an alternative to legislation that specifically targeted hunting, Lord Donoughue proposed the Wild Mammals (Protection) (Amendment) Bill. This would have made it the case that "any person who intentionally inflicts, or causes or procures, unnecessary suffering on or to any wild mammal shall be guilty of an offence." A matching Bill was introduced in the Commons with the support of The Middle Way Group (see below). Both bills failed to become law as they were blocked by Labour members who wanted a specific hunting ban. Animal welfare groups such as the League Against Cruel Sports criticised the Bill on two grounds. Firstly, they opposed the exemption in the Bill for activities undertaken "in accordance with an approved code of conduct". Secondly, they argued that, if an activity was inherently cruel, it should be deemed as such by Parliament, rather than prosecutors having to argue and prove cruelty in every court case. Following a series of evidence hearings in 2002, on 3 December 2002, DEFRA Minister of State for Rural Affairs Alun Michael introduced a bill which would have allowed some licensed hunting. In July 2003, by a majority of 208 in a free vote, the Commons passed an amendment proposed by Tony Banks to ban hunting entirely, but in October 2003 this was rejected by the House of Lords by a majority of 212. Voting, conflict with the Lords and royal assent A bill identical to the one passed by the House of Commons in 2003 was reintroduced to the Commons on 9 September 2004. On 15 September 2004, the day of the final vote (third reading) on the bill, two protesters staged the first invasion of the House of Commons chamber since King Charles I in 1641. The protesters were quickly removed by Parliamentary officials, but the incident led to a review of parliamentary security, given that it was the second breach of the security of the chamber in four months (Fathers 4 Justice activists had thrown purple flour in the Commons four months earlier). Simultaneously, a demonstration of between 8,000 and 10,000 people, including protesters from the Countryside Alliance filled Parliament Square outside. Later, John Holliday wrote for the Guardian an essay on his actions. On 17 November, on one of the days of the Parliamentary session, the Lords again insisted on its amendments to the main Bill. In the Commons, the Government's last-ditch attempt to compromise on