Tariff Concession Revocation Order 20/2010 - Tariff Concession Order 0932294

The instrument relies on a small set of administrative and statutory concepts, as expressed in its short text. Those concepts are:

• Delegated revocation power: the text begins "Under Section 269SD(2) of the Customs Act 1901, I Wendy Knowles a delegate of the Chief Executive Officer (a) revoke ...". The action is exercised by a delegate, invoking s 269SD(2) authority. The instrument therefore embodies the concept of delegated administrative action, exercised to revoke and replace tariff concession instruments.

• Tariff Concession Order (TCO) revocation and substitution: the instrument expressly revokes a named TCO (0910964) and "make[s] in its place the Tariff Concession Orders described in TABLE B." The mechanism is therefore: revoke an earlier concession instrument and replace it with a new instrument; the replacement relates to the same goods list but changes classification particulars.

• Goods identification by detailed description: the instrument lists the goods subject to the TCOs as "PARTS, HORIZONTAL STIRRED GRINDING MILL" followed by a detailed enumerated list (a) to (ag). The classification of goods for customs purposes therefore turns on the textual match with those descriptions.

• Tariff classification codes: the tables provide explicit Customs Tariff classification numbers. TABLE A records the earlier classification as 8479.90.00; TABLE B records the replacement classification as 8474.90.00. The instrument thus modifies the numerical tariff heading associated with the listed goods.

• Schedule 4 linkage: the instrument states that the goods in Column 1 of TABLE B are goods to which "the item in Part III of Schedule 4 to the Customs Tariff Act 1995 specified in Column 2 of TABLE B applies." Column 2 in TABLE B records the number "50". The concept is that those goods become (or are confirmed as) subject to the treatment in Schedule 4 Part III item 50.

• Date of effect and retrospective application: the instrument makes clear the effective date for revocation and substitution, stating "This Revocation has effect from 01.04.09" and that "The Order shall have effect from the date notified in paragraph (a) above as the date of effect for the Revocation." The instrument therefore operates with a retrospective operative date in relation to its signature date (02.09.09).

• Identification and administrative reference numbers: the instrument provides operational notation "Op. 01.04.09 - TC 0910964" for the revoked TCO and "Op. 01.04.09 - TC 0932294" for the replacement. The instrument thus creates or records administrative reference numbers importers, brokers and customs will use.

These are the core legal-administrative concepts present in the instrument text. They function together: a delegate utilises statutory power to revoke a named concession instrument and substitute a new one that assigns the listed goods a specific tariff classification and an explicit tie to a Schedule 4 Part III item, effective from the stated date. The instrument does not itself detail tariff rates, refund mechanisms, or administrative processes beyond identifying the relevant TCO numbers, classifications, schedule item and date of effect.

The instrument specifically targets "the goods described" in TABLE A and TABLE B. Those goods are the enumerated parts of a "HORIZONTAL STIRRED GRINDING MILL", listed item-by-item from (a) drive end flanges through (ag) shell liners. Any party that imports, exports, claims concessions for, manufactures, supplies or otherwise deals with those specific parts in a customs context is directly affected because the instrument changes the tariff classification and the recorded application of an item of Part III of Schedule 4 to those goods.

More concretely, the following categories of actors will be affected by the instrument's changes as recorded:

• Importers and their customs brokers: the instrument changes the customs tariff classification recorded against the listed goods (from 8479.90.00 to 8474.90.00) and associates the new entry with Schedule 4 Part III item 50. Importers and brokers are the parties who lodge customs declarations and therefore must know which TCO number and classification to use for correct entry. The instrument supplies the operative TCO number for the replacement (TC 0932294) and the operative date (Op. 01.04.09).

• Exporters and domestic suppliers who rely on tariff concession treatment for calculations, pricing or claims: any party that relies on the former TCO (0910964) to make pricing, accounting or contractual calculations may be affected, particularly given the stated retrospective date of effect.

• Customs administration and compliance officers: the instrument is an administrative act that the customs agency will need to reflect in its records and in the application of Schedule 4 Part III item 50. The instrument itself is the record of a change the agency must operationalise.

• Manufacturers and OEMs of horizontal stirred grinding mills or of replacement parts: manufacturers who import spare parts, source parts internationally, or compete with imported parts might be affected because tariff classification and schedule application can alter duty treatment, which in turn can affect cost structures. The instrument identifies the precise parts by description; any manufacturer whose parts match those descriptions will be within scope.

