Referrals Committee Decision - Eamon Tyrrell
THE TURF CLUB
Referral of Eamon Tyrrell, in the matter of a disqualification imposed on him by the British Horseracing Authority, (BHA)
The Committee (Judge Tony Hunt (chair), Mr. John Moloney and Mr. Sean Barry) convened at the Turf Club on 3 April 2012, to consider the referral of Eamon Tyrrell (Trainer) by Mr. Denis Egan, Chief Executive of the Turf Club. Mr. Tyrrell was represented by Mr. Andrew Coonan (of Coonan Cawley, Solicitors), and the Turf Club was represented by Mr. Conal Boyce, (of Wilkinson & Price, Solicitors).
On 3 April, the Committee heard evidence from Mr. Egan to the effect that he was also a member of the Executive Council of the International Federation of Horseracing Authorities, which is an umbrella body responsible for the of The International Agreement on Breeding, Racing and Wagering (“the international Agreement”), to which the Turf Club was a subscriber at all material times, as the competent horseracing authority for Ireland.
The terms of Article 10 of the international Agreement were opened to the Committee, dealing with reciprocation of penalties by horseracing authorities, and Mr. Egan gave evidence of the receipt of various communications from the British Horseracing Authority (“the BHA”, also a subscriber to the Agreement) requesting reciprocation of a disqualification imposed upon Mr. Tyrrell effective from 5 October 2010.
On receipt of these communications, Mr. Egan referred the matter to the Referrals Committee pursuant to the provisions of Rule 274(i) of the relevant Turf Club rules.
Having heard this evidence, and legal argument, the Committee was satisfied that Mr. Egan had proved the existence of the disqualification of Mr. Tyrrell, the subsequent request for reciprocation by the BHA, and that he had initiated a proper referral to the Committee on foot of that request. The Committee also found that the provisions of Regulation 18 of the Turf Club Rules were also applicable and potentially available to Mr. Tyrrell, as he had exhausted all avenues of appeal in the jurisdiction of the BHA.
Following consultation, Mr. Tyrrell instructed Mr. Coonan to make an application on his behalf to the Committee pursuant to the provisions of Regulation 18, requesting the Committee not to enforce a reciprocation of the BHA sanction of disqualification.
The Committee then fixed a time for the provision of a written submission on behalf of Mr. Tyrrell as to the grounds upon which the committee ought not to reciprocate the said disqualification pursuant to the provisions of Regulation 18. The Committee also provided for a written response from the BHA to any case made by Mr. Tyrrell. The Committee then adjourned the hearing to 21 May 2012 for the purpose of considering submissions received and of hearing any evidence necessitated by such submissions.
The Committee duly received submissions Mr. Tyrrell and from the BHA in response, and having considered those submissions and further legal argument, was of the view that oral evidence from Mr. Tyrrell and, if necessary, the BHA would be required in order to resolve the issues raised by the documents submitted.
Mr. Tyrrell made the following claims in his submission:-
1. He was initially informed by the BHA that he was alleged to be in breach of BHA rule C45 and was provided with and referred to Guide to Procedures and Penalties 2010/BHA.
2. He was unaware in advance of the disciplinary hearing of the gravity of the offence of which he was accused, and was entirely unaware of the penalties available to Disciplinary Panel of the BHA when he received this notification.
3. Had he been aware of it that there was a possibility of being banned or disqualified for a three-year period, he would have made attempts to ensure that he was legally represented at any subsequent panel hearing.
4. The BHA ought to have informed him of the possibility of an adjournment of the Disciplinary Panel hearing listed for 22 September 2010, when he informed the BHA on 20 September 2010 that he was unable to continue to retain legal advisers to act on his behalf on the hearing date, due to an inability to pay their fees.
5. He was under the impression that he was obliged to proceed with the hearing on 22 September 2010 in the absence of legal representation, and was not made aware by the BHA of the possibility of seeking an adjournment of the matter to investigate obtaining finances to retain representation.
6. During the course of the disciplinary hearing the presenter of the BHA complaint (Mr. Graham McPherson QC) repeatedly intervened when he sought to ask questions or to explain his situation, and that the said presenter requested the Panel to disregard his questions and evidence as being irrelevant to the enquiry being conducted by the Panel. Therefore, that the enquiry was conducted in an entirely one-sided manner, and he was unable to understand or follow the sequences of submissions being made by the presenter as against both himself and Mr. Behan.
