Official hearing page

24 January 2024 – Raymond Grant

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(10.00 am)

Mr Beer: Good morning, sir, can you see and hear us?

Sir Wyn Williams: Yes, thank you very much.

Mr Beer: Thank you. May I call Raymond Grant, please.

Sir Wyn Williams: Of course.

Raymond Grant


Questioned by Mr Beer

Mr Beer: Good morning, Mr Grant, my name is Jason Beer and I ask questions on behalf of the Inquiry. Can you give us your full name, please?

Raymond Grant: Raymond Grant.

Mr Beer: In front of you there is a witness statement. It’s two and a bit pages long, and it’s dated 3 January 2024. The Inquiry’s URN for that is WITN10540100. It needn’t be displayed.

Can you turn to the third page of it, please?

Raymond Grant: Yes.

Mr Beer: Is that your signature?

Raymond Grant: Yes, it is, yes.

Mr Beer: Are the contents of the witness statement true to the best of your knowledge and belief?

Raymond Grant: Yes.

Mr Beer: Why is your witness statement so short?

Raymond Grant: I received the bundle of papers on 5 December last year. My current role is I work in a homeless centre for a Christian organisation. It has 30 residents in it. I am the programme manager in that unit. My job is to ensure that these residents get the level of respect and dignity that they deserve. Part of the role is to ensure that at that time of the year, December, in the Christian calendar, there are a lot of activities going on: carol services, Christmas dinners, various other bits and pieces.

We were, at that point, five members of staff short. I was working somewhere in the region of 10 to 11-hour days. I was going home, walking my dog and, at the same time, the home where I was living, I was asked to vacate it by the 31 December, and so I was in the process of trying to purchase a property, view a property, deal with conveyancing issues, dealing with mortgage arrangements. So there was a clear clash of priorities, as far as I was concerned.

I chose my current job as being the most important, as it directly affected 20 members of staff and 29 homeless residents. I fully understand my obligations to this important Post Office Horizon IT Inquiry. However, my time was limited, for all the things that I’ve said previously.

I managed to negotiate an extra month on my rented property and I have to be out of that by the 31st. So I was contacted by one of the senior lawyers involved in the Inquiry by telephone and explained that to that person. Following what I would describe as their priorities being different from mine, in reading, digesting, understanding an inordinate amount of documents, 450 at that time, subsequently another 350 on top of that –

Mr Beer: When you say “documents”, do you mean pages?

Raymond Grant: Yes, pages, sorry, yes, I beg your pardon – and then having to prepare a detailed statement from my memory from my time of employment, which was 16 years ago, to any involvement in any Post Office investigation. Some of the documents I was asked to review did not even exist at the time of my departure from Post Office Limited. I received a second call some days later advising that I had to complete the task and submit my draft statement by 2 January 2024.

I explained again to the caller it was not physically possible for me to devote my personal time to answer all the questions required. They pointed out to me that failure to do so, I would potentially be breaking the law and I had to comply.

Again, I stated all the priorities that I had going on but my pleadings were going on deaf ears. I explained about me moving home and the caller asked if I should – that I should provide details of my conveyancing lawyer so it could be checked up on.

Mr Beer: So, in short, it was a clash of priorities?

Raymond Grant: Yes, I’m just getting to it, if you allow me, I’ve just got one –

Mr Beer: There’s more?

Raymond Grant: Just one more thing, if you don’t mind. Thank you.

The next level of communication I had was that Sheriff Officers appeared at my door and issued me with the a Section 21 Notice to say that I had to comply and be here today.

Mr Beer: That’s right, you’re here under the threat of the exercise of compulsory powers. We had to serve a Section 21 notice to get you here.

Raymond Grant: Yeah, I agree with that. That kind of focused me and, in my time, I then was able to – my first day off during that was 1 January, following a 10-hour night shift during New Year’s Eve and New Year’s morning. That was when I drafted this minimum statement to comply with the Section 21 order. I apologise to the court but, for all the reasons I’ve said, that’s the reason why it’s such a short statement.

Mr Beer: Well, let’s see if we can improve on it today, now that carol services and dog walking are out of the way.

We asked you as the first question to address, “please set out the date on which you began work at the Post Office”, and you didn’t address it.

Raymond Grant: No.

Mr Beer: When did you start to work at the Post Office?

Raymond Grant: Since I drafted this statement, I’ve sort of tried to think back. I think – I started with Royal Mail as a postman in 1982 and, from there, I’ve held a number of positions, if you allow me just a second. I was postman for a number of years, then I went to postman higher grade, got the role as duty clerk in the office. I then became an Assistant Delivery Office Manager, 140 staff, and there was only two managers. I then got a role as a Royal Mail Investigation Manager. Don’t ask me years or when that happened because I have no conscious memory of that. I then transferred over to Post Office Investigations, I had various job titles after that –

Mr Beer: Is there any point in me asking you when that was?

Raymond Grant: No.

Mr Beer: Thank you. Please move on.

Raymond Grant: The Security Investigation Manager, our titles changed, Security Manager then became a Fraud Advisor all with Post Office Limited.

Mr Beer: One of the documents that we provided you with, in order to help you make your witness statement, was a witness statement that you had made in the investigation of William Quarm, back in 2008. Can we just look at that, please: POL00166685.

Can you see this is your witness statement? It doesn’t actually bear a date but, from the context, it relates to events that have happened in 2008 and appears obviously to have been made before you left the Post Office. So I’m going to suggest that it’s 2008 as a date.

If we look at the first paragraph there, you say:

“I have been employed by Royal Mail Group in various roles for around 26 years. My current position [is] Investigation Manager.”

You explain what one of the main roles of an Investigation Manager was.

So, if this is right, you’ve been working for the Royal Mail Group for 26 years, so around 1982, which is as you’ve told us today.

Raymond Grant: That’s correct.

Mr Beer: Is there any reason why you couldn’t have just said that in the witness statement?

Raymond Grant: At that point I hadn’t read that document because, as I said earlier, I was finding time constraints were very difficult for me to read any of the documents that I’d been sent.

Mr Beer: The 78 documents that we sent you, the 350-odd pages, you don’t refer to any of them in your witness statement, apart from the transcript of Mr William Quarm’s interview, do you?

Raymond Grant: That’s correct.

Mr Beer: Why was that? Why did you pick Mr Quarm’s interview as the one document that you did refer to?

Raymond Grant: Well, this Inquiry is about the degree of fairness that was applied to postmasters during the course of investigations and the subsequent prosecution of them. I was reminding myself what had been said during that interview, and it was the one thing that I believe that I had a major part in because I was the Lead Investigator in that interview, so, therefore, I thought it was important to refresh myself.

Mr Beer: The fact that you didn’t look at or refer to the other 77 documents, that was because of the competing priorities on your time; is that right?

Raymond Grant: That’s correct.

Mr Beer: When you made the witness statement, did you think that Mr Quarm continued to be guilty of the crime of embezzlement?

Raymond Grant: This witness statement here today?

Mr Beer: Yes.

Raymond Grant: Yes, I did.

Mr Beer: Does that remain your view?

Raymond Grant: I’ve subsequently been advised that the verdict has been reversed, so he is now not guilty of the offence.

Mr Beer: I’m talking about in your mind?

Raymond Grant: In my mind, I still think that Mr Quarm had a role to play in the loss of the money.

Mr Beer: That’s an answer to a different question. The question would be: did Mr Quarm have a role to play in the events?

The question I, in fact, asked was: do you think, do you remain of the view that he’s guilty of the crime?

Raymond Grant: Yes, I do.

Mr Beer: Despite the verdict of the High Court of Justiciary in Scotland?

Raymond Grant: Yes.

Mr Beer: Was that amongst the reasons that you didn’t regard this Inquiry as a priority?

Raymond Grant: No.

Mr Beer: You haven’t said that to any of the solicitors in the Inquiry before, “Mr Quarm was guilty, I don’t know why you’re asking me questions about this”?

Raymond Grant: If I’ve said that, then that would be my view at that time, yes.

Mr Beer: “It may be a priority for you investigating but it’s not a priority or me.”

They would accord with your sentiments, wouldn’t they?

Raymond Grant: Well, I think you’re mixing up the priority. I’m talking about the priorities that I had in my personal role 16 years on from being a Post Office Investigator, working for another organisation, who pay me my salary. There was nobody paying me the salary to do the work that we’re here talking about today. I was being asked to do that in my own personal time. My personal time was being used up for my personal reasons that I’ve already explained. I do not think that it was a fair thing to ask me to do in such a short space of time, considering that this Inquiry has been going on for a number of months and years and Phase 4, certainly, since, I believe, October.

That – for me to get that in a space of 26 days to review and take cognisance of all the facts that had been presented to me and to make comment on them, as I said, some of the documents that were contained within there I subsequently found out that they did not apply to me because they weren’t published until after I’d left the business.

Mr Beer: You say in your witness statement to the Inquiry that you recall nothing at all and, essentially, none of the documents that we sent to you help you in any way; is that correct?

Raymond Grant: At that time I wrote that statement, that is correct.

Mr Beer: Is it still correct that none of the documents we sent to you help you to recall matters in any way?

Raymond Grant: Since then, I’ve had a bit of time. I was actually off sick last week, I spent some time in my sickbed reading up some of these things to prepare for today. There’s some that I still don’t recognise, still I don’t recall but, in general terms, I’ve done a bit of research since, in my own personal time, I hasten to add, I’m not employed by the Post Office any more.

My employer is the Salvation Army. They require me – there are occasions when I’m on call and I have to be on call, so, in reality, it’s, again it’s about priorities. I recognise the seriousness of this Inquiry and I understand why it’s being done but to ask a layperson, which is what I am right now, these facts and figures, documents, to recall 16 years ago, I find that very difficult.

Mr Beer: If we just look at your witness statement, WITN10540100 and look at the bottom of page 2, please, at paragraph 7. Having referred to the transcript, you say:

“In addition to this and in answer to all the other subsequent information you have requested from me, I can say quite clearly that I have no recollection nor knowledge nor any details of any documents that will assist me to answer the collection of questions you raise in your requests.”

Had you actually read any of the documents when you said that?

Raymond Grant: I glanced over them.

Mr Beer: So you were saying that none of the documents will help you, even though you hadn’t read them?

Raymond Grant: Well, as I said, my priorities was not to read all that information. As you say, what was it, 78 documents were sent to me, it’s actually 450 pages of information, and for me to spend my time, when I had other things that were more pressing for me to deal with, I wrote this statement on 1 January. It had to be in by 2 January. So, in that space of time, it was my one day off that I had in the time allotted to provide this witness statement, so I gave it my best shot. What I’ve written down here is what I was dealing with at the time.

Mr Beer: When did you leave the Post Office?

Raymond Grant: It was somewhere early 2009.

Mr Beer: Do you hold any qualifications that are relevant to conducting criminal investigations into allegations of embezzlement, fraud, false accounting or theft?

Raymond Grant: When you say qualifications, I was, in my early days, as a Royal Mail Investigator, I was assigned to Post Office Investigations branch.

Mr Beer: I’m going to ask you about your experience in a moment and your training in a moment. At the moment, I’m just asking about formal qualifications?

Raymond Grant: I do not have any formal legal qualifications, no.

Mr Beer: When you became an Investigation Manager employed by Post Office Limited, what was your previous experience of conducting investigations; how long had you been doing that for Royal Mail Group before then?

Raymond Grant: I think it’s around five years.

Mr Beer: Can you help us as to roughly when you became an Investigation Manager for Post Office Limited?

