What’s New: Ministry of Justice 2024 automation reform implements automatic travel ban lifting upon case conclusion eliminating manual cancellation requests. Zero Government Bureaucracy Initiative (2024-2025) reduces travel ban cancellation paperwork from nine steps to zero steps with automatic system notification. Dubai Police App (2024) enables travel ban status checking via Emirates ID providing real-time ban status information. UAE Civil Procedure Code Articles 324-327 establish civil travel ban procedures enabling court-ordered restrictions for civil cases. Article 667 (updated 2024) bounced cheque legal notice procedures establish travel restrictions and resolution timelines. Automatic travel ban lifting processing timeline is 3-7 working days as standard.
Author Credentials: This guide is prepared by Abdulla Alateibi Advocates & Legal Consultancy’s legal counsel specializing in travel restrictions, court procedures, and practical legal compliance. Our team works directly with Ministry of Justice, Dubai Courts, Dubai Police, and legal authorities to coordinate travel ban procedures, status verification, and temporary relief applications.
Scope of Legal Advice: This article provides general information about travel restrictions during pending court cases under UAE Civil Procedure Code, Criminal Procedure Code, Article 667 (Bounced Cheques), and Ministry of Justice Travel Ban Procedures as of December 2025. For specific advice regarding your pending court case and travel restrictions, consultation with qualified legal counsel is recommended.
Receiving pending court case notification and discovering travel restrictions represents major disruption to personal and business plans. Many residents face urgent travel needs while cases pending including business commitments, family emergencies, and employment requirements. Understanding travel restrictions, checking ban status, and pursuing relief options enables informed decisions.
Based on our experience at Abdulla Alateibi Advocates & Legal Consultancy, most residents do not understand when travel bans apply, how to check status, or how to pursue temporary relief. 2024-2025 Ministry of Justice automation reforms dramatically simplified procedures with automatic ban lifting on case conclusion and Dubai Police app status checking eliminating paperwork burden.
This guide walks through practical steps for managing travel during pending court cases including understanding travel bans, determining case type restrictions, checking ban status, understanding 2024 automation, exploring travel options, applying for temporary relief, and understanding consequences.
Understanding Travel Restrictions and Court Cases
Pending court cases create complex legal landscape affecting personal and business travel. Understanding restriction types, legal basis, and procedures enables informed decision-making.
What is a Travel Ban
A travel ban is formal legal restriction preventing person from leaving country. Ban typically prevents exit from UAE, entry after departure, receipt of exit visa, and re-entry on same visa. Travel ban is enforceable at airports through departure prohibition, immigration record flagging, and police detention if attempted exit.
Legal Authority
Multiple authorities can impose travel bans. Courts impose civil travel bans (Articles 324-327, Civil Procedure Code). Public Prosecution imposes criminal travel bans. Police impose emergency travel restrictions. MOHRE can impose labor or absconding bans.
Reasons for Travel Bans
Travel bans are imposed to ensure person remains available for court proceedings, prevent flight and escape from jurisdiction, protect victims or witnesses, enforce financial obligations, and secure financial penalties. Each reason reflects court concern about person’s availability and compliance.
Types of Travel Bans
- Criminal Travel Ban: Criminal travel ban imposed when person charged with criminal offense. Ban typically automatic upon serious criminal charge. Criminal ban remains in effect until case concluded (acquittal or conviction), bail conditions modified, or court order lifts ban.
- Civil Travel Ban: Civil travel ban imposed by court in civil disputes (contract disputes, money claims, property matters). Civil ban typically requires minimum claim amount (typically AED 10,000+). Court may impose civil ban to secure financial claim, ensure attendance, or prevent asset removal.
- Financial Travel Ban: Bounced cheque cases (Article 667) subject to special travel restrictions. Ban may be imposed following bounced cheque legal notice serving as enforcement mechanism. Debt collection cases similarly subject to financial travel ban.
- Employment and Immigration Bans: Absconding cases (employment law violations) may result in employment-related travel bans. Immigration violations (visa overstay, illegal residency) result in immigration travel bans.