7. The Disciplinary Panel proceedings were significantly weighted against him in circumstances where the enquiry was presented and chaired by legally qualified persons, as against Mr. Behan and Mr. Tyrrell acting on their own behalf.
8. He subsequently appealed only against the severity of the penalty and costs imposed by the Disciplinary Panel, due to his perception of prior prejudice on the part of the BHA arising from the conduct of the original enquiry by that Panel.
9. The Committee in those circumstances ought not to order the reciprocation of the three-year disqualification imposed on him by the BHA.
By direction of the Committee, the submissions of Mr. Tyrrell had been notified to the BHA in advance of the resumed hearing, and the committee was also in receipt of their written submissions in reply. The replying submissions counter-claimed as follows:-
1. Upon receipt of the referral by the Newcastle stewards, the BHA decided that the case to be put forward against Mr. Behan and Mr. Tyrrell was that the Casela Park (IRE) had been deliberately stopped from winning the Newcastle race. In those circumstances, the recommended penalty in the 2010 Guidelines for such an offence was a disqualification for the rider and trainer for a period of between one and five years, with an entry point of 18 months.
2. In those circumstances, it was imperative that the rider and trainer concerned were fully aware of the charge and possible consequences, and had the requisite opportunity to mount a full defence to such a charge.
3. A letter specifying the charge to be levelled against Mr. Behan and Mr. Tyrrell was sent on 11 August 2010, with a proposed hearing date of 3 September 2010. Mr. Lyn Williams of the BHA spoke to Mr. Tyrrell on the same day, with the dual motive of ensuring that he understood the nature of the proposed charge, and of establishing a method for transmission of the relevant letter of charge and enquiry papers. In the course of that conversation, during which Mr. Williams spoke to both Mr. Tyrrell and his wife, it was explained to Mr. Tyrrell by Mr. Williams that the nature of the BHA allegation was that Mr. Behan had deliberately stopped the gelding from winning and that Mr. Behan could be disqualified. It was also explained that such a disqualification would be effective in Ireland and would mean the loss of Mr. Tyrrell’s trainer's licence and of any involvement by him in horse racing in Ireland. Mrs. Tyrrell requested that any documentation be sent via fax to a nominated third party, a solicitor based in Celbridge, Co Kildare. She also confirmed that both her husband and Mr. Behan were taking legal advice and would be represented at the proposed enquiry.
4. Following this conversation, and based on the information that Mr. Tyrrell and Mr. Behan would be legally represented at the subsequent enquiry, the BHA decided to retain counsel to present the case on their behalf.
5. On 16 August 2010, a second letter was sent to Mr. Behan, which was copied to Mr. Tyrrell, setting out explicitly the BHA complaint over his riding, and the allegation that the gelding would have won but for Mr. Behan not riding it on its merits. To ensure receipt, Mr. Williams made a further telephone call to Mr. Tyrrell, during which he again spoke to Mrs. Tyrrell, who confirmed that Mr. Behan and Mr. Tyrrell were to be represented by the same solicitor, and that papers for Mr. Behan should be sent by post to the yard and by fax to the third-party fax number, and would always be passed on. Mr. Williams again explained the seriousness and possible consequences of the allegations against Mr. Behan and Mr. Tyrrell.
6. On 24 August 2010, the BHA was notified by a solicitor based in the United Kingdom that he would be representing Mr. Tyrrell. As he intended to instruct counsel, a short adjournment was requested. It was also confirmed to Mr. Williams that the solicitor in question would not be representing Mr. Behan, thereby constituting the first indication to the BHA that Mr. Tyrrell and Mr. Behan might not be attending at the enquiry “as one”. As this solicitor was not previously known to Mr. Williams to act in racing related matters, he explained to him in ordinary terms the seriousness of the charges against his client and the severity of the penalties involved. A new enquiry date of 22 September 2010 was agreed, subject to Mr. Behan and his legal representative being available.
7. On either 24 or 25 August 2010, Mr. Williams rang Mr. Behan to advise him of the cancellation of the original enquiry date and to ask to whom he should speak in relation to a new date. Mr. Behan advised Mr. Williams to speak to Mr. Tyrrell, as it appeared to the BHA that Mr. Tyrrell had a new solicitor, and it was necessary for Mr. Behan to clarify his situation. Some time later, the BHA received a call from another solicitor based in the United Kingdom, who was previously known to Mr. Williams from other disciplinary matters, who indicated that he was likely to be representing Mr. Behan at the enquiry, and was available for the adjourned date.
