Jon Pike, Department of Philosophy, The Open University UK
©author: please do not cite without express permission
Paper presented to the conference
Academic Freedom and the Politics of Boycotts
January 25-6 2006
Bar Ilan University,
In this paper I claim that the many objections to the short-lived AUT boycott of Haifa and Bar-Ilan were consistent and mutually reinforcing. In contrast, the arguments for the selection of Israeli Universities did not sit happily together (aside from their individual defeasibility). I sketch a ‘fully featured’ conception of academic freedom and indicate some of its implications for Israeli and Palestinian universities: in particular that defenders of academic freedom ought to take seriously the multiple ways in which the impact of occupation disrupts the academic activities of Palestinian students and academics. I then provide a justification of academic freedom in broadly Kantian terms, and show how this highlights a serious moral objection to boycotts, independently of consequential considerations. This, combined with the unwarranted selectivity involved in the singling out of Israeli academics for special punishment, licenses uncompromising hostility to the boycott.
Finally, I consider the view that the Israeli boycott was simply a generalization of ordinary trade union activities. I defend those activities but condemn the Israel boycott, by pointing out the morally relevant distinctions between the practice of grey-listing, applied in the case of a dispute involving AUT members at Brunel University (UK), and the proposed, defeated, Israel boycott.
Introduction: Obviousness and mutual reinforcement
I want to begin with some remarks about obviousness. In the paper that follows I hope to present a fairly abstract and rigorous philosophical argument that pinpoints something important about what was wrong with the AUT boycott. But this is something of a luxury. It was not necessary to have a sophisticated argument against the boycott. It was, to me, and to most members of the AUT, simply obvious that the boycott was wrong. Here are some of the reasons, in no particular order:
1. The boycott contravened several important moral principles (both consequentialist ones and Kantian ones): it was lightminded, or worse, about academic freedom
2. The boycott imposed an unacceptable political test as a precondition on ordinary academic interchange.
3. The boycott was, in effect, anti-semitic: it singled out Israeli academics for special treatment in the absence of any justifying relevant moral property.
4. The boycott was counterproductive for peace and mutual recognition in the region
5. The boycott was determined undemocratically, and defended undemocratically
6. The boycott was justified by manifest falsehoods.
7. The boycott was presented dishonestly
8. The boycott rested on the delegitimisation of Israel.
What is the relation between these claims? These are mutually reinforcing arguments. Our disagreement with the boycotters was not ‘merely tactical’ (though with some people of good will who naively voted for the boycott because they wanted to help Palestinian academics, we had, amongst other things, a ‘tactical’ disagreement.) It also rested on these other claims. The arguments reinforce one another, and can fruitfully be pursued side by side. The arguments converged in the political opposition to the boycott, an opposition which led to its overturning at the Special Council of the AUT on May 26th 2005
Contrast the argument for the ‘singling out’ of Israel, and Israeli academics for special treatment and special punishment.
Lots of reasons were given, and they did not overlap. As Norman Geras argued, the boycotters ‘…all assure us that this isn’t about blank prejudice. It’s about human rights, racism and what have you, and Israel just happens to be the privileged exemplar. But when you ask for a principled reason which picks out Israel, and Israel exclusively, not only can the boycotters and blacklisters not give one satisfactory reason, they don’t even converge on a common reason. Now it’s supposedly because they were called upon by Palestinian organizations. Now it’s because no one has yet brought a resolution to the AUT on China, or Sudan, or Chechnya, or Iran, or Zimbabwe, or Iraq (in Saddam’s day), or the US (since then)(1). Or else Israel isn’t a special case, but it is a case; and it’s good enough if it’s a case; and this just happens to be the case we’re focusing on. Or it’s because of illegal occupation, or because of UN resolutions. Or it’s because of racism, like with apartheid (or, sotto voce, and sometimes not so sotto voce, like with Nazi Germany).
But for want of decent reasons, the boycotters have something unfortunately as powerful; and this is a fixed hostility towards the State of Israel…’
Here, then, there is no mutual reinforcing of the argument – the argument dissolves into fixed hostility. I take it that this asymmetry derives from something like a moral fact: that there were very many things wrong with the boycott and nothing much right about it. So in arguing against the boycott, it is not necessary to agree on which is ‘the’ key, ‘the’ right argument. (Nor is it necessary to be motivated by an affective identification with Israel, (and I am not) in order to argue – and organise – effectively against an academic boycott.)
