HAALEBOS AND 79 OTHERS AND DE NEDERLANDSE VERENIGING VOOR THORAXCHIRURGIE v. THE NETHERLANDS



                      AS TO THE ADMISSIBILITY OF

                       Application No. 21741/93

     by 1. Maximiliaan Maarten Pieter HAALEBOS and 79 others, and

        2. De Nederlandse Vereniging voor Thoraxchirurgie;

                       against the Netherlands

      The European Commission of Human Rights (Second Chamber) sitting

in private on 11 January 1995, the following members being present:

           Mr.   H. DANELIUS, President

           Mrs.  G.H. THUNE

           MM.   G. JÖRUNDSSON

                 S. TRECHSEL

                 J.-C. SOYER

                 H.G. SCHERMERS

                 F. MARTINEZ

                 L. LOUCAIDES

                 J.-C. GEUS

                 M.A. NOWICKI

                 I. CABRAL BARRETO

                 J. MUCHA

                 D. SVÁBY

           Mr.   K. ROGGE, Secretary to the Chamber

      Having regard to Article 25 of the Convention for the Protection

of Human Rights and Fundamental Freedoms;

      Having regard to the application introduced on 8 November 1992

by Maximiliaan Maarten Pieter HAALEBOS and 79 others and De Nederlandse

Vereniging voor Thoraxchirurgie against the Netherlands and registered

on 26 April 1993 under file No. 21741/93;

      Having regard to the report provided for in Rule 47 of the Rules

of Procedure of the Commission;

      Having deliberated;

      Decides as follows:

THE FACTS

      The applicants are 80 cardio-pulmonary surgeons working in the

Netherlands, and the Dutch Society for Thoracic Surgery (Nederlandse

Vereniging voor Thoraxchirurgie, hereinafter referred to as the "NVT"),

of which all of the above 80 cardio-pulmonary surgeons are members. The

particulars of the 80 surgeons are appended to this report.

      In the proceedings before the Commission, 68 of the 80 cardio-

pulmonary surgeons are represented by Mr. E.C.M. Wagemakers, a lawyer

practising in Breda, the Netherlands. The NVT acts on its own behalf

and on behalf of its members. The NVT itself is represented by its

President, Mr. M.M.P. Haalebos (applicant No. 28), and its Secretary

Mr. T. Ebels (applicant No. 19), both of whom are represented by Mr.

E.C.M. Wagemakers.

      The facts of the case, as submitted by the applicants, may be

summarised as follows.

1.    General background

      In 1982, the Health Care Tariffs Act (Wet Tarieven Gezondheids-

zorg, hereinafter referred to as "WTG") came into force. This act aims

at a balanced system of determining health care tariffs in order to

control the escalation of health care costs.

      Pursuant to the WTG, health care tariffs are determined through

negotiations between, on the one hand, the institutions paying for

health care (public health services and medical insurance companies),

and, on the other hand, medical institutions (such as, inter alia,

hospitals, convalescent hospitals, maternity clinics) and persons

providing health care (such as, inter alia, physicians, dentists,

pharmacists, specialists).

      In order to avoid having to negotiate with an ever increasing

number of parties, the public authorities have fixed criteria for

selection based on the idea of representativeness of organisations.

Participation in tariff negotiations is limited to the organisations

that have been recognised as representative organisations by the

Ministry of Welfare, Public Health and Cultural Affairs (Ministerie van

Welzijn, Volksgezondheid en Cultuur) pursuant to Section 3 of the WTG.

      Each representative organisation represents a category of

institutions or people within the health care system. In the Decree on

Representative Organisations (Besluit houdende representatieve

organisaties, hereinafter referred to as the "1984 Decree"), the

categories of institutions and persons within the health care system

are listed. Only for the categories listed in this Decree,

representative organisations can be recognised. The Decree became

effective in 1984, and has been amended in later years to include new

categories of institutions or persons. The Decree prescribes, inter

alia, that all medical specialists form one category; cardio-pulmonary

surgeons are not mentioned as a separate category.

