The first volume of the Gomery Report, released on November 1, 2005, cleared Martin of any wrongdoing while placing blame for the scandal on Chrétien. However, many have criticized the Gomery Inquiry as not having the scope to assign criminal responsibility for the Scandal or to investigate Martin's role, and indeed some have accused Martin of purposely "tying Gomery's hands." While the Gomery Report: Phase 1 exonerated Martin from responsibility and liability for the misspending of public funds, Chrétien has decided to take an action in Federal Court to review the commission report on the grounds that Gomery showed a "reasonable apprehension of bias", and that some conclusions didn't have an "evidentiary" basis.