In this paper I (i) discuss and defend a full notion of academic freedom, (ii) say something about a Kantian critique of academic boycotts, and (iii) say something about a special case of withdrawal of good will from an institution.
(i) For a full and consistent notion of academic freedom
It is customary in the philosophical literature to draw a distinction between positive liberty and negative liberty, a distinction most famously formulated in Isaiah Berlin’s famous essay Two Concepts of Liberty.(Berlin 1969) On this account, negative freedom – freedom from an external restriction – is often taken to be the paradigm, and positive freedom, commonly characterised as freedom to is seen as a suspect notion, easily amenable to the distortions of totalitarians. Moreover, sometimes, legal or juridical restrictions of liberty are prioritised over the constraints on freedom that result from lack of resources or from extra-juridical constraints.
It is customary, but a mistake nonetheless. Berlin’s account is not so much wrong, but it tries to do too much, conflating an historical account of the development of the concept of liberty with an insufficiently analytical model. If we use it as a model of academic freedom, we will end up with a too thin, impoverished notion. As MacCallum has shown, a full conception of freedom is tripartite rather than dualist. (MacCallum 1967). For each putative case of freedom case, we can ask ‘is X free from Y to do Z?’ And this analysis can be applied to the case of academic freedom. So, for example is an Israeli academic free from an AUT boycott, to attend a conference? Is a scientist at Haifa free to engage in joint research with British colleagues? But equally, on this analysis, is a Palestinian student free from being detained at a checkpoint to get to her university? When the answer to each question is no, then in each case there is a restriction of academic freedom, and each is to be condemned. Just as we are at fault if we diminish one sphere of freedom instrumentally, in the service of another, supposedly more ‘basic’ one, so we are at fault if we maintain academic freedom as a narrowly demarcated set of abstractions, applying specifically to professional academics under conditions of geo-political stability and affluence.
Judith Butler made this very point in addressing and criticising(Butler 2006) the argument presented by Omar Barghouti, in favour of the AUT boycott, to the effect that academic freedom of Israeli academics was trumped by the more basic and fundamental human rights that were abrogated by the occupation of the West Bank (and Gaza). Bhargouti’s argument aimed to show that academic freedom in Israel ought to be infringed in the service of the more basic rights of Palestinian students (and academics) in the occupied territories.
In response, Butler argues that academic freedom is generally conceived of as the freedom to research, to publish, to travel to conferences, to partake in international intellectual exchange. But these are not separate rights epiphenomenal upon ordinary and material human rights to travel freely, and so on. Academic freedom is part of those rights, and an instantiation of them. For this reason, some debates about the boycott make a mistake because the preventions of academic freedom involved when checkpoints are in place are placed outside the rights discourse by boycott opponents. But the rights associated with academic freedom rights are of those rights general rights, and an instantiation of them. Supporters of academic freedom ought to be able to generalise that support in order to criticise the everyday restrictions that thwart the academic lives of Palestinians. But some opponents of the boycott, who raise the abstract liberal right, can be silent about the ‘geopolitical conditions of the exercise of academic freedom’ – as Butler puts it. But this can be sustained only on the basis of a restricted conception of the rights associated with academic freedom. But on a full conception of freedom, and a full conception of rights, we should not be so silent about these geo-political conditions.
Viewed from this perspective, we can consider the restrictions placed on the freedom of Israeli academics, postgraduates and students by the boycott and the restrictions placed on Palestinian academics and students by the continued occupation of the West Bank. It is a mistake to think of these as arguments about different categroies of academic liberty. Such positive and general considerations throw into relief two objects of criticism – first, an argument – such as Barghouti’s about the trumping of the rights of Israeli academics by the ‘more basic rights of Palestinians’, and second – the restriction of the rights of academic freedom to very narrow confines. These two critical poles underpin the call of Sari Nussebeih for those who opposed the boycott of Haifa and Bar-Ilan to oppose also the restrictions placed by the Wall on the movement of Palestinian teachers in East Jerusalem.(Nussebeih 2005)
(ii) Kant, objectification, and academic boycotts
So that is the full conception of academic freedom. I now turn to the basis of respecting academic freedom. The argument here distinguishes two broad bases for valuing academic freedom – first in terms of its consequences, and second in more Kantian terms. I want to suggest that respect for academic freedom is justified not only, or (to my mind), in the end, on a consequentialist basis. That is, respecting academic freedom is not, in the end, a good simply because it permits the advancement of scientific discovery and human progress (although it undoubtedly does, and it is a good for those reasons.(Blakemore, Dawkins et al. 2003)) Respecting academic freedom also involves respecting individuals as rational persons – it has a Kantian flavour.
