Transgender Athletes: What now for the sporting community? The Effect of for Women Scotland [2025] UKSC 16

In April 2025, the UK Supreme Court handed down its highly anticipated judgment in For Women Scotland v Scottish Ministers [2025] UKSC 16 (“For Women Scotland”).

The Supreme Court answered a narrow question of statutory interpretation. Namely, whether the Equality Act 2010 (“EA 2010”) treats a transgender woman with a Gender Recognition Certificate (“GRC”) pursuant to the Gender Recognition Act 2004 (“GRA 2004”) as a woman for all purposes within the provisions of the EA 2010, or when it speaks of a “woman” and “sex” it is instead referring to a “biological woman” and “biological sex”.[1]

This article will consider the Supreme Court’s decision in the context of transgender athletes’ participation in sports. Considerations related to athletes who are intersex, have Differences in Sex Development, or are non-binary are beyond the scope of this article. This article will, after a short commentary on terminology, examine the following questions:

• What are the protections under the EA 2010 for transgender athletes?
• What are some key takeaways from the Supreme Court judgment?
• What do these protections mean for sporting bodies and transgender athletes?

I.                TERMINOLOGY

Terminology is a sensitive subject. As acknowledged by the Supreme Court, “taxonomy itself can generate controversy”.[2] This article uses the following key concepts and terminology:

As to the terminology used in the EA 2010 it is worth noting that this legislation is 15 years old, and some of its provisions are built on much older foundations. Since then, our social understanding of and the dialogue around sex and gender-related issues has moved on significantly. The following points are worthy of particular note:

• The EA 2010 uses the terms “sex” and “gender” interchangeably, which in the authors’ view, conflates two distinct concepts. For example, s.7 EA 2010 (which deals with gender reassignment) makes reference to reassigning the person’s sex.
• The EA 2010 uses the term “transsexual” (s.7 EA 2010) to refer to people who have the protected characteristic of “gender reassignment”. However, (i) there may be transgender people who fall outside of the s.7 definition (the two are not necessarily synonymous and the point has not yet been tested in litigation); and (ii) some consider the term to be outmoded and offensive.

II.             THE EA 2010 PROTECTIONS FOR TRANSGENDER ATHLETES

The EA 2010 is a statutory Act consolidating previous anti-discrimination legislation. It protects people (falling within the scope of the Act) against discrimination. In advancing equal treatment, it seeks to “strike a balance between the rights of one group and another, rights that can conflict with or contradict one another in some circumstances.”[3]

 The material provisions for the purposes of this article are as follows:

(a) Prima facie protection from discrimination

Under the EA 2010, a transgender athlete would prima facie have protection from the following treatment in respect of the provision of services:

1. Direct sex discrimination (s.13 EA 2010): less favourable treatment because of the protected characteristic of (biological) sex (see analysis arising from For Women Scotland and Haynes v Thomson & Anor [2025] EWCC 50 (“Haynes”) below).
2. Direct gender reassignment discrimination (s.13 EA 2010): less favourable treatment because of the protected characteristic of gender reassignment.[4]
3. Direct sex discrimination by perception (s.13 EA 2010): less favourable treatment because of the protected characteristic of sex. In that a transgender woman and/or transgender man is “perceived” to be a woman or man, without having to declare their biological sex.[5]
4. Direct sex discrimination by association (s.13 EA 2010): less favourable treatment because of the transgender woman’s or transgender man’s association with women or men.[6]
5. Harassment related to sex and/or gender re assignment (s.26 EA 2010): unwanted conduct related to sex/gender re-assignment, and which had the purpose or effect of violating the transgender person’s dignity, or creating an intimidating, hostile, degrading or offensive environment for them.[7]
6. Indirect discrimination (ss.19/19A EA 2010): both in respect of any particular disadvantage suffered by them as a group sharing the characteristic of gender reassignment and, where members of the sex with which they identify are put at a particular disadvantage, insofar as they are also put at that disadvantage.[8]

However, in the sporting context, the above protections are, crucially, subject to s.195 EA 2010. Further, the exception in Paragraph 28 of Schedule 3 EA 2010 may apply. Both are considered below.

(b) The application of the s.195 EA 2010 exceptions

ss.195(1)-(2) EA 2010 provide that:

“(1) A person does not contravene this Act, so far as relating to sex, only by doing anything in relation to the participation of another as a competitor in a gender-affected activity.

