Most people are dead. Nevertheless, dead people have little in the way of legal rights. They are (probably) not eligible for many of the common important rights: the right to bodily integrity and physical liberty; political, social and economic rights. In a striking exception, the wishes of the deceased in respect of their property are protected by the well-developed process of probate. That branch of the law aside, it may generally be said that, once a person passes away, the law washes its hands of them. Inquests deal with the dead, of course, but they are primarily concerned with rights that the subject had in life, rather than with any rights that they retain. The same goes for litigants whose estates can be represented in proceedings after their demise.
So I sat up when this Tweet by Andrew Tettenborn crossed my desk:
The decision referred to in the Tweet was ML v Slovakia [2021] ECHR 821 (application number 34159/17), which had been handed down by the European Court of Human Rights that day, 14 October 2021. The case provoked a small amount of displeasure on the platform, including on the part of the well-loved anonymous legal commentator SpinningHugo, who described the decision as “a disgrace”.
How did we get here? How did the European Convention on Human Rights reach a point where (in Professor Tettenborn’s words) it “may require the reputation of the dead to be protected”? In this blog post, I will follow the lines of authority that lead the Court to the decision in ML v Slovakia in order to clarify exactly what it stands for. Luckily for us, the cases are generally interesting and varied in their subject-matter. But I should say, for the benefit of anyone who would rather not read about such topics, that one of them, Hadri-Vionnet v Switzerland, discusses the consequences of a stillbirth, and another, ML itself, mentions sexual abuse by a Catholic priest.
I intend to stick to the expository side of legal analysis and not give my opinion on what the law should be. But it would be remiss of me to fail to contextualise the discussion. That is why I included the opening paragraph, and why I note that the field of information law in the UK generally excludes the dead too. Recital 27 of the GDPR, which has been incorporated into UK law, provides that “this Regulation does not apply to the personal data of deceased persons”. And section 1(1) of the Law Reform (Miscellaneous Provisions) Act 1934 provides that, in contrast to most claims, defamation claims may not be maintained on behalf of the estate of a deceased person. This context is what makes ML v Slovakia interesting.
Before we explore the cases, it is worth briefly reminding ourselves about Articles 8 and 10 of the ECHR and the relationship between them. Article 8 provides as follows:
(1) Everyone has the right to respect for his private and family life, his home and his correspondence.
(2) There shall be no interference by a public authority with the exercise of this right except such as is in accordance with the law and is necessary in a democratic society in the interests of national security, public safety or the economic well-being of the country, for the prevention of disorder or crime, for the protection of health or morals, or for the protection of the rights and freedoms of others.
And Article 10 provides as follows:
(1) Everyone has the right to freedom of expression. This right shall include freedom to hold opinions and to receive and impart information and ideas without interference by public authority and regardless of frontiers. This Article shall not prevent States from requiring the licensing of broadcasting, television or cinema enterprises.
(2) The exercise of these freedoms, since it carries with it duties and responsibilities, may be subject to such formalities, conditions, restrictions or penalties as are prescribed by law and are necessary in a democratic society, in the interests of national security, territorial integrity or public safety, for the prevention of disorder or crime, for the protection of health or morals, for the protection of the reputation or rights of others, for preventing the disclosure of information received in confidence, or for maintaining the authority and impartiality of the judiciary.
A qualified ECHR right such as Article 8 or 10 generally has a certain structure. The purpose of the right is primarily to restrain state action. In certain circumstances, the Articles place the state under a positive obligation to take action, but this is less common. An Article makes it unlawful for the state to do A, or requires it to do A as the case may be, but carves out an area B, described by its paragraph (2), that is not encompassed by A. A is the state’s zone of obligation and B is its zone of freedom. Article 8 prevents the state from doing 8A (interfering with privacy etc generally), but permits it to do 8B (interfering with privacy etc in accordance with law when necessary in a democratic society and for a purpose listed in paragraph (2)). Article 10 prevents the state from doing 10A (interfering with the freedom of expression generally), but permits it to do 10B (interfering with the freedom of expression as prescribed by law, necessary in a democratic society and for a listed purpose).
