A fourth and last group of articles pertains to judicial issues. Article 107 is the "codification article". It imposes that that private law, penal law and the separate procedural laws covering these subjects must indeed be formal law and treated in a general Civil Code and a Penal Code, although certain subject might be covered by special laws. Delegation is allowed but doctrine holds that criminal law (which is seen as a more limited field than general penal law) must be determined by formal law only. This means provinces and municipalities cannot create their own criminal codes and government cannot make a certain act a crime by a Royal Decree not based on formal law. As the administrative law of the Netherlands is so complex, it was deemed impossible to incorporate it in a single code, but its general rules must be covered in a general code (Subarticle 2) as has indeed gradually been done since the nineties, be it with great difficulty. Article 108 (investigative bodies for civil complaints) has been abrogated in 1999. Article 109 states that the position of civil servants, including their protection and workers' participation must be determined by law. This has as yet not been done in any general way. Doctrine holds that civil servants enjoy full protection by constitutional basic rights. Article 110 imposes a duty upon government to safeguard by formal law sufficient public access to information regarding governmental activities. Delegation is allowed. The government does not see this as some general "right to public access to information" and this has been the reason not to insert it into Chapter 1, but this interpretation is quite popular in doctrine as the right does even more resemble a freedom right than a social right.