In the Groundwork of the Metaphysics of Morals Kant gives a non-consequentialist objection to certain sorts of treatment of others:
‘the man who has a mind to make a false promise to others will see at once that he is intending to make of another man merely as a means to an end he does not share. For the man whom I seek to use for my own purposes by such a promise cannot possibly agree with my way of behaving to him and so cannot himself share the end of the action… then it is manifest that a violator of the rights of man intends to use the person of others merely as a means without taking into consideration that, as rational beings, they ought always at the same time to be rated as ends – that is, only as beings who must themselves be able to share in the end of the very same action’ (Kant 1948)
The driving normative principle here – which specifies the impermissible act – is the use of another person merely as a means to an end he cannot share. To make a false promise to a person contradicts regarding that person as an end in himself. The analogy with an academic boycott is close but – like all analogies – not exact. The Kantian problem with a boycott is that it generally involves the intention to make use of another person merely as means to an end, an end he does not share. The person boycotted is generally an instrument to a political end of the person boycotting. However, it is not true to say that a person could not agree with being boycotted in a special sense, in the way that Kant suggests applies in the case of false promises, and the use of a boycott need not, in a restricted set of cases, involve contradiction with respect for persons as rational beings. I want to distinguish between voluntary and non-voluntary boycotts (or what I have called elsewhere(Pike 2005) boycotts as punishment and boycotts as solidarity).
A key argument against the boycott, which has been indicated by Yudkin(2) is, in this way, Kantian in form. This is the sense of Yudkin’s analogy with hostage taking. It draws on the notion of using persons solely as a means to an end. The boycott in the AUT was, of course, of this illicit non-voluntary form. It failed to respect Israeli academics as individuals, individuals with whom one may agree or disagree, with whom one may have rows. Rather, even on an extremely charitable reading, it treated them simply as means to the end of changing Israeli government policy. (Sometimes, of course, the end was much more than this – something like ‘the dissolution of the Zionist entity.’) Within the AUT debate this was fairly explicit. Let’s start with a datum: a handful of Israeli academics such as Ilan Pappe, and Tanya Reinhardt agreed with the boycott. The vast majority, including many known for their strong opposition to the Occupation, did not. How did this fact fit into the debate within the AUT?
Crucial to the AUT boycott was the systematic dismissal of the rational capacities of the Israeli academics who were the objects of the campaign. Those – objectified – academics just didn’t count. Their opposition to the boycott policy – to being themselves boycotted – was not a factor in the case presented by the boycotters(3). And so a consequent feature of the boycott debate was a refusal to engage at all with those who sought to defend their institutions against the specific charges made against them. Thus the boycotters:
‘We were informed by the Executive that Bar-Ilan University had asked to send a speaker on the Thursday, saying that she was unable to attend on the Friday due to the Passover. As trade unionists we consider it totally improper that a member of Bar-Ilan university management should expect to address Council.
…If the Executive can find an Israeli trade union in Higher Education which has taken a stand against the occupation of the Palestinian territories, we would welcome an invitation to their representative too. We do not welcome an invitation to representatives of the management of any university in any country, including the UK.’(4) (Benjamin 2005)
This is disingenuous. The widespread opposition of Israeli academics was well known to the boycotters. But it was simply excluded from the considerations of the AUT. Similarly, opposition from the ‘objects’ of the boycott – Israeli academics – was dismissed by some Palestinian supporters of the boycott. As Omar Barghouti puts it:
‘Are we to judge whether to apply sanctions on a colonial power based on the opinion of the majority in the oppressors’ community? Does the oppressed community count at all?’(Barghouti 2004)
This particular dismissal of the very widespread opposition explicitly rests the argument for an academic boycott on the depiction of Israel as a colonial power – and simply a colonial power, simply as an oppressor state, and one, therefore, where opinion doesn’t matter. The ABC of kitsch-left international justice will then tell you that the right thing to do with colonial powers is to get rid of them, to wage an anti-colonial struggle for national liberation, and drive them out. This is a response to an argument about opinion in Israel – not about colonial-style practices in the occupied territories. It works only on the basis of a simple minded ‘blocist’ account of the ‘oppressor’ and ‘oppressed’ community, one that is blind to the pluralities of thought and politics in both Israel and Palestine, and, worse, it is premised on the’ illegitimacy’ of Israel, consequently on the end of Israel as a nation-state. The illegitimacy of Israel is the driving assumption that licenses the objectification of Israeli academics, and their treatment only as means to an end and not as an end in themselves, not as rational beings. There was, in the arguments of the boycotters, a continual reduction of Israeli academics, on the basis of their supposed complicity in the occupation – a reduction of individuals to obstacles which licensed their treatment as objects.
