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I know one of the reasons its so bad is that it was done in a hurry, but I'd have thought the civil service's top legal bods would have been all over this SI. I work on legislation in the civil service (IANAL) and even with the standard legal team they are very good at helping us spot and work through loopholes.
I'm surprised its so shit. It's not the government drafting this stuff, so I'm disappointed in the civil service really.
Scrabble
It's a good thing they aren't in charge of anything important, like drafting laws...
I've definitely no knowledge of how prosecution works, but the way I read it, I don't think intent would come into it, as buying food is a reasonable excuse to leave house.