with the observation or study of the wild mammal.” No more than two dogs may be used, and no dog below ground. The activity must take place on land which belongs to the hunter, or which he has been given permission to use for the purpose. Each dog used must be kept under close control to ensure that it does not injure the wild mammal. Failed challenges Challenges to the Act which questioning the legality of the Parliament Act 1949 in the High Court and Court of Appeal failed (for example Jackson v Attorney General) The House of Lords in their judicial capacity agreed with the lower courts in a judgment delivered in October 2005. An application for judicial review was made to the High Court of England and Wales which argued that the anti-hunting legislation contravenes individual human or property rights protected in the European Convention on Human Rights (ECHR) and under European Community law and on grounds of the free movement of goods and services. The application was dismissed by the High Court in July 2005, the Court of Appeal in June 2006 and the House of Lords in November 2007. An application to the European Court of Human Rights was ruled inadmissible. Penalties and enforcement A person guilty of an offence under this Act is liable on summary conviction to an unlimited fine at the discretion of judges. (The provisions of the law state a penalty not exceeding level 5 on the standard scale, however, level 5 currently has no upper limit). Analysis published in 2015 by pro-hunting pressure group the Countryside Alliance of 2005-14 data from the Ministry of Justice shows that 378 people have been convicted of Hunting Act offences over that period, but only 24 of the offenders were involved with registered hunts. They therefore conclude that more than 94% of Hunting Act convicted offenders were not members of registered hunts but were involved in poaching or other casual hunting activities. Justice Minister Crispin Blunt said in a written answer to Parliament in June 2011 that "it is not possible to separately identify those specific cases proceeded against under the Hunting Act 2004 related to hunts recognised and regulated by the Council of Hunting Associations" since "statistical information available centrally does not include the circumstances of each case." In 2014, the number of successful convictions under the act had risen to 430. Animal welfare