This is possibly an overcomplication of a familiar mechanism, but it is worth spelling it out in this way to make a preliminary point. Frits Hondius said in 1983: “Article 8 and 10 are each other’s reflection in the mirror”. One person’s right to privacy often has to be weighed against another person’s right to freely express information. This is structurally possible because Article 8(2) provides that “the protection of the rights and freedoms of others” is a justification for interfering with privacy, and Article 10(2) provides that “the protection of the reputation or rights of others” is a justification for interfering with the freedom of expression. The state is permitted to interfere with a person’s right to privacy in order to protect the freedom of expression in circumstances that put the interference within 8B. But that does not mean that that interference, which constitutes protection of the freedom of expression, will itself be required under Article 10. 10A does not begin where 8B ends. And, similarly, 8A does not begin when 10B ends. A state may be free to limit privacy to protect the freedom of expression where that protection goes beyond its obligations under Article 10. And a state may be free to limit the freedom of expression to protect privacy beyond what Article 8 requires.
The point to take away from this is that it matters whether the court is deciding a case under Article 8 or 10 ECHR, even if issues of both privacy and the freedom of expression are at stake. A court’s decision in an Article 8 case about balancing privacy and the freedom of expression may well not be seamlessly transferable to an Article 10 case. If you think this point is obvious, please join me on my journey through cases in which that does not appear to be the universal position.
Our starting-point is Editions Plon v France (application number 58148/00), which was decided in 2004. This case revolved around the death of François Mitterrand. Mitterrand was President of the French Republic from 1981 until 1995. In 1981, shortly after his first election as President, Mitterrand was diagnosed with prostate cancer, and it was from this illness that he died on 8 January 1996. The cancer was not revealed to the French public until a surgical operation took place on 11 September 1992. Even then, it was not public knowledge that the President had been diagnosed long before.
On 8 November 1995, Editions Plon, a French publishing company, signed a contract to acquire the rights to Le Grand Secret, a book co-written by a journalist and Mitterrand’s former doctor, Claude Gubler. The big secret to which the title referred was the concealment of the French President’s illness for longer than ten years. The publication of the book, originally scheduled for mid-January 1006, was postponed upon Mitterrand’s death. However, this decision was reversed because of what were perceived to be public slights upon Dr Gubler’s professional reputation. Publication was set for 17 January 1996. The Mitterrand family sought and were granted in urgent proceedings an injunction prohibiting distribution of the book on 18 January 1996. The injunction was subsequently made permanent in standard civil proceedings and upheld on appeal, not on the ground of interference with the privacy of Mitterrand or his family, but on the ground of the breach by Dr Gubler of his duty of medical confidentiality towards the late President. The publisher, its managing director and Dr Gubler were each ordered to pay damages to the Mitterrand family. Further, Dr Gubler was convicted of the crime of breaching professional confidence and given a suspended sentence.
The publisher made a claim against France before the European Court of Human Rights for breach of its Article 10 rights. It claimed that the injunction was not prescribed by law, did not pursue a legitimate aim, and was not necessary in a democratic society. It further claimed that the fine it had to pay was disproportionate to the aim it pursued.
The Court allowed the publisher’s claim in part. It held that the interference with the publisher’s Article 10 rights was prescribed by law and pursued a legitimate aim. The urgent injunction had been necessary in a democratic society, but the permanent injunction had not been. As a result, the publisher’s Article 10 rights had been violated. The Court did not make a finding about the damages the publisher had been ordered to pay.
For our purposes, the interesting part of the judgment is at paragraph [34]. Here, the Court is deciding whether the injunction against distributing Le Grand Secret pursued a legitimate aim. The Court said as follows (emphasis added):
It is apparent both from the reasoning of the judgments of the domestic courts, in particular the Court of Appeal’s judgment of 27 May 1997, and from the Government’s submissions before the Court that the judicial authorities based their decisions on a combination of two of the “legitimate aims” listed in paragraph 2 of Article 10 of the Convention, namely “preventing the disclosure of information received in confidence” (information covered under the national legislation by the rules of medical confidentiality) and protecting the “rights of others” (those of the President, and of his widow and children, to whom they were transferred on his death).
It is not for the Court to determine whether the civil liability incurred on account of the breach of medical confidentiality comes, in abstract terms, under the first of these legitimate aims, the second or both at once. It is sufficient for it to note that in the instant case the measures complained of, namely the interim injunction and the decision on the merits to keep the ban in force, were intended to protect the late President’s honour, reputation and privacy, and that the national courts’ assessment that these “rights of others” were passed on to his family on his death does not appear in any way unreasonable or arbitrary. Moreover, it is precisely because much of the information disclosed in the book was classified in law as secret, and was therefore a fortiori received in confidence, that it was capable in practical terms of infringing the rights of others, the protection of which is deemed legitimate in paragraph 2 of Article 10.
