The smell of power: A contribution to the critique of the sniffer dog

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Radical Philosophy 167 (May/June 2011)
The smell of power
A contribution to the critique
of the sniffer dog
Mark Neocleous
On 8 July 2005, the day after the London bombings, the International
Association of Chiefs of Police issued its new guidelines on the detection
and prevention of suicide bombings. The IACP is the primary organization
through which senior police executives across the globe try to coordinate their powers
and practices, and it does this through a number of ‘Training Keys’. The two ‘Training
Keys’ issued in July 2005, numbers 581 and 582, were called Suicide Bombers: Part
I and Suicide Bombers: Part II. Training Key 582 concerns the use of lethal force,
emphasizing shooting at a suspect’s head and thus shooting to kill. Training Key 581
instructs police ofcers in how to detect potential suicide bombers. It focuses on a set
of behavioural and physical characteristics, including sudden changes in behaviour such
as a religious person starting to visit sex clubs, the wearing of loose or bulky clothing
in the summer, dgeting or pacing, failure to make eye contact, mumbling, being overly
concerned about their bags, strange hair colouring. Among this range of ‘suspicious’
things are also some indicators based on smell: ‘is the individual wearing too much
cologne or perfume, or does he or she smell of talcum powder or scented water?’ To
reinforce this point, the Training Key references the advice given to border ofcials by
the Department of Homeland Security, to look out for individuals who ‘may smell of
herbal or ower water’. Smell is here treated, quite casually, as a technique of police
power.
Aside from a few critics noting the racial proling implicit in the instructions, such
comments concerning smell have been largely overlooked. This oversight is sympto-
matic of a much wider focus within ‘surveillance studies’ on sight and vision. Extensive
analyses of CCTV, spy cameras and technologies of global satellite tracking follow a
long tradition which has homed in on the ocular as a locus of power. It is the gaze that
has dominated critical discussions of surveillance. The ubiquity of the panopticon as a
theoretical tool for grappling with the powers of discipline and punishment captures this
exactly, but there are a host of other critical analyses which have centred on the practice
of ‘seeing like a state’. After sight, it is mechanisms of aural surveillance such as eaves-
dropping, bugging and phone-tapping which dominate the debate. Little is said about
how the state smells, despite the obvious implications that arise when thinking about
the powers of sight and sound in the body politic. The ‘new surveillance’ studies has
failed to analyse smell as part of the state’s sensory apparatus despite being founded on
the ‘extension of the senses’,1 and the literature on identity as surveillance has picked
up on the eye, face, nger, hand or voice in its discussions of the body, but rarely the
smell: a major and increasingly inuential edited collection such as Jane Caplan and
John Torpey’s Documenting Individual Identity, for example, contains just one comment
on smell, in an essay on ‘body surveillance’ by one leading surveillance studies thinker,
and that is to dismiss the ‘hype’ surrounding any new technology in the eld.2

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Why is this? Why, with a critical intellectual culture
saturated with analyses of biopolitics, biosecurity, bio-
surveillance and biometrics, has so little been said
about the smell of power? Why is the state’s ‘nosiness’
still understood almost solely through the ocular and
the aural?
One reason might be that ‘olfaction is often deemed
the least “intellectual”, or the least informative, of our
senses’. Seemingly dealing with ‘the airy, the insub-
stantial, and the formless’, olfaction appears to be a
poor cousin to sight when it comes to power. Compared
to sight, ‘whose perceptions are so rational that they
may be analyzed by the laws of geometry, olfaction
rejects geometrical analysis’ in much the same way that
it rejects localization.3 On this view, there is little for the
state to be doing with smell. ‘Due to its marginal and
repressed status in contemporary Western culture, smell
is hardly ever considered as a political vehicle’, notes one
cultural history; ‘power appears odourless’.4
Yet power’s appearance of being odourless does not
mean that smell is not also political. We know well
enough that smell clearly has been a political vehicle,
from the deodorization of the nineteenth-century city
as an exercise in class power through to its articulation
as a means of delineating the otherness of the foreign,
the state has long exercised a kind of olfactory police as
part of its fabrication of order. But really to grasp this
we need to understand how the state is now concerned
less with merely eradicating the disgusting smell or
mobilizing against the foreign smell, and much more
with using it. Crucial to this process is the sniffer dog.