      The criteria that must be met in order for an organisation to be

recognised as representative are laid down in a public notice of the

Deputy Minister of Welfare, Public Health and Cultural Affairs. Two of

those criteria concern the number of members. The representative

character of an organisation in this respect is assessed at two levels.

      In the first place, the organisation must have a significant

number of members in the group which it wishes to represent; secondly,

the number of members should not be disproportionately small compared

with the number of members of other organisations within the same

category.

      The recognised representative organisations, insofar as relevant

for the present case, are the "Vereniging van Nederlandse Zieken-

fondsen" (VNZ) - representing the public health services -, the

"Kontaktorgaan Landelijke Organisaties van Ziektekostenverzekeraars"

(KLOZ) - representing the private medical insurance companies -, the

"Kontaktcommissie Publiekrechtelijke Ziektekostenregelingen voor

Ambtenaren" (KPZ) - representing the medical insurance companies for

civil servants -, the "Nationale Ziekenhuisraad" (NZR) - representing

the medical institutions -, and the "Landelijke Specialisten

Vereniging" (the National Association of Specialists, hereinafter

referred to as "LSV") - representing the specialists.

      Pursuant to the 1984 Decree, all specialists form one category.

Within the category of specialists there are 26 sub-categories of which

the cardio-pulmonary surgeons is one. As far as tariff negotiations are

concerned, all specialists working in the Netherlands are represented

by the LSV. The LSV has approximately 7,450 members. A number of

cardio-pulmonary surgeons used to be members of the LSV.

       The NVT used to be a separate organisation within the framework

of the LSV. The NVT is a legal person under Dutch law, founded in 1948.

According to Section 4 of its articles of association (statuten), the

aims of the NVT are to advance the development of cardio-pulmonary

surgery and to promote the interests of its members. Allegedly, all

cardio-pulmonary surgeons working in the Netherlands are NVT members.

      Within the LSV, each of the 26 sub-categories of specialists has

one vote. In addition to the 26 sub-categories of specialists, there

are 20 geographical regions, each one having one vote.

      The results of the tariff negotiations are sent to the Central

Body for Health Care Tariffs (Centraal Orgaan Tarieven Gezondheidszorg,

hereinafter referred to as the "COTG"), which approves or adjusts the

tariffs. The COTG is a public body, whose independent members are

appointed by the Government.

      The COTG may be provided with guidelines on the level, the

structure and the way of calculation of tariffs, which it should take

into account in the exercise of its functions. These guidelines are

determined by the Minister of Welfare, Public Health and Cultural

Affairs, on the basis of advice by the COTG and in agreement with the

Minister of Economic Affairs (Minister van Economische Zaken), the

Minister of Social Affairs (Minister van Sociale Zaken) and other

Ministers involved.

      Pursuant to Section 2 of the WTG, it is a criminal offence to

charge a tariff that has not been approved or determined by the COTG.

      Pursuant to Section 35 of the WTG, an appeal can be lodged with

the Industrial Appeals Tribunal (College van Beroep voor het Bedrijfs-

leven) against the COTG's decision to approve or adjust tariffs by,

inter alia, individual specialists.

      On 11 December 1989, the so-called "Five Parties Agreement" was

concluded between the VNZ, the KLOZ, the KPZ, the NZR and the LSV.

These five representative organisations stated in this agreement that

the tariffs for operations performed by a number of sub-categories of

specialists were either too low or too high, and did not reflect the

required balance between the costs of the operation and the

remuneration. The agreement aimed at correcting this unbalance.

According to the agreement, the tariffs for operations performed by six

sub-categories of specialists had to be lowered, the tariffs of six

others raised, and the remaining fourteen could remain unchanged. The

tariffs for operations performed by cardio-pulmonary surgeons had to

be lowered by 30%, in three steps of 10% each.

      On 26 January 1990, following the Five Parties Agreement, the NVT

broke off all relations with the LSV. The NVT informed the LSV that it

no longer wanted to be represented by the LSV in tariff negotiations.