• Accounting and compliance advisers, legal advisers, and auditors charged with ensuring correct customs treatment: these professionals need to reconcile previous entries that referenced TC 0910964 with the substituted TC 0932294, and the instrument's effective date.

• Parties with prior entries between the retrospective date and the instrument signature date: because the instrument declares the revocation and new order have effect from 01.04.09, any party that imported or declared such goods during the period 01.04.09 to 02.09.09 will be affected by the retrospective change in classification. The instrument does not itself set out transitional processes or refunds, but the revocation and substitution will alter the legal basis for past entries and future entries.

The instrument itself does not name any individual importers or firms; it identifies only the set of goods that fall within the scope. The text therefore creates an obligation for those who deal with goods that correspond to the described parts to check whether their goods are covered, and to update declarations or records to reflect the new TCO number, classification, and Schedule 4 Part III linkage. The instrument makes the delegate the actor who decided the revocation and substitution, so parties seeking to query or appeal the instrument would need to identify the decision-maker indicated in this notice.

The instrument does not itself create an explicit new code of duties, or articulate rights in discrete sections; rather it performs administrative legal acts that change the legal basis for customs treatment of identified goods. From the text the following duties and rights can be drawn as practical legal consequences that parties must observe or can exercise:

• Duty to apply the substituted TCO/classification on entries: the instrument replaces TCO 0910964 with the TCO described in TABLE B (TC 0932294). A party lodging a customs entry for any of the listed parts must, to reflect the state of the law as expressed by this instrument, use the replacement tariff classification (Column 1 of TABLE B: 8474.90.00) and the TCO reference TC 0932294 where appropriate. The instrument itself records the operative classification and identification numbers that define legal treatment.

• Duty to recognise the Schedule 4 Part III linkage: the instrument states that the goods in Column 1 of TABLE B "are goods to which the item in Part III of Schedule 4 to the Customs Tariff Act 1995 specified in Column 2 of TABLE B applies." Column 2 records "50". The practical consequence is that persons dealing with those goods must treat the item-50 Schedule 4 application as the statutory reference for whatever legal consequence Schedule 4 Part III item 50 confers. The instrument places a duty on users to apply that schedule item.

• Duty to observe the effective date, including retrospective effect: the instrument makes the revocation and replacement effective from 01.04.09. Any party who made entries, claimed concessions or otherwise relied on the prior TCO during or after that date must account for the fact that the legal record now states that the revocation/replacement had effect from that date. The instrument therefore changes the legal baseline as at 1 April 2009.

• Right to rely on the instrument as the public administrative record: the instrument is a formal record that the delegate revoked TCO 0910964 and made TCO 0932294 in its place, effective from the stated date. A party may rely on the instrument as evidence of that administrative action in discussions or administrative reviews.

• Right (implicit) to seek administrative clarification or correction: the instrument names the delegate and provides TCO numbers, so a party with queries about the scope of the goods description or the application of Schedule 4 item 50 has an identifiable administrative decision to challenge or inquire about. The instrument itself does not set out appeal mechanisms, but by identifying the delegate and the Act under which the revocation is made, it creates a discrete administrative act that may be the subject of administrative processes under the referenced Acts.

• Duty to match goods to the textual description: the parts are defined by a detailed textual list. Parties must match their goods to that textual description to determine whether the instrument applies. The duty is practical and textual , the list (a) to (ag) defines the scope.

• Duty to use the correct tariff heading: the change from 8479.90.00 (TABLE A) to 8474.90.00 (TABLE B) is the operative classification change that parties must observe in customs entries, accounting, and any concession claims.

The instrument does not spell out penalty provisions, refund rights, or transitional relief. It does not include procedural provisions for seeking retrospective refunds or adjustments. The practical duties and rights flowed from the instrument therefore are to adopt the revised classification, apply Schedule 4 Part III item 50 as recorded for the replacement TCO, and account for the effective date record in any prior or subsequent customs dealings. These duties and rights derive from the instrument's revocation and substitution, and reference to the Customs Act 1901 and the Customs Tariff Act 1995 as the statutory frameworks within which the instrument has effect.

