Dr Matthew Wilkinson

For the many patriots and supporters of justice who have been following this case, I will now be keeping you all up-to-date via the Counter Jihad Warrior website. Here is my original application to have the Crown Prosecution expert witness, Dr. Matthew Wilkinson, punished for Contempt of Court following my political show trial in March 2017. After nearly six months, we are “still” trying to have this application processed, however we have run into a wall of prevarication and obfuscation from the British legal system. As a consequence, we have stepped up the pressure by applying to the Royal Courts of Appeal, asking for them to adjudicate on the failure of HHJ Taylor of Southwark Crown Court (the lower court) to act according to established procedure and to provide us with a written judgment.

It’s interesting that the lower court could have simply replied to say that the application had no merit. The fact that the lower court did not do this says to my barrister that the application does indeed have merit, but to process it in my favour (which would result in my conviction being overturned) would cause the Government extreme embarrassment due to Dr. Matthew Wilkinson’s involvement with some other very high profile cases over the past few years – some of which relate to terrorism, and all of which would need to be revisited – with all of the enormous legal costs that would entail.

The application contains a lot of legal jargon, but is well worth reading to obtain a sense of the lengths that the British legal system will go to in order to protect prominent members of the Establishment and to achieve a result that serves as an example to others, no matter how unjust – i.e. the conviction of someone who cares passionately about free speech in this country and who opposes the insidious onslaught of Islamisation.

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Application to punish for contempt of court in the case of R. v. Timothy Burton (Southwark Crown Court, Case Ref: T20160559, 27-30/3/2017)

Timothy Burton (Applicant), Dr. Matthew Wilkinson (Respondent)

 Allegation

Introduction

1. The basis of this application is that the respondent, Dr. Matthew Wilkinson, signed a statement of truth (in an expert’s report) which he either knew to be false or did not honestly believe to be true. This is contempt of court.
2. Matthew Wilkinson acted as an expert witness for the prosecution (the Crown Prosecution Service or CPS) in the case of R. v. Timothy Burton, which was tried before Recorder Alex Gordon in the Southwark Crown Court from 27/3/2017 to 30/3/2017 (Case Ref: T20160559). He gave an expert opinion on the Islamic doctrine of taqiyya, which broadly means deception or lying, as discussed below.
3. The defendant, Timothy Burton, was charged under s.32 Crime and Disorder Act 1998 with religiously aggravated harassment of a certain Fiyaz Mughal. Fiyaz Mughal is a Muslim who set up and was, until 2014 I believe, the head of an organization called ‘Tell Mama’, which allows people in the UK (generally Muslims of course) to report anti-Muslim ‘hate crimes’.
4. The alleged offence consisted of a number of E-Mails which Timothy Burton sent to ‘Tell Mama’, but which the court found were intended for Fiyaz Mughal. The most important of these described Fiyaz Mughal as a ‘mendacious grievance-mongering taqiyya artist’; that is, a liar, as explained below.
5. It is critical to note that the basis of this application is not that there was, in fact, a conflict of interest or that there was even a risk of a conflict of interest in the mind of the ordinary reasonable man, it is that Dr. Wilkinson knew that he had a duty to report any potential conflict of interest (it was for the court to decide the matter, not him), as per the CPS guidance quoted below, and that he either intentionally or recklessly did not disclose a potential conflict of interest and signed a statement of truth in his expert’s report to the effect that he had disclosed any potential conflict of interest, as per the CPS guidance, and that this conduct amounts to contempt of court.