And this objectification is a general feature of boycotting. The model that was continually raised by the boycotters was, of course, that of South Africa. I’m very reluctant to indulge that analogy because it is fundamentally misconceived. Nevertheless, if considered in detail and carefully, and not as a Stalinist totem, the South African boycott can be instructive. For example, the decades-long opponent of Apartheid, Neville Alexander, observed this same objectification in calls for a “total boycott” of South Africa:
‘A “total boycott” assumed that human beings – working people especially – were willing instruments in a political game played by elites that had absolute control over them.’(Alexander 1995)(5)
These worries about objectification of rational persons suggest a Kantian threshold for action of this sort – that boycotts that fail to treat the people boycotted as rational agents are impermissible. The considerations invoked in calling down harm on yourself, your institution, are different to those involved in calling down harm onto others. In calling down harm on yourself, or your institution, you take on some of the responsibility for that harm – you engage in a joint project. Calling down harm on others, requires a justification of the very serious disrespect involved in the attitude to those on whom harm is called down. The disrespect for persons is shown by the use of coercion rather than reason to get them to change their view. In the debate within the AUT this disrespect, in the Kantian sense, was a mark of an anti-Semitic discourse, because it was combined with an unwarranted selectivity. The calling down of a boycott on another institution showed a terrifying lack of confidence and lack of respect for argument and reason, and a lack of respect and confidence in the capacity of argument with respect to Israeli academics in particular, singled out for special treatment in the absence of a morally relevant justification: these academics, it says, cannot be reasoned with, these academics are complicit, or bought off, or suborned or uniquely venal, these academics, need to be coerced. The combination of this Kantian view with the unwarranted selectivity underpins the claim that the boycotts were, in effect(6) anti-semitic.
(iii) Remarks about greylisting
Now, in line with this argument, I present some general thoughts about the practice of relations between academics and institutions. These considerations are more or less independent from the argument contained in the first part of this paper. However, I want to address the argument that the boycotts of Haifa and Bar-Ilan were in some way just an extension onto the international plane of ordinary trade union action. A consequence of this view is that either the ordinary trade union actions are ruled out by indicating the very serious objections to an academic boycott of Israel, or that the permissibility of ordinary trade union actions justifies the permissibility of such a boycott. I want to disconnect these two, arguing for the permissibility of ordinary trade union acts but at the same time maintaining the impermissibility of the academic boycott of Israel. (These considerations are also relevant because of the needs of the author to contribute to a general policy in the AUT on the sorts of sanctions that an academic trade union might apply in order to defend the interests of its members.)
I make here the assumption that it is reasonable to take some sort of collective action, as a resource that provides a countervailing power to the power of a university administration to hire and fire. The argument for this, which I have made elsewhere (Pike 1998) is, again, Kantian in form – it involves the notion that it is morally impermissible to use someone solely as a means to an end they cannot share, and that resistance to being so used, in the form of a countervailing power – is consequently permissible.
It sometimes happens that there are disputes between a university administration and its academic staff. It sometimes seems appropriate for academic staff at other institutions to show solidarity with the staff involved in those disputes: There is a specific example in the UK at present: The administration at Brunel University has fired two academics, members of the AUT, in order to improve its ratings in the Research Assessment Exercise. These two academics are charged with ‘over teaching’ and the case is a particular example of the general phenomenon known as ‘publish or perish.’ What actions may academics at other institutions reasonably take in protest against these dismissals? The AUT executive, in response to a request from Brunel AUT voted to ‘greylist’ Brunel.
