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Boris Johnson's standards adviser says there is a "legitimate question" over whether the PM broke the ministerial code after getting fined for Partygate.
Lord Geidt said he repeatedly told the PM's team to be ready to explain if his actions stuck within the rules - even if he thought there was no breach.
But he said the advice had not been "heeded", calling on Mr Johnson to set out his case to the public.
In response, the prime minister insisted he had not broken the code.
Writing to Lord Geidt, Mr Johnson said had considered former minister's action when they "unwittingly breached regulations", and he said he had been "fully accountable to Parliament and the British people".
The ministerial code outlines the rules government ministers must follow when in office, including the "overarching duty" of ministers to comply with the law.
If the code is broken, the convention in Westminster is for a minister to resign.
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