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The Post Office Horizon IT Inquiry 8 December 2022
Thursday, 8 December 2022
(10.00 am)
THE USHER: Good morning everyone. This is just to
let you know that unfortunately we need to pause
for about ten minutes. The hearing will be
starting probably about 10.10, I would think,
Thank you very much, Ill come and do another
announcement shortly.
(10.02 am)
(Proceedings delayed)
(10.15 am)
THE USHER: Ladies and gentlemen, thank you for your
patience. We are trying to resolve an important
technical glitch, so now the hearing has been
deferred until 10.30. Thank you. I shall
announce again when we're ready to start
(10.16 am)
(A short break)
(10.33 am)
THE USHER: Ladies and gentlemen, a quick update:
the Chair would like to make a brief
announcement so he'll be coming in shortly.
Thank you.
SIR WYN WILLIAMS: This not what I had in mind, but
I've come in because I want to know from those
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hear this and wishing to view it and have been
waiting to do so.
SIR WYN WILLIAMS: No, no, I follow all that.
MR STEIN: So we may need, even a few minutes right
now, just to discuss this particular issue.
SIR WYN WILLIAMS: Well, on the basis of your
estimates, we can reasonably delay for at least
another 30 minutes, which is what I'm prepared
to do. We resume it at that point. But, of
course, I'l be holding you all to your
estimates much more strictly, even than usual.
(10.35 am)
(A short break)
(11.00 am)
SIR WYN WILLIAMS: Give us a factual update,
Mr Beer.
MR BEER: Yes, of course. I'm afraid it’s not been
possible to resolve the technical issue that is
preventing the Inquiry from presently streaming
the proceedings. That is an issue to do with
this building's connectivity. However, if you
do decide to proceed, sir, I have been told that
a transcript of today's proceedings will be made
as we go along and, in fact, will be displayed
for people in this room in the usual way. But,
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who intend to speak how long, realistically,
they want because, although there is a great
Public interest in having a live feed, in my
view, there's a greater public interest in
dealing with this expeditiously today and also
giving people a reasonable amount of time.
So there's a limit on how long I'm prepared
to wait for a live feed -- that's what it boils
down to -- but it would obviously assist me if
people could explain how long they intend to
take.
So let’s go by the batting order, I think
Mr Chapman was first up.
Oh, sorry, Ms Gallafent. There we are, I'm
completely disoriented, I'm sorry.
MS GALLAFENT: I will be definitely 45 minutes,
possibly a litle bit longer.
SIR WYN WILLIAMS: Right.
MR CHAPMAN: Ten minutes.
SIR WYN WILLIAMS: So that's an hour-ish.
MR MOLONEY: 25, sir.
SIR WYN WILLIAMS: Mr Henry?
MRHENRY: 40, sir.
SIR WYN WILLIAMS: Mr Stein?
MR STEIN: 45. We have clients who are wishing to
2
more importantly, that will be uploaded to the
Inquiry’s website at the conclusion of
proceedings today.
An audio and visual recording of today's
proceedings will also be made and that will also
be uploaded to the Inquiry's website in the
normal way, So people who missed the proceedings
unfolding today can watch them back after they
have concluded.
So, essentially, what is missing is the live
YouTube feed, which means that members of the
public who are not in this room, and those Core
Participants who are not in this room, will be
unable to see and hear the proceedings, as they
unfold.
SIR WYN WILLIAMS: My inclination is that, in those
circumstances, although it's not ideal, it's
better than adjourning, which is the option, in
effect.
Mr Stein?
MR STEIN: We have clients that have been emailing
my instructing solicitors asking for when the
live stream is going to be available and hoping
that they will be able to take part in this
remotely. On the other side of the coin, there
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is the practicality that, if we adjourn from 1 Submissions by MS GALLAFENT
today's date, what further date would we get, 2 MSGALLAFENT: Good moming. Thank you, sir. As
when would that be, and the like. 3 you know, I appear on behalf of Post Office, we
Our rather reluctant but necessarily 4 are grateful for the opportunity to update the
practical answer is to agree, sir, that we go 5 Inquiry on developments in relation to issues of
ahead today, partly, I must admit, in my own 6 compensation. In our opening statement, at the
mind thinking that I am last in terms of the 7 beginning of Phase 2, we provided a short update
speaking order and we may well resolve problems 8 ‘on developments since the compensation hearings
by the time we get there, at least for my own 9 of July, and last week we submitted detailed
part. 10 written estimates setting out developments to
SIR WYN WILLIAMS: Yes, well, 'm not sure if "1 the end of November.
Mr Beer mentioned this, but if the live stream 12 For the purpose of today's hearing, I intend
is rescued, then it will begin as soon as it 13 to structure our oral submissions by the
can. So there is that possibility but, 14 reference to the key conclusions reached by you,
obviously, we can't rely on that possibility. 15 sir, in your progress update, dated 15 August of
MR STEIN: Thank you, sir. 16 this year, focusing on those conclusions, which
SIR WYN WILLIAMS: I also think it is important to 7 concemed matters for which Post Office has
explain that, if there had been live evidence, 18 responsibility, and leaving aside, for the time
particularly of important witnesses, I might 19 being, those conclusions which you've indicated
have taken a different view. But I think, given 20 may be considered in Phase 5 in due course.
that we are simply dealing with submissions, the 21 {do so having particular regard to your
balance falls in terms of carrying on. So 22 indication in that document that, if it became
that's what we'll do. 23 clear in subsequent weeks that progress was too
Ms Gallafent? 24 slow, in particular finalising a Group
25 Litigation Scheme and/or making payments
5 6
thereunder, you would very likely determine that 1 if just four more offers go out today, we will
you should deliver to the minister an interim 2 have made 95 per cent as of today. We
court, pursuant to the Inquiries Act, containing 3 anticipate four, if not more, offers will be
specific recommendations. 4 going out today.