Critical theory has never really asked the question:
what is the political meaning of a sniffer dog? As a
sniffer dog it has an obvious range of uses, as witnessed
by the snarling creatures confronting prisoners being
tortured at Abu Ghraib and protestors being ‘kettled’ in
London. But as a sniffer dog its meaning lies less in its
ability to generate fear and more in its ability to enact a
politics of smell; the use of the Chihuahua as a sniffer
dog in Japan and the attempt to replace the sniffer dog
with sniffer technologies are evidence of the fact that
it is the power to smell rather than the power to scare
that is important. Investigating this power situates the
sniffer dog at the heart of police power. As such, an
investigation of the sniffer dog takes us past the banali-
ties of surveillance studies and civil liberties discourse,
and straight to the heart of the state’s role in the perma-
nent reinvention of bourgeois order.
Smell, stop, search
It is a little-noted fact about the process of personal
identity that before ngerprints were introduced as a
primary means of police identication, Barruel had
offered to the French police his ‘discovery’ concerning
the odour of blood when, in 1829, he proposed ‘smell
prints’ as a means of identifying criminals.5 Not much
came of it then, and it would appear to have died
out as a result of the growth of ngerprinting in the
late nineteenth century and advances in haematology
which ruled out blood as the basis of smell prints. Yet
regardless of his focus on blood, Barruel was indeed
on to something with the idea of smell prints.
In 2007 it was revealed that German police had col-
lected scent traces of activists prior to the G8 summit
in Heiligendamm in June of that year. At the time,
many thought this an unusual infringement of civil
liberties and a new indication of how far the state is
now willing to go in intelligence-gathering. But it was
neither unusual nor new. In her analysis of ‘Stasiland’,
Anna Funder reports visiting one room in the Stasi
museum in Leipzig and seeing a cabinet containing
glass jars. The woman who ran the museum explained
that the jars were ‘smell samples’.
The Stasi had developed a quasi-scientic method,
‘smell sampling’, as a way to nd criminals. The
theory was that we all have our own identifying
odour, which we leave on everything we touch.
These smells can be captured and, with the help of
trained sniffer dogs, compared to nd a match …
The Stasi might break into someone’s apartment and
take a piece of clothing worn close to the skin, often
underwear. Alternately, a ‘suspect’ would be brought
in under some pretext for questioning, and the vinyl
seat he or she had sat on would be wiped afterward
with a cloth. The pieces of stolen clothing, or the
cloth, would then be placed in a sealed jar. The
containers looked like jam bottling jars. A label read
‘Name: Herr [Name]. Time: 1 hour. Object: Worker’s
U nd e r p a nt s ’.6
Funder adds that the number of jars suggests that
the Leipzig Stasi had smell samples of the entire politi-
cal opposition in the area. The jars disappeared soon
after the 1989 revolution, but then turned up in the
ofce of the Leipzig police, who thought they might
still be of use after the revolution and thus kept them
in a ‘smell pantry’. So the collection of scent traces
of political activists by German police may well be an
‘unsavoury’ reminder that German security agencies
are ‘using methods that the Stasi once practiced’, as
Hans-Christian Stroebelle, a Greens leader, put it.7 But
what if it can’t be explained away as a relic of the Stasi
period in German history? What if something else
is at stake, something far more telling about liberal
democratic regimes? What if the liberal state is more
interested in smell than we realize?

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In the early 1960s the CIA produced a fairly lengthy
report called Human Scent and Its Detection. The
document considers in great detail the science of sweat
production, including several paragraphs discussing
the different functions of the eccrine, apocrine and
sebaceous glands, and noting the different ways in
which they produce smells. The political purpose
of the scientic detail is to raise the possibility of
estimating the amount of odour that a human body
might produce and the distance that might enable a
dog to smell a person. The document suggests that such
research might have an important role in future intel-
ligence work. More recently, the Defense Advanced
Research Projects Agency (DARPA), the US state’s
key agency for military research, has developed a
‘Unique Signature Detection Project’, formerly known
as the ‘Odortype Detection Program’, and has been
working since 2007 on a system of Identication Based
on Scent (IBIS). ‘DARPA wants to be able to detect,
track, and even positively identify them [criminals
and terrorists] from a distance … using nothing more
than the heat and sweat that emanate from a person’s
pores’, notes the Information Awareness Ofce report
‘Detecting Sweaty, Smelly Security Threats’.8 Both
the Department of Homeland Security in the USA and
the Ministry of Defence in the UK fund research into
smell, in the form of Remote Air Sampling Canine
Olfaction (RASCO).9 Signicantly, RASCO is said to
be more accurate than, say, a retinal scan, because a
person’s smell is thought to be less controllable than
their eyes, and dogs are trained to smell past the
attempts to camouage real smells with false ones.