8. Thereafter, the BHA received a detailed written outline of the full defence to be put forward by Mr. Tyrrell and Mr. Behan, as furnished by their respective solicitors. So far as Mr. Tyrrell was concerned, the document furnished on his behalf by his solicitor, and apparently drafted with the assistance of counsel familiar with BHA matters, averred that he gave Mr. Behan such instructions as were necessary to ensure that the horse would run on its merits and, for the avoidance of doubt, if Mr. Behan intentionally failed to ensure that the horse was run on its merits, it was averred that this was notwithstanding that the rider was given appropriate instructions under BHA Rule C45.1 and Mr. Tyrrell was thereby not liable to disciplinary action and under C45.4. The Concise Substance of Case appended to this document suggested inter alia that the rider might probably have given the gelding a more positive ride, although Mr. Tyrrell had indicated to the Newcastle stewards that he was initially satisfied with the ride on the day of the race.
9. At approximately 2pm on 20 September 2010, the BHA received a notification from the respective solicitors that neither they nor counsel would be in attendance at the Panel hearing scheduled for two days later. Accordingly, as of that time, Mr. Behan and Mr. Tyrrell would be attending at the Disciplinary Panel hearing by themselves.
10. Immediately after receipt of this information, Mr. Williams rang Mr. Tyrrell to check if this was correct, and to ensure that he personally understood the seriousness of the charges and the possible implications of his not being legally represented. He asked Mr. Tyrrell if he wished the enquiry to be adjourned to enable him to obtain a new solicitor, to which Mr. Tyrrell replied to the effect that nothing was to be gained by so doing, as he could not afford legal representation whether the enquiry was heard then or later. Mr. Williams again referred Mr. Tyrrell to the distinct possibility that both he and Mr. Behan could be disqualified if found in breach of the Rules. Mr. Tyrrell confirmed to Mr. Williams that they would both attend and to inform the Panel that they had not been involved in any wrongful conduct.
11. At that point, the BHA decided to continue with counsel instructed to present the BHA case to the Disciplinary Panel, having regard to the fact that he had already been instructed and that the hearing was less than two days away. The BHA instructed counsel to present the case in a manner appropriate to the circumstance that Mr. Tyrrell and Mr. Behan would not have the benefit of legal representation and to make the presentation of the evidence, submissions and cross-examination as simple and straightforward as possible.
12. The Disciplinary Panel was chaired by a legally qualified chairman (Mr. Tim Charlton QC), who ensured that every question put to either Mr. Behan or Mr. Tyrrell was understood by them, and that they had every opportunity to address the panel in full. The Chairman had stopped proceedings at any point where he thought that either Mr. Tyrrell or Mr. Behan may not have understood the question being asked, and ensured that the video recording of the race was available to Mr. Behan and Mr. Tyrrell if their evidence could be better illustrated by its use.
13. After being found in breach and penalised by the Disciplinary Panel, Mr. Tyrrell lodged an appeal to the Appeal Board, for the purposes of which he was represented by an Irish solicitor and English counsel. That appeal was conducted on the basis of a transcript of the original enquiry, and was based on submissions that there was insufficient material upon which the Panel could have made their adverse finding, and there was a procedural unfairness in the making of the decision in that they took into account an irrelevant factor. It was also submitted that the penalty imposed by the Panel was disproportionate and unreasonable. The Appeal Board subsequently upheld the finding and penalty determined by the Disciplinary Panel.
On that date, the Newcastle stewards held an enquiry into the running and riding of Casela Park (IRE), and the Committee was satisfied from a transcript of that hearing that those stewards found that Mr. Tyrrell's jockey (Jason Behan) was in breach of BHA rule (B)59.2 (intentionally failing to ensure that the horse ran on its merits). Having informed Mr. Tyrrell and Mr. Behan of this finding, they further referred the running and riding of Casela Park (IRE) to the BHA, informing Mr. Tyrrell “that he will be required to attend a disciplinary panel hearing in due course.”
Mr. Tyrrell then continued with evidence in support of the claims set out in his submission referred to above. At the conclusion of this evidence, the committee heard further legal submissions from both sides, and then adjourned the Referral to 1 June 2012, to permit a representative of the BHA to attend and give evidence on the issues raised by Mr. Tyrrell.