(2) A person does not contravene section 29, 33, 34 or 35, so far as relating to gender reassignment, only by doing anything in relation to the participation of a transsexual person as a competitor in a gender-affected activity if it is necessary to do so to secure in relation to the activity—

 (a) fair competition, or

(b) the safety of competitors.”

These provisions create two legal exemptions which apply to sport:

1. 195(1) EA 2010 makes it lawful to treat athletes differently based on sex as regards participation in a gender-affected activity, without this being sex discrimination. This applies to competitive sports and in respect of any part of the EA 2010. As a result, a sporting competition could have men-only and women-only events, or award higher prize money to men than women in relevant events (e.g., in the men’s and women’s finals at Wimbledon). This is a complete exemption.
2. 195(2) EA 2010 makes it lawful to treat transgender athletes differently with regard to gender-affected activities: (a) in respect of the provision of services or the management of premises; (b) if it is necessary to secure fair competition or the safety of competitors, without this being gender reassignment discrimination. This is a partial exemption.

ss.195(1) and (2): is the activity a “gender-affected activity”?

Both s.195(1) EA 2010 and s.195(2) EA 2010 require there to be a “gender-affected activity”: it is a “gateway condition”.[9]

s.195(3) EA 2010 defines a gender-affected activity as “a sport, game or other activity of a competitive nature in circumstances in which the physical strength, stamina or physique of average persons of one sex would put them at a disadvantage compared to average persons of the other sex as competitors in events involving the activity.” This can be broken down into the following questions:

• Is the sport, game or other activity of a “competitive nature”? 195 EA 2010 only applies to competitive sports. Unhelpfully, there is very little case law on what “competitive” means in this context. However, take for example, a gym. Arguably, this is not a “competitive” environment. As a result, the exemption from gender reassignment discrimination in s.195 EA 2010 is, in the authors’ view, unlikely to provide a defence to a women-only gym which excludes a transgender woman, a men-only gym which excludes a transgender man, or a mixed-gender gym which excludes transgender people altogether. That said, these are largely unchartered waters, which may yet be litigated following the Supreme Court’s judgment.
• Would the physical strength, stamina or physique of average persons of one sex put them at a disadvantage compared to average persons of the other sex as competitors in events involving the activity? The relevant comparison to be made is with “average persons”, not the individual who may be complaining. Additionally, there has to be a disadvantage in respect of an “event” (i.e., not just disadvantage generally). In respect of children, s.195(4) EA 2010 notes that in considering whether a sport, game or other activity is gender-affected in relation to children, it is appropriate to take account of the age and stage of development of children who are likely to be competitors. This may account for why, for example in football, pre-pubescent children often play in mixed teams.

s.195(2) only: is it necessary to do the act (in relation to the participation of a transsexual person as a competitor) to secure, in relation to the activity, (1) fair competition or (2) the safety of the competitors?

s.195(2) EA 2010 has an additional hurdle to s.195(1) EA 2010: even if a sport is deemed to be “gender-affected”, for the defence to be successfully relied on, the action taken would need to either be necessary to secure fair competition or the safety of the competitors.

“Safety” is a relatively high threshold and will be determined against the nature of the specific sport being considered. For example, the arguable necessity of excluding a transgender woman from a contact sport such as rugby, were she of considerably greater physique than cisgender women playing, may be greater than a lower-contact sport such as football or a non-contact sport such as individual athletics.[10]

“Fair competition” invites more complex consideration. For example, in some cases, a transgender woman may benefit from advantages of the male physique. She may have spent a considerable period with suppressed or eliminated testosterone levels and elevated female hormone levels, affecting muscle mass and fat distribution, but not bone structure. There may also be differences between those who have transitioned from male to female at puberty, and those who transitioned post-male puberty.[11] These factors will differ from person to person. There is no one-size-fits-all approach.

The following flow chart identifies the questions to be asked in relation to the applicability of s.195 EA 2010.

(c)     The application of Schedule 3, Paragraph 28 EA 2010 exception

Schedule 3 EA 2010 is headed “Services and public functions: exceptions”. Under  Paragraph 28, and for the purposes of s.29 EA 2010, it is not unlawful gender reassignment discrimination if:

1.         the conduct relates to: (a) the provision of separate services for persons of each sex; (b) the provision of separate services differently for persons of each sex; (c) the provision of a service only to persons of one sex (per Schedule 3, Paragraph 28(2)); and

2.         the conduct is a proportionate means of achieving a legitimate aim.

