the public defender system has been heavily criticized by Russian lawyers for the way it works in practice. Investigators often appoint lawyers themselves without waiting for the detained to choose, and prefer to appoint lawyers with whom they have a comfortable working relationship with, so in practice the publicly appointed lawyers will often in fact help the prosecution by not vigorously defending their clients and simply signing the necessary documents and attending the necessary proceedings, and investigators will stop appointing lawyers who inconvenience the prosecution. Defendants may opt for privately retained counsel instead, though some administrative obstacles exist. For cases tried by the Federal Security Service or Main Investigative Directorate, there is a closed group of attorneys who represent defendants. United Kingdom England and Wales Before the Prisoners' Counsel Act 1836, felony defendants did not have the formal right of being represented by a counsel in English courts although, from the mid-18th century such had been routinely indulged where defendants could afford them. It was thought, at the time, that the presence of defence counsel would serve no purpose in criminal proceedings, where what matters is deciding fact: the defendant should simply tell the truth to the court, without the interference of some counsel. William Hawkins in his A Treatise of the Pleas of the Crown: or a system of the principal matters, relating to that subject, digested under their proper heads Vol. II. of 1721 wrote........ [I]t requires no manner of Skill to make a plain and honest Defence, which ... is always the best; the Simplicity and Innocence, artless and ingenuous Behaviour of one whose Conscience acquits him, having something in it more moving and convincing than the highest Eloquence of a Person speaking in a cause not their own. This changed as more and more prosecutions became, for reasons of public policy, funded by the Crown, who employed professional counsel. An innate sense of fair-play prevailed therefore, permitting defence counsel to be present, albeit at the defendant's own expense. Penurious defendants were obviously at a significant disadvantage. Legal aid in England and Wales is provided through the Legal Aid Agency, which provides aid in both civil and criminal cases. Legal aid in civil cases is means-tested, with only those showing they cannot afford the legal costs and the case is serious eligible. In criminal cases, everyone questioned at a police station is entitled to free legal advice.