Such projects have been assisted by the chemical
industries aiming to get in on the security bandwagon:
the European Network of Excellence in Articial
Olfaction and the International Society for Olfaction
and Chemical Sensing now list security politics as a
major research interest.
In virtually all cases the focus of the research
points to the sniffer dog as key to the politics of smell.
Police forces work on the assumption that police dogs
can detect a whole range of substances on a person.
Note that this means that for the most part the dogs
are used not to identify individuals, along the lines of
a ngerprint or retinal scan, but to identify (or, more
correctly, to appear to identify) substances. They are
frequently employed in order to ‘catch’ a whiff of
drugs on people as they go by and have therefore been
a key weapon in the ‘war on drugs’. Yet anyone who
travels on public transport will have noticed a rather
signicant increase in the use of dogs around transport
terminals in the last decade. This is often said to be
about continuing the ght in the ‘war on drugs’, but it
is also clear that the increased presence of police dogs
in public spaces is an outcome of more generalized
security measures in the ‘war on terror’. ‘Dogs are
the public face of the war on terror’, as one journalist
puts it.10 The use of dogs by the state has increased
so much that they now have their own publication, the
bi-monthly K9 Cop Magazine, launched in 2009.
One of the main functions of the dogs, as the public
face of the ‘war on terror’, has been identical to their
role in the war on drugs: to justify ‘stop and search’
routines. Dogs sniff the air, the person and their bags,
and the police ofcer reacts accordingly. If it is the
case that ‘what smells good is good’ and, conversely,
that ‘what smells bad is ba d ’, 11 then from the police
perspective what smells suspicious is suspicious. Yet it
is also the case that anything appearing to the police
ofcer to be ‘suspicious behaviour’ is grounds for a
suspect to be stopped and searched, including trying
to avoid the dogs or even looking like one might be
trying to avoid them. Once this occurs the police have
‘reasonable grounds’ to engage in a stop-and-search
routine. Thus one can be stopped without knowing
whether one is caught up in the war on drugs, war
on crime or war on terror at that precise moment
in time. The sniffer dog is thus both an emblematic
and a symptomatic gure in the universal warfare of
contemporary bourgeois order.
The standard civil liberties approach to this ques-
tion is to point to the fact that sniffer dogs have been
found to be wrong in their ‘judgement’ somewhere
in as many as three out of ve searches, or that the
dogs can be inuenced by the way their handlers hold
their leads, and that the dogs are often overly trusted
by handlers who think the dog is never wrong (an
assumption reinforced by a wider such belief among
the public).12 But such arguments fail to address the
ways in which the dog is, in effect, a technology of
state power. A series of case laws across the Western
world challenging the use of sniffer dogs reinforces
this point. In New South Wales, the Council for Civil
Liberties (CCL) challenged the use of police dogs
through the case of a person stopped by a plain-clothes
police ofcer who had been working with a dog near a
nightclub. As the defendant walked by, the dog sniffed
the air, ared its nostrils and then started snifng the
defendant. The police ofcer’s search of the defendant
then found cannabis. The CCL claimed that the use of
dogs in such a way amounted to an illegal search, but
the NSW Supreme Court held that the use of the dog
was not unlawful. The basis of the judgment was that
‘a police ofcer would have been entitled to walk in

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the vicinity of the appellant and, if he were to smell
cannabis leaf in the appellant’s possession, form a
reasonable suspicion sufcient to entitle him to search
the appellant.’ The fact that a dog was being used to
do this did not change the situation. In other words, as
the Supreme Court made clear, it was ‘treating a drug
detection dog as an extension of the police ofcer, an
aid to his olfactory senses’.13 More or less the same
legal interpretation applies in all Western societies, as
Amber Marks research suggests.14 Thus, legally, the
dog is an extension of the police ofcer. If the police
ofcer is the long arm of the law, the police dog is the
nose of the state.
