IN THE BRADFORD CROWN COURT
REGINA
-V-
KHAYYAM ISHAQ
ADDENDUM DEFENCE
CASE STATEMENT
1. This Addendum Defence Case Statement is served in addition to the original
Defence Case Statement dated 29" August 2012.
The Horizon Online system.
2, The malfunctions to the Horizon Online System and the defendant's actions in
response included the following:
i. The Horizon Online system would often crash and freeze and would give
inaccurate total figures at the end of trading and/or balance periods ;
ii, As a result of these problems the defendant called the Horizon Help Desk in
the region of 8-10 times a month on the telephone number f ~
These calls were made over a period of about 12 months ;
iii, The following are some of the reports (date of report and corresponding
allocated reference number) made by the defendant to the Horizon Help Desk
on telephone number! sing an automated switchboard when he
selected the option which dealt with technical problems with the Horizon
system.
a. 19/04/2010 : Report H-22766041
b. 11/05/2010, Report had no Reference Number
FUJ00153991
FUJ00153991
c. 24/06/2010, Report H-22792410
d. 10/07/2010, Report H- 22792410 & Report 2572046
e. 12/7/2010, Report H-022792410
f. 13/07/2010, Report H-22792410
g. 21/07/2010, Report H-2572046
h. 9/08/2010 Report H-2572046
i. 10/08/2010 same reference number as above regarding same problem
Report H-2572046
j. 11/08/2010 same reference number as above regarding same problem
Report H-2572046
k. 12/08/2010 same reference number as above regarding same problem
Report H-2572046
I. 16/08/2010 Report H — 16795487
m. 1/08/2010 Report T1687336
n. 16/09/2010 No reference number
0. 6/10/2010 Report H-16923076
Pp. 27/10/2010 Report H-16951682
It is noted that the telephone call logs recently served by the prosecution deal
only with specific identifiable transaction problems (for example a DVLA tax
disc issued incorrectly) and not with problems experienced with the Horizon
Online system generally whereby erroneous and/or inexplicable results
appeared to be produced by the system ;
When a balance and/or trading report produced by the system showed there
was a shortage of cash the system would give the defendant an option to
“make good the discrepancies’ ;
FUJ00153991
FUJ00153991
FUJ00153991
FUJ00153991
vi. On occasions the defendant did not accept that he had made an error and
requested that the issue be dealt with centrally by the Post Office. On such
occasions he received a letter from Chesterfield (‘Central’) ;
vii. Approximately twice the defendant called Chesterfield (‘Central”) on the
telephone number I to discuss the
discrepancies and shortfalls and in order to explain the problems he was
encountering with the system. No reference numbers were provided by the
Chesterfield staff to the defendant but he was assured the matter would be
investigated ;
vii. Specifically in relation to the indictment period the defendant estimates the
dates to be Mid September 2010 and Mid December 2010 when such calls
were made.
ix. Prior to the indictment period, the problems and issues were discussed by the
defendant with Post Office staff in Chesterfield during the middle of each
calendar month from about November 2009 to August 2010.
This addendum defence statement has been read and approved by me.
(Khayyam Ishaq)
Musa A Patel & Co Solicitors
73 Bradford Road
DEWSBURY
West Yorkshire
WF13 2EG
DX 23371 DEWSBURY