Taqiyya

6. This E-Mail gave rise to the question of what the word taqiyya means and whether to call a person a ‘taqiyya artist’is an insult from the point of view of a Muslim. I believe that the defendant’s position was that taqiyya is conduct mandated by the Koran and that, in the appropriate circumstances, using taqiyya is a praiseworthy thing. It follows that it cannot be an insult to describe a Muslim as a ‘taqiyya artist’, because, for Muslims, the term carries positive connotations; either lying to protect oneself or one’s fellow Muslims from harm or lying to advance the cause of Islam. In short, while lying might be a bad thing from Timothy Burton’s viewpoint, the particular type of lying (taqiyya) is a good thing from the viewpoint of a Muslim.
7. In 2014, in relation to a separate incident, Mr. Timothy Burton had been charged with racially-aggravated harassment of Fiyaz Mughal in the Birmingham Magistrates’ Court, by using the same word, but had been found not guilty. In Timothy Burton’s mind, this amounted to confirmation by a court of law that using the word taqiyya could not amount to harassment, whether racial, religious or just plain vanilla. Mr. Burton’s expert witness in that case, Dutch scholar of Islam, Professor Hans Jansen, Houtsma Professor for Contemporary Islamic Thought in the Department of Arabic, Persian and Turkish at the University of Utrecht,explained that the doctrine of taqiyya involves both lying to protect oneself or other Muslims from possible harm and lying to advance the cause of Islam, and that the doctrine is acknowledged by leading Muslim theologians and commentaries on the Koran.
8. Wilkinson was instructed to provide an expert opinion about:
   1. the linguistic and religious meanings of the Arabic word taqiyya;
   2. the sources of taqiyya in Islam;
   3. the historical practice of taqiyya and,
   4. the contemporary understanding and significance of taqiyya.
9. In broad terms, Dr. Wilkinson, said that the doctrine of taqiyya allows Muslims to conceal, or lie about, their religion, but only when their lives (or the lives of fellow Muslims) are in danger. He rejected the notion that taqiyya could be used by Muslims in other circumstances; that is, to advance the cause of Islam by concealing the true nature of it (such as, say, by concealing the fact that Islam requires the murder of apostates). In Western culture, it may be acceptable to lie to avert some threat of harm, but it is generally not acceptable to lie in other circumstances. In short, one can see why, if the Koran does allow Muslims to lie when they are not in danger, they would want to conceal that fact.

Conflict of interest

10. Wilkinson (a Muslim),runs an organization, Curriculum for Cohesion, a patron of which is, according to its website, a senior CPS employee (Ms. Baljit Ubhey OBE, who is Chief Crown Prosecutor (CCP) for the Crown Prosecution Service in London); a connection he failed to disclose to the court. This is an extremely serious matter, as explained below.
11. In this context see Toth v Jarman [2006] EWCA Civ 1028 at 99 and following. At 102 it says: ‘Where an expert has a material or significant conflict of interest, the court is likely to decline to act on his evidence, or indeed to give permission for his evidence to be adduced. This means it is important that a party who wishes to call an expert with a potential conflict of interest[my emphasis] should disclose details of that conflict at as early a stage in the proceedings as possible.’
12. See also the CPS document ‘Expert Evidence’,(https://www.cps.gov.uk/legal/assets/uploads/files/expert_evidence_first_edition_2014.pdf), p. 8, which says: ‘However, it is vital that any potential conflict[my emphasis] is disclosed to the court and other parties to the proceedings by the party wishing to call the expert as soon as possible, so that an informed decision can be made as to whether the expert is impartial and what weight to be attached to his evidence – see Toth v Jarman[2006] EWCA Civ. 1028 and R v Stubbs[2006] EWCA Crim. 2312.’
13. So, it is necessary to assess whether the conflict of interest is significant. Well, we have an expert witness who runs an organization and a patron of that organization is a senior employee of the prosecution authority (the CPS) for whom the expert witness prepared his expert’s report. I simply cannot see how such a relationship can be considered insignificant.
14. In this context, see Pinochet, In re [1999] UKHL 1; [2000] 1 AC 119; [1999] 1 All ER 577; [1999] 2 WLR 272, where there was no question of actual bias on the part of the judge, merely a question of whether the judge’s interest in or connection to the case gave rise to a reasonable apprehension or suspicion on the part of a fair minded and informed member of the public that the judge (Lord Hoffmann) might be biased. In that case, reference was made to Lord Hewart’s famous dictum that it is “of fundamental importance that justice should not only be done, but should manifestly and undoubtedly be seen to be done.” (see Rex v. Sussex Justices, Ex parte McCarthy [1924] KB 256, 259).
15. So, not only is actual bias sufficient to disqualify a person, a reasonable perception of a risk of bias is enough (without any suggestion of actual bias). Even a reasonable suspicion of possible bias must be avoided.
16. In Director General Of Fair Trading v Proprietary Association Of Great Britain & Ors [2000] EWCA Civ 350, a case binding on Southwark Crown Court, it was said at 41 (emphasis added): ‘We start our analysis of the authorities with the decision of the Divisional Court in Rex v Sussex Justices, ex p. McCarthy [1924] 1K.B. 256. That decision concerned a prosecution before the lay magistrates for dangerous driving. Unknown to the Defendant and his Solicitors, the Clerk to the Justices was a member of the firm of Solicitors acting in a civil claim against the Defendant arising out of the accident that had given rise to the prosecution. The Clerk retired with the Justices, who returned to convict the Defendant. On learning of the Clerk’s provenance, the Defendant applied to have the conviction quashed. The Justices swore affidavits stating that they had reached their decision to convict the Defendant without consulting their Clerk. In giving the leading Judgment Lord Hewart C.J. said at pp.258-9:

“It is said, and, no doubt, truly, that when that gentleman retired in the usual way with the justices, taking with him the notes of the evidence in case the justices might desire to consult him, the justices came to a conclusion without consulting him, and that he scrupulously abstained from referring to the case in any way. But while that is so, a long line of cases shows that it is not merely of some importance but is of fundamental importance that justice should not only be done, but should manifestly and undoubtedly be seen to be done. The question therefore is not whether in this case the deputy clerk made any observation or offered any criticism which he might not properly have made or offered; the question is whether he was so related to the case in its civil aspect as to be unfit to act as clerk to the justices in the criminal matter. The answer to that question depends not upon what actually was done but upon what might appear to be done. Nothing is to be done which creates even a suspicion that there has been an improper interference with the course of justice. Speaking for myself, I accept the statements contained in the justices’ affidavit, but they show very clearly that the deputy clerk was connected with the case in a capacity which made it right that he should scrupulously abstain from referring to the matter in any way, although he retired with the justices; in other words, his one position was such that he could not, if he had been required to do so, discharge the duties which his other position involved. His twofold position was a manifest contradiction. In those circumstances I am satisfied that this conviction must be quashed, unless it can be shown that the applicant or his solicitor was aware of the point that might be taken, refrained from taking it, and took his chance of an acquittal on the facts, and then, on a conviction being recorded, decided to take the point. On the facts I am satisfied that there has been no waiver of the irregularity, and, that being so, the rule must be made absolute and the conviction quashed.”‘

 

17. One further point. As a Muslim, Dr. Wilkinson must believe that there is no higher authority than the Muslim god, Allah. If he doesn’t believe this, then he is not a Muslim (and he therefore lied in his expert’s report when he said he was). It follows that Sharia law (the law of Allah) is, to a Muslim, superior to and overrides any man-made law, and a Muslim’s duty to obey that god-made law, and of loyalty to other Muslims, must override any man-made law, including the laws of England. Where there is a conflict between Sharia law and man-made law, a Muslim is bound to adhere to the former, as far as possible. If he does not do so, then he is not a Muslim and is subject to the penalty in Sharia law for apostasy; that is, death. This is an absolutely irreconcilable conflict of interest. Clearly, where Muslims are in a position of weakness (as, say, a minority in another country), they may have no option but to appear to outwardly accept the supremacy of a non-Sharia legal system, but this does not mean either that they inwardly accept the supremacy of that system or that they are absolved from doing everything they can to work towards the implementation of a Sharia legal system (that is, to make the country a Muslim one) or from doing everything they can to protect and further the interests of their fellow Muslims in the interim without obviously contravening existing laws. It follows that if they can contravene our laws and get away with it, they will. Necessarily, this involves an outward appearance of compliance, including doing such things as signing a statement of truth. This means that Dr. Wilkinson’s statement (‘I do not consider that any interest which I have disclosed affects mysuitability as an expert witness on any issues on which I have givenevidence.’is (must be) false.
18. To say otherwise, and to allow Dr. Wilkinson to act as an expert witness, is directly comparable to allowing a witness to give evidence having sworn, on entering the witness box: ‘I swear to tell the truth, the whole truth and nothing but the truth – unless it conflicts with my duty as a [insert name of religion here].’This is because saying ‘I am a Muslim’ equates to saying ‘I acknowledge no other law than the law of Allah and I therefore do not acknowledge the supremacy of your laws.’There is no way on earth that any court in England would accept such an oath, so how can any court accept the glaring conflict of interest between Dr. Wilkinson’s duty to the court as an expert witness and his duty to the law of Allah and to his fellow Muslims as a Muslim – given that the latter necessarily (by virtue of Dr. Wilkinson’s faith) overrides the former?
19. Ask yourself a simple question. How can someone who does not accept the supremacy of our laws over his religious beliefs honestly say that he acknowledges that he has an over-riding duty to the court? He can’t; so, when he says such a thing he is lying. Either he is lying when he says he is a Muslim or he is lying when he says that, as a Muslim, he acknowledges an over-riding duty to the court. Ask any Muslim in the street and (if he is unguarded – see above) he will tell you that Sharia law overrides man-made law. In fact, the truth of the matter is that he doesn’t recognize our laws as laws at all. He obeys our ‘laws’ (but only as far as he must) temporarily and out of necessity, that is all.