I star, sir, if I may, with the Historical 5 The total value of the offers made to date
Shortfall Scheme. At first the issue of the 6 is approximately £74 million, including interest
pace of making offers, paragraph 7.2 of your 7 and the deduction of withheld tax.
update. 8 Of those offers, 1,804 applicants, which is
So far as the pace of making offers of 9 over 80 per cent, have accepted the offer made
compensation is concerned, you noted in your 10 to them, and payments have been made in
previous update, this had quickened considerably "1 98 per cent of those cases. That amounts to
during the course of the previous 12 months. 12 a total value of payments at approximately
That pace has been maintained in the last 13 £44.5 million, again including interest and the
four months, in each of which month the Post 14 deduction of withheld tax.
Office has exceeded its target for the 15 There currently remain just 134 applicants
percentage of offers made in respect of eligible 16 who have not yet received an offer letter. Now
applications. 17 that's usually in the light of a case specific
From the group of applications made before 18 complexity, meaning it's been slower to progress
the original extended deadline in November 2020, 19 to the point of an offer. They can broadly fall
as of yesterday, Post Office has made offers to 20 into three categories. The first is
2,240 applicants. That represents offers in 21 applications with complexities concerning
94 per cent of eligible applications. Sir, as 22 insolvency or bankruptcy.
you'll be aware, the target by the end of this 23 Now, it has taken longer to establish the
month is 95 per cent. I was told shortly before 24 relevant circumstances of these applications, in
coming into the hearing room this morning that 25 the light of the potential interest or interests
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of the bankruptcy or insolvency practitioners, 1 and I'll come on to that in the context of the
such as the Official Receiver. To date, offers 2 second process in relation to overturned
have been made in 19 of such cases. 3 historical convictions in due course — again,
Separate to that the Independent Advisory — 4 the Independent Advisory Panel is considering
SIR WYN WILLIAMS: Ms Gallafent, do you have 5 the fair approach to this category of applicants
a figure for how many insolvency cases there 6 and expects to make offers again in respect of
are, in the HSS, even approximately? 7 them, again, early next year.
MS GALLAFENT: I don't, but I'm sure someone will be 8 The third group of somewhat slower cases --
able to tell me when I'm on my feet. But we're 9 SIRWYNWILLIAMS: So that I'm clear, these are
talking about 134 in total and this is one of 10 people who were prosecuted but not convicted —
the groups of people, which is a dwindling 11 MSGALLAFENT: Yes
number, if I can put it in that way. 12 SIRWYN WILLIAMS: -- who did not form part of the
There are also, within this category, 13 GLO.
a group of cases where a claim has been made of 14 MSGALLAFENT: Exactly, sir, and I'll come on to
losses flowing from the bankruptcy or insolvency 15 that in due course.
and the Independent Advisory Panel is 16 The third category then, in relation to the
considering the fair approach to be adopted in 7 HSS, where matters have been slower than
that case. Post Office expects to make offers 18 otherwise, is where information is required from
in respect of those claims early next year. The 19 the respective applicant or a third party in
second category where things have taken slightly 20 order to fairly assess them. So that might
longer is applicants who were prosecuted but not. 21 include circumstances in which responses are
convicted. 22 outstanding for the applicant, for example, if
Now, with the benefit of the progress made 23 someone has ill health and there is a delay in
on the issue of non-pecuniary losses for 24 responding, or outstanding requests from the
postmasters who were prosecuted and convicted — 25 National Health Service, for example, in terms
9 10
of medical records in support of a personal 1 that revised offers can be made as appropriate.
injury claim 2 Sir, you may like to note that such revised
‘As soon as information is received, the 3 offers have been made to applicants, whether or
panel will consider the application and 4 not they've had legal representation and, to
an appropriate offer letter will be prepared and 5 assist, sir, to date, 29 applicants have
sent. Again, in this context, Post Office is 6 received revised offers of increased value,
particularly mindful of the importance of 7 before going on to settle their claims as part
striking the appropriate balance between the 8 of either the pre, post or during the good faith
speed of decision making and considerations of 9 meeting stages, none of whom had legal
faimess. 10 representation.
For completeness, I note, in this context, "1 Now, there are points made in relation to
the points raised by Hudgell Solicitors in their 12 delays in holding good faith meetings. You may
written submissions, in a section entitled 13 wish to note that 100 of those meetings have
“Independence Issues" that, in fact, concerns 14 been held since the scheme began. 21 are
the question of heads of loss, which they say 15 planned over the next two months. Again, I'd
were not identified until after the initial 16 emphasise that a good faith meeting isn't held
offer has been made by Post Office 17 in every case where an initial offer is
It's unnecessary, for my purposes today, for 18 rejected.
me to go into the detail of the three cases they 19 in more than half of those cases, following
identify but I would emphasise that Post 20 interactions between the applicant and the Post
Office's position is that the purpose and value 21 Office, which are prompted by Post Office
of the good faith meeting, under the procedures 22 seeking to understand the reasons for rejecting,
of the Historical Shortfall Scheme, is to be 23 the offer is accepted without proceeding to
able to discuss exactly those sorts of issues 24 a good faith meeting.
and any other issues that might arise, in order 25 Where a good faith meeting is offered,
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The Post Office Horizon IT Inquiry 8 December 2022
either upon request or proactively, an applicant
is offered three dates on which to attend.