Note the obvious difference: between this case and the proposed boycott of Israel – the greylisting was called for by Brunel academics, through Brunel AUT. The Kantian threshold – that persons were not being used solely as a means to an end – was passed and their wishes were being respected(7).
The argument outlined suggests one practical threshold – a necessary condition of any action taken against an institution with a functioning staff association or trade union – is the action approved by the appropriate staff body at that institution?
If it is, then the Kantian threshold may be overcome, because the action then is not an action against, but joint action with the person. It is not, then, the case that the person ‘cannot possibly agree with my way of behaving to him and so cannot himself share the end of the action.’ It is possible for academics to assent to their institution being greylisted. There is a world of difference between the claim ‘harm them’ (the claim involved in the proposal for a boycott of Israeli institutions) and the claim ‘harm me.’ (the claim involved in the greylisting of Brunel. And the difference is captured in the Kantian thought that if the claim is ‘harm me’, then there is some acknowledgement of the rational standing of the individual who is being boycotted.
However, there are still very many considerations and constraints on permissible action. I hope to tidy up some intuitions here, which go to show the gulf between the actions of the Israel boycotters and permissible actions, including greylisting, which, for the sake of clarity are probably best not described as a boycott. A Kantian distinction which will serve as a method of capturing these intuitions, is between perfect and imperfect duties to others: perfect duties to others are morally binding, imperfect duties are prescriptions of general ends and the process of filling them by specific actions calls for judgement (Kant 1948). An example of the distinction applied to this particular area is as follows: I have a perfect duty to consider all applications from prospective students, or postgraduates or applicants for a staff post without reference to institutional affiliation, political view or nationality. (Contrast the view and actions of Andrew Wilkie, Sue Blackwell, Mona Baker.) This is an absolute obligation, regardless of any decision taken by a staff association or union.
According to Kant, I have a general obligation of beneficence.
Something like this is reflected in my contractual obligation with my employer – the Open University – to ‘promote philosophy’. But the way in which I pursue this general end, ‘calls for judgement.’ I am, it seems, obliged to attend philosophical conferences. But I am not required – in the sense that I have a binding duty – to attend a particular conference. So I am not required to attend philosophy conferences that take place at Burnel University, and it is permissible for me to act in line with the AUT greylisting of Brunel. The AUT advice on this matter(8) has three features: these actions are supported – indeed called for – by the academic staff at Brunel, they are explicitly deliberative and communicative and, to that extent they engage with the rational capacities of those against whom the action is directed, and they involve actions towards Brunel, an institution towards which no particular obligation is owed, rather than actions against individuals – staff or students from Brunel to whom an absolute duty of just treatment is owed.
There is a directional element – I respond to people from the institution in specified ways on the basis of general and absolute obligations of fairness. I act towards the institution in other ways – I do not have a binding obligation to apply for a particular attractive post at a particular university, or accept an invitation to a particular conference: these are particular acts that might fall under a general obligation of beneficence. A fully featured theory of the (im)permissibility of academic boycotts and greylisting, would then have to take account of all these constraints.
If this account is right, I have shown both something of what was fundamentally wrong with the proposed academic boycott of Haifa and Bar-Ilan, and also circumstances in which a superficially related, but in fact very different action: ‘greylisting’ might reasonably be pursued. Even if my account is not wholly right, any fully adequate account needs to capture both the (non-consequentialist) intuition that a core problem with boycotts is their objectification of those whom they target, and the intuition that I am, in the end, entitled to decline an invitation to a conference at an institution that treats its staff badly, in support of those staff.
However, there are further restrictions even on this. Greylisting is a form of discrimination: it involves special treatment of particular people. Is it a form of unjust discrimination? This is a question of contingencies, which cannot be answered without an account of the way the world is. As David Edmonds says in Caste of Thousands, speaking of racism in a context of the political exclusion of African-Americans:
‘relevant groups cannot be identified by their intrinsic characteristics alone. In other words, in itself, skin pigmentation is no more relevant or irrelevant a factor than toe size. To understand the nature of discrimination requires knowledge of the real world and in particular of how society is actually divided; whether, for example, it is divided by sex or by toe size. And these are contingent facts. Only given these contingent facts can one assess the morality of taking into account certain characteristics in the distribution of jobs or places in higher education. It is not the case that discriminating on grounds of race must necessarily be worse than discriminating on grounds of toe size. One can imagine a world in which the reverse was the case.’(Edmonds 2006)
The world in which we live, matters. The world in which we live is one in which actions have consequences, nations have histories, and speech acts have audiences. An abstract analysis of these matters has its limits. There is no serious question of discrimination against the people of West Drayton(9).