The statement of truth

20. But there is a far more serious point. An expert witness is required to sign a statement of truth in which he certifies that he has disclosed, amongst other things, any interest or relationship which might affect (or might be considered likely to affect) his independence. The statement includes the words: ‘I know of no conflict of interest of any kind, other than any which I have disclosed in my report.’(CPD V, Evidence, 19B, ‘Statements of Understanding and Declarations of Truth in Expert Reports’). It is contempt of court to sign a statement of truth either knowing it to be false or not honestly believing it to be true.
21. Note further that the statement of truth ends: ‘I confirm that the contents of this report are true to the best of my knowledge and belief and that I make this report knowing that, if it is tendered in evidence, I would be liable to prosecution if I have willfully stated anything which I know to be false or that I do not believe to be true.’(CPD V, Evidence, 19B, ‘Statements of Understanding and Declarations of Truth in Expert Reports’).
22. Now ‘willfully’ means ‘recklessly’; that is, ‘careless as to the truth of’. This means that an actual intention to lie is not required; it is enough to be careless (reckless) as to whether what you say is true (that is, going ahead in spite of an awareness of a risk or likelihood of untruth). See Derry v Peek [1889] UKHL 1(http://www.bailii.org/uk/cases/UKHL/1889/1.html): ‘Fraud is proved when it is shown that a false representation has been made (1) knowingly or (2) without belief in its truth or (3) recklessly, careless whether it is true or not.’ If recklessly making a false representation is sufficient to prove fraud, it is surely sufficient to prove contempt of court.
23. Now, it is inconceivable that Dr. Wilkinson did not know about the relationship/connection; that is, that Ms. Baljit Ubhey OBE, who is Chief Crown Prosecutor (CCP) for the Crown Prosecution Service in London, is a patron of the organization he runs. It is inconceivable that he was not aware that the relationship might reasonably be seen as giving rise to a risk of bias on his part (he prepared a report for an organization and a senior employee of that organization is a senior figure in the organization which he, Dr. Wilkinson, runs; a classic case of a relationship that could give rise to a bias or a perceived risk of bias). It follows that he must have known that he had a duty to disclose the relationship and deliberately chose not to do so. In other words, he intentionally concealed the relationship. Again, what matters here is not so much what was concealed but the patent dishonesty of the act of concealment. In short, we have an expert who is demonstrably dishonest. This is what matters. It is comparable to committing perjury in relation to a minor criminal offence; it is not the seriousness of the original offence that matters but the fact of lying to the court, which is what Dr. Wilkinson did. Bear in mind that Dr. Wilkinson has considerable experience of acting as an expert witness. It is not as if he was ‘the new kid on the block’. He has no excuse whatsoever.

Consequence of exclusion of expert’s report

24. It becomes clear not only that Dr. Wilkinson’s report should be excluded, but becausehis report was an important element of the prosecution’s case (if it had been unimportant it would have been unnecessary to employ experts in the first place), the conviction cannot stand. See Regina v. Connor & Anor [2004] UKHL 2 (http://www.bailii.org/uk/cases/UKHL/2004/2.html) at 5: ‘If there are substantial reasons to doubt the impartiality of the tribunal, the matter must be examined in order to determine whether there has been a breach of this fundamental guarantee [of an impartial tribunal]. That is so even if the reasons for doubt about the impartiality of the tribunal only emerged after the verdict. If there has been a breach [of Article 6 ECHR], the conviction cannot stand.’
25. Article 6 ECHR (right to a fair trial) gives an absolute right to a hearing before an impartial tribunal. Where the state, in the form of the state prosecutor (CPS), employs an expert witness who deliberately conceals a relationship with that state prosecutor, how can it possibly be claimed that the tribunal is impartial (free from actual bias or a perceived risk of bias)? In the broader context of the right to a ‘fair trial’, a person clearly cannot have a fair trial where key evidence (an expert’s report in this case) is treated by the court as being impartial, and is admitted on that basis, when it clearly should have been excluded because of actual bias or a reasonable perception of a risk of bias.