Delays can occur where other parties, such as
legal representatives or medical practitioners,
are part of the process, or where additional
information is requested as a prerequisite to
the good faith meeting.
But, again, I'd make the point, which is
Post Office continues to look at ways to
streamline the dispute resolution process,
including the good faith meetings, to reduce the
time taken, whilst continuing to ensure that it
enables applicants and applications to be
resolved fairly and in good faith.
Can I turn to late applicants, dealt with at
paragraph 7.3.
SIR WYN WILLIAMS: Before you do, just so I can keep
track of what you say, have I got this right:
there have been 100 good faith meetings?
MS GALLAFENT: Yes.
SIR WYN WILLIAMS: In 29 of them, there's been
an increase in the offer where people are
unrepresented, yes?
MS GALLAFENT: No, the increases in the offer where
people are unrepresented, that may have been
13
that date, it had extended its financial support
to Post Office so that it could accept eligible
late applications as part of the scheme.
Post Office has now written to all but one
of the 230 postmasters who previously told it
that they wished to join the HSS, after the
November 2020 deadline, inviting them to join
the scheme, providing them with an application
form and the Consequential Loss Principles and
Guidance. On 12 October Post Office also put
a notice on the Historical Shortfall Scheme.
website, inviting further such applications,
linking to a late applicant specific question
and answer document and the application form.
Sir, we provided copies of those documents to go
with our written submissions for your note.
As at yesterday, Post Office has received
93 late applications, of which 66 contain
a complete set of information. At this stage,
Post Office has assessed 68 claims for
eligibility under the scheme. I note that some
applications contain more than one claim, for
example, if there was more than one Post Office
under that particular postmaster.
There should be confirmation of eligibility
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before a good faith meeting, at a good faith
meeting or afterwards.
SIR WYN WILLIAMS: So have you got any information
about what has happened after a good faith
meeting in terms of increase or acceptance?
MS GALLAFENT: Yes, and I'll ~ those are set out in
our written submissions. I can take you to them
at paragraph ~ yes, we have set those out.
Yes.
SIR WYN WILLIAMS: Thank you. Right.
MS GALLAFENT: So I was just picking up on the
‘ongoing consideration of ways we can streamline
the process.
Moving then to late applications,
paragraph 7.3, these are obviously applications
that are made or will be made after the
27 November 2020 deadline for the scheme. For
the purposes of today, I'm not going to focus on
the reasons for delay in determining whether
those applications should have been accepted or
rejected into the scheme. I obviously recognise
that’s a matter to which the Inquiry may wish to
return to in Phase 5, but I intend instead today
to provide an update on developments since
BEIS's announcement on 6 October that, as of
14
sent to applicants in the next week or so, once
identification and verification checks are also
complete. 27 of the late applications, are
partially complete and we are contacting
applicants for missing information.
Sir, one of the other key conclusions in the
progress update was that any applicant whose
claim is rejected by reason of having been made
after 27 November 2020, should have the right to
have that decision reviewed by the Independent
Advisory Panel, and the scheme amended to make
that clear.
Now, the website for the scheme confirms
that applicants are asked to explain why they
were unable to submit an application by the
November 2020 date, provides, by way of example,
they didn't know about the scheme, were poorly,
overseas, caring for a relative.
Post Office has recently updated the
question and answers on the website to clarify
the approach to be taken in circumstances where
a late applicant has provisionally been declined
by Post Office, on the basis that they've not
provided a sufficient reason for missing the
original deadline. Such applicants will be
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The Post Office Horizon IT Inquiry
presented with a further opportunity to provide
one, and Post Office will suggest a list of the
reasons that might apply, in their cases.
If an applicant still cannot provide
a reason or their reason isn't, for whatever
reason, accepted by Post Office, it will let
them know and the matter will be referred to
an independent third party for a final decision.
Post Office considers that this will provide
the requisite independence for determining the
issue, but without adding to the workload of the
Independent Advisory Panel and, therefore,
risking slowing down its consideration of other
substantive claims.
To date, no applications have been
provisionally declined by Post Office, on the
basis that the applicant hasn't provided
a sufficient reason.
In the light of the revised Q&A document,
the Post Office expects there will be very few,
if any, applications deemed to be ineligible on
the grounds of absence of a reason for lateness
alone.
SIR WYN WILLIAMS: If that is the case — and
obviously I accept what you tell me,
7
current approach under the scheme to processing
applications that were made by late applicants,
and it was suggested that would be subject to
ensuring any such variations but not result in
any less fair a process.
Having considered the issue further, I can
confirm that Post Office has no intention to
introduce any variations in this respect. Late
applications which are accepted as eligible will
be processed in exactly the same way as those
received prior to the November 2020 deadline.
Can I turn to the subject of legal advice
and assistance? Again, in line with your
recommendation, sir, as I explained in our
opening statement, with effect from 10 October
of this year, Post Office has been offering to
pay the reasonable legal costs of the remaining
applicants in the scheme, whose claims are of
a higher value and more complex than those which
were previously settled.