Note, however, that in contrast to the occasional use
of smell by a police ofcer, dogs are always already
snifng something. In stark contrast to police ofcers
and their far more limited olfactory powers having to
deliberately move in close to check a smell, the police
dog is permanently snifng, and permanently snifng
a far wider area than might be sniffed by the human
police gure. That is, this extension of police power
means that when a dog is in the vicinity, a permanent
and sweeping olfactory search of a wide and inden-
able space is taking place. The presence of the dog
means the state is engaged in a de facto search of an
indenable area and persons in the vicinity, creating
the grounds for a de jure stop and search. A critical
analysis of the sniffer dog, then, must deal with the
nature of ‘stop and search’; and this has to be under-
stood not in terms of surveillance or civil liberties,
but in terms of the violence of original accumulation.
Suspicion, possession, oppression
Writing about original accumulation in Capital, Marx
outlines what he calls the ‘police methods’ used from
the early sixteenth century to accelerate the accumula-
tion of capital.
Henry VIII, 1530: Beggars who are old and in-
capable of working receive a beggar’s licence. On
the other hand, whipping and imprisonment for
sturdy vagabonds. They are to be tied to the cart-
tail and whipped until the blood streams from their
bodies, that they are to swear on oath to go back to
their birthplace or to where they have lived the last
three years and to ‘put themselves to work’…
James I: Anyone wandering about and begging
is declared a rogue and a vagabond. Justices of
the peace in Petty Sessions are authorized to have
them publicly whipped and to imprison them for six
months for the rst offence.
And on it goes through a series of ‘terroristic laws’
(his term again) perfected through four centuries of
capitalist development, through which the masterless
men and women of the displaced peasantry were
whipped into shape as the working class and bourgeois
order was fabricated.
The laws in question were the various Vagrancy
Acts passed throughout the Western world. One of the
features of such laws was their vague and incredibly
broad scope, as they formed an all-encompassing
discretionary power which could be used more or less
at will by agents of the state. They allowed individuals
to be stopped and searched purely on the grounds of
suspicion; they were, in effect, the original ‘sus’ laws.
The Vagrancy Act of 1824, for example, provided for
‘the Punishment of idle and disorderly Persons, and
Rogues and Vagabonds’. It was this Act which con-
stituted the core police power exercised by the ‘new’
British police created in 1829 (and which explains why
the Act creating the ‘new police’ was so thin: because
the powers that were to be exercised by the new police
already existed in the Vagrancy Act). The powers
in question were consolidated with the Metropolitan
Police Act 1839, which allowed the police to stop and
search ‘any Person who may be reasonably suspected
of having or conveying in any Manner anything stolen
or unlawfully obtained’.
The ambiguity built into the laws and the breadth of
powers they offered means that they were ‘sweep laws’:
they allowed individuals to be stopped on the grounds
merely of suspicion, and even perhaps on the grounds
of suspected criminal intent. Hence a huge range of
acts or non-acts, forms of behaviour and inactivity,
fell foul of the laws, such that a ‘sweep’ of any area
would easily nd guilty parties. In granting sweeping
powers to target anything considered ‘disorderly’ or
‘suspicious’, the determining principle underpinning
the vagrancy laws was not the liberty of the subject but
the well-ordered society. Once we grasp that policing
is about the fabrication of social order rather than ‘law
enforcement’, the vagrancy laws can be seen as the
police power par excellence; which is to say, they were
a fundamental weapon in the class war.