The ‘best of deceivers’

26. In addition to the above, an expert is required to state in his statement of truth that ‘I have endeavoured to include in my report those matters, of which I have knowledge or of which I have been made aware, that might adversely affect the validity of my opinion. I have clearly stated any qualifications to my opinion.’ (CPD V, Evidence, 19B, ‘Statements of Understanding and Declarations of Truth in Expert Reports’).
27. Now, Dr. Wilkinson said, in essence, that lying is not mandated in Islam unless a person is in danger. Lying is therefore generally a bad thing in Islam, so to call someone a liar is to insult him, not praise him. This was the logic. But there are well-known verses in the Koran that describe Allah as the ‘best of deceivers’ or similar. The point is that, logically, Allah can do no wrong, so if he is the ‘best of deceivers’ (note not ‘worst’), this can only mean that deceiving (or lying) is a good thing; that is, if Allah does is, it must be good. This would appear to contradict Dr. Wilkinson’s argument.

*Qur’an 3:54-‘And they (the unbelievers) planned to deceive, and Allah planned to deceive (the unbelievers), and Allah is the best of deceivers.’

Qur’an 7:99-‘Are they then safe from Allah’s deception? No one feels safe from Allah’s deception except those that shall perish.’

Qur’an 8:30-‘And (remember) when the unbelievers plotted deception against you (O Muhammad), to imprison you, or kill you, or expel you. They plotted deception, but Allah also plotted deception; and Allah is the best of deceivers.’

28. But the point is not whether the description of Allah as the ‘best of deceivers’ actually does contradict Dr. Wilkinson; it is that this clearly might adversely affect the validity of his opinion (the statement above says:‘…that might adversely affect the validity of my opinion.’). This means that Dr. Wilkinson had a duty to highlight the matter and to explain why lying in Islam is a bad thing in spite of the fact that Allah is described as the ‘best of deceivers’.

Tawriya

29. Other Islamic teachings and caveats permit Muslims to deceive even fellow Muslims. For example, I believe that the doctrine of tawriya allows Muslims to lie in virtually all circumstances, provided that the lie is articulated in a way that it is technically true. The authoritative Hans Wehr Arabic-English Dictionary defines tawriya as ‘hiding, concealment; dissemblance, dissimulation, hypocrisy; equivocation, ambiguity, double-entendre, allusion.’ Conjugates of the trilateral root of the word, w-r-y, appear in the Quran in the context of hiding or concealing something (e.g. 5:31, 7:26).
30. In other words, a central issue in the case was whether Islam allows Muslims to lie. Even if the doctrine of taqiyya does not allow Muslims to lie except when their lives are in danger, it appears that there is another doctrine in Islam (tawriya) which does allow Muslims to lie when their lives are not in danger. Dr. Wilkinson should have disclosed this fact; he should have said, in effect, that the questions about taqiyya are too narrow. In other words, Dr. Wilkinson gave a false overall impression that Islam does not allow lying. He had a duty to point out the broader truth.
31. His failure to mention tawriya amounted to lying by omission.
32. Further Sahih Bukhari (3, 49, 857) (http://sahih-bukhari.com/Pages/Bukhari_3_49.php), narrated by Um Kulthum bint Uqba states ‘That she heard Allah’s Apostle saying, “He who makes peace between the people by inventing good information or saying good things, is not a liar.”‘
33. Thus, if a Muslims lies about a wrong he has done, denial of doing the wrong arguably ‘makes peace between the people’ in the sense that it avoids (or attempts to avoid) confrontation, accusations and so on that might result from the wrongdoing.