Comparison Table: Travel Ban Types
| Ban Type | Authority | Case Trigger | Typical Duration | Lifting Method | Status Check |
|---|---|---|---|---|---|
| Criminal | Prosecution/Courts | Criminal charge | Until case conclusion | Auto-lift or court order | Dubai Police App ✅ |
| Civil | Courts | Money claim (AED 10K+) | During case | Settlement or judgment | Dubai Police App ✅ |
| Bounced Cheque | Courts/Prosecution | Article 667 | Until payment | Payment or settlement | Dubai Police App ✅ |
| Employment | MOHRE | Absconding | Until resolved | Employer settlement | MOHRE portal |
| Immigration | GDRFA | Visa violation | Until resolved | Visa correction | Immigration portal |
Actionable Takeaway: Understand travel ban type imposed in your case. Different ban types have different authorities, durations, and lifting procedures. Use Dubai Police App to check criminal or civil ban status. Contact MOHRE or GDRFA for employment or immigration bans. Contact Abdulla Alateibi Advocates & Legal Consultancy for travel ban analysis.
1. Understand Travel Bans and When Imposed
First critical step is understanding whether travel ban applies to your case type. Not all pending cases result in travel bans.
Automatic vs Court-Ordered Bans
- Automatic Travel Bans in Criminal Cases: Criminal cases generate automatic travel bans upon criminal charge. Prosecution automatically files travel ban request upon serious charge. Automatic ban requires no court hearing or specific order.
- Court-Ordered Travel Bans in Civil Cases: Civil travel bans require court application and judicial order. Plaintiff applies to court requesting travel ban as enforcement mechanism. Court exercises discretion determining travel ban necessity based on claim amount, evidence of flight risk, and case complexity.
Discretionary Factors
Courts consider multiple factors imposing travel bans including claim seriousness and amount, defendant’s financial resources (ability to escape), prior legal violations, and citizenship or residency stability. Flight risk assessment is critical. Courts impose bans only when genuine flight risk exists.
Triggering Events and Timeline
- Criminal Case Timeline: Criminal case initiates with investigation. Upon sufficient evidence, prosecution charges person. Prosecution simultaneously files travel ban request (typically automatic). Travel ban imposed within days of charge.
- Civil Case Timeline: Civil case filed with court complaint. Defendant served with complaint and ban request. Court may impose preliminary ban before full hearing if emergency circumstances exist.
- Bounced Cheque Timeline: Bounced cheque triggers 30-day legal notice period (Article 667). If notice unresolved after 15 days, case proceeds and travel ban may be imposed. Resolution (payment or court settlement) required to lift ban.
Actionable Takeaway: Determine whether travel ban applies to your case. Criminal charges result in automatic bans. Civil cases require court order. Bounced cheque cases follow Article 667 timeline. Contact Dubai Courts or legal counsel if unclear whether ban exists. Contact Abdulla Alateibi Advocates & Legal Consultancy for ban determination.
2. Determine If Your Case Type Restricts Travel
Second critical step is determining your specific case type and corresponding travel restrictions. Not all case types result in travel bans.
Case Type Analysis
- Criminal Cases: Criminal cases virtually always result in travel bans. Only exceptions are minor traffic violations or minor administrative violations not involving imprisonment. Serious criminal charges (assault, theft, fraud, cybercrime) automatically trigger travel bans.
- Civil Contract Cases: Civil contract disputes frequently result in travel bans if claim exceeds AED 10,000. Travel ban depends on claim amount, defendant’s financial situation, and court discretion. Small civil claims (under AED 10,000) rarely result in travel bans.
- Property and Tenancy Cases: Property disputes sometimes result in travel bans particularly if significant financial claim involved. Eviction cases typically do not result in travel bans (unless damages claim). Mortgage and mortgage-related cases may result in travel bans if significant amounts involved.
- Employment and Labor Cases: Employment disputes (wrongful termination, unpaid salary) result in travel bans if significant financial claim. Absconding cases result in employment-related travel bans preventing exit. Labor dispute settlements often include ban lift condition.
- Intellectual Property Cases: IP infringement cases (trademark, copyright violations) typically result in travel bans due to criminal component. Cybercrime cases result in automatic travel bans.
How to Know If Ban Exists
Best method is checking travel ban status via Dubai Police App. App enables instant status confirmation. Alternatively, contact lawyer requesting ban status verification. Lawyer can access case records confirming ban.
No Ban Does Not Mean Complete Freedom
Absence of formal travel ban does not mean absolute travel freedom. Case conditions may include court permission requirement for travel, bail conditions restricting movement, or prosecution direction limiting travel. Verify all restrictions comprehensively, not just formal travel ban.