The success of this defence will be specific to the legitimate aim relied on. However, in practice, it is likely to overlap with the questions the court has to consider under s.195(2) EA 2010. Fairness of competition/safety of competitors are undoubtedly legitimate aims, and so if the conduct of the governing body is deemed necessary to secure fair competition or the safety of competitors, that action is likely to be deemed a proportionate means of achieving a legitimate aim (see Haynes below, in which Paragraph 28 of Schedule 3 was argued as a defence).

III.            KEY TAKEAWAYS FROM FOR WOMEN SCOTLAND

(a) “Sex” in the EA 2010 refers to biological sex, irrespective of a GRC

In For Women Scotland, the Supreme Court held that, in light of the context and purpose of the statute, the definitions of “sex”, “woman”, “female”, “man” and “male” in the EA 2010 are defined by biology. It held that “sex” means “biological sex”, “woman” means “biological woman”, and “man” means “biological man”.

In the Supreme Court’s judgment, if a transgender person has a GRC, this does not alter their biological sex for the purposes of the EA 2010. That is the case, even though s.9(1) GRA 2004 stipulates that: “Where a full gender recognition certificate is issued to a person, the person’s gender becomes for all purposes the acquired gender (so that, if the acquired gender is the male gender, the person’s sex becomes that of a man and, if it is the female gender, the person’s sex becomes that of a woman).”

The position is now that a transgender man with a GRC is still to be treated as a “woman”, and a transgender woman with a GRC is still to be treated as a “man”, for the purpose of s.11 EA 2010. The EA 2010 effectively makes provision to disapply s.9(1) GRA (within the meaning of s.9(3) GRA 2004).[12]

(b) The consequences in a sporting context

Sport is addressed specifically at [232]-[236] of the judgment.

The Supreme Court determined that “sex” in s.195(1) EA 2010 means “biological sex”[13]. It went on to state as follows (emphasis added):

236. […] a biological definition of sex would mean that a women’s boxing competition organiser could refuse to admit all men, including trans women regardless of their GRC status. This would be covered by the sex discrimination exception in section 195(1). But if, in addition, the providers of the boxing competition were concerned that fair competition or safety necessitates the exclusion of trans men (biological females living in the male gender, irrespective of GRC status) who have taken testosterone to give them more masculine attributes, their exclusion would amount to gender reassignment discrimination, not sex discrimination, but would be permitted by section 195(2). It is here that the gender reassignment exception would be available to ensure that the exclusion is not unlawful, whether as direct or indirect gender reassignment discrimination.”

A small but important point is the use of the word “could” in the first line of the above paragraph. The court did not say that the women’s boxing competition it uses as an example must exclude transgender women, just that it can lawfully do so by relying on s.195(1) EA 2010.

Lord Sumption affirmed this interpretation in an interview on Radio 4’s PM Programme (18 April 2025). In his view, sporting competitions can limit participation to cisgender athletes. However, they are not legally obliged to do so. Their discretion remains intact. He commented that:  “Sporting bodies could decide to allow trans women to compete on the same basis as biological women, some sporting authorities do. Although, I think that in the light of the latest judgment, they would be wise to say so expressly in their rules”.

The reality is that the Supreme Court’s decision has done little to change the landscape in the sporting context:

• It reaffirmed the importance of s.195 EA 2010.
• 195(1) EA 2010 may be applicable, for example, where a sports governing body seeks to exclude transgender women (biological males) from women’s categories.
• 195(2) EA 2010 may be applicable, for example, where a sports governing body seeks to exclude transgender men (biological females) who have taken testosterone from women’s categories.
• In so far as 195(2) EA 2010 is not applicable, the EA 2010 continues to protect transgender people from discrimination based on the protected characteristic of gender reassignment and from discrimination based on perceived sex or association with a sex, as explained above.[14]
• However, transgender athletes cannot bring direct sex discrimination claims on the basis of their acquired gender, as certified by a GRC. For example, if a sporting body were to require a transgender woman with a GRC to participate in the men’s category of a competition, she could not claim sex discrimination, despite possessing a She would only be able to claim discrimination relying on the characteristic of gender re-assignment (and only if s.195 EA 2010 did not apply).

(c) A real life example

Since For Women Scotland, there has been (at the time of writing) one sports case applying the Supreme Court’s judgment: Haynes.