Since that date, Post Office has invited
applicants, who consider they may require
additional support, to discuss and ultimately,
we hope, agree the position with them.
We hope that this ensures that applicants
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8 December 2022
Ms Gallafent -- doesn't this seem a great
rigmarole to go through, going back and forth
about reasons as to why they haven't applied in
time, when the reality is going to be that
they'll be accepted?
MS GALLAFENT: Sir, I wouldn't anticipate it as
a great rigmarole; it may be a sentence added to
the application form.
SIR WYN WILLIAMS: The time is important in this
‘case and I am anxious to avoid unnecessary
bureaucracy. Anyway, there we are.
MS GALLAFENT: Of course, sir. Your recommendation
or, as it were, key conclusion was that there
should be an independent person to review, if
required. That we have accepted or put in
place,
SIR WYN WILLIAMS: But that was on the basis there
might be a fight over it, Ms Gallafent. If
there's nothing to be a fight over it then -
MS GALLAFENT: We anticipate it is unlikely, sir.
SIR WYN WILLIAMS: All right.
MS GALLAFENT: You may recall in our opening
statement, at the beginning of Phase 2, we
indicated that Post Office was considering
whether there should be any variations to the
18
may obtain the assistance they require in
confidence that Post Office will pay those
reasonable legal costs
But since 10 October of this year, there
have been 29 requests received for legal fees.
Post Office has endeavoured to work through
those fee requests as quickly as it can, to
avoid delay in processing applications and with
a view to establishing a more standardised, and
therefore quicker and easier, basis for cost
claims going forward.
As of yesterday, agreement has been reached
with Hudgell Solicitors on initial sample cases,
as well as a general process for assessing the
reasonableness of the costs. It is hoped that
agreement can similarly be reached quickly on
the applications received from other
representatives.
The next key conclusion I propose to address
is interim payments. I indicated in our opening
submissions in October that Post Office would be
keeping under review the issue of whether it
should reconsider its policy on interim payments
and it has now done so.
As recently announced on its website, to
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assist postmasters, including those who may be 1 suggested, was necessary, either as a matter of
experiencing financial difficulties or suffering 2 jurisdiction or in order to publicise the
from health issues, Post Office will consider 3 availability of such payments. Of course, in
making an interim payment to an applicant of up 4 making these submissions, we hope to make
to £30,000, in advance of its sending a final 5 awareness of the potential for interim payments
‘outcome letter, once it's accepted the 6 amongst applicants and potential applicants. In
application, informed the applicant it met the 7 substance, however, we have accepted your
eligibility criteria and identified the likely 8 recommendation in this respect.
shortfall amount. 9 Before turning to the key conclusions in
Post Office has particularly confirmed it 10 relation to overturned historical convictions,
will not ask for such payments back, whatever "1 can I just anticipate one point raised in the
the ultimate outcome of the claim. Moreover, if 12 written submissions of Howe+Co, in relation to
an applicant has received an offer but needs 13 the unusual position of an individual who it
more time to review or dispute it, Post Office 14 seems may have been effectively running a Post
will also consider making an interim payment of 15 Office branch, whilst not a postmaster or
at least 50 per cent of the offer. 16 an employee of the branch.
‘As well as updating the website to this, 7 The position of that individual is
effect, the ability to request an interim 18 particularly complex, and Post Office will be
payment will be specifically drawn to the 19 reviewing her position further and reverting to
attention of any applicants who enter the 20 Howe+Co as soon as it is able to do so.
scheme's dispute resolution process and each 21 Turing, then, to overturned historical
application for such a payment will, in due 22 convictions. I start with the payment of
course, be assessed on a case-by-case basis. 23 interim payments.
Post Office didn't consider that a revision 24 Of the 83 convictions that have been
to the scheme's terms of reference, as you've 25 overturned on appeal, to date, applications for
21 22
initial interim payments have been made in 82 1 MSGALLAFENT: Excellent. Thank you for the
cases; the solicitors representing the remaining 2 warning. It could have gone horribly wrong if
case have indicated and confirmed they didn't 3 I hadn't been tipped off, thank you
wish to apply for an interim payment. 4 So I was just dealing with the amount of
Initial interim payments have been offered 5 interim payments made to date, just short of
in 79 cases and accepted in 77, with two pending 6 £14 million.
acceptance. Those two offers were only issued 7 You'll also wish to note that, in the light
in the last week or so. The remaining four 8 of Lord Dyson's findings, in the early neutral
cases consist of the three public interest only 9 evaluations process, Post Office decided to
cases, which I'll come on to, and the one who 10 increase the value of future interim payments it
has confirmed that an interim application will "1 may make up to £163,000.
not be made. 12 20 claimants who have previously received
Post Office has, in addition, made second 13 an initial interim payment, but unable to submit
additional interim payments in respect of three 14 a non-pecuniary claim, have been offered
cases and offered a second interim payment in 15 a further top-up payment of up to £63,000 from
a further three cases. 16 on or around 1 December of this year.
As at yesterday, the combined value of those 17 Of those, 17 have accepted the offer and
interim payments is, approximately, 18 payment has been processed for payment before
£7.975 million, so very little under £8 million. 19 the end of this year.