Much as the heyday of vagrancy laws was the
sixteenth through to the nineteenth century, the laws
themselves remained in place until the second half of
the twentieth century, at which point their vagueness,
their criminalization of status without any particular
criminal act being committed, and their overt class
and race bias, came to be seen as problematic. Symp-
tomatically, however, their abolition coincides with
the birth of the quintessential social wars of the late
twentieth century: the wars on drugs and crime. The
key operative law in these wars has been the law of

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possession. In such laws, possession qua possession
becomes the crime itself, or can be used as evidence
of intent to commit a crime. And so the law on posses-
sion has become what Markus Dubber calls the sweep
offence of choice in modern policing, being used in
exactly the same manner as the original vagrancy
laws.15
In offering sweeping powers, ‘possession’ shares
the central advantages of ‘vagrancy’ as a policing
tool: it is exible and convenient, it relies heavily on
the idea of suspicion, it panders to the law’s belief that
intent can be identied, and it continues the state’s
declared mandate to determine what constitutes a
public threat and eliminate it accordingly. Moreover,
in being focused on possession rather than vagrancy,
possession law not only expands the scope of police
powers into the home, thereby exploding the liberal
myth of privacy, but also functions in a way that
means millions of people commit some form of crime
every day or could be suspected of being about to
commit a crime. They often don’t know this, until
stopped and searched by a police ofcer after having
been ‘detected’ as possibly possessing something sus-
picious. The list of items for which people have been
found in possession is almost endless: drugs, drug
paraphernalia, rearms and other weapons are obvious
candidates for such a list. But it would also include
imitation weapons, toy weapons, air pistols and ries,
any implement or instrument that might be used as
a weapon, ammunition, body vests, equipment that
might be used in burglary, stolen property, instruments
that might be used for grafti, counterfeit trademarks,
unauthorized recordings of performances, public
benet cards, forgery devices, embossing machines,
vehicle identication numbers, prison contraband,
obscene material, eavesdropping devices, reworks,
noxious materials, slugs, and on it goes, right down
to items deemed by the police to constitute a threat
to ‘security’. This list of items, compiled by Dubber
from possession cases in just one US state, New York,
could be extended to include those people held for
possessing spearshing equipment (in Florida) and
undersized catsh (in Louisiana).
Now, the extent to which this police power perme-
ates the social world can be seen in the fact that many
possession offences begin with a simple trafc stop,
a salutary reminder that trafc police are never just
policing trafc. But it can also be seen in the fact
that many possession offences start from the nose of
a sniffer dog. The main law brought into action when
sniffer dogs are thought to detect anything is the law
on possession. Because of the more or less permanent
‘sweep’ mode that comes from the dogs snifng every-
thing and anything that passes by them or even near
them, the ‘sniff’ very easily generates ‘reasonable
grounds’ for an ofcer to stop and search; the sniff
produces the suspect. The mythical reliability of the
dog means that the initial sniff is virtually unchal-
lengeable in the courts and thus the police ofcer has
very simple and universal grounds for stopping and
searching.
Note, however, that most uses of stop-and-search
powers actually reveal very little ‘crime’, in the sense
of leading to formal arrests and prosecutions. What
stop-and-search powers do, rather, is open the pos-
sibility for the police to impose their authority as
state ofcials on individuals and groups considered
problematic, threatening, or, in the terms of that key
concept of police power, ‘disorderly’. The sniffer dog
plays a crucial role in this process, thereby drastically
extending the sensory reach of the technology of the
state.
This is what explains the increased presence of
dogs in public spaces since 2001, but also throughout
the disciplinary apparatus of the modern state, in
institutions such as schools, prisons and mental health
institutions (visits to which are sold to us as exercises
in ‘community policing’ but which are designed to
nurture greater social acceptance of the dogs and to
carry out searches – de facto and thus de jure – while
on the premises). The inection of the war on vagrancy
(that is, the class war) into the war on drugs, the war
on drugs into the war on crime, and the war on crime

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into the war on terror, and then the war on terror back
into the wars on drugs and crime, is a mechanism
for articulating the enemy as existing anywhere and
everywhere in a way that requires police inltration
of all space. The power of smell plays a crucial role
in this inltration. In the endless warfare of contempo-
rary political order in which the complicated cultural
practices surrounding drugs, the social dynamics sur-
rounding crime and the political tactics surrounding
terrorism are reduced to an amorphous and ubiquitous
‘enemy’ of good order, police discretion becomes a
key to victory. And in this war, the sniffer dog is in
the front line.
Yet one of the crucial features of this war is pre-
cisely that there is no front line in the traditional
military sense of the term. This is why so much effort
is being made to mechanize the sniffer dog. Much is
made in the media of such new technologies: from
the CIA’s original attempt to create a ‘mechanical
dog’ (which, ‘when he is born’, the CIA report notes,
‘should be much more unobtrusive than his natural
ancestor, should be able to tell us just whom he has
smelled, and should maintain a reliable permanent
record of his visitors’); DARPA’s spending in excess
of $3 million a year since 2001 developing an E-Nose;
the Commonwealth Scientic and Industrial Research
Organization’s ‘cybernose project’ (tagline: ‘snifng
a better future with Cybernose’), which prioritizes
cheese, wine and biosecurity; the new ashlight called
the Passive Alcohol Sensor, which contains a new
smell detection technology (‘the sniffer’, as the police
call it, ‘an extension of the police ofcer’s nose’);
right down to a new sensor called Scentinel to identity
individual body odours, developed by a UK company
called Mastiff Electronic Systems (note the dog ref-
erence in the name). Many of these developments
imagine the technological sniffer as electronic ling
system as well as the detector of the initial informa-
tion, and reconnect the politics of olfaction back to the
question of identication. But, as I have been arguing,
the real political issue is not the smell of identication;
it is how the smell of power functions in terms of the
fabrication of order.