Ms Haynes is a professional eight-ball pool player, and a transgender woman, who claimed direct discrimination on the ground of gender reassignment against the English Blackpool Pool Federation (“EBPF”). The EBPF had introduced a change in its rules so that only people who were born female would be permitted to play in its female competitions and teams, which meant that Ms Haynes could no longer play for her team.[15]

Was the treatment sex or gender reassignment discrimination?

HHJ Parker dismissed Ms Haynes’ claim. The effect of For Women Scotland was that Ms Haynes “must be regarded as male”.[16] HHJ Parker held that she had been treated as a man by the EBPF, in  accordance with the law as stated in For Women Scotland, and was therefore ineligible for the women’s competition.[17] Her exclusion was a matter of sex discrimination, not gender reassignment discrimination (i.e., she was excluded because she was biologically male, not because she was transgender).[18] The claim therefore fell at this first hurdle.

It was noted that if Ms Haynes had claimed for sex discrimination, the Defendants would have needed to prove that pool was a “gender-affected activity” in order to justify her exclusion under s195(1) EA 2010. However, she had only claimed gender reassignment discrimination and since there was none, s195(2) EA 2010 did not arise.[19]

Is pool a gender-affected activity?

Although it was not necessary to decide whether pool is a gender-affected sport, it was an issue on which both parties called expert evidence and so HHJ Parker answered the question in any event. Both parties agreed that pool is a “sport, game or other activity of a competitive nature”.

The critical issue was whether pool is a game conducted “in circumstances in which the physical strength, stamina or physique of average persons of one sex would put them at a disadvantage compared to average persons of the other sex as competitors in events involving the activity” (per s.195(3) EA 2010).[20] HHJ Parker accepted that any advantage only needed to be “more than minimal”, because in sport a “small but clear advantage can make the difference between winning and losing.”[21]

HHJ Parker split the consideration of s.195(3) EA 2010 into two questions and offered guidance on how each should be approached[22]:

1. Whether there are differences between the physical strength, stamina or physique of average persons of one sex compared with average persons of the other sex?

• The court must consider the physical differences that exist between men and women as a whole.
• “Average persons of one sex” do not include people who were of the opposite sex at birth.
• “Strength” means whether there is a difference in “absolute strength” between the average male and the average female (i.e., not strength relative to body size).

2. If so, whether those are differences which “would put them at a disadvantage […] as competitors“?

• The court must assess what would happen if two persons of different sexes and of average physical characteristics competed in the relevant activity.
• It should not be assumed that the competitors are unskilled. s.195 EA 2010 only applies to events which have been organised with a degree of formality, as part of which there are rules about who may or may not take part.
• Most people who compete in organised events have a level of skill and experience significantly above that of the average person. It is these hypothetical competitors the court should consider when deciding whether one sex would be at a disadvantage.

In short, “s195(3) EA 2010 requires the court to consider whether a woman of average physical strength, stamina and physique and who is reasonably experienced in the relevant sport game or activity would be at a disadvantage when competing against a similarly experienced man of average physical strength, stamina and physique.”[23]

Four experts gave evidence on a wide range of potential factors, from the speed of break shots to the impact of hormonal cycles in cue sports. HHJ Parker found that the break shot in pool is important and a factor in doing this successfully is achieving the highest cue speed possible without losing accuracy.[24] Greater absolute strength gives an advantage in pool because it translates to a higher achievable cue speed and thus a better break shot.[25] The ability to take more shots without resorting to a rest is a further sex-related advantage enjoyed by the average male over the average female.[26] Lesser strength and reach put the average woman at a disadvantage when competing against the average man at English eight-ball pool. Therefore, pool was held to be a gender-affected activity.[27]

Was the exclusion necessary to secure fair competition?

In respect of s195(2) EA 2010, “necessary” was taken to mean “something that is more than merely desirable, but may be less than utterly essential”.[28]

The starting point in determining this issue was said to be the “relevant differences of physical strength, stamina and physique as between trans women and biological women”.[29] Given the expert evidence, it was difficult to identify what steps (short of exclusion) would be enough to ensure fair competition.[30]

HHJ Parker noted that testing for testosterone suppression and allowing transgender women to compete in pool if they tested below a certain level would not be viable since that would not remove the advantage of reach, and the impact on strength was unclear.[31] A suggestion that some form of handicap could work was not proposed in enough detail for the judge to be persuaded that it could provide a fair alternative to exclusion.[32]

As a result, HHJ Parker held that there was no reasonable alternative way of achieving fair competition short of exclusion, so even if this had been a case of gender reassignment discrimination, the exclusion of transgender women from female English eight-ball pool would have been justified under s195(2) EA 2010, in any event.[33]

Was the exclusion a proportionate means of achieving a legitimate aim?