Having regard to various criticisms made by Mr. Tyrrell in his submissions and supporting evidence concerning the procedures and actions of the BHA leading to the imposition of a sanction of disqualification on him and, in particular, to shortcomings in the conduct of the Disciplinary Panel by both the presenter and Chairman thereof, the Committee requested the provision of a transcript of those proceedings in order to better assess the evidence of Mr. Tyrrell and any evidence that might subsequently be given by the BHA in that regard.
This transcript was duly supplied to the Committee prior to the adjourned date, when further evidence was heard from Mr. Tyrrell. The Committee then heard evidence from Mr. Lyn Williams of the BHA in support of the claims set out in its replying submission, as also set out above, and in furtherance of the application to have the Turf Club reciprocate the sanction of disqualification imposed by the BHA on Mr. Tyrrell. The Committee then heard final legal submissions from each side at the close of the evidence, and reserved a decision pending further consideration of the matter.
On the basis of the evidence and submissions, the Committee decided as follows:-
The general purpose of the international Agreement is to permit owners trainers and riders to participate in the sport in signatory countries without the necessity of taking out a separate license in each case. The convenience of this arrangement is underpinned by a number of principles.
Firstly, when a horse is entered in a race run in a foreign country, its owner, trainer and rider are deemed to have knowledge of the rules of racing applicable in that country and to have agreed to be bound by those Rules.
Secondly, where such Rules provide that an owner, trainer or rider is liable to be banned, either by the stewards of a meeting or on appeal, they have the following minimum natural justice rights:
1. to be informed, in a language which they understand, of the nature and cause of the accusation against them,
2. to have adequate time for the preparation of their defence,
3. to defend themselves in person or be represented by a person nominated by them,
4. to examine witnesses against them and to obtain the attendance and examination of witnesses on their behalf under the same conditions as the witnesses against them,
5. to have the free assistance of an interpreter if they cannot understand or speak the language used in the hearing.
Thirdly, where a ban is imposed on an owner, trainer or rider, the Horseracing Authority concerned must immediately advise the Horseracing Authority where the trainer is registered or licensed of the original ban and subsequently of the result of any appeal hearing and, if deemed necessary, request that reciprocation of the penalty be applied.
Article 10 bis. III of the international Agreement and then provides as follows:-
“The ban will then automatically apply in that country, subject to any special conditions required by the laws of natural justice in that country.”
Fourthly, each signatory to Article 10 of the international Agreement (including Ireland and GB) is obliged to include in its domestic Rules of Racing provisions dealing with the reciprocation of penalties, mirroring to the maximum extent possible the contents of the model rule set out in Article 10 ter. of the international Agreement.
In 2010, the obligations of the Turf Club under the international Agreement were implemented by Rule 274 and Regulation 18 of the 2010 Rules of Racing.
Rule 274 dealt with sanctions imposed by a Turf Authority of any other country. Where a foreign sanction of disqualification was imposed and notified to the Turf Club, a Senior Racing Official (Mr. Egan) shall refer the matter to the Referrals Committee.
Regulation 18 separately permitted the subject of any foreign sanction to apply to the Referrals Committee on terms specified therein to declare that such sanction shall not have effect, specifying that:
“The only ground which the appellant may rely on is that the principles of natural justice were not complied with by the Foreign Turf Authority in the procedures leading to the sanction”.
Accordingly, once the matter was validly referred to the Committee by Mr. Egan, and when Mr. Tyrrell then invoked Regulation 18 for a declaration that the BHA disqualification not have effect under the Turf Club rules, the scope of the Referral was strictly confined to a consideration of the procedures leading to the BHA disqualification.
The Committee emphasised to Mr. Tyrrell on a number of occasions during the hearings that it was expressly precluded from reviewing the substantive issues leading to the BHA finding and consequent penalty.
On the procedural issues, there were a number of areas of conflict between Mr. Tyrrell and Mr. Williams. The Committee resolved those conflicts in favour of Mr. Williams, firstly because it was of the opinion that Mr. Williams was a more credible witness, and secondly because the documents submitted and, in particular, the transcript of the BHA Disciplinary Panel hearing strongly corroborated the claims and evidence of Mr. Williams and the BHA, rather than those of Mr. Tyrrell.
In this regard, the Committee laid particular emphasis that on 1 June 2012, after the transcript of the Panel hearing was distributed, Mr. Tyrrell withdrew in evidence earlier serious allegations made by him about the conduct of the presenter and Chairman of the Disciplinary Panel, stating instead that he was not able to decide what questions to ask, rather than alleging that he was prevented from asking questions or that his input was immediately discounted.