Actionable Takeaway: Determine your case type (criminal, civil, property, employment, IP). Research typical travel restrictions for your case type. Use Dubai Police App to verify formal travel ban status. Contact lawyer to verify all restrictions and conditions. Contact Abdulla Alateibi Advocates & Legal Consultancy for case analysis.
3. Check Your Travel Ban Status Immediately
Third critical step is checking travel ban status using official methods. Verification is essential before making travel plans or booking flights.
Dubai Police App Checking
- App Procedure: Dubai Police App provides instant travel ban status checking via Emirates ID. Download app from official app store. Log in with Emirates ID and password.
- Checking Steps: Navigate to “Services” or “Inquiries” section. Select “Travel Ban Status” or “Restrictions Check”. App displays real-time travel ban status including banned, not banned, or conditional restrictions.
- Understanding Status Display: Status displays “No Travel Ban Imposed,” “Travel Ban Active,” or “Travel Ban with Conditions”. If ban active, display shows ban reason, imposing authority, and estimated duration. Conditional status indicates temporary restrictions, pending appeal, or special conditions.
- App Limitations: App covers criminal and civil bans (Dubai Police and Courts). App does not cover employment bans (MOHRE) or immigration bans (GDRFA). For employment or immigration bans, contact MOHRE or GDRFA directly.
Alternative Verification Methods
- Direct Court Inquiry: Contact court directly requesting travel ban status verification. Provide case number, parties, and brief case description. Court provides written confirmation of ban status and terms.
- Lawyer Verification: Lawyer can access case records and verify travel ban status. Lawyer review is comprehensive including formal bans and conditional restrictions. Lawyer provides written verification and strategic advice regarding travel options.
- Official Portal: Official UAE Government Portal (u.ae) provides service inquiries for legal status. Some emirates enable case status checks through official portals.
Documentation
Request written confirmation from Dubai Police, court, or relevant authority. Official documentation useful if challenging travel restriction or proving status. Document retention essential for travel planning and legal defense.
Travel verification serves as basis for flight booking, documentation for employer (explaining travel constraints), evidence if airport questions arise, and basis for temporary relief application.
Actionable Takeaway: Use Dubai Police App immediately to check travel ban status. If ban shown, note reason and duration. If conditional status shown, contact lawyer for interpretation. If employment or immigration issues suspected, contact MOHRE or GDRFA. Obtain written confirmation from court or police. Contact Abdulla Alateibi Advocates & Legal Consultancy for status verification.
4. Understand 2024 Ministry of Justice Automation
Fourth critical step is understanding major 2024-2025 Ministry of Justice automation reforms dramatically simplifying travel ban lifting procedures.
2024 Automation Reforms
- Automatic Travel Ban Lifting: Ministry of Justice 2024 automation implements automatic travel ban lifting upon case conclusion. When case concludes (acquittal, conviction, settlement, judgment), system automatically lifts travel ban. Manual cancellation requests eliminated with automatic system notification to authorities.
- Zero Bureaucracy Initiative: Zero Government Bureaucracy Initiative (2024-2025) reduces travel ban cancellation paperwork from nine steps to zero steps. Previous requirement included manual application submission, documentation gathering, authority approval, and notice period. Current process is automatic system lifting upon case conclusion with zero additional action required.
- Timeline for Automatic Lifting: Automatic lifting typically occurs within 3-7 working days of case conclusion. System processes automatically when case conclusion detected, ban status updated, and authorities notified. Person can verify lifting status through Dubai Police App within 7-day window.
- System Integration: Ministry of Justice system integrates with Dubai Police database, Courts system, and Immigration database. Case conclusion in courts automatically triggers ban lifting across integrated systems. No manual notification to traveler required.
Benefits of Automation
- Elimination of Delays: Previous process required visiting court office, submitting written application, providing case documents, and waiting for processing. Processing commonly took 2-4 weeks. Current automatic process eliminates delays with lifting occurring automatically within 3-7 days.
- Cost Elimination: Previous process required lawyer fees for ban lifting application, court filing fees, and travel for office visits. Typical cost was AED 2,000-5,000. Current automatic process has zero cost, zero paperwork, and zero office visits.
