EGSC - I take your point and accept it. To make it perfectly clear a Pan or Mayday should be made. But if it isn't, and clearly there is a reluctance some times for these to be made (don't ask me why), and an ATCO has ignored a statement that an aircraft is short of fuel - IF something nasty happens, I would expect the ATCO to be one of the defendants. That is just the way things are these days, and it would probably be a good idea to wise up and not rely on some CAA position statement