The instrument itself contains no penal clauses, fines, or explicit enforcement mechanisms. It records an administrative act , revocation and replacement of a tariff concession order , but it does not set out sanctions or state enforcement procedures. The only explicit statutory references in the instrument are to "Section 269SD(2) of the Customs Act 1901" (as the grant of power for the delegate) and to "Part III of Schedule 4 to the Customs Tariff Act 1995" (as the register to which Column 2 refers).

From the instrument text, therefore, the following points on penalties and enforcement can be stated with textual grounding:

• The instrument does not itself impose penalties: no monetary penalties, infringement notices, or enforcement actions are enumerated in the text. The instrument functions as an administrative record of a change in concession status and classification.

• Enforcement implications arise via the referenced Acts: the instrument is made under the authority of the Customs Act 1901 and affects application of an item in the Customs Tariff Act 1995. Any sanctions or enforcement consequences for incorrect classification, false declarations, or non-compliance with customs entry requirements are matters that would be provided for under those Acts, not in this instrument. The instrument names those statutory frameworks as the legal context.

• Retrospective effect complicates enforcement exposure: because the instrument states that the revocation and replacement "has effect from 01.04.09", entries or claims made between that date and the instrument signature date (02.09.09) will now fall within the changed legal record. The instrument itself does not state whether administrative remedies, refunds, penalties or other enforcement actions will follow from this retrospective change; it simply records the revocation and substitution. Accordingly, implicated parties may face enforcement scrutiny or liability under the wider statutory regime if customs authorities, in applying the Customs Act 1901 and the Customs Tariff Act 1995, treat prior entries as inconsistent with the instrument. The instrument does not itself instruct what enforcement steps, if any, will be taken.

• Administrative implementation will determine practical enforcement: as a record, the instrument requires customs administration to update records and to apply the replacement TCO to future entries. Whether and how customs treat past entries (for instance, by adjusting duty, reclaiming underpayments, or issuing penalties) is not detailed in the instrument but follows from the administration of the referenced Acts.

In summary, the instrument itself is silent on penalties and enforcement. It changes the legal basis for classification and schedule application; any penalties or enforcement consequences must be sought in or under the Customs Act 1901 and the Customs Tariff Act 1995, the statutes that the instrument references as its legal frame.

The instrument explicitly situates itself within two statutory frameworks by citation and by effect. The first citation is "Section 269SD(2) of the Customs Act 1901", which the instrument invokes as the statutory authority enabling the delegate to revoke a TCO. The second statutory reference is to the "Customs Tariff Act 1995", specifically to "Part III of Schedule 4". The instrument therefore operates as an administrative action that changes the application of the Customs Tariff Act 1995 to particular goods, and which is taken under powers found in the Customs Act 1901.

Key interactions identifiable from the instrument text are:

• Source of administrative power: the revocation is made "Under Section 269SD(2) of the Customs Act 1901". The instrument therefore is an exercise of a power under that provision. The text does not reproduce s 269SD(2); it simply records that section as the legal source of power. The interaction is that the Customs Act authorises administrative acts of revocation and substitution of TCOs by delegates.

• Effect on the Customs Tariff Act 1995 schedule application: the instrument asserts that the goods in TABLE B "are goods to which the item in Part III of Schedule 4 to the Customs Tariff Act 1995 specified in Column 2 of TABLE B applies." Column 2 is "50". The instrument thus amends the set of goods recorded as falling within Schedule 4 Part III item 50. That is not a legislative amendment to the statute; rather the instrument alters the administrative record of tariff concession application as per the statutory structure that allows TCOs to identify goods associated with particular schedule items.

• Interaction by changing tariff headings: the tables show a change in tariff headings from 8479.90.00 (TABLE A) to 8474.90.00 (TABLE B). These headings are entries in the Customs Tariff nomenclature; by changing the recorded heading for the goods in the TCO, the instrument alters which tariff classification heading is tied to the goods for the purpose of customs administration and schedule application. The instrument thus interacts with the tariff classification system used in the Customs Tariff Act 1995 and related customs processes.

• Administrative record linkage: the instrument provides administrative identifiers for the TCOs (TC 0910964 and TC 0932294) and operative dates. Those references will be used in customs administration and in any cross-reference to entries made under the Customs Act 1901. The instrument therefore creates linkages across administrative records (TCO registers and customs entry systems).