- Uncertainty Reduction: Previous system created uncertainty about when ban would be lifted, need for follow-up inquiries, and repeated office visits. Current automatic system eliminates uncertainty with predictable 3-7 day timeline, clear system notification, and app-based verification.
Conditions Requiring Manual Action
- Case Still Pending: Automation applies only to concluded cases. While case pending, automatic lifting does not occur. Pending cases require case resolution, court decision, or settlement for lifting.
- Special Circumstances: Some cases require additional documentation for lifting. Examples include conditional judgments requiring specific performance or cases with restitution obligations. If case conclusion contains conditions, verify with court whether conditions satisfied before assuming ban lifted.
- Temporary Relief Available: While case pending, temporary travel relief available through application. Application procedures remain for emergency travel needs during case pending.
Actionable Takeaway: Understand 2024 automation reforms including automatic ban lifting on case conclusion within 3-7 days, zero paperwork, and zero cost. If case pending, automation does not apply and temporary relief required. After case conclusion, verify ban lifting within 7-10 days through Dubai Police App. Contact Abdulla Alateibi Advocates & Legal Consultancy for timeline verification.
5. Options for Traveling With Pending Case
Fifth critical step is understanding available options for traveling with pending court case. Travel options vary by case type and circumstances.
Travel Options by Case Type
- Criminal Cases: Criminal cases typically prohibit travel entirely. Only exception is court-approved travel with specific conditions. Conditions typically include specific travel dates, return ticket requirements, and itinerary submission.
- Civil Cases: Civil cases sometimes permit travel with conditions. Travel depends on case stage, defendant’s cooperation, and court discretion. Some civil cases enable travel if settlement proceeding, voluntary court appearance scheduled, or defendant cooperation demonstrated.
- Bounced Cheque Cases: Bounced cheque cases (Article 667) provide settlement option enabling travel. If cheque paid within 15-day notice period, travel ban may not be imposed. If case proceeds beyond settlement window, travel restricted until resolution.
- Employment Cases: Employment or absconding cases may restrict travel during case. Employment case settlement often includes travel ban lift provision enabling immediate travel upon settlement.
Settlement as Travel Strategy
- Settlement Impact: Case settlement immediately resolves underlying dispute enabling travel ban lift. Settlement agreement may include explicit travel ban lift clause. Even without explicit clause, settlement effectively resolves case enabling automatic ban lifting.
- Settlement Negotiation: If urgent travel need exists, settlement negotiation may resolve case enabling travel. Early settlement enables travel sooner than case conclusion. Lawyer can initiate settlement discussions emphasizing travel urgency if legitimate.
- Cost-Benefit: Early settlement may cost more than case judgment but enables immediate travel. Consider settlement amount versus case uncertainty and travel urgency versus litigation timeline. Lawyer provides settlement evaluation assisting decision-making.
Actionable Takeaway: Analyze your case type to understand travel options. Criminal cases typically prohibit travel entirely. Civil cases may permit conditional travel. Settlement provides fastest resolution enabling travel. Consider settlement negotiation if urgent travel need exists. Contact Abdulla Alateibi Advocates & Legal Consultancy for travel option analysis and settlement strategy.
6. Apply for Temporary Travel Permission
Sixth critical step is understanding procedures for requesting temporary travel permission from court for emergency or urgent travel needs.
Temporary Permission Application
- Grounds for Permission: Temporary travel permission granted for legitimate emergencies. Grounds include medical emergency (family member hospitalization, serious treatment abroad), family death (funeral attendance required), or critical business need (irreplaceable business meeting or contract). Court discretion determines what constitutes legitimate emergency.
- Application Process: Application submitted to court imposing travel ban. Application includes detailed emergency explanation, supporting documentation (medical reports, funeral notice, business letters), proposed travel dates, and itinerary. Application should be professionally prepared, submitted promptly, and documented comprehensively.
- Supporting Documentation: Medical emergency requires hospital admission letters, doctor letters, and treatment necessity documentation. Family death requires death certificate, funeral notice, and relationship proof. Business emergency requires business letter explaining necessity, contract documents, and meeting confirmation.
- Conditions Imposed: Court typically imposes conditions including specific travel dates (no deviation), return ticket requirement, itinerary submission, and bail bond posting. Violating conditions results in permission revocation, additional criminal charges, and case prejudice.