Accordingly, the interference in issue pursued at least one of the “legitimate aims” set out in the second paragraph of Article 10 of the Convention.
It is important to see what the Court says here in the context of the Article 10 analysis. The Court is saying that France was free to restrict the publisher’s freedom of expression in order to “protect the late President’s honour, reputation and privacy”. It is not saying anything about what Article 8 requires. In 2004, there was no indication that Article 8 required the protection of the reputation of the dead.
Our next case is Hadri-Vionnet v Switzerland (application number 55525/00), in which judgment was handed down in 2008. In 1996, Dalila Hadri-Vionnet, an Algerian national, sought asylum in Switzerland. On 4 April 1997, Ms Hadri-Vionnet gave birth to a stillborn baby. When asked immediately after the birth, the baby’s mother and father said that they did not want to see the body. The local civil service proceeded to transfer the baby’s body to a communal grave for stillborn babies, where the body was buried without a ceremony. Ms Hadri-Vionnet’s criminal complaints against the authorities for misuse of official authority, disturbing the repose of the dead, unlawful removal of property, and violation of her personal freedom under the Swiss Federal Constitution. The last complaint was made in the light of a decision of the Swiss Federal Court that the constitutional right to personal freedom encompassed the right of parents to object to any unjustified intervention in relation to the remains of a deceased child. All of Ms Hadri-Vionnet’s complaints were dismissed by the Swiss courts. She applied to the European Court of Human Rights in December 1999, complaining that her not having been able to attend her child’s funeral and the body’s transportation in an ordinary delivery van violated her rights under Article 8 ECHR.
The Court held that Article 8 had been violated. Having established that Ms Hadri-Vionnet’s Article 8 rights were engaged and interfered with in the circumstances, the Court was quickly able to decide that there had been no legal basis for the interference. Of interest are paragraphs [50] to [52] of the judgment, where the Court said as follows (emphasis added):
50. The Government did not contest the applicability of Article 8 to the instant case.
51. The Court reiterates that the concepts of private and family life are broad terms not susceptible to exhaustive definition (see, for example, Pretty v. United Kingdom, no. 2346/02, § 61, ECHR 2002‑III). Thus the former Commission had considered that the wish to have one’s ashes scattered on one’s own land was covered by the first concept (see X v. Germany, decision of 10 March 1981, no. 8741/79, Decisions and Reports 24, p. 137). Later, in the case of Znamenskaya v. Russia (no. 77785/01, § 27, 2 June 2005), the Court considered the “private life” aspect of Article 8 to be applicable to the question of whether a mother had the right to change the family name on the tombstone of her stillborn child. In the case of Pannullo and Forte v. France (no. 37794/97, § 36, ECHR 2001‑X), the Court considered the excessive delay by the French authorities in returning the body of their child following an autopsy to be interference with the private and family life of the applicants. Lastly, in the case of Elli Poluhas Dödsbo v. Sweden (no. 61564/00, § 24, ECHR 2006‑…), the Court considered that the refusal to authorise the transfer of the urn containing the applicant’s husband’s ashes was a matter falling within the scope of Article 8, without however stating whether the interference found related to the concept of private life or family life.
52. In the light of that case-law, the Court considers Article 8 to be applicable to the question of whether or not the applicant was entitled to attend the burial of her child, possibly accompanied by a ceremony, and to have the child’s remains transported in an appropriate vehicle.
There are two points to note in these paragraphs. First, Switzerland did not contest the applicability of Article 8, so although the Court stated that its conclusion was supported by its previous decisions it would not have heard full argument on the point. Second, the decision is focussed on the wishes and feelings of the living applicant, Ms Hadri-Vionnet. Both the Court’s conclusion and the decisions cited concern the impact of state action or inaction on a living person. Paragraph [52] puts within the scope of Article 8 whether “the applicant was entitled to attend the burial” and “to have the child’s remains transported in an appropriate vehicle”,with Ms Hadri-Vionnet as the grammatical subject despite the second component concerning the treatment of the body, not of the mother. It was emphatically Ms Hadri-Vionnet’s Article 8 rights, as a matter of both substance and form, that had been violated.