The Defendants had also advanced a Schedule 3, Paragraph 28 EA 2010 defence. They argued that the exclusion of transgender women from female competitions was a proportionate means of achieving a legitimate aim, that aim being to ensure (i) fairness of competition and (ii) diversity through the inclusion of females.[34]

HHJ Parker dealt with this briefly, finding that whether the exclusion was a proportionate means of achieving a legitimate aim “substantially overlaps” with whether the exclusion of transgender women was necessary to secure fair competition.

He held that “fairness of competition is undoubtedly a legitimate aim, and if… exclusion is necessary to achieve fairness then it must be a proportionate means of doing so.”[35]

In relation to the other aim relied on – diversity through the inclusion of females – while encouraging greater female participation was found to be a legitimate aim, the exclusion of transgender women was not deemed to be a proportionate means of achieving it.[36]

What does Haynes show us?

This case illustrates how:

• The Supreme Court’s decision as to the meaning of “sex” in For Women Scotland will impact how transgender athletes are able to bring claims of discrimination. Consideration should be given as to whether claims should properly be brought as sex or gender reassignment discrimination.
• The success of any claims brought will depend on due consideration being given to the specific wording of s.195 EA 2010, most notably, whether the sport being considered is a “gender-affected activity” and (if applicable) whether the action taken by the governing body was “necessary” to secure fair competition and/or safety; and
• The operation of the defence provided in Paragraph 28 of Schedule 3 EA 2010, will often overlap with questions under s.195 EA 2010.

IV.            CONSIDERATIONS FOR SPORTING BODIES

Current sporting body policies

Sporting bodies have adopted a range of policies in respect of the participation of transgender athletes. For example:

Risks of discrimination claims

As set out above, in reality, the Supreme Court decision has done little to change the landscape in respect of transgender participation in sport.

Issues of direct and/or indirect discrimination are likely to arise if transgender athletes are either included or excluded from single-sex sporting categories and/or competitions without proper consideration of the applicability of s.195 EA 2010. This is not an easy conflict to resolve. The Supreme Court has left it open to sporting bodies to grapple with this issue.

As well as the potential for transgender athletes to bring discrimination claims if they are excluded, there are also risks of cisgender athletes bringing claims if they are made to share their single-sex category with a transgender athlete.

Take the example of a cisgender woman competing in the women’s category of a sport, who challenges her sporting body, because it has allowed transgender athletes to opt-in to the competition category that corresponds with their acquired gender. She might claim indirect discrimination contrary to s19 EA 2010, in which case:

• The opt-in permission afforded to transgender athletes would constitute a provision, criterion or practice (“PCP”) (s.19(1) EA 2010).
• The PCP is applied to men and women (s.19(2)(a) EA 2010).
• The PCP would arguably put women at a particular disadvantage when compared to men (s.19(2)(b) EA 2010) (the “group disadvantage” requirement). However, this will be fact-specific to the particular sport and its unique
• It would also be similarly fact-specific whether the PCP put the cisgender woman at that disadvantage (s.19(2)(c) EA 2010) (the “individual disadvantage” requirement). Though, if there was no individual disadvantage it would be unlikely for a claim to be brought.
• If the aforementioned elements of s.19 EA 2010 are made out, the PCP will be prima facie discriminatory, unless the sporting body can demonstrate that it was a proportionate means of achieving a legitimate aim (s.19(2)(d) EA 2010) (the “justification defence”).

Whether a sporting body is likely to be successful in a justification defence will be highly case- specific. How the case was put and argued will be of central importance. A court or tribunal may readily accept that promoting transgender inclusivity is a legitimate aim. However, the critical battleground is likely to be on proportionality. This will require a careful assessment of the potentially discriminatory impact of the sporting body’s approach, against the aims pursued by that approach, and whether there were alternative ways of achieving those aims.