Raymond Grant: I think that’s probably around five years as well.

Mr Beer: So about 2003/4?

Raymond Grant: Yeah, around that time, yes.

Mr Beer: When you were an Investigation Manager for Post Office Limited, where were you based?

Raymond Grant: I had an office in the Royal Mail Depot at Perth, at 53 Feus Road in Perth.

Mr Beer: Was that for the entirety of the period?

Raymond Grant: Yes.

Mr Beer: Was it an office-based job, ie that was your base to which you would return?

Raymond Grant: Yes, it was shared with the Royal Mail Investigation Team. We had the upper floor of a building in that yard.

Mr Beer: Were you part of a Post Office Limited Investigation Team?

Raymond Grant: Yes.

Mr Beer: How many people were in the Post Office Limited Investigation Team at that time?

Raymond Grant: When I commenced?

Mr Beer: Yes.

Raymond Grant: Based in Scotland?

Mr Beer: Yes.

Raymond Grant: On the investigation side, I think it was four Investigators and a Team Leader.

Mr Beer: The Senior Investigator, was he or she your line manager?

Raymond Grant: Yes.

Mr Beer: Do you recall who that was?

Raymond Grant: In that short period of time of five years, I had six different line managers.

Mr Beer: Were they based in Perth too?

Raymond Grant: No.

Mr Beer: Where were they based?

Raymond Grant: One was based in Glasgow, the other five were south of the border in England.

Mr Beer: When you were working for Post Office Limited, what did your role as an Investigation Manager consist of?

Raymond Grant: I was required to conduct any business which may be related to suspected criminal activity against Post Office Limited.

Mr Beer: Investigations of the type we’re going to look into –

Raymond Grant: Yes.

Mr Beer: – namely alleged conduct by subpostmasters involving the financial affairs of the Post Office that they were running, what proportion of your work involved that kind of investigation?

Raymond Grant: You’re quite right, there were various other activities that we would do for external agencies who were committing fraud against the Post Office. But, in real terms, I would say – suggest 65, 70 per cent of the – there was the kind of activity that we’re going to be discussing, in relation to audit shortages.

Mr Beer: When you joined Post Office Limited, did you receive any initial training in the conduct of such investigations?

Raymond Grant: Yeah, well, I was carrying over five-years’ experience from Royal Mail. The laws were the same, the different aspect of it was, instead of investigating crimes against Royal Mail, it was investigating crimes against Post Office Limited. So I had a very good mentor, a man called Peter Webb, who took me under his wing. He took me out on several inquiries before he allowed me to be a Lead Investigator.

Mr Beer: That was in Royal Mail Group?

Raymond Grant: No, sorry, this was in Post Office Limited.

Mr Beer: So there was some on-the-job work shadowing; is that right?

Raymond Grant: Absolutely, yes.

Mr Beer: Was there any formal training?

Raymond Grant: Yes, there was.

Mr Beer: What was the formal training in Post Office Limited?

Raymond Grant: Wasn’t on Horizon training, when it was introduced.

Mr Beer: That must have been when you were in the Royal Mail Group Investigation Department.

Raymond Grant: Oh, sorry, when I was introduced to it, I beg your pardon, that was a play on words there. When I was introduced to Post Office Limited I was asked to go into a Crown Office and work shadow some people in there.

Mr Beer: How long did that training on the Horizon system last?

Raymond Grant: I think it was two to three days.

Mr Beer: What did the training consist of?

Raymond Grant: It was watching people serve and watching how they balanced, what kind of reports the Horizon system could produce and how to – if there was an anomaly at the end of the day, where the balance was out, how to carry out the checks prior to any dockets or any counterfoils – before they left the office, to carry out the investigation prior to any of that left the building, so that the counter clerk had to balance at the end of the day.

Mr Beer: That was in a Crown Office?

Raymond Grant: Yes.

Mr Beer: How many counters were there in that Crown Office; can you remember?

Raymond Grant: In Perth Crown Office at that time, I think it was seven.

Mr Beer: Did you receive any training about the work of or role of a subpostmaster in a sub office?

Raymond Grant: Yes. Mr Webb was very good because he had some postmasters with whom he had associated himself with in the past and he took me round and we visited a few post offices, he introduced me to the postmaster, and we had conversations about what went on in that particular office. Because not every post office sold the same products. There were some specialist products that some post offices had that others did not.

Mr Beer: Did you receive any training on the analysis of data produced by the Horizon system?

Raymond Grant: I believe I did. I – do you mean ARQs?

Mr Beer: I’m deliberately asking an open question; I didn’t mean anything in specific terms yet.

Raymond Grant: Right, okay. So if we’re talking about analysis of the Horizon system, it’s a computer, it’s factually based. If you put in figures and you produce dockets, at the end of the day, it should balance. If it doesn’t balance, then you carry out an investigation yourself. The counter clerk should do that or a subpostmaster should do that on a daily basis.

Mr Beer: Did you receive any training as to the sources of data or the varieties of data that could be produced by the Horizon system –

Raymond Grant: Yeah –

Mr Beer: – in the event of the need to investigate the conduct of a subpostmaster or a counter clerk?

Raymond Grant: Yes, there were various avenues we could go. There was a Horizon System Helpdesk where we could gain reports, if necessary. There was a National Business Centre who took calls from postmasters –

Mr Beer: So the HSH, the NBSC?

Raymond Grant: – yes, and, if required, we could go to – we could go via our Casework Team down in Croydon and ask them if they could request from Fujitsu ARQs.

Mr Beer: How did you go about that then? What did the process involve with the Casework Team in Croydon?

Raymond Grant: Well, we would – there would be a discussion with my line manager. The discussion would then – he’d say, “Yeah, action that”.

Mr Beer: Why would there need to be a discussion with the line manager?

Raymond Grant: It’s to check understanding that I’m going down the right road and I’m not wasting resource that might not be necessary. So it would be to have an overview of the case, to see if that would be a good thing to do.

Mr Beer: Was that almost a standing instruction, that, before you made a request for Horizon data, it had to be discussed with or cleared by your line manager?

Raymond Grant: No, that was my way of dealing with it.

Mr Beer: Right. It wasn’t something that was imposed on you; it was just your way of working?

Raymond Grant: Yeah, it was my way of working, yeah.

Mr Beer: So you would discuss any request for Horizon data with your line manager?

Raymond Grant: Yes.

Mr Beer: Yes, you were telling us, you said there was HSH information available, NBSC information available –

Raymond Grant: Yes.

Mr Beer: – and you were telling us about getting data from Fujitsu via the Casework Team in Croydon?

Raymond Grant: Yes.

Mr Beer: Would you fill out a form to do that?

Raymond Grant: It would be in the form of an email, I believe, if my recollection is right. I can’t remember ever filling in a form before.

Mr Beer: Okay. The email would be sent to the Croydon team?

Raymond Grant: Yes, it would be to a chap called Graham Ward.

Mr Beer: Yes, who we’re going to be hearing from next week.

Raymond Grant: Oh, right, good.

Mr Beer: What would determine in your mind whether it was necessary to request data from Fujitsu?

Raymond Grant: If there was a – you see, the ARQ provides more than – it will tell you who was on a stock unit, what they did on that stock unit, what product was being sold at the time. So it can prove or disprove information that could be relevant to you as an individual, as an Investigator.

It can rule people out of the inquiry because – I can recall one particular case, it was at another Crown Office, where it was a busy Crown Office in Edinburgh, and we were trying to establish who was in the building at the time, and who was logged on to the system at the time of whatever event that was. I can’t remember what the event was.

So we requested the data to see who was actually logged on to the system and what stock units were open at the time a transaction had taken place. We were able to identify all the people who were there and logged in. Now, that’s taking into account that they were logged in under their own passwords, with their own usernames, because the system can be manipulated if people share passwords or share usernames.

Mr Beer: Other than in a case like that where you’ve got potential multiple suspects and you need the ARQ to see who was logged on for the relevant transactions –

Raymond Grant: Yeah.

Mr Beer: – what would determine and whether when you would seek ARQ data? So say a single postmaster in a branch office –

Raymond Grant: Um …

Mr Beer: – what would be the trigger?

Raymond Grant: I suppose, if there was a dispute over a transaction or even if I just wanted clarity within myself to check up on what was being said was accurate.

Mr Beer: Said by who?

Raymond Grant: Sorry?

Mr Beer: Said by who? Yes, you wanted to check up if what was being said was accurate: said by who?

Raymond Grant: Yes, if the person who was being interviewed for the criminal – potential criminal activity had mentioned something that required to be corroborated, as it were, as we use in Scotland, so there was – if that was needed to be done, then there were every possibility where I would have requested ARQ data for that type of event.

Mr Beer: Did you ever regard the ARQ data as being a necessary element of your case, in every case of proposed prosecution of a subpostmaster, because it was the data necessary to prove the loss?

Raymond Grant: No.

Mr Beer: What else was sufficient in your mind to prove the loss?

Raymond Grant: We’re going to come on to the Paible case just in a second but, if during the course of the Inquiry, there was a suspicion that something had a – a fictitious transaction had gone through, that would have required a document to be sent to an agency. There’s a possibility, by approaching that agency for the particular to docket to support the transaction, we would have been able to recover that, maybe not in its actual original content, but a facsimile copy because a lot of businesses, when they receive all these pieces of paper, they immediately just photocopy them and, if you asked them to provide it, that’s in the form it would come – it would come back in the form of a facsimile of the original document, which is not best evidence but is the best that is available.

Mr Beer: In your role as Investigation Manager, did you undertake any training specifically about duties of disclosure of information and evidence?

Raymond Grant: It would have been covered in my training, yes.

Mr Beer: Which training?

Raymond Grant: Royal Mail training because that was my original role for five years.

Mr Beer: What, therefore, by the time you got to the Post Office role in 2003/4, did you understand your duty of disclosure or revelation to entail?

Raymond Grant: Yeah, if I was the Investigation Manager and – my understanding is that my role as Disclosure – if I was there the appointed Disclosure Officer, if it was a complex inquiry, there was a possibility that a separate Disclosure Officer would be appointed but, in normal circumstances, in normal investigations, the Investigation Manager would also became the disclosure person.

Mr Beer: Yes, so that’s about the role. Sometimes in the less complex investigations you would double hat –

Raymond Grant: Yes.

Mr Beer: – is that right?

Raymond Grant: Yes, that’s correct.

Mr Beer: Okay and what did you understand your duties as Disclosure Officer to entail?

Raymond Grant: To disclosure all material where it showed bias towards the offender or bias for the offender. It was to make sure that all the documents that were available were –

Mr Beer: The “offender”: do you mean the suspect?

Raymond Grant: Sorry.

Mr Beer: Because it’s assuming a bit too much, isn’t it?

Raymond Grant: It’s been a long time, Mr Beer. Sorry.

Mr Beer: So whether it pointed towards or away –

Raymond Grant: Yes.

Mr Beer: – from the guilt of the suspect?

Raymond Grant: Yes.

Mr Beer: How did you go about giving such disclosure in a case that was to be prosecuted in Scotland?

Raymond Grant: It would be in the form of a production document, where all the documents would be listed that had been used in the course of the investigation, ensuring that all documents, whether used or not in the actual report, so that when the Prosecution Authority in Scotland – is the COPFS – if they – when you present that to them, that’s what the prosecutor has. He – if you don’t give them everything, then he doesn’t know everything, you know, and it’s clear to me that – and I believe that I followed that through.