On the issue of the conduct of the Panel hearing, the Committee was satisfied completely by the evidence of Mr. Williams that the enquiry was presented and chaired in a scrupulously fair fashion. Contrary to Mr. Tyrrell’s assertions, the transcript disclosed that he was given a long and uninterrupted opportunity to present his evidence on the Newcastle race and on all the other material relied on by the BHA in support of the charge. He was also given an opportunity to question the only other witness, and at no stage was he unduly interrupted, or was his contribution denigrated or discounted. The Committee found that he was treated in a manner appropriate to an unrepresented person appearing before a panel on a serious charge, and was unable to discern any breach of the principles of natural justice so far as the conduct of the hearing was concerned.
Mr. Tyrrell also claimed that he did not understand before or during the hearing the nature of the charge or the possible extent of the penalty that might have followed from a finding against him. The Committee was satisfied to a high level of certainty that Mr. Tyrrell knew that he was facing a serious charge, carrying the probability of a significant penalty, including disqualification.
This finding was based on the following factors:-
1. Mr. Tyrrell was deemed to have knowledge of the BHA Rules and to have accepted the application thereof, including penalties thereunder, when entering a race run under those Rules,
2. Mr. Tyrrell was likely to have had a working knowledge of the English Rules based on his long involvement in the industry, and must have been aware that involvement in the intentional “stopping” of a horse would be likely to have significant consequences,
3. Mr. Tyrrell had specific knowledge of the possibility of at least a minimum disqualification period of 12 months following correspondence with the BHA, and conversations with Mr. Williams in the aftermath of the Newcastle race. The Committee accepted the evidence of Mr. Williams that from as early as a telephone conversation on 11 August, he had at all times taken care to impress upon Mr. Tyrrell that a serious penalty was in question and that legal representation was therefore advisable. A letter of 16 August to Mr. Behan, copied to Mr. Tyrrell also set out in detail the nature of the charges and the factual allegations forming the basis thereof.
4. That Mr. Tyrrell appreciated that the matter was of some import was evidenced by the immediate retention by him initially of an Irish solicitor, followed by early reference to an English solicitor, who retained counsel in connection with the proposed enquiry. Solicitor and counsel then completed the form furnished by the BHA to Mr. Tyrrell, presumably on his instructions.
That form contained a clearly drafted “Denial of Breach of Rules” on behalf of Mr. Tyrrell, adverting to the particular Rules applicable to the case, together with a “Concise Substance of Case”. The denial clearly pleaded that if the Rider intentionally failed to ensure that the horse was run on its merits, this was:
“notwithstanding that the Rider was given appropriate instructions under C45.1 and that Mr. Tyrrell is not liable to disciplinary action under C45.4”.
5. The particulars of the denial then set out his instructions to the rider and his opinion of the run of Newcastle race. It continued as follows:
“Having looked at the race on a number of occasions since it was run at Newcastle, I can understand why the ride given to the horse attracted questions and criticism and would accept that it was not Jason’s finest hour. On reflection, Jason could probably have given the horse a more positive ride. But in Jason’s defence, it would be easy to judge him too harshly or come to the wrong conclusions as the horse is very difficult to ride. It was no more than a bad day for Jason riding a very difficult horse. I accept that I indicated to the stewards on the day of the race that I was satisfied with Jason’s ride. However, it has to be appreciated that I have now had longer to reflect upon the race, and also the fact that my loyalty to Jason, combined with the fact that the horse is so difficult, makes it hard for me to be too critical of him. It may be relevant to note that Jason told the stewards that the horse had frightened him.”
6. The Committee held that it was highly likely that Mr. Tyrrell had discussed with his then legal advisers the Rules mentioned in that document, and the substance of the case to be made within the framework of those Rules, before the document was delivered to the BHA. Consequently, it was highly unlikely that the discussion would proceed in that context without any reference to the question of potential penalty.
7. After discovering on the afternoon of 20 September 2010 that neither Mr. Tyrrell nor Mr. Behan would be represented at the hearing scheduled for less than 48 hours later, the Committee was satisfied that Mr. Williams spoke directly to Mr. Tyrrell about this development, informed him once more of the potential for disqualification and raised the possibility of an adjournment to secure alternative representation, which was declined by Mr. Tyrrell on the basis that his financial position was unlikely to change so as to permit this.
