European Union – Environment. The defendant Secretary of State had not been entitled to treat the convictions of the claimant's estate keeper for killing wild birds on the claimant's estate, without more, as having satisfied the requirement in art 23 of the Council Regulation (EC) 73/2009 that cross-compliance breaches be the result of an act or omission directly attributable to the farmer. The Administrative Court held that some further enquiry directed at the level of fault, if any, on the part of the claimant in connection with the keeper's actions had been required.