Bail Bond Requirements
- Bond Requirements: Temporary travel permission often requires bail bond posting. Bail bond amount varies from AED 5,000-50,000 depending on case seriousness and flight risk. Bail bond ensures person returns for case proceedings.
- Posting Procedures: Bail bond posted with court. Can be posted as cash deposit, bank guarantee, or insurance bond. Bank guarantee typically preferred enabling holding without cash.
- Bond Refund: Bail bond refunded upon safe return and case appearance. Refund processed within 3-5 business days of case return. Non-compliance with return results in bail bond forfeiture, additional criminal charges, and international arrest warrant.
Application Success Factors
- Success Factors: Application success depends on legitimacy of emergency, supporting documentation strength, court confidence in return, and defendant’s prior case compliance. Strong documentation and professional presentation significantly improve approval likelihood.
- Processing Timeline: Court typically processes application within 3-5 working days. Urgent applications sometimes processed within 1-2 days if sufficient documentation provided. Early application submission maximizes approval timeline.
- Lawyer Assistance: Lawyer can prepare professional application, gather documentation, and present to court. Lawyer presence improves application credibility and approval likelihood.
Actionable Takeaway: If urgent travel need exists due to legitimate emergency, apply for temporary travel permission from court. Document emergency thoroughly with medical, death, or business letters. Prepare professional application with specific travel dates and itinerary. Anticipate bail bond posting requirement. Submit application as early as possible. Use lawyer for application preparation. Contact Abdulla Alateibi Advocates & Legal Consultancy for temporary permission application.
7. Understand Consequences of Attempting Travel
Seventh critical step is understanding serious consequences of attempting to leave UAE while travel ban in effect.
Airport Detection
- Detection Procedures: Airport immigration systems automatically flag travel ban status. When person attempts check-in, system displays ban status. Airline staff notified of ban preventing boarding.
- Airport Detention: Person attempting to depart while banned typically detained for questioning. Detention at airport police station pending investigation. Detention timeline is 2-6 hours typical for questioning and documentation.
- Additional Criminal Charges: Attempting travel while banned results in additional criminal charges. New charges include violation of court order, contempt of court, and obstruction of justice. Additional charges compound case severity and penalties.
- Case Prejudice: Court views travel attempt as contempt and disobedience. Judge imposes penalties including increased damages, attorney fees, and court costs. Attempt significantly damages legal position and settlement prospects.
Financial and Legal Escalation
- Increased Fines: Violating court travel ban results in significant fines. Typical fines range AED 5,000-20,000 depending on case severity. Fines are in addition to original case liability.
- Passport Cancellation: Repeated travel ban violations may result in passport cancellation. Cancellation prevents any international travel. Passport cancellation significantly impacts employment and future travel for years.
- Adverse Judgment: Courts often rule against person attempting to violate court orders. Judge may award full damages claimed without hearing defense. Violation demonstrates disrespect for court authority triggering harsh judicial response.
Employment and Immigration Impact
- Employer Notification: Employer notified of criminal charges or court violations. Employment typically terminated upon serious criminal charges or jail sentence. Travel ban violation viewed as serious misconduct.
- Visa Cancellation: Travel ban violation may trigger visa cancellation. Cancellation results in loss of legal residency, deportation proceedings, and UAE re-entry ban. Re-entry ban typically 1-3 years preventing business and personal travel.
- Deportation: Serious violations trigger deportation investigation. Deportation can result in forced exit from country, long-term re-entry ban, and criminal record. Deportation completely eliminates UAE residency and employment opportunities.
Personal Impact
- Criminal Record: Travel ban violation adds criminal record. Criminal record affects future employment, professional licenses, and business dealings. Record remains permanent unless specifically expunged.
- Reputational Damage: Business community learns about travel ban violation. Reputation damage affects business relationships, partnership opportunities, and credit access. Reputational damage often more costly than financial penalties.
Actionable Takeaway: Never attempt to leave UAE while travel ban in effect. Consequences dramatically exceed inconvenience including additional criminal charges, fines, employment loss, visa cancellation, and deportation. Request temporary permission if legitimate travel need exists rather than attempting to violate ban. Court cooperation demonstrates respect and improves case outcome. Contact Abdulla Alateibi Advocates & Legal Consultancy before considering any travel while banned.