Mr Beer: Can I break that down a little bit, then.

Raymond Grant: Yeah.

Mr Beer: At what stage in the process would you pass to the Procurator Fiscal the list of productions consisting of what we call unused material, namely documents that you’re not using to seek to establish the guilt of the suspect?

Raymond Grant: Now, this is where there are – different Procurator Fiscals work in different ways. They all work to the same rules but some of them don’t like to receive the productions until nearer the trial, right.

Mr Beer: This is what I want to investigate with you –

Raymond Grant: Okay.

Mr Beer: – namely, on what material the Procurator Fiscal makes a decision to prosecute?

Raymond Grant: Well, when he’s given us the instruction that he requires the productions to be sent to him, it can be four or five weeks before the trial; it could be two weeks before the trial. Different Procurator Fiscals worked in different ways, that’s what I’m trying to say, Mr Beer.

Mr Beer: Is it right, trying to cut through this, that the Procurator Fiscal made decisions to prosecute on the basis of a report, rather than the productions, the underlying material?

Raymond Grant: Yes.

Mr Beer: So, unlike perhaps in England, they don’t see the underlying material at the point of making the decision to prosecute?

Raymond Grant: Yeah.

Mr Beer: That comes later; is that right?

Raymond Grant: If you’re talking about the Post Office Limited decision to prosecute, we would submit the file to the Criminal Law Team down in Croydon. They would then send that to the – the report to the Designated Prosecution Authority, which was a person – a Senior Manager within Post Office Limited Investigation Team.

Mr Beer: Yes, we’re going to see that in a minute and we can see, in this case, it was Mr Pardoe?

Raymond Grant: Yes, correct, and Mr Pardoe would then give the nod and the wink to go ahead with the prosecution and submit the report to the Procurator Fiscal.

Mr Beer: We’re jumping ahead a little bit.

Raymond Grant: Sorry.

Mr Beer: You referred to it as a “nod and a wink”.

Raymond Grant: Yes.

Mr Beer: Is that what it consisted of or did it consist of a detailed analysis of the merits of the evidence?

Raymond Grant: I’m not sure what the DPA – the Designated Prosecution Authority, what he understood, but he would be in possession of the case file, so that he could review the case file and to see whether he was satisfied that it complied with Post Office Limited –

Mr Beer: So there’s two stages, one which is internal to Post Office –

Raymond Grant: Yes.

Mr Beer: – where the Designated Prosecution Authority, call it Mr Pardoe, is making a decision whether, essentially, to pass the papers on to the Procurator Fiscal?

Raymond Grant: Correct.

Mr Beer: Then the second stage is, when it gets to the Procurator Fiscal, I’m just at the moment looking at that second stage –

Raymond Grant: Okay.

Mr Beer: – at that second stage, they got a report, is that right, rather than evidence?

Raymond Grant: Correct.

Mr Beer: Did you understand, therefore, the importance of including in the report all material or reference to all material, whether it pointed towards the guilt of the suspect or away from such guilt?

Raymond Grant: Yes, I was aware of that.

Mr Beer: Because, unlike in England, if they’re not looking at the underlying material themselves, that’s got to be included in the report for them to make a fair and balanced decision, hasn’t it?

Raymond Grant: I’ve never prosecuted – I’ve never been the lead Investigation Manager in an English case, so I can’t do the comparison that you’re talking about.

Mr Beer: Well, let’s just stick to Scotland, then.

Raymond Grant: Okay.

Mr Beer: If a person is going to make a decision based on a summary, ie the report that you’re writing for them, in order for them to make a fair and balanced decision, you’ve got to reflect all of the evidence fairly, whether it points towards or away from the guilty of the suspect, haven’t you?

Raymond Grant: Yeah. If I can just add some value here, because it’s just come in my head there just now, is that there were occasions where a Procurator Fiscal would call you in to discuss matters, like you’re talking about, and he may have, in the past, asked you to bring the evidence with you, so that would be a review. That didn’t happen in every case though.

Mr Beer: During your time as an Investigation Manager you were involved in investigating other Scottish cases, other than that of William Quarm, yes?

Raymond Grant: Yes.

Mr Beer: How many before William Quarm’s?

Raymond Grant: Oh, err –

Mr Beer: Just in Post Office Limited.

Raymond Grant: In the five years, probably – can I just say, I had one big case which took me nine months and it was a massive case, almost £500,000, and that took up an inordinate amount of my time, that one particular case. So, in real terms, probably 20. That’s a guess. That’s an absolute guess.

Mr Beer: So 20 in five years?

Raymond Grant: Yes.

Mr Beer: I should have asked at the time: the other people in Post Office Limited Investigation working in Scotland, were they, like you, former postmen?

Raymond Grant: I think most Investigators had come through the ranks, if you like, at various stages, whether they were postmen or whether they were counter clerks or whether they were – they would have been – you were normally not headhunted but it would be somewhere in your development plan.

Mr Beer: Did you receive any training or instruction on Scottish law?

Raymond Grant: Yes.

Mr Beer: When was that?

Raymond Grant: Oh, I think it’s – it’s actually a bone of contention for me because when – the majority of training of any type, either Royal Mail or Post Office Limited, we were always – the training would be held in England, at the end of every session or every session of training, I would ask the question, “So what is the difference? How can we apply these rules to Scotland?” and the people who were training said, “Well, you can learn by experience”.

There was not any great level of training. I do remember having some Procurator Fiscals at some point coming in and speaking to the team in Scotland but that was rare, in fact very rare. I think it only happened once.

Mr Beer: So there was any one occasion you remember, in the time you were in Scotland, getting –

Raymond Grant: I can’t – sorry.

Mr Beer: – bespoke training on Scottish law?

Raymond Grant: Yes.

Mr Beer: Now, I think, by the time you came to William Quarm’s case, is it right that there were just two of you investigating cases in Scotland?

Raymond Grant: I think that’s correct and it was Mr Daily and myself.

Mr Beer: Yes, that’s what he told us yesterday, Mr Daily, that by 2008/9 there were just two of you. Why were there just the two of you investigating cases in Scotland?

Raymond Grant: During my time in both Royal Mail and at Post Office Investigations there were lots of occasions where there was headcount reductions, where people had to apply for their own job and whether you were successful or not determined whether you remained in the security industry or the Security Team.

Mr Beer: Is that what eventually happened to you in 2009?

Raymond Grant: That’s exactly what happened to me in 2009.

Mr Beer: So in the case of William Quarm’s investigation, he told us that you were the Lead Investigator and he was the Second Officer; is that right?

Raymond Grant: That’s correct.

Mr Beer: Then, when you left, the file was transferred to him; is that right?

Raymond Grant: My understanding now is that’s what happened. I think all my files were pending – were transferred to the last Investigator in Scotland, which was Mr Daily.

Mr Beer: In your Inquiry witness statement, you make no reference to any awareness of subpostmasters experiencing issues or problems with the Horizon system and you tell us in your witness statement, “At no time was there any suggestion that the Horizon computer system had created any errors which could have caused resultant cash shortages”; is that right?

Raymond Grant: Are we talking about in Paible Post Office?

Mr Beer: No, you’re talking generally here?

Raymond Grant: Oh, generally, right. Okay. I was not aware of any instance where anybody had pointed out to me that Horizon was causing issues. I believe that on – when it was being introduced to offices, there were technical difficulties but I’m not aware of any operational difficulties, if you understand what I mean by that.

Mr Beer: Yes. The breadth of that statement, you were not aware of any operational difficulties with Horizon at all after it had been introduced into an office; is that correct?

Raymond Grant: That’s correct.

Mr Beer: So were there no prior cases in which you were an Investigator where issues or concerns over Horizon were raised?

Raymond Grant: I don’t recall any.

Mr Beer: Do you remember any suggestions being made by subpostmasters in other cases that Horizon had created errors that could have caused cash shortages or balancing problems?

Raymond Grant: At that time, no.

Mr Beer: Did you receive any information from others in the organisation, whether from Senior Managers or Executives, cascaded down to you, as to the reliability or unreliability of Horizon?

Raymond Grant: I do know that when – on occasion where I required to satisfy myself that would request a statement from Fujitsu to say that the computers were working normally at the time of the transaction, or transactions, and that was to satisfy myself that there wasn’t an issue that could – I mean, computers are computers.

Mr Beer: What do you mean by that, “computers are computers”?

Raymond Grant: Well, you get glitches in every computer. I mean, we’ve had a few in this particular Inquiry yourself where the screens go blank and various other different things. It happens but I’m not aware of anything that was pointed out to me by any individual.

Mr Beer: Why were you seeking statements from Fujitsu to prove that the computer was working properly?

Raymond Grant: Sometimes you like to be thorough and covering all –

Mr Beer: You like to be thorough all the time, don’t you, as an Investigator?

Raymond Grant: Yeah, absolutely, but what you’re doing is that you’re making sure that you’ve got to cover all the bases, that, if you’re an Investigator, you’re expected to take reasonable lines of inquiry; I think that’s a reasonable line of inquiry.

Mr Beer: So reasonable line of inquiry is obtaining an evidential foundation that the computer that produced the data that you relied on to prove a loss was working properly?

Raymond Grant: Well, it can prove a gain as well. So, I mean, it can also – if there are things that are not correct in the office balance and the postmaster is denying culpability, which he’s quite entitled to do, then, you know, you satisfy yourself that “Is there a problem that I’m not aware of”, and you would seek reassurance that there’s nothing else that could have caused it.

Mr Beer: So just back to my question, then. You did regard it as a reasonable line of inquiry to obtain evidence that showed that the computer was working properly?

Raymond Grant: Yes.

Mr Beer: What would determine whether you decided to be thorough and got such evidence or decided not to get such evidence?

Raymond Grant: I honestly don’t know the answer to that one.

Mr Beer: Because we know that in Mr Quarm’s case you didn’t?

Raymond Grant: Well, I wasn’t given the opportunity, is more to the truth.

Mr Beer: Who denied you the opportunity?

Raymond Grant: The fact I was made redundant.

Mr Beer: When you put the case up for prosecution, though, you hadn’t obtained any such evidence, had you?

Raymond Grant: Does it not say that – something about the ongoing inquiries?

Mr Beer: Well, we’ll get to that but, by the time you put the report up for prosecution, you hadn’t obtained such evidence?

Raymond Grant: I had to get that report in within 12 days.

Mr Beer: So let’s take it in stages.

Raymond Grant: I think it actually says that there are further lines of inquiry.

Mr Beer: Was that going to be one then? Is that what you’re saying?

Raymond Grant: Well, I mentioned earlier about the recovery of dockets from other agencies with whom the Post Office has contracts. That would have been one of the avenues that I would have explored.

Mr Beer: I’m asking about the Fujitsu evidence. Are you saying that a line of inquiry that you’re referring to in your report, which says that there are further inquiries outstanding, or words to that effect, was to obtain evidence from Fujitsu?

Raymond Grant: It would have been something that would have been a reasonable thing to do, yeah.

Mr Beer: Why would it have been a reasonable thing to do?

Raymond Grant: Because it would have shown the transactions and all the other things that were not available to me from the branch trading statements, which was all I had.

Mr Beer: I think you, in fact, know from reading the documents that was never done, was it?

Raymond Grant: Reading the documents, no.

Mr Beer: No ARQ data was obtained?

Raymond Grant: I’ve read the production schedule and you’re correct – quite right there.

Mr Beer: No witness statements from Fujitsu obtained?

Raymond Grant: No.

