paid counterparts on other days. The audiences were notably more diverse on the Monday, with more students and families present, resulting in a more informal, but no less engaging, performance environment.

Background: COPD is a major healthcare burden in the UK. A prior cost effectiveness pyramid has been proposed suggesting that triple inhaled pharmacotherapy was one of the least cost effective interventions. CBT is thought to reduce anxiety and minimise panic-associated COPD admissions. When we looked at COPD interventions in Hartlepool and Stockton, we discovered that CBT wasn9t currently commissioned. Despite this, within the stakeholder groups, we learnt through discussion that the consensus was that CBT would be a very beneficial intervention. Methods: Our Star-COPD team used a modelling approach to calculate the cost effectiveness of known interventions in COPD within Hartlepool and Stockton. We speculatively included CBT and analysed this alongside other COPD interventions. Results: Our model provides some practical consensus-derived evidence that commissioning CBT services would be beneficial for patients with COPD. CBT was second only to smoking cessation and way ahead of more conventional inhaled drug therapies. Conclusions: Our modelling suggests that focussing on using non-pharmacotherapy based interventions including CBT may offer benefits in the management of COPD. Using the Star approach in a local health economy provides a pragmatic solution incorporating stakeholder consensus and service user input.

The adoption of both recording technology and electronically generated sounds has led to new explorations of ideas initially conceived for acoustic instruments, and has itself generated radically pioneering concepts. The chapter identifies and explores the various progressive uses of technology since the rise of minimalism in the 1960s, and how technology has helped shaped the notion of similarity and repetition in prominent minimalist composers' approaches. The paradox of how technology has become a dominant feature for certain composers, yet steered others towards a focus on acoustic instruments (which provide a more humanistic quality) with technology acting in a supporting role, is discussed throughout. \ud \ud An example of the different consequences technology has had is exemplified in the experiences of La Monte Young and Steve Reich. Whilst Young's instrumental work with the Theatre of Eternal Music led to the electronically-generated sine tones of the Dream House, Reich's experiences with tape loops and the Phase Shifting Pulse Gate encouraged him to return to working with acoustic instruments. His gradual transition from an interest in technology within the performance context to a dissatisfaction is explored, and how the technologies of later works rendered a stronger sense of humanity because of this. \ud \ud Repetitive minimalism relies heavily on the well-documented early studio experiments of Reich and Terry Riley with tape loops in both Europe and the US. The chapter investigates the various influences between them, and how two composers who are all too often grouped together held significantly differing approaches to the use of technology in their music. \ud \ud Other areas which tend to be more neglected are also discussed within the chapter, such as James Tenney's early process-based work with tape and computer compositions which parallels mainstream minimalist music in simplicity of structures designed to focus perception upon surface detail. The pioneering work involving technology in live performance from Alvin Lucier is also examined in relation to simplicity in process, alongside more recent work from Chiyoko Szlavnics and Peter Adriaansz.\ud \ud Sustained tone minimalism since Young has developed significantly with the use of electronic means; amplification, the introduction of sine tone manipulation, synthesisers and software development have all enabled composers who are interested in gradual parametric change to gain superior control over their material. The music of Charlemagne Palestine, Phill Niblock, and Eliane Radigue is discussed in detail, in relation to the composers’ various employment of technology, their outlooks on its performative capabilities and its evolving influence over their compositional approach. \ud \ud Recent trends in minimalist electronic music are also explored, with artists such as Richard Chartier, Ryoji Ikeda and snd providing a focal point for discussion on the capabilities of digital processing. As well as outlining the capabilities of the new technologies, importance is given to how these technologies enable artists to develop on compositional concepts which have existed since the beginnings of minimalism.The tendencies towards extreme sparsity, use of digital silence and finer creative control over surface detail show how these artists’ work operates from within a minimalist lineage, but also expands the conceptual and experiential possibilities of recent digital technologies.

Promoting consistent and correct condom use remains a priority public health activity, although some HIV- and STI-related providers remain challenged by some men's resistance to condoms, which some claim do not fit properly or do not feel comfortable. Although these perceptions have been examined across multiple populations, they have not been documented among men living with HIV. During spring 2008, data were collected from 215 men living with HIV at HIV service organizations in the Midwestern and Southeastern United States. Participants completed the Condom Fit and Feel Scale and measures related to demographics and condom use during sexual interactions within the past 90 days. Men were primarily homosexual, African American, with a high school degree or higher, and unemployed. More than half of participants had used condoms for sexual intercourse within the previous 90 days. The majority of the men reported few problems with the fit and feel of condoms, with 63.1% reporting that condoms "fit my penis just fine," and 80.9% reported being able consistently to find condoms that they perceived to be "sized appropriately for my penis." Some men did report specific characteristics of condoms that challenged fit and feel, including 20.6% endorsing (always or often) that condoms feel too tight, 15.9% that condoms are too short, 17.8% or that condoms would not roll down far enough to cover their penis completely (15.6%). These data provide insights into mechanisms through which providers can help to increase men's access to the diverse range of condoms in the marketplace.

The purpose of this article is to consider the lack of certainty surrounding the law on dishonesty in theft in the context of events that occurred on Branscombe beach following the grounding of the MSC Napoli on the South Devon coast in January 2007—that is the ‘looting and plundering’ of the containers that came ashore. It will be contended that the hesitant response of the police to the incident may be explained, in part, by uncertainty in the law on dishonesty. Further, it will be argued that the offence of theft is contrary to the rule of law and that the Napoli incident highlights the need for a statutory definition of dishonesty that replicates the law in New Zealand.

This article examines the concept of the evidential burden and argues that the decision in R v Malinina illustrates that the concept of the evidential burden is in desperate need of clarification. It will be contended that, ultimately, codification would be the best means of achieving that end.