The Court decided some relevant cases between 2008 and 2011, including Palade v Romania (application number 37441/05), Hachette Filipacchi Associés v France [2007] ECHR 5567 (application number 71111/01) and John Anthony Mizzi v Malta [2011] ECHR 1960 (application number 17320/10). However, none of these contributed anything new after Editions Plon and Hadri-Vionnet. The next case worth examining in detail is Putistin v Ukraine [2013] ECHR 1154 (application number 168882/03), decided in 2013. The applicant, Vladlen Mikhaylovich Putistin, was the son of Mikhail Putistin, a professional footballer who had taken part in the “Death Match”, a notorious football match between Ukrainian and German players during World War Two. When the Ukrainian side lost, at least eight of its members were sent to concentration camps and at least three, which were executed. Fast forward to 2001, by which time Mikhail Putistin had died, not by execution of the Nazis. A newspaper published an article that essentially alleged that the Ukrainian players who had not been executed after the match had been collaborators with the Gestapo. The article did not mention Mikhail Putistin’s name. But his son applied to the Ukrainian courts for rectification of untrue information and damages. He had no success. He applied to the European Court of Human Rights to complain of a breach of his right to the protection of his reputation under Article 10 ECHR, but the Court decided that the application should be considered under Article 8. The Court decided that Article 8 was applicable to the application before dismissing it on the basis that that the interference with the applicant’s Article 8 rights had been minimal and the Ukrainian courts had struck an appropriate balance between the competing rights of the applicant, the newspaper and the journalist. Paragraph [33] is the interesting part, where the Court considered the applicability of Article 8. The Court said as follows:
33. The question of whether the damage to the reputation of an applicant’s family can be considered an interference with the right to respect for the applicant’s private life was raised, but not finally decided, in Palade v. Romania ((dec.), no. 37441/05, § 25, 31 August 2012). The Court can accept, as do the Government, that the reputation of a deceased member of a person’s family may, in certain circumstances, affect that person’s private life and identity, and thus come within the scope of Article 8.
Three points to note. First, again, Ukraine accepted the applicability of Article 8 to the situation, limiting the precedential value of the decision on this point and perhaps contributing to the terseness of its expression. Second, while still formally directed to the applicant and not to his late father, the formulation of what falls within the scope of Article 8 is more protective of the deceased individual than Hadri-Vionnet. In that case, what mattered was the protection of the applicant’s agency in respect of her child and her feelings consequent to the denial of that agency. In this case, the applicant’s relationship with his late father was not in any way interfered with. It was simply the impact on the applicant of the impact on the father’s reputation that mattered. This seems to be different. Third, the “certain circumstances” are not fleshed out at all. Especially in the light of the novelty of the conclusion, the Court does not give any guidance as to how, or how often, it will apply.
The decision in Putistin was considered in an interesting 2014 decision, Yevgeniy Yakovlevich Dzhugashvili v Russia (application number 41123/10). This case related to a complaint by the grandson of Joseph Stalin that the Russian state was failing to protect the reputation of the latter against attacks in newspapers. The Court essentially rejected the application on the basis that legitimate criticism of public figures was to be distinguished from defamatory attacks on private persons. Part of the Court’s reasoning, in paragraphs [21] to [27], is worth reading in full. The Court said as follows (emphasis added):
21. The complaint is twofold. In so far as the applicant can be understood to be complaining of a violation of the Convention rights of his grandfather, the Court will first examine the applicant’s locus standi in this respect.
22. In the case of Sanles Sanles v. Spain ((dec.), no. 48335/99, ECHR 2000-XI) the applicant, as the heir of a deceased person, was complaining on behalf of the latter in respect of his claims for recognition of the right to die in dignity. The Court considered that the right claimed under Article 8 of the Convention, even assuming that such a right existed, was of an eminently personal nature and belonged to the category of non‑transferable rights.
23. The Court confirmed the principle that Article 8 rights were non‑transferable when it refused a universal legatee to pursue an application lodged by the immediate victim in the case of Thevenon v. France ((dec.), no. 2476/02, 28 June 2006).
24. The Court does not find sufficient reasons to depart from its established case-law in the instant case. It follows that the applicant does not have the legal standing to rely on his grandfather’s rights under Article 8 of the Convention because of their non-transferable nature.
25. It follows that this part of the complaint is to be rejected under Article 34 as being incompatible ratione personae with the provisions of the Convention.