Mr Beer: Do you know why that was?

Raymond Grant: I think I’ve already referred to it in my previous answer, was that I was taken out of the Security Investigation Team, I was actually, in my words, put on gardening leave and I spent the Christmas of that year stocking shelves in a Crown Office.

Mr Beer: Can we look, please, before we move to Mr Quarm’s case, to something that happened before you started his investigation, at POL00093246. You’ll see, if we go to the third page, please, this is a document authored by you on 3 April 2002; can you see that?

Raymond Grant: Yes.

Mr Beer: If we go back to the first page, please. We can see from the first line it’s about the Raeburn Place sub post office; can you see that?

Raymond Grant: Yes.

Mr Beer: Is that a suburb of Edinburgh?

Raymond Grant: Yes.

Mr Beer: It’s about the alleged loss of £52,300-odd pounds, yes?

Raymond Grant: Correct.

Mr Beer: If we can look at the second paragraph, which is on the page there, thank you, it is now at the top of the page:

“An examination of the cash accounts for … Weeks 25 … to week 27 indicate that weekly shortages and overages were simply carried over to the next accounting week. The cash account weeks in which the three large shortages occurred were examined and compared to other accounting weeks. There were no apparent reasons for the losses identified.”


Raymond Grant: Correct.

Mr Beer: Then if we read the next paragraph:

“During the time that the office was being defunded a document was discovered within the office believed to be in Miss Saleem’s handwriting [I think she was the subpostmistress]. This document would appear to be a response to the recovery of the shortages due to the Post Office … Miss Saleem indicates that the problem would appear to be ‘gletches …’”

I think that’s glitches; is that right?

Raymond Grant: I think it’s a Scottish colloquialism, gletches/glitches, it’s the same word.

Mr Beer: “’… in the system’ she indicates that she was told this by the Helpdesk. It has not been possible to identify who from the Helpdesk is giving out this information. It does, however, give concern to Post Office Security that operators are being advised that the Horizon system is faulty and produces inaccurate results. This document is being held by Lothian and Borders Police as a production of evidence.”

If we go to page 3, please. You say that what was happening was:

“… contrary to the Losses and Gains Policy … to allow several large shortages to be held in suspense … guidelines state that all subsequent losses should be made good immediately.”

If we just go back to third paragraph on page 1, you say that it’s of concern that people in the Helpdesk are telling postmasters that the Horizon system is faulty, yes?

Raymond Grant: Yes, that’s what it says, yes.

Mr Beer: Why was it a concern that people in the Helpdesk were telling subpostmasters that the Horizon system they were using was faulty?

Raymond Grant: I mean, this is 2002. It’s –

Mr Beer: 2001, I think, the incident was, and your report is April 2002?

Raymond Grant: Okay, so this is now 23 years on. I have got very little recollection of this but it would be a concern at that time. I don’t know when Raeburn Place got their Post Office or Horizon equipment installed. If this is around 2001, that would sort of tie in with that, but –

Mr Beer: Are you saying we might be able to write this up as a technical difficulty in installation?

Raymond Grant: I really don’t know because, once I saw that the outcome – that three large losses were placed in the suspense account, to do that you need authorisation, and –

Mr Beer: You’re critical of Post Office staff for doing that without authorisation, at the end of the report, I think?

Raymond Grant: Yeah, but Mr – the Retail Line Manager, that became a Retail Line Manager. That, to me, was not a criminal activity; that was something that was fundamentally wrong with the way – in fact, I think I recommended that Mr Athwal was subject to some kind of disciplinary action, I think it says on the last paragraph, because that should never happen – should never happen.

Mr Beer: I’m more interested in the –

Raymond Grant: In the glitches.

Mr Beer: – why Post Office Security would be concerned that the Helpdesk are telling people that the Horizon system is faulty and produces inaccurate results. Why would that be a concern to Post Office Security Department?

Raymond Grant: I think because it brings the integrity of the Horizon system into question at a very early stage of its inception.

Mr Beer: Why is that a concern?

Raymond Grant: I think for – knowing what we know now, yes, I think it most certainly was a concern.

Mr Beer: Yes, but why was it a concern at the time?

Raymond Grant: I think what I’m saying is if it’s found that the Helpdesk are passing out that type of information to individuals, they perhaps should be reporting it in the other direction, so that the senior management team or their line managers can be – it could be looked at to see if there is an issue. But to just tell the postmasters that there’s glitches in the system without a name, without a reason, and just to put it down in a bland statement like “there’s glitches in the system”, it’s not helpful. I mean, the Helpdesk is there to provide help, not to give opinions.

Mr Beer: Was that your concern, that they shouldn’t be saying things like this?

Raymond Grant: I mean, the actual quote that I’ve highlighted, I can’t recall actually typing this document but I must have done because it’s got my name against it, but I really can’t give you much more, Mr Beer. Sorry.

Mr Beer: It reads, do you agree, as if you’re saying the problem isn’t that there might be glitches in the system; the problem is that somebody is saying that there are glitches in the system?

Raymond Grant: Yeah, I can see where you’re coming from, yeah.

Mr Beer: As an Investigator, that was something that you would need to investigate, whether, in fact, there were glitches in the system which were relevant to Miss Saleem’s case, wouldn’t you?

Raymond Grant: I think, because I passed it back to the Retail Line Manager team and I’ve highlighted it in my report to the Retail Line Manager’s team, I would have expected them to follow that through, because this – I was a Criminal Investigator, this was not a criminal offence.

Mr Beer: Why was this not a criminal offence?

Raymond Grant: Because of the way that the Retail Line Manager had dealt with it.

Mr Beer: What, they had authorised –

Raymond Grant: Yes.

Mr Beer: – the retention of the £50,000-odd in suspense?

Raymond Grant: Yes.

Mr Beer: Would that, in your view, preclude a criminal investigation?

Raymond Grant: Well, it’s certainly not helping.

Mr Beer: Why does it not help, that there’s been in authorisation to hold the money in suspense?

Raymond Grant: Well, it says there that – the Losses and Gains Policy that the loss should be held in a suspense account for a maximum of eight weeks. This exceeded that, so, therefore, there was a loss of information, there was loss of data, there was a loss of dockets, there was a loss of lots of what would be important evidence to have been protected. The fact that –

Mr Beer: Why would that evidence have been lost?

Raymond Grant: Because if you’re – when you’re balancing at the end of the day or the end of the week, you’re required to check all the dockets, all the foils, all the – at that particular time there would be foils from payment order books, which were the old pension payment dockets. They would all have been sent away. They would now no longer be available for me to get any meaningful investigation to try to enquire why or how this came about. So there was a loss of evidence due to the inaction of the Retail Line Manager, Mr Athwal, and –

Mr Beer: Drawing it out more broadly, would you say that agreement by a Retail Line Manager to hold money in suspense essentially precludes a criminal investigation?

Raymond Grant: Not in every case but, in this particular case, when there are three large ones, I would think that it’s certainly a major breach of the Losses and Gains Policy.

Mr Beer: When I asked you a moment ago about whether you had heard whether there were any suggestions that the Horizon computer system had created errors that could have caused cash shortages, and you said no, in fact the answer would be yes, because this document shows that you had?

Raymond Grant: Yes.

Mr Beer: Were there other occasions in the run-up to Mr Quarm’s investigation, in the five years or so that you were working for Post Office Limited, in which people raised problems or glitches with the Horizon system?

Raymond Grant: I can’t recall any.

Mr Beer: In this case, in Raeburn Place, are you essentially saying that this wasn’t a matter for you to investigate because this was being sent back to the Retail Line Manager chain for recovery, presumably as a civil matter?

Raymond Grant: I think – could you go back to the top of the report for me, please?

Mr Beer: Yes, of course.

Raymond Grant: Thank you.

Mr Beer: If we just scroll up, please.

Raymond Grant: I think this is a report going back to the Retail Line to say – basically say “I’ve had a look at this, I’m not comfortable with it”, although it doesn’t say it in those words, “There were breaches of policies and procedure by the Retail Line Manager and I’m sending it back to them to take ownership of it”.

Mr Beer: Do you know what happened as a consequence of your report?

Raymond Grant: No, I don’t.

Mr Beer: Okay, that can come down. Thank you.

Can we look please –

Sir Wyn Williams: Hang on, Mr Beer, there’s just one phrase I’d like to ask a question about on that document. It’s back on the second page where Mr Grant is relaying the concern of Post Office Security.

Mr Beer: I think that’s the third paragraph.

Sir Wyn Williams: Yes.

Mr Beer: If we scroll down. Thank you. So it’s “During the time”.

Sir Wyn Williams: Yes, that’s the paragraph.

You’ll see, Mr Grant, the last-but-one sentence:

“It does however give concern to Post Office Security …”

Now, I’ve taken that to mean that you were not there expressing your personal concern but a wider concern; is that correct?

Raymond Grant: As a member of the Post Office Security Team, yes, I do believe – yes.

Sir Wyn Williams: So who is covered in this document by that expression “Post Office Security”? Does that mean your colleagues in Scotland? Does the mean something wider than that? Explain it to me.

Raymond Grant: I believe what I’m talking about there is the broad spectrum of the whole of Post Office, because we kept on changing titles, so Security Investigation, Fraud Team, it’s – at that time in 2002, I think we were all listed as Post Office Security. So my comment there, “It does however give concern to Post Office Security”, is for the overall team, nationwide.

Sir Wyn Williams: I’m sorry to be pedantic. Does “nationwide” equal Scotland or does “nationwide” equal UK?

Raymond Grant: Sorry, you’re quite right. Because we’re all separate nations. It would be the UK.

Sir Wyn Williams: Thank you. Yes.

Mr Beer: Thank you, sir, can we move on, please, to another document – again, this is in the run-up to the investigation of William Quarm – and look at POL00113067. This is, essentially, a schedule of documents prepared for disclosure in the course of other litigation and it describes what the document is in the second column. It gives a control number in the first column and then, in the third column, it sets out an extract or extracts from the document. I just want to use this to look at what is said to be within a document by looking at the second page, please. It’s the box at the bottom, please, the third box down. If we can just blow that up, please.

Thank you. So the document is a “Casework Management Report for the case of”, and then a cipher has been applied, that’s because it’s somebody who is not caught up in this Inquiry:

“… written by Shirley Stockdale, Investigation Manager, and dated 2 December 2003.”

So this is, essentially, an extract from a document, which it is said Shirley Stockdale wrote back in December 2003. Do you remember Shirley Stockdale?

Raymond Grant: Yes, I do.

Mr Beer: Was she a colleague of yours in a Scottish element of the Post Office Security –

Raymond Grant: Yes, she was an Investigation Manager, the same grade as myself. Yes.

Mr Beer: So this is before the cut down from four or five of you down to two?

Raymond Grant: Well, yeah, yeah, exactly so, yeah. We had so many of them it was difficult.

Mr Beer: What she’s reported as saying is:

“Because B190 [that’s the person] was declaring his losses it was felt that there was no criminal intent and that there somehow must be a procedural error taking place.

“Arrangements were made for myself [Shirley Stockdale] and [you] Raymond Grant to attend the training suite at Springburn DMB” –

So I think a DMB is a directly managed branch; is that right?

Raymond Grant: That’s correct.

Mr Beer: Springburn is part of Glasgow?

Raymond Grant: Yes, it’s a suburb of Glasgow, yes.