Frequently Asked Questions
Depends on case type. Criminal cases virtually always impose travel bans. Civil cases may or may not impose bans. Check travel ban status via Dubai Police App immediately.
Travel ban is legal restriction preventing person from leaving country. Imposed to ensure court attendance, prevent flight, secure financial obligations, or protect witnesses.
Use Dubai Police App (fastest method), contact court directly, or consult lawyer. App displays instant status via Emirates ID.
Airport immigration system detects ban, prevents boarding, detains person for questioning, results in additional criminal charges, fines, and potential jail time.
Yes, court may grant temporary permission for legitimate emergencies (medical, family death, critical business). Application requires documentation and typically bail bond posting.
Typically 3-5 working days. Urgent applications with sufficient documentation may be processed in 1-2 days.
Reform implementing automatic travel ban lifting upon case conclusion. Zero paperwork, zero cost. Automatic lifting within 3-7 working days.
Only if case concludes. While case pending, automatic lifting does not apply. After case resolved, automatic lifting occurs within 3-7 days.
Yes, settlement resolves underlying dispute enabling automatic ban lifting. Settlement often fastest path to travel freedom.
Financial guarantee (typically AED 5,000-50,000) ensuring person returns for court appearances. Refunded upon safe return and case appearance.
Additional criminal charges, fines (AED 5,000-20,000+), jail time, employment termination, visa cancellation, deportation.
Yes, travel ban can be appealed to higher court. Appeal requires strong grounds and legal representation. Does not automatically suspend ban during appeal.
Automatic system lifting within 3-7 days. No manual action required. Verify through Dubai Police App after waiting period.
Only through settlement (resolving case), temporary permission (court application for emergency), or appeal (challenging ban validity).
Lack of knowledge not legal excuse. You are responsible for checking status. Court assumes person knows about court orders.
Conclusion
Understanding travel restrictions during pending court cases enables informed decision-making protecting legal compliance and minimizing consequences. Practical steps including understanding travel bans, determining case type impact, checking ban status, understanding 2024 automation, exploring travel options, applying for temporary relief, and understanding consequences provide systematic guidance.
Most critical understanding is that travel bans exist for legitimate legal purposes and violating bans results in severe consequences dramatically exceeding inconvenience of delayed travel. 2024-2025 Ministry of Justice automation reforms dramatically simplified post-case procedures with automatic ban lifting within 3-7 days with zero paperwork.
Based on our experience at Abdulla Alateibi Advocates & Legal Consultancy, clients following systematic approach and respecting legal restrictions protect their interests effectively. Clients ignoring bans or attempting unauthorized travel commonly face additional criminal charges, employment loss, visa cancellation, and deportation.
Whether facing criminal case, civil dispute, bounced cheque issue, or employment case, understanding travel restrictions and available options enables appropriate decision-making. Check travel ban status immediately, respect restrictions, pursue temporary permission if legitimate emergency exists, and plan travel timing after case resolution.
Contact Abdulla Alateibi Advocates & Legal Consultancy immediately regarding travel restrictions or travel planning during pending court cases. Our legal specialists provide comprehensive guidance protecting your interests.
Legal Disclaimer
This article provides general information about travel restrictions and does not constitute legal advice. Information reflects UAE Civil Procedure Code, Criminal Procedure Code, Article 667 (Bounced Cheques), and Ministry of Justice Travel Ban Procedures as of December 2025. Individual circumstances vary significantly based on case nature and specific legal proceedings.
Abdulla Alateibi Advocates Advisory Capacity: This content is prepared by Abdulla Alateibi Advocates & Legal Consultancy within our expertise in travel restrictions and court procedures. For specific advice regarding your pending court case and travel restrictions, consultation recommended. Contact Abdulla Alateibi Advocates for immediate guidance.
Jurisdictional Scope: This information focuses on travel restrictions in UAE involving Federal Courts, DIFC Courts, and Dubai Courts. This guide addresses UAE travel restriction procedures only.
No Attorney-Client Relationship: Reading this article does not create attorney-client relationship. For specific legal advice regarding your pending court case and travel circumstances, contact our office to establish formal consultation.
Regulatory Currency: Travel restriction landscape changes through legislative updates and automation improvements. Information represents current framework as of December 2025. Always verify current procedures with Ministry of Justice, Dubai Courts, and qualified legal counsel.