A strong prima facie case

34. For the above reasons, it is submitted that Dr. Wilkinson:
    1. was aware that a senior CPS employee is a patron of an organization which he runs (Curriculum for Cohesion);
    2. was aware that this gave rise to a potential conflict of interest in relation to preparing an expert’s report for the CPS;
    3. was aware that he had a duty to disclose any potential conflict of interest (‘any’ being the word used in the CPS document ‘Expert Evidence’, as quoted above);
    4. therefore, either intentionally or willfully, he did not disclose that potential conflict of interest;
    5. was aware, as a Muslim scholar, of the ‘best of deceivers’ verses in the Koran (Dr. Wilkinson claims to have memorized large sections of the Koran and he was an Imam in the Mosque of Norwich from 1999 to 2003 and ran the Koran school there);
    6. was aware that these verses might affect the validity of his opinion on the subject of taqiyya (lying), orwas aware that others might think that these verses could affect the validity of his opinion and that he was therefore aware that he should, at the very least, explain why these verses do not affect the validity of his opinion (in other words, the verses are an obvious hurdle because they appear to say that lying (to further the cause of Islam) is mandated in Islam, whereas Dr. Wilkinson claims that it is not);
    7. therefore, either intentionally or willfully, he did not disclose those verses.
    8. was aware that there is a doctrine in Islam (tawriya) which does allow Muslims to lie;
    9. was aware that, to give a proper understanding of the broad issue of whether Islam allows Muslims to lie, he should have disclosed the existence of tawriya;
    10. therefore, either intentionally or willfully, he did not disclose the existence of tawriya.
35. It is submitted, on this basis, that there is strong prima facie case that Dr. Wilkinson is in contempt of court.
36. Note, in this context, that if Dr. Wilkinson is not aware of the ‘best of deceiver’ verses or the doctrine of tawriya then he can hardly be regarded as a scholar of Islam; in which case, he is not qualified to give an expert opinion in the first place.
37. In short, if Dr. Wilkinson is aware of these matters then he should have disclosed them (in which case his expert’s report will have to be excluded on the basis that he knowingly excluded matters which he should have included); if he is not aware of these matters then he is not an expert (in which case his expert’s report will have to be excluded for that reason). Either way, his expert evidence must be excluded, and since that evidence was a significant part of the prosecution’s case, it is clear that excluding that evidence will necessarily mean that the conviction cannot stand.

Public interest

38. If a person has been wrongly convicted largely on the basis of expert evidence which should not have been admitted in the first place, for the reasons stated above, then there is a clear public interest in doing justice to the person wronged. One of the most important aspects of a justice system is that it should be seen to make good its own mistakes (which will inevitably happen in the best of systems) as speedily and as effectively as possible. If mistakes or other wrongs of this nature are simply covered up to avoid embarrassing, exposing or punishing those responsible then, inevitably, the justice system will, over time, fall into disrepute – and when people cease to respect the justice system, respect for the rule of law (one of the essential pillars of an ordered and just society) will be eroded. With scandals like the Birmingham Six, Hillsborough, the Rotherham rape scandal and so on, we are dangerously far down that road already; so far down that it might already be impossible to save the situation. Every instance of this kind is another small nail in the coffin of a civilized and law-abiding democracy. When the short-term self-interest of those responsible in avoiding exposure and sanctions is weighed against the long-term interest in preserving respect for the justice system and, ultimately, the rule of law, where the public interest lies is obvious.
39. The choice is clear; it is between the short-term aim of protecting certain individuals within, or associated with, the justice system and the long-term aims of maintaining respect for the justice system and the rule of law. Perhaps the justice system can survive just one more nail in the coffin. Maybe. Perhaps we haven’t quite reached the breaking point yet; the point at which people consider that the entire justice system is actually a criminal enterprise. Maybe.

Proceedings would be proportionate

40. ‘Proportionate’ means ‘suited to the objective, need or problem’, which, in this case, means actions suited to (not excessive in relation to) the wrong that needs to be made good and to the aim of preserving respect for the impartiality of the justice system and the rule of law. In relation to the latter two objectives, it is difficult to envisage an action that would be disproportionate, given their over-riding importance. Certainly, sanctioning one person and overturning the conviction of another cannot be regarded as somehow unwarranted and excessive in that context.
41. Proceedings for contempt of court are clearly proportionate in relation to the aim of doing justice to a person wrongly convicted (if he was wrongly convicted) and preserving respect for the impartiality of the justice system and the rule of law.

Conclusion

42. Proceedings for contempt of court are in the public interest and would be proportionate, both in relation to the wrong that needs to be made good and in relation to the aim of preserving respect for the justice system and the rule of law.
43. There is a strong prima facie case of contempt because Dr. Wilkinson:
    1. intentionally or willfully concealed a relationship which would give rise to a reasonable apprehension or suspicion on the part of a fair minded and informed member of the public that he might be biased;
    2. intentionally or willfully failed to explain the insurmountable conflict between his duty as a Muslim and his duty to the court;
    3. intentionally or willfully failed to identify matters which appear to directly contradict his opinion or which, at the very least, might be seen by the ordinary, reasonable man to adversely affect the validity of his opinion, and which therefore required explanation, as follows:
       1. the ‘best of deceivers’ verses;
       2. the doctrine of tawriya.

We respectfully request that you process this application in an appropriate and timely fashion.

Yours, etc

Tim Burton