• No textual amendment to statute: the instrument does not purport to amend the text of either statute. It carries out an administrative act permissible under the Customs Act 1901 and records the application of a schedule item under the Customs Tariff Act 1995. Its interaction is administrative and applicative, not legislative.

• Temporal interaction: the instrument sets a retrospective operative date (01.04.09) that predates the instrument signature (02.09.09). That temporal dimension means that the legal status of entries made during that interval interacts with the statutory obligations and remedies under the Customs Act 1901 and Customs Tariff Act 1995. The instrument itself does not describe how those statutory processes will operate in relation to the retrospective change; it merely establishes the record that the revocation and substitution had effect from that earlier date.

These are the express interactions the instrument records. Any further operational effects , for example, on duty liability, refunds, or administrative appeals , will be governed by the procedures, definitions and enforcement provisions in the cited Acts. The instrument therefore functions as an administrative change recorded under the authority of the Customs Act 1901 and with direct application to the operation of Schedule 4 of the Customs Tariff Act 1995.

The instrument itself records one discrete administrative amendment: the revocation of TCO 0910964 and its replacement by TCO 0932294. From the text, the following timeline and amendment details are explicit:

• Prior instrument: Tariff Concession Order Number 0910964 was "made on 19.06.09", and is the instrument expressly revoked in paragraph (a). TABLE A is the descriptive record for the goods that were subject to that earlier TCO. TABLE A lists the customs tariff classification 8479.90.00 and the goods description, and annotates the operative note "Op. 01.04.09 - TC 0910964". TABLE A also shows in its Column 2 a notation that reads "50N/A". The instrument does not further explain that notation; it is recorded as printed.

• Revocation and new instrument: the revocation has effect from 01.04.09, and in place of the revoked TCO the instrument "make[s] in its place the Tariff Concession Orders described in TABLE B." TABLE B contains the replacement instrument details: it lists the goods (identical textual description) and the customs tariff classification 8474.90.00, with the operative note "Op. 01.04.09 - TC 0932294" and Column 2 entry "50".

• Effective date: the instrument expressly ties the effective date of the replacement to the date of effect for the revocation recorded in paragraph (a): "The Order shall have effect from the date notified in paragraph (a) above as the date of effect for the Revocation." The revocation date is stated as 01.04.09; the instrument is dated 02 September 2009 and signed by Wendy Knowles as delegate. Hence the replacement TCO is recorded as having the same operative date as the revoked TCO, retrospectively.

• Administrative signature and date: the instrument is dated "Dated 02 September 2009" and signed by the delegate of the Chief Executive Officer, Wendy Knowles. It contains the textual marks "This is page 1 of 2 Pages of the instrument...Wendy Knowles........................Dated 02 September 2009 Delegate of the Chief Executive Officer" and similar on page 2.

• No further amendments recorded: the text provides no subsequent amendment entries, expiry dates, or sunset provisions. TABLE B's Column 2 shows "50" but leaves the "Last date of effect" cell blank. TABLE A's Column 2 prints "50N/A" in the available field. Beyond the revocation and substitution set out in the instrument, no other amendment history is recorded within the instrument itself.

• Administrative continuity: both the revoked and replacement instruments carry the operational notation "Op. 01.04.09", indicating the operative legal date for both entries is the same. The instrument thus documents an administrative change in classification while maintaining an identical operative date across the revoked and replacement TCOs.

In sum, the amendment history recorded in the instrument comprises a single revocation of TC 0910964 (made 19.06.09) and replacement with TC 0932294, both recorded as operative from 01.04.09, with the instrument itself executed on 02.09.09 by a delegate. The instrument contains no further historical amendments or temporal modifications beyond those entries.

The instrument contains no reference to any litigation, judicial review, or legal proceeding. No cases, decisions, appeals or controversies are named or cited in the text. The document is an administrative revocation and substitution notice executed by an authorised delegate; it records the exercise of administrative power but does not identify any court challenge or past litigation connected to the TCOs concerned.

Therefore, from the instrument alone the following points can be stated:

• No litigation referenced: the instrument does not record nor mention any litigation or dispute relating to the TCOs it revokes or replaces.

• No precedent cases named: the instrument makes no mention of legal authorities, case law, or judicial interpretations. It cites statutory authority only.