Thus far more telling is the attempt to develop
technology that reinforces the obliteration of any front
line in the new universal war: the ‘sniffer helicopter’.
By radically extending the potential area to be sniffed,
this technology makes possible a signicant shift in the
policing of territory, extending the powers of olfaction
from individual ofcers and their dogs in a relatively
small amount of space to a much wider ground. If
successful, such mechanization will overcome the
limitations imposed on the state’s use of real dogs
– the training, maintenance and handling are expen-
sive, time-consuming and cumbersome – and will be
another tool in the technological armoury of the state.
This move, from ‘canine cop’ to ‘techno cop’, will be
one more step towards realizing the state’s dream of
exercising a permanent and ubiquitous police power to
obliterate anything regarded as disorderly.
Notes
1. Gary T. Marx, ‘What’s New about the “New Surveil-
lance”: Classifying for Change and Continuity’, Surveil-
lance and Society, vol. 1, no. 1, 2002, pp. 9–29; p. 16.
2. David Lyon, ‘Under My Skin: From Identication Pa-
pers to Body Surveillance’, in Jane Caplan and John
Torpey, eds, Documenting Individual Identity: State
Practices in the Modern World, Princeton University
Press, Princeton NJ, 2001, p. 300.
3. F. Gonzalez-Crussi, The Five Senses, Vintage, New
York, 1991, pp. 65, 71.
4. Constance Classen, David Howes and Anthony Syn-
nott, Aroma: The Cultural History of Smell, Routledge,
London, 1994, p. 161.
5. Alain Corbin, The Foul and the Fragrant, Paper mac,
London, 1996, p. 187; Simon A. Cole, Suspect Identities:
A History of Fingerprinting and Criminal Identica-
tion, Harvard University Press, Cambridge MA, 2002,
p. 12.
6. Anna Funder, Stasiland: Stories from Behind the Berlin
Wall, Granta, London, 2003, p. 8.
7. Cited in Erik Kirschbaum, ‘Germans Outraged by
“Scent Proling” Ahead of G8’, Reuters, 23 May 2007.
8. ‘Detecting Sweaty, Smelly Security Threats’, 27 April,
2010, www.information-awareness-ofce.org/IAO___
DAR PA _ N EWS _ PAGE 2.html.
9. Spencer Tebrich, Human Scent and Its Detection, CIA
Historical Review Program (n.d., originally for ofcial
use only, released 22 September 1993 – the release date
suggests that the document was produced in 1963); De-
partment of Homeland Security, Five Year Research and
Development Plan, August 2008; ‘Second Memoran-
dum from the Ministry of Defence’, to the House of
Commons Select Committee on Defence, 29 September
2006.
10. John Hind, ‘You Are Being Sniffed: Why Dogs Are the
Public Face of the War on Terror’, Observer, 5 March
2006.
11. Anthony Synnott, The Body Social: Symbolism, Self,
and Society, Routledge, London, 1993, p. 190.
12. See, for example, New South Wales Council for Civil
Liberties, Review of the Police Powers (Drugs Detection
Dogs) Act, August 2004, p. 4; David Grainger, ‘Sit! Stay!
Te s ti fy! ’, Fortune Magazine, vol. 149, no. 2, 26 January
2004.
13. Darby v. Director of Public Prosecutions, NSWCA 431
(26 November 2004), para. 62.
14. Amber Marks, ‘Drug Detection Dogs and the Growth
of Olfactory Surveillance: Beyond the Rule of Law?’,
Surveillance and Society, vol. 4, no. 3, 2007, pp. 257–71.
15. Markus Dirk Dubber, ‘Policing Possession: The War
on Crime and the End of Criminal Law’, Journal of
Criminal Law and Criminology, vol. 91, no. 4, 2001, pp.
829–996.