8. The Committee was satisfied that it was reasonable for the BHA to continue to use counsel as the presenter at the inquiry, as he had been briefed in the expectation that Mr. Behan and Mr. Tyrrell would have the benefit of legal representation, and by the time that situation changed he had already received complete instructions and had fully prepared for a hearing then less than two days away. The Committee also accepted that Mr. Williams instructed Mr. McPherson QC to tailor his conduct of the enquiry to the fact that he was then dealing with non-lawyers, and accepted on the basis of the subsequent transcript that Mr. McPherson in fact carried out those instructions by presenting the BHA case in a clear, proper and patient manner.
The Committee was of the opinion that the fact that the presenter was legally qualified when the subjects of the enquiry were not legally represented did not, of itself, amount to any breach of the principles of natural justice, once the proceedings were otherwise conducted in accordance with those principles.
9. Mr. Tyrrell in his last piece of evidence to the Committee conceded that he had heard Mr. Williams refer to the issue of disqualification, but thought that this was because Mr. Williams was “making a mistake”.
The Committee was of the view that there was no basis for this assumption on Mr. Tyrrell’s part, and there is no evidence that he thought fit to query Mr. Williams on this perceived mistake.
Consequently, whilst the Committee was prepared to accept that Mr. Tyrrell may have been under some form of misapprehension about the possible extent of the applicable penalty when he initially read the Guidelines on Penalty furnished by the BHA at an early stage of the procedure, it was of the opinion that based on the factors outlined above Mr. Tyrrell could not justifiably have been unaware of the nature and extent of the charges against him, or of the possible consequences of an adverse finding, for a significant period before he attended at the hearing of the BHA charges on 22 September 2010. The Committee found that he was clearly aware of the basis on which it was contended that he was in breach of the relevant Rules, and of the nature of the defence which was open to him in response to those charges.
As to the subsequent procedures, the Committee noted that the BHA had acted properly by going so far as to prepare and submit an extensive written plea in mitigation of penalty on behalf of Mr. Behan once the Panel had found him in breach of the Rules. The Committee also noted that that Mr. Tyrrell was represented by solicitor and counsel at the subsequent appeal, which was conducted not by a full re-hearing of evidence, but by written and oral submissions on the transcript of the Panel proceedings.
Although the initial grounds of appeal complained of unfairness in the conduct of the Panel hearing, it appeared that this was refined at the appeal hearing to limit the procedural unfairness alleged to “the taking into account of an irrelevant factor”. The appeal was dismissed, and no submission was made to this Committee that there was any lack of natural justice in respect of the appeal procedures, but it was noted that no general complaint of unfairness against the Panel was pursued by or on behalf of Mr. Tyrrell at his BHA appeal.
Accordingly, the Committee found that Mr. Tyrrell had not established any factual basis for his application for a declaration under Regulation 18 that the disqualification sanction imposed on him by the BHA was tainted by a want of natural justice, and the Committee was in fact satisfied that the procedures leading to that disqualification were in conformity with both the minimum requirements set out in Art.10 of the international Agreement, and with the concept of natural justice as generally understood in this jurisdiction.
Therefore, the Turf Club was obliged to reciprocate the BHA sanction of disqualification under the international obligations referred to herein, and the matter having been referred to the Committee by Mr. Egan to decide upon reciprocation, it exercised its right under Rule 19A8 (iii) to declare Mr. Tyrrell to be a disqualified person from the date of this decision (18 June 2012) to the date of expiry of the BHA sanction (6 October 2013).
At the close of the hearing the Committee heard an application by the Turf Club for a contribution to the costs and expenses of the three-day hearing in the event of the penalty being reciprocated, and a response on behalf of Mr. Tyrrell.
The Committee ordered that Mr. Tyrrell pay a contribution of €2,000 in that respect.
|tyrrell-eamon-referral decision-pr-21-06-12.doc||[ ]|
- Withdrawl Times
- The Science Behind This Work
- How Detection Times Are Agreed
- EHSLC Detection Times August 2012
- Barragry 2006: Continuing Education - Doping and drug detection time in horses: new data for therapeutic agents. Irish Vet J 59, 394-398
- P-L Toutain (2010) how to extrapolate a withdrawal time from an EHSLC published detection time: A Monte Carlo simulation appraisal EVJ 42(3)