• If parties seek judicial review or other legal action in connection with the revocation or replacement, such challenges would not be recorded in this instrument; any litigation history relevant to the instrument is absent from the text and therefore cannot be reported from the instrument itself.

• Administrative avenues and appeals are not described: the instrument does not recite procedural remedies for contesting the revocation or substitution. The presence or absence of litigation would therefore be external to the instrument's text.

In short, the instrument does not provide a litigation history. Any litigation records or proceedings that may exist in relation to this administrative action are not part of this document and would need to be sourced elsewhere; they are not present in the instrument supplied.

The instrument is brief but contains a number of concrete features that create potential compliance pitfalls and interpretive questions for practitioners. These are drawn directly from the instrument text and its mechanical effects.

• Retrospective operative date: the instrument states that the revocation and the replacement TCO "has effect from 01.04.09" while the instrument is dated 02.09.09. This creates an immediate temporal issue for any entries, claims or commercial arrangements carried out between 1 April 2009 and 2 September 2009: the legal record as now stated makes the revocation and substitution effective from the earlier date. Practitioners must therefore note that the instrument can retroactively change the legal basis for past customs entries. The instrument does not itself set out transitional arrangements or administrative remission/refund procedures for entries made in that interval.

• Identical goods description, different tariff headings: TABLE A and TABLE B contain practically identical textual lists of goods (a) through (ag), but the tariff classification changes from 8479.90.00 (TABLE A) to 8474.90.00 (TABLE B). The same descriptive list being associated with two different tariff headings means that whether a particular import entry is correctly classified depends on which TCO applies as of the operative date. Because the instrument records the replacement as effective from 01.04.09, entries should be reconciled to the replacement classification for that date.

• Schedule 4 linkage ambiguity in print: TABLE A's Column 2 prints "50N/A". TABLE B's Column 2 prints "50" with the "Last date of effect" blank. The instrument's operative text says the goods in TABLE B "are goods to which the item in Part III of Schedule 4 ... specified in Column 2 of TABLE B applies." Column 2 in TABLE B is clearly "50", so the replacement explicitly ties the goods to Schedule 4 Part III item 50. The Table A print "50N/A" is ambiguous in format; practitioners should rely on the instrument's recital (which pins the Schedule 4 linkage to TABLE B Column 2) and check administrative records if there is doubt about the status of the earlier TCO’s schedule application.

• Administrative reference numbers and record-keeping: the instrument records operational notations "Op. 01.04.09 - TC 0910964" and "Op. 01.04.09 - TC 0932294". Practitioners must ensure customs declarations reference the correct TC number applicable to the goods for the correct period. Confusion between the old and new TC numbers, or applying the wrong tariff heading in entries spanning the operative date, can create compliance exposure.

• No express statement on duties or rate effects: the instrument does not state what effect the Schedule 4 Part III item 50 confers in terms of duty rates, exemptions or concessions. The instrument does not itself declare whether any duty reduction, remission or zero-rate applies; it simply records the administrative fact that item 50 of Schedule 4 applies to the goods in TABLE B. Users cannot infer the financial consequence of item 50 from this document alone; they must consult the referenced Schedule 4 of the Customs Tariff Act 1995 to determine precise tariff treatment.

• Absence of procedural instructions for past entries: the instrument does not set out how customs will treat prior entries that were made under the revoked TCO while it was in effect, nor does it set out processes for adjustments, refunds, or penalties. Parties with entries during the retrospective period therefore face uncertainty about administrative process for correction or claims. The instrument supplies the legal change but not the operational remedy.

• Single administrative actor named: Wendy Knowles is recorded as the delegate making the revocation and substitution. If a party needs to question the decision or seek review, the instrument’s record provides an administrative reference point but no procedural details. Practitioners should note the identity of the decision-maker for any enquiries.

• Exact textual matching required: the goods are defined by a detailed list. Small differences in part description between a party’s physical goods and the items (a) to (ag) could determine whether the TCO applies. Parties must match the precise text to the goods to confirm coverage.

These are practical "gotchas" that arise directly from the instrument's text: retrospective effect, a change in tariff heading despite an identical goods list, ambiguous table printing, absent operational instructions on remedies, and the need for exact textual matching in claims. Each creates a concrete compliance or interpretive cost that importers, brokers and advisers will need to manage.