Mr Beer: So the pair of you had arrangements made for you to attend the training suite at this directly managed branch in Springburn:

“… where we attempted to reconstruct the cash account for the weeks immediately prior to the audit in an attempt to establish what effect this practice of redeclaring the cash at a higher value would have on the actual cash account, it was suggested that the loss may have been inadvertently ‘doubled up’, however the exercise at the training suite has disproven this and as far as enquiries have revealed to date the only thing that is sure is that the deficit of [£38,800-odd] realised at audit is not as a result of any errors that we are aware of at this time. It would appear to be missing cash for which neither of the staff or the subpostmaster can give any explanation.”

Just looking at this – and I realise this is an extract where you don’t have the whole context of the document and you don’t have the identity of the subpostmaster concerned – do you remember this, attending a training suite and trying to reconstruct an error that a postmaster had alleged?

Raymond Grant: I didn’t until I’d read this but I do remember the incident of – or the actual action that we took, and I remember going and doing this with Shirley Stockdale. What we were trying to do was, based on the information that Shirley had and the information that we had from the previous cash accounts, was to reconstruct using training equipment, Horizon training equipment, which was based in a room – it’s called the training suite there – and, without having read that, I wouldn’t have recalled it but I do remember actually doing that.

Mr Beer: The first paragraph there suggests that this was being done because the postmaster was declaring his losses and, therefore, it wasn’t to be treated as crime?

Raymond Grant: Yeah.

Mr Beer: Can you explain that: because the postmaster was declaring losses, that equates to not treating this as crime or having a criminal intent?

Raymond Grant: To determine whether it’s a crime, you would look at what efforts have been made to disguise this, this postmaster was being upfront. He was publishing in his accounts what was – his end results were. I can’t recall the case, I don’t even remember the name of the office, but it would be one of those where I think it would require the Retail Line Manager to take ownership of.

Mr Beer: So, again, this one that wouldn’t go down the crime route?

Raymond Grant: I’m guessing because it wasn’t – I was only there to corroborate what Shirley Stockdale was trying to do and help if I could, because the two of us were – we were pretty much the same level of experience.

Mr Beer: Do you remember, in your time before 2009, this being an issue that was raised more than once, ie the system inadvertently doubling up figures?

Raymond Grant: I’d heard about operator error, when you’re trying to resolve an issue and, if you didn’t do the process correctly, it would result in a duplication of the loss or whatever it was you were trying to do. But that was put down to operator error, not following the procedure to remove the money from one place to another or to resolve the difficulty that had been identified.

Mr Beer: I’m thinking about the thing that’s described here as “inadvertent doubling up”. Had you heard about that in other cases –

Raymond Grant: Not inadvertently, no.

Mr Beer: – before you left in 2009?

Raymond Grant: No, I had not, no.

Mr Beer: Other than attending the training suite and trying to replicate what the postmaster had alleged, can you recall whether any other investigations were carried out in relation to this alleged procedural error?

Raymond Grant: For this particular event? No, I’ve no idea.

Mr Beer: Thank you. That can be taken down.

Sir, it’s 11.20 now. That might be an appropriate moment for the morning break.

Sir Wyn Williams: Yes.

Mr Beer: Can we break until 11.35 please?

Sir Wyn Williams: Yes.

Mr Beer: Thank you very much.

(11.19 am)

(A short break)

(11.35 am)

Mr Beer: Sir, good morning. Can you continue to see and hear us?

Sir Wyn Williams: Yes, thank you very much.

Mr Beer: Thank you very much.

Mr Grant, how would you describe your role in the Post Office Investigation Department, in terms of your relationship with the Procurator Fiscal?

Raymond Grant: There was never a single Procurator Fiscal because they’re very regionally based. I think there are 11 in total in Scotland.

Mr Beer: I should say that I’m referring to the Procurator Fiscal as meaning the office of?

Raymond Grant: Oh, right, sorry. I beg your pardon.

Mr Beer: So Procurators Fiscal?

Raymond Grant: Yeah, it’s a difficult plural. We would be there, we would submit a report. Initially, it was done via a written report, subsequently there was an electronic version brought in. I can’t remember –

Mr Beer: 2006 onwards?

Raymond Grant: I think it was 2006, around about that time. And we would submit – if I stick with the written report first of all, the written report would contain the relevant information that we would think that the Procurator Fiscal would need to do, or Procurators Fiscal would need to initiate. They would then probably come back to you on – either on a personal basis or you would – you could even – might be invited to go and see them at their premises and explain what it is you were tying to do. That didn’t happen in every case. Sometimes they just took your documents as being accurate and reasonable for them to make progress on what they were going to do with it.

Mr Beer: Assuming they took a case on and prosecuted it, what format would the communication occur in after that? Was it by meeting, email or more formal written communications?

Raymond Grant: I think it would be a combination of all of those.

Mr Beer: In the process of us asking you to write your witness statement, I think we referred you to a document, a Post Office document, called “Investigation Policy, Disclosure of Unused Material – Criminal Procedure and Investigations Act 1996 Codes of Practice”. I wonder whether we could just look at that, please. It’s POL00104762.

If we just look at the foot of the page first. We can see it’s dated May 2001. If we go up the page to the top, please, you can see the title. Just reading that document and the purpose of it, is this a policy or a procedure document that would have applied to your work when you were an Investigator in Royal Mail Group?

Raymond Grant: Yes.

Mr Beer: Is it a document that would have applied to your work when you moved to the Post Office?

Raymond Grant: I believe it would, yes.

Mr Beer: Can we look, please, at the bottom of the page, paragraph 3.2. If we scroll down to the second bullet point from the bottom:

“Investigators and Disclosure Officers must be fair and objective and must work together with prosecutors to ensure that disclosure obligations are met. A failure to take action leading to proper disclosure may result in a wrongful conviction. It may alternatively lead to a successful abuse of process argument or an acquittal against the weight of evidence.”

Then, over the page, please. If we go to the third bullet point from the bottom:

“Disclosure Officers must specifically draw material to the attention of the Prosecutor for consideration where they have any doubt as to whether it might undermine the prosecution case or might reasonably be expected to assist the Defence disclosed by the accused.”

Do those two paragraphs fairly reflect your understanding of the duties of disclosure when you were investigating cases in Scotland?

Raymond Grant: Yes.

Mr Beer: These, I think, are mirrored in a document that applies to all Specialist Reporting Agencies, as they were called, in Scotland. If we can look at that, please, WITN10510102. So this isn’t a Royal Mail Group or Post Office publication; it’s a publication of the Crown Office and it applies as a guide to all so-called Specialist Reporting Agencies.

If we can look, please, at page 5., just to see what it’s about. The foreword by the then Lord Advocate, Lord Boyd:

“I am pleased to be able to provide you with [a guide with that title].

“Over fifty agencies other than the police report cases to Procurators Fiscal each year …

“This requires understanding on the part of the Procurators Fiscal to of the relevant legislative provisions and appreciate of the role and functions of the reporting agencies. The other essential ingredient is that the reporting agencies follow best practice in the investigation and reporting of cases to Procurators Fiscal and in preparation for the giving of evidence by their officers in court.”

Then, just over the page, lastly:

“The purpose of the guide is twofold:

“1) to assist the Specialist Reporting Agencies in knowing exactly what the Procurator Fiscal requires … and to provide some indication of how trials are conducted in Scotland; and

“2) to identify and to address common problems in reporting and prosecuting such cases which more often than not involve employees or members of Specialist Reporting Agencies.”

Was this a guide with which you would have been familiar, from at least 2002/3 onwards, when you took over responsibility for investigations – or became part of the team in Post Office Limited?

Raymond Grant: I’m familiar with the document and I would have read it at the time.

Mr Beer: I should have said this is the 7th Edition, dated 2006, so I think it’s the one that’s applicable to Mr Quarm’s investigation, from earlier iterations?

Raymond Grant: I probably had the previous version as well, when I was a Royal Mail Investigator, because these were issued to us. I’m not sure if somebody just copied them or whether we were – they were handed out at one of our team meetings or something. But I am familiar with that document.

Mr Beer: So this was essentially a guide to a range of Specialist Reporting Agencies, non-police investigators and prosecutors?

Raymond Grant: Yes.

Mr Beer: It’s a list of, essentially, the things that the PF Office require?

Raymond Grant: It was what – it was their – it was a guideline for us to follow, yes.

Mr Beer: Can we look, please, at page 30. Under “Detrimental Evidence”:

“… it is important material which may be detrimental to the prospect of a conviction is not omitted from the statement. In order to perform his or her function properly the [PF] must be aware of all the evidence which has been gathered regardless of whether it contributes to the evidence against an accused person or is in his or her favour. Procurators Fiscal proceed in the public interest which necessarily connotes a broader approach than the wishes of the reporting agency alone.”

Is that something you would have understood as an obligation on you in the Post Office Investigation Department?

Raymond Grant: Yes.

Mr Beer: That fairly reflects the policy document that I showed you, the internal policy document, agreed?

Raymond Grant: Yes.

Mr Beer: That can come down, thank you.

So how was that obligation, how were those duties discharged in the case of any material that may show that Horizon was not functioning properly?

Raymond Grant: I mean, if I was aware of an issue or a problem or a difficulty with any aspect of the report that I was preparing for a Procurator Fiscal, that would be declared in the substance of the report. If it wasn’t, then that would be remiss of me, but I don’t recall ever being challenged on it by a Procurator Fiscal or in any other previous case that I’d handled or dealt with.

Mr Beer: We looked earlier at a couple of examples where somebody had raised an issue about the functioning of Horizon?

Raymond Grant: Yes.

Mr Beer: How would you go about discharging the duty to find and then disclose to the Procurator Fiscal information about the functioning of Horizon, generally: not whether there was a glitch in the branch but whether Horizon as a system was functioning properly?

Raymond Grant: I mean, if you’re referring to the document, I – where I quoted glitches in the system, then, to me, that was not a criminal activity. It was something I referred back to the Retail Line for them to deal with. I was not aware of what the context of what the glitches of the system was. I couldn’t make investigations into it because we didn’t know of the name of the originator of that statement or whether the statement was, in actual fact, true.

Mr Beer: Is the broader to answer my question, then, you didn’t see it as part of the role of you as an Investigator to provide evidence to the Procurator Fiscal about problems in Horizon because in no criminal investigation were you aware of any problems in Horizon?

Raymond Grant: That’s correct.

Mr Beer: Up until 2009, when you left, had you heard nothing about allegations concerning the improper functioning or the errors arising in the functioning of Horizon concerning, in particular, balancing?

Raymond Grant: I’m fairly certain, in my recollection, that no one, no one, had brought to my attention that there were problems with the Horizon system, and you mentioned balancing and nobody had said to me that there was a problem with the Horizon system balancing on a Post Office, Crown Office or any other office.

Mr Beer: So two questions arising from that: by contrast, had anyone said anything to you positively about the robustness of Horizon?

Raymond Grant: Yes.

Mr Beer: Who and in what context?

Raymond Grant: It would come – the conversation would be team meetings, when we were talking about getting statements from Horizon and the need – why we would need the statements and what they contained. And the consensus would be that Horizon was working normally and, in normal circumstances, if you required to get a statement from Fujitsu, it always came up with the same type of narrative: that the system was working and functioning normally. So there was no need for us to question that, as far as we were concerned, because we were getting an expert witness from Fujitsu.

Mr Beer: Did you ever investigate a case in which an expert witness from Fujitsu provided a witness statement?

Raymond Grant: I think in my time at Post Office Limited, there were probably two occasions, but not …

Mr Beer: When you’re referring there to an expert witness, are you referring to somebody who has particular knowledge and expertise in the system, or are you referring to somebody who is formally treated for court purposes as an expert witness?