26. As to whether the applicant’s own right to respect for his private and family life are at stake in the instant case, the Court will proceed with the examination of whether the two above-mentioned disputes and the way in which they were resolved by the domestic courts affected the applicant’s own private and family life and, if so, whether the State took such measures as to secure effective respect of the latter.
27. In its recent case-law the Court has accepted that the reputation of a deceased member of a person’s family may, in certain circumstances, affect that person’s private life and identity, and thus come within the scope of Article 8 (see Putistin v. Ukraine, no. 16882/03, §§ 33, 39, 21 November 2013, where a publication in the mass media allegedly provoked the presupposition that the applicant’s father had been a Gestapo collaborator).
This is worth reading for two reasons. First, it is authority, if any were needed, for the proposition that, as a formal matter, a family member cannot apply to the Court to vindicate a deceased person’s Article 8 rights. Any rights protected must belong to a living person. Second, the Court accepted in principle the decision in Putistin, although it said at [28] that it was “not ready to draw a parallel with the Putistin case” because of the different subject matter of the application. Although it is not clear, this indicates that the Court did not reject the application on the basis of justification for interference, but on the basis that the “certain circumstances” did not extend to Yevgeniy Yakovlevich’s situation, meaning that no Article 8 rights were interfered with at all. So we have a small indication of how the “certain circumstances” are to be drawn.
For our next case, we leave the terrain of Article 8 and return to Article 10. In Genner v Austria [2016] ECHR 36 (application number 55495/08), Michael Genner had written a piece for publication on the website of an organisation supporting asylum seekers and refugees that celebrated the death of the Austrian Interior Minister, Liese Prokop (referred to as “L.P.” in the judgment). Mr Genner was convicted of the crime of defaming Ms Prokop, partly due to the association of the late Ms Prokop with Nazi ideology. His conviction was upheld on appeal and he complained to the European Court of Human Rights that his Article 10 rights had been violated. The Court dismissed the application, since the interference with Mr Genner’s Article 10 rights was prescribed by law, pursued the legitimate aim of protecting the reputation and rights of both Ms Prokop and the members of her family, and was proportionate.
Two short passages stand out. First, when discussing the relevant principles, the Court said at [35] as follows:
35. Dealing appropriately with the dead out of respect for the feelings of the deceased’s relatives falls within the scope of Article 8 (see with further references Hadri-Vionnet v. Switzerland, no. 55525/00, § 51, 14 February 2008, Editions Plon v. France, cited above § 46 and Putistin v. Ukraine, no. 16882/03, § 33, 21 November 2013). […]
It may be said that this is a pedantic point, but to say that the action described here simply “falls within the scope of Article 8”, with no mention of the “certain circumstances” from Putistin, is striking. Perhaps this is part of a trend of moving the whole battle into the justification stage from the earlier interference stage. Or perhaps, because this is not strictly an Article 8 case, the Court did not feel the need to express itself precisely on this point. Whatever is the fair judgment on that point, it is concerning that the Court cites Editions Plon, an Article 10 decision that does not mention Article 8 once, to support a proposition about Article 8. It is unclear why it was thought relevant to explain this Article 8 principle at all, when any balancing exercise between Articles 8 and 10 is far from explicit in this case. It is all the harder to work out when paragraph [46], to which the reader is referred, does not appear to be relevant and it may have been an error to cite it.
Second, when applying the principles to the facts of the case, the Court said at [41] as follows (emphasis added):
41. The Court further agrees with the government that the interference did pursue the aim of the protection of “the reputation or rights of others”, namely those of L.P. and the close members of her family ‒ in particular her husband ‒ which constitutes a legitimate aim within the meaning of paragraph 2 of Article 10 (see, Editions Plon v. France, cited above, § 34).
What we remarked upon at the start of our journey in Editions Plon is referenced and repeated: as a matter of justification for interfering with Article 10 rights, a state is free to consider that the rights of a deceased person continue to be capable and worthy of protection. This is in marked contrast to the formal position under Article 8, as expressed in Dzhugashvili at [24]. The fact that the principles in these two classes of case need to be carefully distinguished is what makes it problematic that the Court cited Editions Plon in the way it did at [35].