Compliance in relation to this instrument requires actions that mirror the instrument’s administrative character: confirm precise scope, update customs entries and records to reflect the replacement TCO and its operative date, and manage any retrospective exposure for entries made between the operative date and the instrument signature date. The instrument provides the necessary identifiers and descriptions; compliance steps derived from the instrument follow.

Recommended compliance steps drawn from the instrument are:

1. Identify affected goods by textual match. The instrument lists in both tables the exact descriptions of covered goods as "PARTS, HORIZONTAL STIRRED GRINDING MILL" followed by itemised components (a) through (ag). Match each physical part or SKU against that textual list. Only goods that correspond to the listed descriptions fall within the TCOs recorded in this instrument. The instrument itself is the textual source of coverage.

2. Use the replacement tariff classification and TCO number for entries with effect from 01.04.09. The instrument records the replacement classification in TABLE B as 8474.90.00 and the administrative reference "Op. 01.04.09 - TC 0932294". Because the instrument states the revocation and replacement "has effect from 01.04.09", declarations, accounting and records should reflect TC 0932294 and the tariff heading 8474.90.00 for that operative date.

3. Confirm application of Schedule 4 Part III item 50. The instrument expressly ties the goods in TABLE B to "the item in Part III of Schedule 4 to the Customs Tariff Act 1995 specified in Column 2 of TABLE B", where Column 2 is recorded as "50". Practitioners must therefore treat Schedule 4 Part III item 50 as the statutory item applying to the listed goods and consult the Customs Tariff Act 1995’s Schedule 4 text (not contained in this instrument) to determine the precise concession or treatment item 50 confers.

4. Reconcile past entries in the 01.04.09-02.09.09 window. Because the instrument is dated 02.09.09 but states that the revocation and substitution take effect from 01.04.09, parties with entries or claims during that period should undertake a reconciliation exercise: identify any customs entries that referenced TC 0910964 or used tariff heading 8479.90.00 for the listed parts; determine whether those entries should have referenced TC 0932294 and 8474.90.00; and prepare documentation to support any adjustments or enquiries. The instrument itself does not provide the administrative route for adjustments; practitioners should therefore prepare to submit enquiries and supporting documentation to customs or the relevant administrative body.

5. Update internal accounting and supply-chain records. Because tariff classification can affect landed cost, VAT/GST accounting, and pricing, update ledgers and internal costing to reflect the replacement TCO and its operative date. Record the administrative citation (TC 0932294) and the effective date (01.04.09) together with the delegate's instrument (dated 02.09.09) in internal compliance files.

6. Engage customs broker or legal adviser for ambiguous cases. If a part’s description is not a clear textual match to the list (a) to (ag), or if there is uncertainty about the Schedule 4 application, consult the customs broker or legal adviser and cite the instrument’s text (revocation, replacement, TCO numbers, and operative date). The instrument supplies the controlling text for scope.

7. Retain the instrument as evidence of administrative action. The instrument is the formal administrative record showing the revocation and substitution and the operative date; retain a copy in compliance files for audit, customs enquiries or potential administrative review.

8. Prepare enquiries for administrative clarification where necessary. The instrument names the delegate and the statutory authority invoked but does not set out procedural remedies for past entries. If an importer seeks a direct administrative determination about the treatment of past entries, prepare an enquiry referring to the instrument (including its date and TC numbers) and the facts of the entries in question.

9. Note that the instrument does not specify duty rates or refund mechanisms. The instrument ties the goods to Schedule 4 Part III item 50 but does not specify the financial effect of that item. For precise duty treatment, consult the text of Schedule 4 Part III item 50 in the Customs Tariff Act 1995 (not contained in this instrument) and the relevant administrative practices under the Customs Act 1901.

10. Record and monitor potential enforcement risk. Because the instrument has retrospective effect, be prepared for customs administration enquiries or actions arising from reclassification. Document all communications, copies of customs entries, invoices, bills of lading and product specifications to support any administrative explanation or claim.

Each of these steps is grounded in the instrument’s text: the descriptive lists of goods, the change in tariff headings, the assignment to Schedule 4 Part III item 50, the TCO reference numbers (0910964 and 0932294), and the operative date 01.04.09, together with the instrument signature date 02.09.09. The instrument carries no additional procedural instructions; compliance therefore requires active reconciliation, record updates and administrative engagement using the instrument as the controlling legal record.