You will also, sir, wish to note that, in 20 Again, the historical matters section of the
the light of Lord Dyson's findings in the early 21 Post Office's website was updated on
neutral evaluation process ~ 22 41 November, to reflect the provision for
SIR WYN WILLIAMS: Can I just stop you to say that 23 interim payments at this level, and legal
the live stream is now working, so that you are 24 representatives have been informed. This should
on screen, as they say, Ms Gallafent. 25 ensure that all claimants who are eligible for
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an interim payment have the opportunity to 1 them being apply to Post Office in the same way
receive up to £163,000 by the end of this year. 2 as those with overturned historic convictions
Sir, in relation to your reservations 3 currently do, or by applying to the Group
concerning the three cases in applications for 4 Litigation Scheme announced by the Secretary of
interim payments have been declined, which we've 5 State.
described as the "public interest only cases", 6 In circumstances where the Group Litigation
as we explained in our opening statement, it has. 7 ‘Scheme is intended to deliver compensation for
been agreed with Hudgell Solicitors to go to 8 GLO members who were not convicted of criminal
independent mediation, in order to seek to 9 offences, which would obviously include those
resolve these disputes and we continue to work 10 but not limited to those who were acquitted,
constructively with the solicitors in relation "1 Post Office has not taken any steps to include
to this process. 12 them in its own processes for providing
Ina related conclusion, sir, you indicated 13 ‘compensation
that Post Office should not be the final arbiter 14 In this context, I wish to make it clear
of applications for interim payments if the 15 though, although Hudgell Solicitors suggested in
claim is rejected. In line with its approach in 16 their written submissions that applications by
relation to the public interest only cases the, 7 GLO claimants could already have been accepted
Post Office agrees that it should not be the 18 by Post Office, we suspect this is
final arbiter in such cases, although reiterates 19 a typographical error. The GLO ex gratia scheme
its view that it appears unlikely that the issue 20 will be delivered directly by BEIS, as
will ise again. 21 yesterday's announcement by BEIS confirmed, but
Sir, in your progress update, you identified 22 the applications were never to be made to us.
two alternative routes by which claimants in the 23 Can I move ~
group litigation, who were acquitted, should be 24 SIRWYN WILLIAMS: What you were anticipating on
able to claim compensation, either by way of 25 behalf of the Post Office is that non -- those
25 26
who were acquitted but who did not form part of, 1 whom had participated in the ENE, the early
the GLO can be dealt with under HSS ~ 2 neutral evaluation process
MS GALLAFENT: Yes. 3 Starting then with non-pecuniary claims,
SIR WYN WILLIAMS: -- and those who were acquitted, 4 which, as you know, was the subject matter of
who were part of the GLO, will be dealt with in 5 the ENE process, I start with the cohort of
the GLO scheme -- 6 claimants who participated in that process.
MS GALLAFENT: Exactly. 7 There were ten such claimants. Post Office has
SIR WYN WILLIAMS: -- so that there is a route for 8 made non-pecuniary settlement offers to all ten
everyone; is that what you're telling me? 9 of those ENE claimants. Of those, six of the
MS GALLAFENT: Yes, exactly, sir. 10 ENE claimants have settled and been paid the
Contingency planning, if I may move to that "1 non-pecuniary element of their claim.
topic. In order to address your conclusion that 12 One claimant has already received the value
there should be contingency planning as to how 13 of the non-pecuniary element to their claim via
disputes about final compensation payments are 14 two interim payments, and the other three
to be resolved, in the event that negotiated 15 claimants have accepted terms of settlement that
settlements are not possible, I start by setting 16 payment cannot be made by Post Office until
out progress to date. Together with claimants 17 insolvency arrangements have been finalised.
and their legal representatives, Post Office 18 Moving to claimants who were not
continues to make good progress in settling the 19 participants in the ENE process, Post Office has
claims of postmasters with overtumed Horizon 20 received non-pecuniary claims from a further
related convictions. 21 43 claimants -- again, I exclude the three
Again, as at yesterday, the position as is, 22 public interest only claimants from that
as follows: Post Office has reached full and 23 figure -- all of whom have overtumed Horizon
final settlement covering both pecuniary and 24 related convictions. Of those 43, Post Office
non-pecuniary losses with two claimants, both of 25 has made offers in respect of 33 of those
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claims, and the total value of those offers --
and these, of course, figures exclude the ten
ENE claimants ~- is approximately £4.23 million
Again, that excludes the value of the offers of
interim payments already made in the same cases.
Of those 33, offers have been accepted in
26 of those claims.
Payments have already been made in 19 of
those claims, within the agreed payment terms of
28 days from receipt of signed acceptance
letters. I'd emphasise, in practice, Post
Office endeavours to pay much quicker than this
timescale, usually around ten days if possible.
Of the other seven, four are scheduled for
payment today and payment for the other three,
and those acceptances were only received on 5 or
6 December; payment will be made as soon as
practicable.
Post Office has now made a total value of
approximately £3.1 million, by way of final
compensation, again excluding offers of interim
payments made in those same cases.
The remaining ten claims, in which offers
had not yet been made, were only received at the
end of last month, they are under assessment by
29
historical matters section of its website to
make it clear that it will seek to finalise
compensation that is over and above the interim
payments of up to £163,000, for personal or
non-pecuniary damages at the earliest possible
opportunity, whilst awaiting claims or
finalising settlements in relation to pecuniary
aspects of a claim. This to ensure that payment
of compensation is not unnecessarily delayed.
Can I pause here to return to the issue of
bankruptcy, which has been raised by several of
the postmaster representatives. The
difficulties that that issue gave rise to in the
overtumed historical convictions context, has
been considered at a high level within Post
Office, discussed with BEIS, discussed with His
Majesty's Treasury. It is hoped a position will
be reached early in the New Year.