The latter point is particularly important for sporting bodies. Those who wish to take a transgender-inclusive approach should ensure that they have considered all the options which would achieve its aims and carefully compare their possible discriminatory impact before deciding what to do. This is because it will need to be confident in any justification defence of its policy and willing to face scrutiny of its approach.

 Practical steps

Sporting bodies are advised to do the following:

1. Scrutinise whether s.195 EA 2010 is applicable: Sporting bodies should scrutinise the provisions of s.195 EA 2010 to consider if the section is applicable. This involves considering: (a) whether the sport is a gender-affected activity; and in so far as s.195(2) is concerned, (b) whether the action in relation to the participation of a “transsexual” person as a competitor is necessary to (i) secure fair competition or (ii) safety of competitors. A failure to consider each step and ensure that these are satisfied could risk discrimination claims, without the protection of the s.195 EA 2010 exception. Although, in reality, it may be difficult finding an activity which survives 195(2) EA 2010 and which is not already open to men and women together.
2. Think carefully before imposing a blanket ban: Sporting bodies with blanket bans to exclude transgender athletes, without considering possible alternatives to enable participation may still face discrimination claims. Accordingly, it may be worth considering whether there are more proportionate measures short of blanket exclusion. As noted above, the law does not require sporting bodies to exclude transgender athletes, and although in reality s.195 EA 2010 (if applicable) enables sporting bodies to impose such bans, the boundaries of s.195 EA 2010 remain largely untested and there is still risk involved (reputationally or otherwise).
3. Consider creative solutions for inclusivity such as open or tailored categories: Sporting bodies may wish to establish open categories in which transgender athletes can compete, as British Triathlon has pioneered. Or, tailoring categories, for example, England Hockey has created a female category for “participants recorded female at birth, which includes trans men who have not undergone or are not undergoing gender-affirming hormone therapy” and an open category for “participants recorded male at birth, recorded female at birth (irrespective of whether they have ever commenced or completed gender-affirming hormone therapy), and those who identify as trans or non-binary”, which came into effect from 1 September
4. Cooperate with other sporting bodies: Whilst there is not a collective approach which all sporting bodies are expected to follow, and instead it is for them to determine their own rules, the sharing of ideas, initiatives and policies may help navigate issues as they arise. Cooperation and communication between bodies could also assist in preventing certain bodies coming to decisions which are not based on empirical evidence, but which have political It may also serve as a cost-saving exercise. For example, where there are sports of a similar nature, it may be possible to collectively fund appropriate research. Such cost sharing could be particularly beneficial for smaller sports. Nevertheless, given sports are indeed different, there may be limits to the benefits of such knowledge sharing: governing bodies should not simply adopt the approach of other sports without considering the nuances of their own.
5. Consider the impact of decisions across ALL levels of the sport: Grassroots sports are more likely to be affected by the issues outlined in this article, since it is anticipated that a higher proportion of transgender athletes participate in sport at a grassroots, rather than an elite, level. Accordingly, the considerations set out above should be examined and applied across the various levels of a sport.
6. Seek advice if in doubt: Sporting bodies arguably remain between a rock and a hard place, facing risks of claims from transgender athletes if they are excluded or cisgender athletes if they are included. The success of such claims will likely turn on whether the sporting bodies have got the applicability of s.195 EA 2010 right. Which route is best to take, and what considerations should be taken into account, will be highly fact-specific and it may be wise to take specialist advice.

Mia Chaudhuri-Julyan

Sophie Cashell

[1] [8].

[2] [6].

[3] [151].

[4] [253]. This would be subject to satisfying the definition within s.7(1) EA 2010. However, direct gender reassignment discrimination by perception and/or association did not appear to be considered by the Supreme Court.

[5] [250].

[6] [252].

[7] [256]. Again, the definition within s.7(1) EA 2010 may need to be considered.

[8] [260].

[9] [234].

[10] Robin White, A Practical Guide to Transgender Law, Chapter 17.

[11] Ibid.

[12] [264 – 265].

[13] [234].

[14] [248]; [250 – 261].

[15] [6]-[7].

[16] [70].

[17] [80].

[18] [85].

[19] [85].

[20] [128].

[21] [129].

[22] [133]-[135]; [139]; [241]-[242].

[23] [138].

[24] [239]-[240].

[25] [242].

[26] [246].

[27] [250].

[28] [251].

[29] [254].

[30] [256].

[31] [259].

[32] [260]-[262].

[33] [263].

[34] [264].

[35] [265].

[36] [266].