The applicants allege that, at present, not a single cardio-pulmonary

surgeon working in the Netherlands is a LSV member.

2.    The request of the NVT to be recognised as a representative

organisation

      On 22 March 1990, the NVT requested the Deputy Minister of

Welfare, Public Health and Cultural Affairs to be recognised as the

representative organisation within the meaning of Section 3 of the WTG

for cardio-pulmonary surgeons. On 18 December 1990, the Deputy Minister

rejected the request.

      On 10 January 1991, the NVT lodged an objection (bezwaarschrift)

against this decision. The Deputy Minister rejected the objection on

6 November 1991. He held that cardio-pulmonary surgeons were not

mentioned in the 1984 Decree as a separate category and that,

consequently, the NVT could not be recognised as the representative

organisation for cardio-pulmonary surgeons. He further held that

cardio-pulmonary surgeons formed only a sub-category of all specialists

and that the NVT could not be considered as a representative

organisation for all specialists, since, in absolute figures, it had

few members and represented only a very small number of the specialists

working in the Netherlands.

      Thereupon, the NVT lodged an appeal with the Judicial Division

of the Council of State (Afdeling Rechtspraak van de Raad van State).

In the proceedings before the Judicial Division, the NVT complained,

inter alia, that the refusal to recognise it as a representative

organisation was contrary to Articles 11 and 14 of the Convention.

      On 10 November 1992, the Judicial Division of the Council of

State rejected the appeal and upheld the Deputy Minister's reasoning

and decision. It added that the NVT could request the Deputy Minister

to amend the 1984 Decree to the effect that it would mention cardio-

pulmonary surgeons as a separate category of persons within the health

care system, and that the NVT could start civil proceedings in case the

Deputy Minister would refuse that request.

      As regards the alleged violation of Articles 11 and 14 of the

Convention, the Judicial Division of the Council of State held:

           "Article 11 para. 1 of the Convention safeguards,

      inter alia, everyone's right to form with others trade

      unions and to join trade unions for the protection of his

      interests.

           From this provision can also be deduced the obligation

      of the State to sufficiently enable trade unions to promote

      the interests of their members.

           It follows from the aforementioned judgment [Eur.

      Court H.R., National Union of Belgian Police judgment of

      27 October 1975] that Article 11 para. 1 of the Convention

      leaves each State free to choose the means to this end and

      that a policy which is aimed at limiting the number of

      organisations to be consulted is, in itself, not

      incompatible with this provision.

           The defendant [the Deputy Minister of Welfare, Public

      Health and Cultural Affairs] has submitted that his policy

      aims at limiting the number of representative

      organisations, inter alia, in order to make the tariff

      negotiations progress in an orderly fashion.

           Now that the specialists represented by the appellant

      [NVT] can join the LSV, and the appellant itself has

      opportunities to promote the interests of its members, for

      instance through contacts with the LSV, there is no reason

      to find this policy incompatible with Article 11 para. 1 of

      the Convention. ....

           The complaint that the decision is contrary to Article

      11 read in conjunction with Article 14 of the Convention

      fails as well. ....

           This aforementioned complaint is founded on the

      argument that the defendant wrongly distinguishes between

      the LSV and the NVT.... This argument, however, cannot be

      accepted as correct, since the LSV cannot be put on a par

      with the NVT. The LSV is to be considered as an umbrella

      organisation, including the practitioners of all sorts of

      medical specialisations, whilst the appellant only

      represents a group of so-called super specialists. The

      Division finds furthermore that, even assuming [the

      organisations can be regarded as similar], there is an

      objective and reasonable justification for the difference

      in treatment."

3.    The proceedings concerning the tariffs

      On 5 December 1990, the LSV, the KLOZ, the KPZ and the VNZ

requested the COTG to approve the tariffs on which they had reached

agreement on 11 December 1989.