Those representing postmasters in these
cases will know that Post Office’s position is
that there is no justification for delaying the
settlement of non-pecuniary losses in order to
consider estates’ potential claims. We will
obviously, sir, update the Inquiry, as soon as
we have any developments in this respect.
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Post Office with the intention of issuing offers
before Christmas.
Post Office expects to receive three further
potential non-pecuniary claims by the end of
this year; assuming that is the case, is on
track to have made offers in those by the end of
the year or, if claims arrive later than
expected, early January of next year.
Together with UKGI and BEIS, it is working
hard to see that this is accomplished and,
again, we would like to take this opportunity to
reiterate Post Office's encouragement to all
potential claimants to come forward with their
claims as soon as possible.
As we explained in our opening statement,
Post Office will of more help and support to any
claimants with overtumed convictions who do not
currently have the benefit of legal
representation, to ensure they're aware of the
opportunity to take their non-pecuniary claims
forward on an expedited basis and are aware of
what they need to do so.
In addition, I'd like to flag up one further
development in relation to non-pecuniary
damages. Post Office recently updated the
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SIR WYN WILLIAMS: As far as you were aware, are
there points of legal principle, in respect of
persons who have been made bankrupt, who are
either discharged or undischarged, which are
standing in the way, so to speak, of progress,
or is the law agreed and giving effect to it is
proving difficult?
MS GALLAFENT: Opinions differ, and there is one, as.
I understand it, estate which takes a different
view to the views taken by others. So we hope
to make some progress in respect of coming to
an agreed position. So there is a legal
dispute, not with Post Office — we've made our
position clear -- but there is a legal dispute.
SIR WYN WILLIAMS: There is a legal dispute?
MS GALLAFENT: Yes, there is. But, as I've
indicated, we hope to make progress relatively
rapidly in that respect.
SIR WYN WILLIAMS: Well, I'm only musing aloud but
I might take my own legal advice about this.
MS GALLAFENT: I don't think Post Office would seek
to dissuade you from that, Sir Wyn
Can I move to pecuniary claims. As I've
noted, two of those have already been settled as
part of those full and final settlement
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agreements. Post Office has received a further 1 for consideration of future claims for pecuniary
six claims with supporting schedules of loss, 2 loss is established.
since my open anything statement, in relation to 3 In this context, we note the suggestion made
which Post Office is working with the solicitors 4 by Howe+Co, that the development of a scheme has
concemed on evidential matters to enable 5 caused exceptional delay. Let me emphasise, as
opening offers to be made. 6 demonstrated by the progress made in respect of
The claims for pecuniary losses that we've 7 non-pecuniary claims submitted by Hudgell and Co
received to date are complex. They require 8 (Sic), following the ENE, representing 71 of the
significant legal expertise to assess. In order 9 83 persons whose Horizon convictions have been
to maintain the momentum of the process in these 10 overturned, i's clear, we submit, that the
circumstances, of providing offers to claimants "1 absence of a formal scheme has been no
in respect of pecuniary losses, Post Office will 12 impediment to the bringing of, and settlement
be looking to make partial settlement payments 13 of, claims.
to claimants in respect of agreed heads of loss 14 The alternatives are not, we say, as Howe+Co
as it's done previously. 15 suggest: that the absence of a formal scheme
More broadly, Post Office is in active 16 means that postmasters would be required instead
discussions with claimant representatives about 7 to take the risk of commencing formal legal
the best way to approach the calculation of 18 proceedings. I would note that proceedings have
compensation for pecuniary losses, with a view 19 not been commenced in any of the claims in which
to arriving at a set of principles which is 20 offers have been made to date.
agreed by all concemed. These discussions have 21 At the risk of repetition, I would again
included consideration of incorporating oral 22 emphasise that Post Office would encourage all
hearings into the process. 23 potential claimants to present their claims as
It's hoped that the principles and processes 24 soon as they are able to do so, in relation to
will be clarified in the New Year, and a basis 25 pecuniary loss.
33 34
While I have the opportunity, I would also 1 and help to guide individuals to emotional
like to reiterate publicly, Post Office's 2 support tools.
encouragement to convicted postmasters to 3 Sir, as you will be well aware, Citizens
consider their options for appeal. We've 4 Advice is a well known and trusted brand with
already set out in our written submissions the 5 experience of supporting members of the public
lengths that Post Office has gone to, both 6 ‘on challenging matters such as this.
independently and working together with CCRC, to 7 This service went live on 17 November this
ensure that all convicted postmasters are 8 year, with a dedicated microsite on the Citizens
contacted and encouraged to consider the options 9 ‘Advice web page. Post Office's website also
for appeal. 10 provides a link to the relevant page and it's
Today, I'd just like to highlight a recent "1 working with Citizens Advice to raise awareness
and important development in relation to support 12 of this service through social media channels
for such persons. In February of this year, the 13 and a banner on the Citizens Advice homepage.
BEIS Select Committee recommended the formation 14 In addition, a telephone helpline will be
of an independent body to support individuals 15 available, through which trained agents will be
with potentially relevant convictions, who may, 16 able to answer questions affected individuals
understandably, be reluctant to engage with Post 17 may have.