Raymond Grant: If I was to explain to you the process of achieving an expert witness statement, it would go down to our Casework Review Team down in Croydon. They would then apply to Fujitsu for a witness statement to be gained from them. We would not – I don’t recall ever asking them directly. I would always go through the process of our Casework Review Team to follow on, to get satisfaction that there was no problem with the computers.

Mr Beer: What about the thing I was asking you about, namely the nature of the witness with which you are concerned. Was there an expert report produced or was it in the form of a witness statement?

Raymond Grant: My recollection was it was a witness statement.

Mr Beer: You said that there would have been a consensus amongst team members. The team you’re referring to there, is that Post Office Investigation Department?

Raymond Grant: It would be at that time because there would be no need to get a Fujitsu statement for Royal Mail.

Mr Beer: Why was that issue being talked about in team meetings, the reliability and integrity of the Horizon system?

Raymond Grant: I think, basically, it was the process that you had to go through to get it because it was not always delivered timeously. If you asked for it, you could maybe wait a number of weeks for it and it would then put you under pressure to fulfil a report or submit a report to a Procurator Fiscal, if –

Mr Beer: That’s a timing issue.

Raymond Grant: Yeah.

Mr Beer: But what about the issue of there being a consensus that Horizon was working normally?

Raymond Grant: Well, the consensus was that there was – to the best of my knowledge, and nobody ever challenged it, nobody – it wasn’t open for discussion because, as far as we were – it was a non-event, as far as we were concerned.

Mr Beer: Thank you. Can we move on to the investigation of allegations of embezzlement against William Quarm. Do you now recall investigating William Quarm?

Raymond Grant: Given this was 16 years ago, my recollection was very vague but, having had a chance to look at the transcript of the tapes, which was a major role that I played in that investigation.

Mr Beer: Just to get some context before we look at that interview, which we’re going to look at in a moment, just to jog your memory a little bit about the individual with which we’re concerned, I think he, that’s William, he went by the name of Bill; is that right?

Raymond Grant: Bill, yes.

Mr Beer: He was a man of good character, he’d never been in trouble before in his life; is that right? Was that part of your investigation, to look at his background and antecedents?

Raymond Grant: I wasn’t aware of anything. Nobody had brought –

Mr Beer: I think when we look at your report it will say he hadn’t been in trouble before.

Raymond Grant: If that’s in my report, it must be –

Mr Beer: He was 66 years old, I think it says in your interview transcript, at the time of the investigation and 68 by the time that the prosecution occurred?

Raymond Grant: Yes.

Mr Beer: He was in poor health, I think. I think he told you about that. He’d had some strokes, hadn’t he?

Raymond Grant: Am I allowed to say because I see some of it is redacted out.

Mr Beer: The things I’m referring to are recorded on the documents that aren’t redacted.

Raymond Grant: Right, okay, he had been experiencing minor strokes from the previous year.

Mr Beer: He’d worked at the Post Office in Bayhead, North – and I’m not going to able to pronounce it correctly; you go for it, Mr Grant?

Raymond Grant: Paible?

Mr Beer: Yes. Well, in fact, I was thinking of the island on which the Post Office was situated?

Raymond Grant: Oh, Lochmaddy.

Mr Beer: That is an island in the Outer Hebrides; is that right?

Raymond Grant: Yes, it’s – well, Lochmaddy is a town on North Uist.

Mr Beer: So North Uist is an island –

Raymond Grant: Yes.

Mr Beer: – located on the northwest coast of Scotland?

Raymond Grant: The Hebrides, yeah.

Mr Beer: I think Mr Quarm was a married man; is that right?

Raymond Grant: Yes.

Mr Beer: He had five children, I think he told you –

Raymond Grant: If he said five then, yes.

Mr Beer: – and he was a grandfather?

Raymond Grant: Right.

Mr Beer: Now, I think you know that, as a result of the investigation and the prosecution of him, he lost everything. He had to move out of his house, did you know that?

Raymond Grant: I need to be careful when I answer this one because he didn’t lose everything because of the Post Office inquiry. There were other issues on his private business which were much more serious, as far as – from finances were concerned. Mr Quarm had extensive debts and, if you’re going to cover the financial – the finance, he eventually – 12 days after my interview, he went bankrupt and that was not because of something that happened that the Post Office did.

Mr Beer: I think you know that he passed away two years after he was convicted –

Raymond Grant: I didn’t know that, no, not until you’ve just said it there just now.

Mr Beer: – obviously, therefore, a decade before his conviction for embezzling money from the Post Office was overturned by the High Court in Scotland.

Raymond Grant: Mm.

Mr Beer: So you tell us in your witness statement that you were one of the people who participated in an interview of Mr Quarm on 7 August 2008, right?

Raymond Grant: That’s correct.

Mr Beer: I think you took the lead in questioning Mr Quarm?

Raymond Grant: Yes.

Mr Beer: That was because you were the Lead Investigator?

Raymond Grant: Yes.

Mr Beer: Can we look at the interview, please. POL00166599. This is a transcript of the interview. We can see it’s a 44-minute interview between 10.50 and 11.34 in the morning. There are three Investigators present: you, Robert daily, and Jonathan Bisset, yes?

Raymond Grant: Well, Jonathan Bisset was not an Investigator, he was a finance analyst who was being accompanied – he was work shadowing myself and Mr Daily and so his role was not as an Investigator.

Mr Beer: Okay, so there were three of you and one of Mr Quarm?

Raymond Grant: And his brother-in-law –

Mr Beer: Now, I think page 2, if we skip over the page, please, introductions are made. Then about eight lines in, Mr MacDonald – that’s the brother-in-law, yes –

Raymond Grant: Yes.

Mr Beer: – introduces himself and you say:

“During this interview you can have a friend present if you wish any friend whom you nominate must be over the age of 18 and not involved in the enquiry. They should be a Post Office employee. I understand because of the nature of where we are on a Hebridean island that may not be easy to get our hands on and I’m quite happy to have your friend William MacDonald happy to be here as a friend yeah?”

Mr Quarm says: “Right.”

So the friend that was present –

Raymond Grant: Sorry, Mr Beer, if you can just go back there, just a second, I noticed a typo there.

Mr Beer: If we go back up.

Raymond Grant: I’ve just noticed it just now. It says, “They should be a Post Office Limited employee”. That should read “They should not be a Post Office Limited employee”.

Mr Beer: Right. Why was that? Why shouldn’t they be a Post Office employee?

Raymond Grant: Because that would infer a bias or it would be unfair because that then you would have four people from the Post Office and –

Mr Beer: What about a union rep?

Raymond Grant: There was no requirement under the subpostmaster’s contract for that to happen. If there was –

Mr Beer: They were allowed it though, weren’t they?

Raymond Grant: If that was who Mr Quarm required to be there, he could have had a lawyer there as well, if he’d chosen that, but he’d chose to have his friend William MacDonald.

Mr Beer: What role did Mr MacDonald play in the interview?

Raymond Grant: He was there to corroborate and make sure that Mr Quarm was treated fairly. I think at one point he –

Mr Beer: How did he know that?

Raymond Grant: How did he know that? Because he signs a form, I think it’s a CSO – I can’t remember the number of the form. It’s a Corporate Security form which explains what his role is.

Mr Beer: In fact, he sat there in silence?

Raymond Grant: There was one occasion when he got up to get a glass of water.

Mr Beer: Silently?

Raymond Grant: Silently. Yeah.

Mr Beer: Now, in relation to the form that you went through at the beginning of the interview, was that a standard form, as you’ve just said, setting out the interviewee’s, Mr Quarm’s, legal rights?

Raymond Grant: Yes.

Mr Beer: Was that a form you went through at the beginning of every interview?

Raymond Grant: Yes.

Mr Beer: Did it include the caution telling the interviewee that they didn’t have to say anything but anything they did say could be used in evidence?

Raymond Grant: Yeah, I’m not – I can’t remember if it said it on that form but, most certainly, in the transcript of interview that caution was made.

Mr Beer: Did it say anything about the right to have a legal representative present in interview?

Raymond Grant: No, there was no requirement for that under Scots Law. That changed in 2010, I believe.

Mr Beer: So, at this time in 2008, before the decision in Calder, there wasn’t a requirement to offer a suspect a legal representation?

Raymond Grant: Correct. I think that was actually challenged, as well, Mr Beer. There was a minute on –

Mr Beer: Yes, you know the papers very well, indeed.

Raymond Grant: Right, okay.

Mr Beer: There was a minute where Mr Quarm’s solicitors applied to the court to exclude the interview on the grounds of procedural irregularity and oppression, essentially, and that application was refused by the court.

Raymond Grant: Correct.

Mr Beer: The offer of the friend, was that required under Scottish law or was that a bolt-on provided by the Post Office over and above the interviewee’s legal rights under Scottish law?

Raymond Grant: I think it was part of the Post Office Investigation security requirement, that any person who was being interviewed in this format would be offered the right to have a friend present.

Mr Beer: Now, you’ve read this interview more than once, I think?

Raymond Grant: Yes.

Mr Beer: You tell us in your witness statement that Mr Quarm made full and frank confessions, yes?

Raymond Grant: Yes.

Mr Beer: Can I look at some other aspects of the interview. Can I suggest firstly, would you agree – and I’m trying to take this shortly – that Mr Quarm also suggested that he had insufficient training on Horizon and was not overly confident in using it?

Raymond Grant: I’m not sure he uses – did he use the word “insufficient”? I think he says when he got his training it was four days in Dunfermline, that he got back to his office but the installation of the Horizon equipment happened some time later. So I don’t know – I don’t recall seeing the word “insufficient”.

Mr Beer: I’m trying to summarise number of passages?

Raymond Grant: It’s just that inferred to me that he didn’t get enough training, so –

Mr Beer: I’ll read the passage. You asked him:

“On a scale of 1 to 10 how would you rate your knowledge of the Horizon system?”

He said:

“Well, the whole Horizon system probably quite a low figure because we only have certain –”

Then you interrupted:


Raymond Grant: Yes.

Mr Beer: Was that addressing then a different point in your understanding then?

Raymond Grant: Yes.

Mr Beer: What was the different point being addressed?

Raymond Grant: The different point was that, when he did his training, it covered far more than he was requiring for an office of his type. For instance, it would cover things like passports, driving licences. His office, I believe, didn’t have the authority to issue these sort of documents.

Mr Beer: Did he also say that he had sought help from the Helpdesk?

Raymond Grant: Yes, he did.

Mr Beer: Did he also say that he had identified and sought help with an ATM error that had resulted in a loss?

Raymond Grant: I think the actual – he was phoned up about why he was carrying that loss. I don’t think that he phoned. I think he was contacted to ask why he was carrying that loss and he was asked to make it good.

Mr Beer: He was saying that it was a loss that appeared to be a system fault and it ended without apparent resolution?

Raymond Grant: I’m sorry to interrupt you there, it wasn’t deliberate.

Mr Beer: That’s all right.

Raymond Grant: When ATMs were first introduced, some offices didn’t have them attached to Horizon. So I’m not sure when the ATM was actually attached to the Horizon system. So that could have been a standalone machine. I’m not entirely sure because, as I’ve said before, any investigation that I would have undertaken would have covered that point.

Mr Beer: He agreed, lastly, is this right, that his Branch Trading Statements showed regular shortages?

Raymond Grant: Yes.