      In two decisions of 17 December 1990, the COTG approved the new

tariffs for, inter alia, operations performed by cardio-pulmonary

surgeons. The new tariffs, which were applicable to services rendered

to both persons falling within the scope of the national health care

insurance and persons falling outside the scope of the national health

care insurance (ziekenfondsverzekerden en niet-ziekenfondsverzekerden),

were 10% lower than the tariffs previously charged.

      After the introduction of the present application to the

Commission, the tariffs for operations performed by cardio-pulmonary

surgeons, in accordance with the Five Parties Agreement, were lowered

by a further 20%.

      On 7 January 1991, twelve cardio-pulmonary surgeons, among whom

Mr. M.M.P. Haalebos (applicant No. 28), lodged an appeal against the

COTG's decisions with the Industrial Appeals Tribunal (College van

Beroep voor het Bedrijfsleven). They were all represented by the same

lawyer. Their opponents in these proceedings were, inter alia, the COTG

and the LSV.

      In their written memorial to the Industrial Appeals Tribunal and

at a hearing before the Tribunal, the twelve cardio-pulmonary surgeons

argued that the decisions of the COTG to lower the tariffs were based

on incorrect data concerning, inter alia, workload, turnover and

operating expenses. They complained that the COTG, instead of asking

them for additional and correct data, had based its decisions on the

data provided by the LSV. They invoked Articles 6 and 11 of the

Convention.

      On 19 May 1992, the Industrial Appeals Tribunal rejected the

appeal. It held that, as the LSV was the representative organisation

for cardio-pulmonary surgeons and as the tariffs were based on the

proposals and data of this organisation, the COTG had, in principle,

no legal obligation to consult the NVT for additional data, and that

in the present case there were no particular reasons on the basis of

which the COTG should nevertheless have consulted the cardio-pulmonary

surgeons.

      In its decision the Industrial Appeals Tribunal had regard to the

fact that the cardio-pulmonary surgeons had not produced data on

turnover and workload demonstrating that the data on which the COTG had

based its decisions were in fact incorrect. The Industrial Appeals

Tribunal further noted that the cardio-pulmonary surgeons could have

objected to the proposals within the LSV, but that they had not availed

themselves of that opportunity.

COMPLAINTS

1.    The applicants complain that the refusal to recognise the NVT as

the representative organisation for cardio-pulmonary surgeons and the

way the tariffs at issue were determined are contrary to Article 11 of

the Convention. They allege that, by way of the WTG, the Government has

given the LSV a monopoly position and that this makes it impossible for

cardio-pulmonary surgeons to establish an organisation of their own

which can effectively secure their specific interests in negotiations

concerning the tariffs for cardio-pulmonary surgeons.

2.    The applicants further complain under Article 6 para. 1 of the

Convention that in the proceedings in which the tariffs were determined

they did not receive a fair trial. They submit that, although they had

demonstrated irrefutably that the COTG had based its tariff decisions

on wrong data, the Industrial Appeals Tribunal rejected this argument

holding that these data had been submitted by the LSV, the

representative organisation for all specialists, including cardio-

pulmonary surgeons.

THE LAW

1.a.  The Commission observes that out of the 80 persons enumerated in

the annex, only 68 have issued powers of attorney in favour of Mr.

Wagemakers. The remaining 12 persons have not themselves presented any

application nor have they issued powers of attorney to any other person

to represent them before the Commission. However, the NVT has stated

that it acts also on their behalf.

      The question therefore arises whether the 12 persons can be

considered to have lodged an application with the Commission.

      However, the Commission does not find it necessary to determine

this question in the circumstances of the present case, since it can

examine the identical complaints lodged by the 68 applicants and since

it considers these complaints to be inadmissible for the reasons set

out hereafter.

b.     The Commission further notes that not all the applicants were

party to all the domestic proceedings concerned. The further question

therefore arises whether those applicants who were not a party to

certain domestic proceedings may still complain to the Commission of

the outcome of these proceedings or the manner in which these

proceedings were conducted. The Commission also does not find it

necessary to determine this issue, since for the reasons set out below,

it finds the various complaints to be inadmissible.

