According to this article cases of poisoning of Scottish birds of prey at are the highest level for 20 years. This is despite efforts by the Scottish government to tackle wildlife crime. Conservationists are calling for tougher laws to help combat wildlife crime after the RSPB revealed a record number of poisoning cases against birds such as golden eagles and red kites last year. One idea is to make grouse moor owners legally responsible for attacks on birds of prey that happen on their estates. There were 46 proven poisoning incidents last year including the deaths of two golden eagles, four red kites, 21 buzzards and a sea eagle. The problem is caused by some gamekeepers targeting birds of prey because they eat game birds kept for private shooting.