Mr Beer: Can we look at some specific passages in the interview, then. Again, if we have it on the screen, POL00166599, and page 14, please. The bottom half of the page, please. Thank you. I don’t think that’s page 14. Bottom half of the page, please.

Picking it up about a third of the way down, what’s being shown at the moment, you asked:

“Were you then struggling to pay the invoices?”

Just to put that in context, there’d been a discussion before now, is this right, of the need for him, as he said, to pay invoices for the – I’m going to call it the grocery side of the post office; is that right?

Raymond Grant: That’s correct.

Mr Beer: He says, “Yeah.

“Question: So how did you then pay those invoices?

“Answer: Quite often late [something] the pressure on.

“Question: Right and where did you get the money from to pay those invoices?

“Answer: Well there was money coming in on a daily basis.

“Question: Okay and Post Office money was there ever used to pay invoices?

“Answer: Well it must have been or we wouldn’t have this situation.”

I think your colleague asks:

“Do you ever remember taking money out of the Post Office to pay an invoice?”

“Answer: Not consciously no.

“RD: Not consciously?

“Answer: No.”

Did you take that to be an admission of theft?

Raymond Grant: There were various aspects of the admissions of theft.

Mr Beer: I’m asking about this one.

Raymond Grant: This particular one, no.

Mr Beer: Is that because it rather lacks clarity and he says that he doesn’t actually remember taking money out of the Post Office to pay an invoice?

Raymond Grant: At that point, that’s exactly what he said.

Mr Beer: Then if we go forward to page 17, please. Third line in, fourth line in:

“Well, I think [this is him] it was just moving money, money around.

“Question: I understand what you mean by moving money around but we need to be more specific than that. What money are we talking about are we talking about money from the Post Office if it was money from the Post Office where did we move it to do you know?

“Answer: Well it must have been to my account, shop account.

“Question: … are we talking about the same Alliance & Leicester account business account?”

He said he’s got two Alliance & Leicester accounts and, if we scroll down, and a Royal Bank, I think it’s the Royal Bank of Scotland account. You ask:

“So how would we go about moving it into the second account that we’re talking about now how would you physically do that? Is it also an Alliance & Leicester account?

“Answer: The Royal Bank [of Scotland].

“Question: The Royal Bank but we don’t have online banking here for Royal Bank …”

Then at the foot of the page, about ten lines up:

“… how would it go from the Post Office to the Royal Bank? Would you physically take a lump of cash and deposit it in the Royal Bank?

“Answer: I must have done.

“Question: And if you did that how often would you do that and how much at a time?

“Answer: I couldn’t be specific with that.”

Then you ask him some details about the bank account.

So he may have been saying here that he was using Post Office money, and paying it in, transferring it or depositing cash into either an Alliance & Leicester or a Royal Bank of Scotland account, correct?

Raymond Grant: That’s my understanding, yes.

Mr Beer: So what investigations did you take to evidence the deposit of money that belonged from the Post Office into the Alliance & Leicester and Royal Bank of Scotland accounts?

Raymond Grant: This is where I did not get the opportunity to follow through with that inquiry.

Mr Beer: When did exactly did you leave?

Raymond Grant: It was – if I – I was removed from my post as Investigation Manager about a month or six weeks after this interview. I spent – so this was in August. I was then told to attend the Crown Office in Perth and assist the Branch Manager there and that was prior to Christmas 2008. So I’d actually not left the Post Office Limited, I was still employed, but what you might call gardening leave. I was now no longer part of the Security or Investigation Team.

Mr Beer: Okay, so, essentially, trying to summarise things, Mr Grant, you’re saying that, relatively shortly after this, although you remained a Post Office Limited employee, your job function changed and you didn’t hold the responsibility for pursuing a line of inquiry?

Raymond Grant: That’s correct.

Mr Beer: But it’s a pretty obvious line of inquiry, isn’t it; I think you’d agree?

Raymond Grant: I mean, had I been given the opportunity, I’d have applied to Alliance & Leicester for the dockets.

Mr Beer: In fact, just stopping you there, no need to do that because we know that Mr Quarm was asked to supply all of his bank accounts and he did.

Raymond Grant: Yeah, but I was looking for the actual deposit slips from these agencies –

Mr Beer: I see.

Raymond Grant: – so that we could see what – because what we have here is Mr Quarm, who is having his life disappear underneath his feet, because he’s been an honest man right up until a certain point, he’s made erroneous decisions, in my opinion, to use Post Office funds to support his failing business. He’s used that by various means and I think, if you go onto the third tape, there were – there’s inference that money was being taken from the post office and put into Royal Bank because he was offsetting some loan or debt that he had with them.

There was also fictitious – in my opinion, fictitious deposits for which there was no money being made through the Horizon system into Mr Quarm’s own Alliance & Leicester account. No money existed but the credit was made to his Alliance & Leicester account and then that would allow him to write cheques on the strength of that Alliance & Leicester account to pay the bills for the shop.

Mr Beer: So you’d want to follow the money, wouldn’t you?

Raymond Grant: Yeah, well, that’s where I was going.

Mr Beer: Well, that’s the most obvious thing in the world to do?

Raymond Grant: That’s where I was going but I wasn’t given the opportunity.

Mr Beer: So you’d expect the person who did have the opportunity, Mr Daily, to have done that, agreed?

Raymond Grant: It would have been great but Mr Daily was under a lot of pressure. I know that because I’d several pending cases that were awaiting prosecution or being presented to the Procurators Fiscal, so Mr Daily inherited all of those at very short notice.

Mr Beer: If we can just go, lastly, to page 33.

Raymond Grant: Okay.

Mr Beer: Four lines in:

“You’re declaring what was actually on hand but then what you’re saying to the Horizon system [is] you’re making that good is that correct?”

“Answer: Yeah.”

“Question: Did you in fact put that money in to make the shortage good?

“Answer: No there’s a bank loan to do that.”

What did you understand him to be saying there?

Raymond Grant: Um, it’s – it’s difficult.

Mr Beer: Is overall, looking at –

Raymond Grant: Sorry, it’s difficult because Mr Quarm is now no longer with us. I do think that Mr Quarm believed that there was money coming from the Royal Bank of Scotland and it was his intention to – once that money came from the Royal Bank of Scotland, to repay the money. But further down in the interview, he does get the bank loan and he does not pay the Post Office back.

So, in effect, his understanding, it’s obfuscation, it’s deflection away from actually admitting – I do believe that Mr Quarm was going through a period of grief, the first thing in grief is denial. So you’ve got denial. So I think that’s there he was. The grief – some people call it the grieving process. Grief can happen in any force of life and I believe that Mr Quarm was grieving because he could see his life business disappearing. He knew the status of his shop, which, if we come to that later, then there are things there that can be taken in, that Mr Quarm was not prepared to admit, that “yes, I have taken the money”, but his explanation is that “I’ve got money coming and I’m going to put it back”. That’s what I read into that.

Mr Beer: Did you obtain a clear account from him as to which money he had paid, from which post office account, into either Alliance & Leicester accounts or the Royal Bank of Scotland account?

Raymond Grant: Well, again, we asked Mr Quarm to provide the statements which he very kindly did. So my follow-up after that would be to determine what deposits had actually gone through the Horizon system to allow this transaction to credit his Alliance & Leicester account. Now, if you have no money and then you write out a deposit slip and you put it through the Horizon system into a specific Alliance & Leicester account – and Mr Quarm says he had two, he would put out – there would be a docket – there would be a deposit slip for that.

Mr Beer: So step 1 then, you’d want to find a deposit slip –

Raymond Grant: Yes.

Mr Beer: – going out of the post office account?

Raymond Grant: Yes.

Mr Beer: Okay, then step 2?

Raymond Grant: Step 2 is to – well, recover that, check it against – there would then be an opportunity to go and get ARQ data, compare it to who was logged on to the system when that transaction went through. That should identify who the originator was. If the originator is one and the same person, then you would make an assumption, rightly or wrongly, that that person has put a fictitious transaction thorough to credit his own bank account so he can then make withdrawals using a chequebook to pay bills.

So the money never existed.

Mr Beer: What about step 3, which is check the Alliance & Leicester and Royal Bank of Scotland statements to show the money coming in?

Raymond Grant: Yeah. Yes.

Mr Beer: To your knowledge, were either step 1, 2 or 3 ever undertaken?

Raymond Grant: No. Because I’ve seen the production list, I do not recognise any of those –

Mr Beer: When you left the case, did you have an investigation plan in place?

Raymond Grant: I think there was a casework event log.

Mr Beer: Yes, I mean, we can look at that. All it says is he made full and frank admissions, and then that’s the –

Raymond Grant: Does that not say there was still existing inquiries?

Mr Beer: It may do, I can try and find it. But, even if it did, it didn’t set out step 1, step 2 and step 3?

Raymond Grant: No, it doesn’t, because I wasn’t given the opportunity.

Mr Beer: Was there any investigation, to your knowledge, into the concerns raised by Mr Quarm about the ATM machine and money shortages as a result?

Raymond Grant: To my knowledge, no, there wasn’t.

Mr Beer: Was that, again, because you were, as you put it, denied the opportunity?

Raymond Grant: Yes.

Mr Beer: So looking at the papers now, is it right that there was no investigation into any facts or matters raised by Mr Quarm in the interview before the report was submitted to Post Office in Croydon for the purposes of a decision on prosecution?

Raymond Grant: I wouldn’t say there wasn’t any investigation. I think an examination of the branch accounts and I believe there was some important documents, I’m not sure – I honestly can’t recall but there would be – you do a trial balance, the trial balance will tell you what you should have. You can then go back and redo the balance by altering the figures on hand.

If I could just explain, if the Horizon – I’m just going to use rough figures – if the Horizon system says that you were £1,000 short, you could then go back in and adjust your cash element by £1,000 to make that balance but not have the £1,000 there. Do you understand, Mr Beer?

Mr Beer: Yes.

Raymond Grant: Yeah.

Mr Beer: Can we look, please, at POL00166596.

This is an investigation report, we can see that from the top there, “Post Office Limited Confidential: Investigation, Legal”, yes?

If we go to page 5, please. We can see that it was prepared by you on – at least dated on 2 September 2008, yes?

Raymond Grant: Yes.

Mr Beer: So the following month after the interview. If we just go back to page 1 to see what you wrote in the investigation report and, just to be clear, this isn’t the report to the Procurator Fiscal –

Raymond Grant: No.

Mr Beer: – this is an internal report to Post Office.

Raymond Grant: Yes.

Mr Beer: We can see who it concerns, namely Mr Quarm. We can see his length of service. If we scroll down, please. We can see when he was suspended, 23 July, and who gave that authority. We can see who the Designated Prosecution Authority is, Dave Pardoe, a person with whom we’re very familiar. Then we can see what you wrote under “Corporate Security Criminal Law Team”.

You explain in that paragraph at the bottom what led to the investigation – and then over the page, please – you explain what happened in the audit. Scroll down, please. You say subsequently the case was allocated to you; you then speak about the interview, yes?

Raymond Grant: Yes.

Mr Beer: You say he was cautioned. Next paragraph: he asked for a friend, the GS003 was completed, and you append that as Appendix C. You then summarise some of the interview and produce as Appendix B a copy of a letter that Mr Quarm wrote.

Then scroll down, please. You carry on summarising the interview.

Over the page, please. You say:

“He needed to pay for stock for his grocery business from his main supplier who by this time was insisting on a weekly payment of around £4,200. During the course of this discussion Mr Quarm appeared to be in a bit of a daze and was not understanding the questions put to him. He was asked if he was okay, he replied that because of the interview he had not taken his daily medication.”