2.    The first complaint is that the refusal to recognise the NVT as

the representative organisation for cardio-pulmonary surgeons and the

way the tariffs at issue were determined are contrary to Article 11

(Art. 11) of the Convention.

      Article 11 (Art. 11) of the Convention reads as follows:

      "1.  Everyone has the right to freedom of peaceful assembly and

      to freedom of association with others, including the right to

      form and to join trade unions for the protection of his

      interests.

      2.   No restrictions shall be placed on the exercise of these

      rights other than such as are prescribed by law and are necessary

      in a democratic society in the interests of national security or

      public safety, for the prevention of disorder or crime, for the

      protection of health or morals or for the protection of the

      rights and freedoms of others...."

      The Commission recalls that, while Article 11 para. 1

(Art. 11-1) of the Convention presents trade union freedom as one form

or a special aspect of freedom of association, the Article does not

guarantee any particular treatment of trade unions, or their members,

by the State, such as the right to be consulted by the State or the

right that the State should conclude any given collective agreement

with them (cf. Eur. Court H.R., National Union of Belgian Police

judgment of 27 October 1975, Series A. No. 19, p. 17, para. 38; and

Swedish Engine Drivers' Union judgment of 6 February 1976, Series A

No. 20, p. 15, para. 39).

      The Commission further recalls that the Convention safeguards

freedom to protect the occupational interests of trade union members

by trade union action, the conduct and development of which the

Contracting State must both permit and make possible. It follows that

the members of a trade union have a right, in order to protect their

interests, that the trade union should be heard. Article 11 para. 1

(Art. 11-1) certainly leaves each State a free choice of the means to

be used towards this end. While consultation and the concluding of

collective agreements are two of these means, there are others. What

the Convention requires is that under national law trade unions should

be enabled, in conditions not at variance with Article 11 (Art. 11),

to strive for the protection of their members' interests (Eur. Court

H.R., National Union of Belgian Police judgment, loc. cit., p. 18,

para. 39; and Swedish Engine Drivers' Union judgment, loc. cit., p. 15,

para. 39).

      The Commission notes that the cardio-pulmonary surgeons are not

forced to join the LSV or any other specific professional association.

They are free to create their own professional association, which they

did in fact in 1948 when the NVT was established, or not to associate

themselves.

       The NVT can engage in various activities to promote the

interests of its members.

      The Commission further notes that the Dutch legislature has

created the system laid down in the WTG in order to control the

escalation of health care costs. In order to keep the tariff

negotiations as simple as possible, the legislature has chosen to limit

the number of representative organisations to be consulted. The

Commission finds that this system, in itself, cannot be regarded as

incompatible with Article 11 (Art. 11) of the Convention (cf. Eur.

Court H.R., National Union of Belgian Police case, loc. cit., p. 18,

para. 41).

      The Commission has also had regard to the fact that it is open

to the NVT to seek to achieve a change in the 1984 Decree to the effect

that cardio-pulmonary surgeons are included in the Decree as a separate

category, which would subsequently create the possibility for the NVT

to seek the status of a representative organisation for the purposes

of the WTG. It does not appear, however, that the NVT has in fact tried

to obtain a change in the 1984 Decree.

      The Commission therefore finds that the fact that the NVT is not

recognised as the representative organisation for cardio-pulmonary

surgeons pursuant to Section 3 of the WTG - the consequence of which

is that it cannot participate in tariff negotiations - does not in

itself constitute a restriction on the exercise of the rights

guaranteed by Article 11 para. 1 (Art. 11-1) of the Convention.

      It follows that this part of the application is manifestly ill-

founded within the meaning of Article 27 para. 2 (Art. 27-2) of the

Convention.

3.    The applicants further complain under Article 6 para. 1

(Art. 6-1) of the Convention that in the proceedings in which the

tariffs for cardio-pulmonary interventions were determined they did not

receive a fair trial, in that this determination was based on incorrect

data.