As the Wilkie and Baker cases show, there is a serious question of discrimination against and demonisation of Israeli academics and students. There is a context of widespread anti-semitism in the region, and of existential threats, demagogic or not, to the State of Israel. In the end, attempts to defend the AUT boycott of Haifa and Bar-Ilan as some sort of generalisation of ordinary trade union methods onto the international stage were simply disingenuous. Such attempts simply showed, or perhaps pretended, ignorance of the world in which we live.
Alexander, N. (1995). “Academic Boycotts: Some Reflections on the South African Case.” Perspectives on the Professions 15(1)
Barghouti, O. (2004). Why Boycott Israel?
Berlin, I. (1969). Four Essays on Liberty, Oxford University Press.
Blakemore, C., R. Dawkins, et al. (2003). “Is a scientific boycott ever justified?” Nature 421(314)
Butler, J. (2006). “Israel/Palestine and the paradoxes of academic freedom.” Radical Philosophy(135)
Edmonds, D. (2006). Caste Wars: The morality of treating individuals as though they are members of groups, Routledge.
Kant, I. (1948). Groundwork of the Metaphysic of Morals (published as The Moral Law), Hutchinson University Library.
MacCallum, G. C. J. (1967). “Negative and Positive Freedom.” Philosophical Review 76: 312-34
Nussebeih, S. (2005). Urgent Appeal – The “Security Wall” bars education in Jerusalem. (on liberoblog.com)
Pike, J. (1998). Strikes. Encylopaedia of Applied Ethics, Academic Press
Pike, J. (2005). After the Boycott. Fear of the Other
(1) This ‘procedural’ defence of the AUT boycott, which rests on this idea of convergence, is persuasive on only the most superficial acquaintance. Imagine a teacher who catches a gang of bullies to ask them why they were picking on Fred, and asks ‘why are you picking on Fred?’ What would we make of the answer ‘well, we took a vote, and Fred came top.’ It is, I suppose, an answer.
(2) In his paper to the Bar-Ilan conference, which Prof. Yudkin has kindly passed to me
(3) Compare the view of Noam Chomsky.
(4) The faux workerism of the language here is ridiculous.
(5) It is worth noting, too the consequentialist considerations brought to bear by Alexander on the experience of the South African Academic boycott: ‘Some of the scholarly backwardness of South Africa today is, I am sure, due to the marooning of much of our scholarship in the 1980s. Take, for example, my own field, education: we were almost completely ignorant of the work that was being done in the 1980s on the question of multilingual pedagogy in such countries as Australia, Belgium, and Canada, not to mention India, Nigeria, Tanzania, and the like. Similar examples from all fields are legion, the direct result of an indiscriminate academic boycott.’ Alexander, N. (1995). “Academic Boycotts: Some Reflections on the South African Case.” Perspectives on the Professions 15(1)
(6) Nothing is said, meant, or implied, either way, about the intentions or beliefs of those who supported the boycott here. Those intentions or beliefs, whatever they are, are beside the point.
(7) There are many caveats here, related to the representativeness of a local AUT decision. Perhaps legitimacy here is directly proportional to the representativeness of the local decision. In order to avoid that complexity, assume for a moment the existence of a person called ‘Brunel Academic’ that person could agree with my way of behaving towards them.
(8) ‘Do not apply for any posts at Brunel. If you were actively considering applying for a post, e-mail the head of department concerned to say you will not be applying because you are supporting the greylisting. Alternatively, please also e-mail the HoD to inform them that you would not consider applying for a post at Brunel in the future due to their actions.
Do not attend or participate in any conference to take place at Brunel, unless there is a contractual obligation upon you to do so. Inform the conference organisers in writing that you will not be attending, and ask them to pass your views on to their head of school.
Do not use Brunel facilities for any conferences. If you are planning a conference write to the head of school and to the conferences department telling them that while you had considered using Brunel, you will not be able to because you are supporting the greylisting.’
(9) This is the area of West London where many Brunel University staff live.