You allowed him to do this, and confirmed that he was in a fit state to continue. He said he was fine and wished to continue.

Then you carry on summarising the interview.

Then down to the bottom of the page, please, second paragraph up:

“Due to the health condition of Mr Quarm and the inability to contact anyone in authority because of the remote location of [the branch] it was decided by [you] that it would not be appropriate to conduct searches of [his] home address. [He] gave assurances that he would forward copies of all his bank, mortgage and credit card accounts within one week …”

We know that he did that. You say:

“[He] has admitted that since at least January 2008 he has taken advantage of his position as subpostmaster …”

Over the page:

“In view of the admissions made by Mr Quarm and sufficiency of evidence available to support a successful prosecution, it’s recommended that a report should be prepared and submitted to the Procurator Fiscal’s department for consideration as to what future actions should be taken.”

So, essentially, you were asking for a decision on prosecution on the basis of the admissions, as you saw them?

Raymond Grant: Yes, because the – this report has to be in roughly within two weeks –

Mr Beer: Of?

Raymond Grant: – of the interview. There’s a second report which goes to the conduct manager as well, which omits some of the finer detail there.

But, in effect, this is what I would call an interim report requesting that, based on what is included in the transaction – sorry, the transcripts, I am suggesting that there’s sufficiency of evidence that this has been done deliberately, wilfully and knowingly – although it doesn’t say that – but as a deliberate action to gain advantage, which is why it became an embezzlement charge, because embezzlement requires you to be in a position of trust, which Mr Quarm was, he was trusted with the Post Office funds and he is contracted to secure them.

He didn’t have permission to take them and, in his own letter to branch – or the Contracts Manager, he says he has used the Post Office funds. He then, in that letter, I think, also states that he’s going to get a bank loan. It took seven months for the bank loan to appear, which was insufficient for the – to cover the amount that was actually missing and, when he did get the bank loan, the bank loan was not applied to the post office, it was used to offset some of his other debts, in relation to his personal business.

Mr Beer: So had you, in fact, at this time, got any plans to undertake what we’ve described together as steps 1, 2 and 3?

Raymond Grant: It was in my head. It was in my head. It’s not written down anywhere but, had that come back before a report would have been submitted to the Procurator Fiscal, the other enquiries would have been followed through with and we would have had a much more detailed report to go to the Procurator Fiscal.

Mr Beer: Just look, then, at the case file log, POL00166757. This is the case file log that you were referring to earlier and –

Raymond Grant: Yes.

Mr Beer: – I couldn’t quite find the reference at my fingertips. Is this, essentially, a record or supposed to be a record of significant steps in the course of the investigation?

Raymond Grant: Yes.

Mr Beer: If we scroll down, please. If we look at the penultimate entry – sorry, the antepenultimate – 7 August:

“Interview postmaster who admits false accounting and embezzlement by depositing fictitious amounts into personal bank for use in private retail shop.

“[14 August] Suspect offender report completed and sent.”

Is that the document we’ve just looked at?

Raymond Grant: Yes, or perhaps not. Perhaps not. I don’t know –

Mr Beer: Because the one we looked at, if you remember, was dated the 2nd?

Raymond Grant: Yes, yes. I don’t recall what that one there, Suspect Offender Report –

Mr Beer: No. Then 2 September:

“Legal and personnel reports completed and dispatched for authority to prosecute. Tapes copied and inserted into Appendix B.”

So there isn’t any reference there about –

Raymond Grant: No.

Mr Beer: – taking any of the other investigative steps, is there?

Raymond Grant: I don’t think – correct me if I’m wrong – when we actually received the bank statements from Mr Quarm, I can’t remember the date. So it might pre-date this or post-date.

Mr Beer: Okay. But, in any event, this wasn’t added to –

Raymond Grant: No.

Mr Beer: – to say “We’ve now got the bank statements, we can look at those, we’re now going to take step 1” –

Raymond Grant: No.

Mr Beer: – “and look at counterfoils” –

Raymond Grant: No.

Mr Beer: – “for money going out. We’re not going to look at ARQ data”, or “We are going to look at ARQ data”?

Raymond Grant: By its omission, it’s not – well, it’s not there.

Mr Beer: Can we look, please, at POL00166598. We can see, I think, this is a document dated 16 September 2008. If we just scroll down, we can see who it’s from: terry Crowther in the Fraud Team. That was a person down in Croydon, yes?

Raymond Grant: Yes.

Mr Beer: “Authority to proceed to prosecution has been obtained by the Senior Security Manager, Fraud Strand; a copy of the authority is page 7.

“Please prepare and submit a report to the appropriate prosecuting authority for consideration, and advise this office of the [PF’s] reference number”, et cetera.

So were you still in post performing your function at this time?

Raymond Grant: I think I probably was, yes.

Mr Beer: That refers to “Authority to proceed to prosecution”.

Raymond Grant: Yes.

Mr Beer: Other than your report, do you know what the Senior Security Manager, Fraud Strand received in order to decide whether to prosecute?

Raymond Grant: No, I would imagine that he’s seen sight of the case file, because – or one of the offender reports, or a combination of all. I really don’t know what –

Mr Beer: What did you send down to Croydon for him to decide whether to prosecute?

Raymond Grant: I would have sent down a Green Jacket with everything in it.

Mr Beer: So the Green Jacket is referring to the outer skin of the folder?

Raymond Grant: Yes, yes.

Mr Beer: What is inside the skin of the folder?

Raymond Grant: Oh, numerous documents, plus three appendices, Appendix A, B and C. Each one has got different – there’s a schedule of contents that should be in each one.

Mr Beer: If we look, please, to what the Senior Security Manager Fraud Strand did by looking at POL00166597. Look at the foot of the page, please. This is an email from Mr Crowther, who we’ve just seen on the documents, dated 15 September 2008, to Mr David Pardoe:

“Dear Dave

“Please find attached files for the above case for your authority to prosecute in this case.

“This is a Scottish case which in the normal course of events is not submitted to Royal Mail Group Legal Services for advice regarding the sufficiency of the evidence for prosecution …”

Just stop there. Is that right, that Scottish cases did not go through Legal Services to advise on sufficiency of evidence?

Raymond Grant: It’s my understanding that there was no lawyer employed at Criminal Law in Post Office Limited or Royal Mail Group, I can’t remember – but there was no one qualified to make the decision because they’re not trained in Scots Law.

Mr Beer: I was about to ask what the reason for that was, that they didn’t pass through that – I was going to say safety filter, but process?

Raymond Grant: Yes. Sorry, the – yes, that’s –

Mr Beer: They weren’t trained in Scots Law?

Raymond Grant: They weren’t trained in Scots Law, so they took a hands-off approach, as it were.

Mr Beer: So it just went to Mr Pardoe?

Raymond Grant: Yes.

Mr Beer: Was he trained in Scots Law?

Raymond Grant: I don’t know if he was trained in Scots Law but he was a Team Leader in Scotland for a period of time.

Mr Beer: If we scroll up to see what he says, 6.00 in the morning on the 16th:

“Please continue with PF intervention.”

Was that kind of response normal, that there wasn’t any analysis of the evidential strengths and weaknesses; it was just one liner?

Raymond Grant: You see, I don’t know if he did – from that, it’s short, it’s sharp, it’s direct. But what he actually did, whether he reviewed it or whether he didn’t review it I have no knowledge.

Mr Beer: So you don’t know what the process was after you sent the Green Jacket to Croydon?

Raymond Grant: Well, eventually the Green Jacket comes back and I’m not sure when I got it back or if I got it back because we’re now – I think I was still in post at that point. So I probably did get it back.

Mr Beer: Did they always come back to prosecute or did you get ones that came back when Mr Pardoe said, “No, I’m dissatisfied with the evidential sufficiency in this case”?

Raymond Grant: You know, I can’t recall getting a rejected –

Mr Beer: So every case went to prosecution?

Raymond Grant: Yeah, because the decision to prosecute is preparing the case and submitting it to the Procurators Fiscal. Then the Procurators Fiscal has the decision whether he’s going to run with it, whether he wants more enquiries or whether he wants more evidence, or whether he thinks there’s a sufficiency of evidence.

So, although Mr Pardoe is making a decision, it’s a decision made on behalf of Post Office Limited that, yeah, we’re going to – we think there’s enough, we’re going to put it to the Procurator Fiscal and let them test it in court, or test it at the level at the Procurators Fiscal.

Now, I have, in the past, when I’ve submitted something to the Procurator Fiscal and he calls me in and we discuss it, and he says, “Well I need extra, I need more”, and whatever it is, it would have been similar to someone in England going to our Criminal Law Team, them instructing a barrister, and then the barrister deciding “I need more”.

Mr Beer: Can we look at the last stage in the process, albeit it’s not one in which you were involved, at COPF0000002. Can you see this is a copy of a report to the Procurator Fiscal dated 21 April 2009?

Raymond Grant: Yes.

Mr Beer: Or it was received by them on that date?

Raymond Grant: Yes.

Mr Beer: Is this the format – maybe if we just go and look at the second page, as well, and then over the page. Is this the format of reports that would be submitted by Post Office Limited to the Procurator Fiscal that you referred to earlier, that after 2006 it had to be done via a web portal?

Raymond Grant: It looks – it’s difficult to tell because the actual portal itself is all boxy. When you see it printed like that it looks different, but –

Mr Beer: We understand this report to have been the one submitted in April 2009 by Mr Daily. So this is the report that you would have written if you had continued to be in post. I’m not saying the content would have been precisely the same –

Raymond Grant: It would have been in that format, yeah, but I would have expected it to be much more detailed.

Mr Beer: You would have expected it to be much more detailed because it doesn’t say – I’m not going to go into detail because it’s not your document, but it’s apparent, by April 2009, the bank statements from the three accounts have been obtained but none of the steps that we mentioned had been –

Raymond Grant: Yeah, steps 1, 2 and 3 that we discussed earlier.

Mr Beer: Thank you very much. Those are the only questions that I ask you, Mr Grant.

The Witness: Thank you.

Mr Beer: I’m not sure whether there are other questions from Core Participants. I’m looking at the Hudgells team. No, there are not, sir. Thank you very much.

Sir Wyn Williams: All right.

Well, Mr Grant, thank you for coming to the Inquiry – I take it from Scotland – and thank you for answering Mr Beer’s questions.

So we’ll adjourn now until tomorrow morning, yes?

The Witness: Sorry, Sir Wyn, is it possible for me to make a personal statement?

Sir Wyn Williams: Yes, certainly.

The Witness: The outcome of this Inquiry is a very, very sorry state of affairs. No reflection on you, Sir Wyn. The Post Office let the postmasters down, they let the staff who they employed down, by being less than open and honest with information that should have been shared, wasn’t shared, and the ultimate results have led to significant upset, significant difficulties, for people who were left behind.

I can say this because I’ve got no truck with the – I’ve got no link with the Post Office any more, in that they deceived me and they deceived an awful lot more people. For my part in it, I am humbly sorry. I just hope that people do learn from this and are more honest in the future when you’re affecting other people’s lives. Thank you.

Sir Wyn Williams: Thank you, Mr Grant.

As I’ve said, we’ll adjourn now until tomorrow morning at 10.00.

Mr Beer: Thank you very much, sir.

Sir Wyn Williams: Thank you very much.

(12.43 pm)

(The hearing adjourned until 10.00 am the following day)