      Article 6 para. 1 (Art. 6-1) of the Convention, insofar as

relevant, reads:

      "In the determination of his civil rights..., everyone is

      entitled to a fair...hearing...by an independent and impartial

      tribunal established by law...."

      The Commission notes that the proceedings before the Industrial

Appeals Tribunal were decisive for the fees cardio-pulmonary surgeons

could charge. The Commission is of the opinion that these proceedings

fall within the scope of Article 6 para. 1 (Art. 6-1) of the

Convention, as they determined the cardio-pulmonary surgeons' civil

rights and obligations within the meaning of this provision (cf.

No. 11097/84, Dec. 18.7.86, D.R. 48 p. 204).

      The applicants allege that the proceedings before the Industrial

Appeals Tribunal were unfair, as the Tribunal based its decision on

incorrect data provided by the LSV to the COTG, the LSV being

considered as the representative organisation for specialists,

including cardio-pulmonary surgeons.

      The Commission recalls that, in accordance with Article 19

(Art. 19) of the Convention, its only task is to ensure the observance

of the obligations undertaken by the Parties to the Convention. In

particular, it is not competent to deal with complaints that errors of

law or fact have been committed by domestic courts, except where it

considers that such errors might have involved a possible violation of

any of the rights and freedoms set out in the Convention (cf. No.

17722/91, Dec. 8.4.91, D.R. 69 p. 345).

      The Commission notes that the applicants, insofar as they were

a party to those proceedings, could, and in fact did, challenge the

correctness of the data on which the LSV's tariff proposals and the

subsequent decisions of the COTG were based. The Commission however

further notes that, according to the Industrial Appeals Tribunal, the

allegation of incorrectness of the data remained unsubstantiated as the

applicants failed to produce data on turnover and workload

demonstrating that the data provided by the LSV, on which the COTG had

based its decisions, were incorrect.

      In these circumstances, the Commission cannot find that the

decision by the Industrial Appeals Tribunal as regards the reliability

of the data before it is unreasonable or arbitrary.

      Furthermore, noting that in the proceedings before the Industrial

Appeals Tribunal the applicants, who were represented by a lawyer, have

been provided with ample opportunity to state their case both orally

and in writing, to submit relevant information and to challenge the

arguments of the adversary parties in those proceedings, the Commission

finds no indication that the proceedings were not in conformity with

the requirements of Article 6 para. 1 (Art. 6-1) of the Convention.

      It follows that this part of the application is also manifestly

ill-founded within the meaning of Article 27 para. 2 (Art. 27-2) of the

Convention.

      For these reasons, the Commission, by a majority,

      DECLARES INADMISSIBLE THE COMPLAINT BROUGHT UNDER ARTICLE 11 OF

      THE CONVENTION;

      and, unanimously,

      DECLARES INADMISSIBLE THE REMAINDER OF THE APPLICATION.

Secretary to the Second Chamber       President of the Second Chamber

        (K. ROGGE)                          (H. DANELIUS)