Office, due to the distress their historic 18 Citizens Advice will track any calls
convictions may have caused them 19 received on the helpline outside of working
Post Office has now agreed a package of 20 hours. Individuals will be able to request
support for such individuals through Citizens 21 a callback by completing a form on the website
Advice. This service aims to provide 22 in addition
preliminary information around the appeals 23 Against this background, whilst we entirely
process, the support which may be available 24 agree with Howe+Co's submission that something
through Legal Aid, information around benefits, 25 must be done to contact people whose convictions
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could be challenged, that process, including the
Post Office working together with the CCRC, has
already been underway for many months and will
now be firmly supported by the role to be played
by Citizens Advice.
In conclusion, having regard to the progress
set out in our written submissions and I hope
highlighted in my oral submissions today,
against the key conclusions in your progress
update, insofar as Post Office has
responsibility for those matters, it is our
respectful submission that such progress could
not reasonably be characterised as too slow in
all the circumstances, such as to justify
delivering an interim report to the Minister
containing specific recommendations.
Post Office does, of course, though, welcome
any further views or guidance you may have and,
of course, we stand ready to provide search
updates on compensation issues as the Inquiry
may find of assistance as the hearings progress.
Can I just make two further points. The
first is
SIR WYN WILLIAMS: Before you do that, while it's in
my mind, going back to people who have been
37
straight to the Court of Appeal is the quickest
way.
SIR WYN WILLIAMS: Right. Well, if I found
difficulty in getting that squarely in my head,
it may not be surprising that many other people
find the same difficulty.
MR MOLONEY: Including me, sir.
MS GALLAFENT: The first was I was going to pick
up ~ very helpfully my solicitor has indicated,
you asked, sir, about the number of applications
in which insolvency or bankruptcy issues have
arisen. As of 6 December, there are 72
applications in the Historical Shortfall Scheme,
in which either the Post Office understands the
course of action rests in the insolvency
bankruptcy or practitioner, or it's currently
unclear whether or not it does. Work is ongoing
to establish where it sits. That includes the
19 applications in which offers have been made.
In addition, there are approximately ten of
the 30 dissolved company applications which may
be impacted by insolvency or bankruptcy issues.
Again, the processing of those applications is
ongoing.
Sir, I sense a keen interest on behalf of
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convicted but who haven't yet engaged with
trying to get their conviction overtumed, am
I right in thinking that the Criminal Cases
Review Commission may not be the quickest and
suggest route, especially for those who have
never appealed before? In other words, if you
were convicted in, shall we say, 2010, for the
sake of argument, you didn't appeal, presumably
the quickest route now is simply to apply out of
time for the leave to appeal to the Court of
Appeal, without involving the Criminal Cases
Review Commission, provided, of course, you can
bring yourself within the terms of the Hamilton
judgment.
MS GALLAFENT: I'l defer to Mr Moloney but
I understand that to be the case.
SIR WYN WILLIAMS: Is that right, Mr Moloney, or
have I set a hare running?
MR MOLONEY: No, sir, you're absolutely right. It's
the involvement of the Criminal Cases Review
Commission in alerting people to the possibility
of appeal, whether by way of the CCRC, if
they've had a previous appeal, or they were
convicted in the Magistrates Court, which the
CCRC are were dealing with. Otherwise then
38
all postmasters and, sir, you as well we will
certainly seek to update I think on perhaps
a proactive basis without waiting to be invited,
how things go in relation to insolvency and
bankruptcy issues, in both the OHC and the HSS
context.
SIR WYN WILLIAMS: It’s just the feeling I've got
that this seems to be quite a difficult
problem —
MS GALLAFENT: Yes.
SIR WYN WILLIAMS: — and we want to solve it.
MS GALLAFENT: We also share that.
SIR WYN WILLIAMS: I was using "we" in every sense
of the word "we".
MS GALLAFENT: Absolutely, I'm very grateful.
Sir, just one further matter, if I may, on
the subject of restorative justice. Post Office
notes the points made by Howe+Co on restorative
justice in their written submissions. They
rightly recognise this is not a compensation
issue and, as such, we say it doesn't properly
fall within the scope of today's hearing but,
nevertheless, we'd wish to make two points in
this context.
The first is that Post Office does not
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consider that its offer, which I made, sir, you
may remember, in my oral opening submissions,
for senior members of Post Office to meet
directly with affected postmasters in order to
listen to them and make suitable apologies,
requires the establishment of a formal scheme or
process, necessitating the involvement of
solicitors on either side.
It's approach to arranging meetings will be
flexible and sympathetic to those affected and
supported by the existing dispute resolution
team, who already support applicants to the HSS,
many of whom are former post masters themselves.
The second point is that Post Office's offer
reflected exactly what was requested on behalf
of the Core Participants represented by Howe+Co
in their opening oral submissions. What we
understand now to be proposed in their written
submissions is that, in the absence of Post
Office and BEIS agreeing to establish what they
would describe as a restorative justice fund,
you, sure, should make a formal recommendation
of the establishment of such a process and
funding.
Sir, of course, that goes well beyond the
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The Department wishes to begin by
reiterating its commitment to ensuring
subpostmasters receive full and fair
compensation as quickly as possible, and this
remains a key ministerial priority. As the
Department said it would at the July hearings,
it has listened to the concerns about
compensation arrangements, engaged with them,
and taken action where necessary.
Whilst there will always be room for
improvement and much work remains to be done,
the Department believes that the general
trajectory is now broadly positive but, as
always, it would welcome your views. ll
address each of the three compensation schemes
in turn, starting with the Post Office
administered schemes, the Historical Shortfall
Scheme and the Overtumed Historical Conviction
scheme before turning to the BEIS scheme, the
Group Litigation Scheme.