This brings us to our recent case: ML v Slovakia [2021] ECHR 821 (application number 34159/17). We come back to Article 8. The son of the anonymous applicant had been a Roman Catholic priest and a convicted sex offender before dying in 2006. In 2008, newspapers ran articles about the deceased man that, in the applicant’s view, alleged more than had been proved in court, interfering with both his and her privacy rights and contributing to a deterioration in her health. Although partly successful at first instance in her attempt to secure apologies and damages through the Slovakian courts, the applicant failed following all possible appeals. The applicant applied to the European Court of Human Rights, arguing that her Article 8 rights had been violated. The Court agreed. The applicant’s Article 8 rights had been interfered with; the deceased’s lack of prominence, the sensationalism of the articles, and their lack of any contribution to a debate of general interest should have led the Slovakian courts to conclude the balancing exercise in favour of the applicant.
Two passages demand remarks. First, the Court said at [23] about the applicability of Article 8 as follows:
23. It is clear from the Court’s case-law (see Hadri-Vionnet v. Switzerland, no. 55525/00, § 51, 14 February 2008, with further references; Editions Plon v. France, no. 58148/00, § 46, ECHR 2004‑IV; and Putistin v. Ukraine, no. 16882/03, § 33, 21 November 2013), and the Government accepted, that dealing appropriately with the dead out of respect for the feelings of the deceased’s relatives falls within the scope of Article 8 of the Convention.
This is basically a repeat of paragraph [35] of Genner, with the garnish of Slovakia’s acceptance of the principle. Notably, the same authorities, with the same apparently erroneous or at least unhelpful paragraph reference to Editions Plon, appear to have been copied and pasted in. But Genner itself is not even cited in this case, which is no wonder, because it is an Article 10 case, not an Article 8 case. So why is it the source of such an important principle in this decision?
Second, the Court said at [48] in the context of the balancing exercise as follows:
48. Lastly, the Court is ready to accept that the distorted facts and the expressions used must have been upsetting for the applicant and that they were of such a nature as to be capable of considerably and directly affecting her feelings as a mother of a deceased son as well as her private life and identity, the reputation of her deceased son being a part and parcel thereof (see Putistin, cited above, § 33, and Dzhugashvili v. Russia (dec.), no. 41123/10, §§ 27 and 30, 9 December 2014).
This paragraph seems to be doing nothing more than reassuring the reader that it is substantively as well as formally the rights of the applicant that are at stake, not any rights of her deceased son. But it does so in a fascinating way absent from the other cases. It does not say that the impugned articles were upsetting for the applicant, but that they “must have been upsetting” for her, because they were “capable of” affecting her feelings by reason of her relationship to the dead man. The justification for including the protection of the reputation of family members within the scope of Article 8 is not the real impact on the applicant in this case, but the principled point that the reputation of a deceased family member is “a part and parcel” of one’s private life and identity. This is the opposite of Putistin’s “certain circumstances”, and we have left the applicant-focussed reasoning of Hadri-Vionnet. The reasoning, if not the conclusion, in Dzhugashvili is difficult to maintain in this light. The Court is no longer hesitant to include the protection of the reputation of family members within the scope of Article 8, accepting arguments on a case-by-case basis. It now does so on principle.
It is easy to understand why ML provokes strong feelings. Pre-existing concern with a perceived excessive extension of ECHR rights allies with a distaste for the substance of the claim brought by the applicant in this case. But if hard cases make bad law, it would not have made ML a better decision if it had been decided differently simply because the applicant’s son was a sexually abusive priest. What makes ML a bad decision is that it is built on insecure foundations. We have seen in these cases that states routinely fail to argue arguable points, resulting in thinly-reasoned conclusions; principles are passed between the contexts of Article 8 and Article 10 analysis with insufficient distinction; infelicities in language that are of little importance in one case are carried over into another in which the change is substantial; and the important anchor of the applicant’s own experiences of their private life in Article 8 cases has left the jurisprudential seabed. It is no exaggeration to say that paragraph [48] of ML suggests that deceased persons have a right to the protection of their reputation via the Article 8 rights of their living relatives, in substance if not in form. Seemingly throwaway statements like it in the earlier cases have had serious consequences down the line.
What I’ve been listening to this week…
I’ve been to a marvellous party. Specifically, Shefali and I celebrated our engagement surrounded by as many of our loved ones as circumstances allowed. Not a natural dancer, I approached that aspect of the event with (unnecessary) trepidation. So, of course, I have been listening to You Never Can Tell by Chuck Berry, on a loop, to get my practice in.
Green and Pleasant Blog 