                                ANNEX

                          list of applicants

Name:                            Place of residence    Represented

                                                       by Mr.Wagemakers

1.  Z. Aytug                     Leiderdorp                       Yes

2.  R. Bakhuizen                 Wapenveld                        Yes

3.  P.F.A. Bakker-de Wekker      Hilversum                        Yes

4.  J.H. Bavinck                 Eindhoven                        No

5.  J.A. Bekkers                 Rotterdam                        Yes

6.  E. Berreklouw                Son                              Yes

7.  K. Bloemendaal               Abcoude                          Yes

8.  W.J. de Boer                 Haren                            Yes

9.  A.J.J.C. Bogers              Oegstgeest                       Yes

10. P.W. Boonstra                Groningen                        Yes

11. E. Bos                       Rotterdam                        Yes

12. W.G.B. Brands                Ulvenhout                        Yes

13. J.J. Bredée                  Utrecht                          Yes

14. E. Broekhuis                 Amsterdam                        Yes

15. M.H.J. Brouwer               Haren                            Yes

16. A. Brutel de la Rivière      Nieuwegein                       Yes

17. J.J.A.M. Defauw              Wijk bij Duurstede               Yes

18. R.A.E. Dion                  Bierbeek (Belgium)               Yes

19. T. Ebels                     Haren                            Yes

20. P.S. Eggens                  Breda                            Yes

21. A. Eijgelaar                 Groningen                        No

22. L. Eijsman                   Bussum                           Yes

23. Th.W.O. Elenbaas             Maastricht                       Yes

24. R. de Geest                  Aalst (Belgium)                  No

25. Th.R. van Geldorp            Breda                            Yes

26. G.G. Geskes                  Maastricht                       Yes

27. J.G. Grandjean               Haren                            Yes

28. M.M.P. Haalebos              Hattem                           Yes

29. R. Hamerlijnck               Zeist                            Yes

30. R. Hardjowijono              Huizen                           Yes

31. K. ten Have                  Amsterdam                        Yes

32. M.G. Hazekamp                Noordwijkerhout                  Yes

33. L.A. van Herwerden           Rotterdam                        Yes

34. P.A.E. Hiddema               Rotterdam                        Yes

35. J.F. Hitchcock               Utrecht                          No

36. M.A.J.M. Huybregts           Diemen                           Yes

37. H.A. Huysmans                Oegstgeest                       Yes

38. G.J. van Ingen               Passau (Germany)                 Yes

39. B. Jambroes                  Utrecht                          Yes

40. E.W.L. Jansen                Zeist                            Yes

41. A.P. de Jong                 Haarlem                          Yes

42. G.L. Kaan                    Malden                           Yes

43. J.J. Kloek                   Koog aan de Zaan                 Yes

44. P.J.J.M.L. Knaepen           Bilthoven                        Yes

45. G.J. Kootstra                Breda                            Yes

46. L.K. Lacquet                 Ubbergen                         Yes

47. J.R. Lahpor                  Utrecht                          Yes

48. F. Leicher                   Hattem                           Yes

49. A.P.W.M. Maat                Rotterdam                        Yes

50. Y.A.S. Mashhour              Lieshout                         Yes

Name:                            Place of residence    Represented

                                                       by Mr.Wagemakers

51. J.J. van der Meer            Ulvenhout                        Yes

52. J. van der Meulen            Nijmegen                         Yes

53. J.J. Meuzelaar               Noordwijk                        Yes

54. H.G. Meyne                   Amsterdam                        No

55. B. Mochtar                   Rotterdam                        Yes

56. B.A.J.M. de Mol              Vianen                           Yes

57. W.J. Morshuis                Culemborg                        Yes

58. A.C. Moulijn                 Beuningen                        Yes

59. A. Nijveld                   Hoofddorp                        Yes

60. L. Noyez                     Nijmegen                         Yes

61. O.C.K.M. Penn                Maastricht                       Yes

62. K.B. Prenger                 Meerssen                         Yes

63. J.M. Quagebeur               not stated                       No

64. G.L. van Rijk-Zwikker        Heemstede                        Yes

65. A. Rocher                    Brugge (Belgium)                 No

66. J.P.A.M. Schönberger         Someren                          Yes

67. T.H. Sie                     Hattem                           Yes

68. S.H. Skotnicki               Nijmegen                         Yes

69. A.H.M. van Straten           Oirschot                         Yes

70. H.A. van Swieten             Zeist                            Yes

71. F.E.E. Vermeulen             Nieuwegein                       Yes

72. M.I.M. Versteegh             Sassenheim                       Yes

73. J.G. Vincent                 Nijmegen                         No

74. M.M. Vrakking                Leiden                           Yes

75. H.J. van der Wal             Milsbeek                         No

76. T.W. Waterbolk               Haren                            Yes

77. H.P. Wijnen                  Le Muids (Switzerland)           No

78. C.R.H. Wildevuur             Groningen                        No

79. S.R. Woolley                 Utrecht                          Yes

80. B.S. Zienkowicz              Amsterdam                        No

 

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