Up first, the Historical Shortfall Scheme.
Like the Overturned Historical Convictions
compensation and unlike the Group Litigation
Scheme, the HSS is a scheme designed,
established and administered by POL but the
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previous indication of what was sought in this
context, and I venture to say it's equally
a matter that would appear to go beyond the
scope of the terms of reference of this Inquiry.
Can I just look to my left and right to
confirm if there's anything further that I need
to-
Thank you very much indeed, sir, for that
opportunity. I may have strayed a few minutes
past my time but I'm very grateful.
SIR WYN WILLIAMS: I think you are well within
a margin of appreciation, to use a phrase we're
no longer allowed to use.
MS GALLAFENT: Thank you, sir. Thank you.
SIR WYN WILLIAMS: Yes, Mr Chapman?
‘Submissions by MR CHAPMAN
MR CHAPMAN: I'm hoping the microphone is picking me
up from me here, 'm getting some feedback. Can
you hear me okay?
SIR WYN WILLIAMS: Can everyone hear, Mr Chapman?
MR CHAPMAN: Hopefully that's better. Thank you,
sir.
I make these submissions on behalf of the
Department for Business, Energy and
Industrial —
42
Department has some levers of influence, and it
has not shied away from using them where
necessary. As you know, the Department has
encouraged POL to speed up the HSS process, and
set POL the target of issuing offers to all HSS
claimants by the end of this year.
As you noted in your progress update, that
was an ambitious target, intentionally so, and
with some regret, the Department recognises that
POL will not meet it.
Even so, POL has been making relatively good
progress and the Department's clear expectation
is that offers will have been made in most of
the remaining cases by the end of January.
Once a formal proposal concerning late
applications was made by POL, the Department
worked diligently to arrange and confirm the
substantial additional public funding required.
It welcomes POL's confirmation that applications
following the scheme’s closure will be accepted,
provided that a sufficient reason for the
failure to make the application within the
window is given, and it also welcomes the
confirmation of the role of an independent
review in case of disagreement.
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SIR WYN WILLIAMS: Mr Chapman, I'm a bit it confused
now, because I think Ms Gallafent was more or
less agreeing with me that they were going to be
accepted. You put it in a much more guarded way
and I'd hate there to be any divergence between
BEIS and POL over this.
MR CHAPMAN: I don't think that there's any
divergence at all
SIR WYN WILLIAMS: So I shall carefully note what
Ms Gallafent said and proceed on that basis,
shall I?
MR CHAPMAN: I think that’s fair.
SIR WYN WILLIAMS: Good.
MR CHAPMAN: The Department is very pleased to note
that the previous cap on reasonable legal
expenses has been removed, with POL reimbursing
all reasonable legal costs, both at the offer
stage and for claimants going into the dispute
resolution process.
Finally, on the HSS, the Department welcomes
the development that POL has made provision for
interim payments, irrespective of personal
circumstances and in addition to hardship
payments.
Turning to the Overturned Historical
45
made a statement in Parliament yesterday to
announce the shape of the scheme, following, as
promised, consultation with the GLO claimants
and their representatives.
In line with the views of the substantial
majority of those who responded, the scheme will
follow an ADR model, and will be administered
directly by BEIS, not POL.
The scheme will be overseen by
an independent advisory board, which will be
chaired by Professor Christopher Hodges,
an academic who is an expert in ADR matters, and
its membership will include Lord Arbuthnot and
the Right Honourable Kevan Jones MP, both of
whom have long and distinguished records as
campaigners for the postmasters.
The claims themselves will be considered and
assessed by an independent panel. The
expectation is that the full compensation awards
will begin before the summer, with most cases
being resolved by the end of next year. The
Department has now invited claimants and their
legal representatives to begin preparation of
claims and has announced support for claimants’
initial legal costs: the costs of first
47
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Convictions compensation, the Department is
reasonably pleased at the progress being made,
as just described by Ms Gallafent, though
clearly there remains some way to go. It
welcomes the positive progress being made on the
non-pecuniary damages claims and it welcomes the
increase to the ceiling for interim payments,
including the top-ups for those who received
interim payments previously.
Can I just add this: the Department is very
conscious of the practical hurdles facing
subpostmasters in making pecuniary damages
claims and, in order to help facilitate the
process, the Department has worked with HMRC to
enable easier access to historic tax return
data, so that claimants can particularise their
claims with confidence. The Department
encourages postmasters and their representatives
to bring forward their claims as soon as they
are able to.
Tuming to the Group Litigation Scheme,
unlike the other two schemes, the Group
Litigation Scheme is being set up by BEIS and,
as one would hope, reasonably good progress is
being made. As you know, the Chief Secretary
46
‘engagement with lawyers.
SIR WYN WILLIAMS: That hasn't been met with
universal approval that, has it?
MR CHAPMAN: It hasn't. The amount is specifically
for initial engagement with lawyers and
arrangements of payments of reasonable legal
costs, beyond initial engagement and the costs,
indeed, of acquiring expert evidence, where
necessary, are being finalised
SIR WYN WILLIAMS: I appreciate that there will be
a need to work out rates of pay, putting it
loosely, but the phrase that had been used
consistently was "reasonable legal expenses’, in
previous announcements.
MR CHAPMAN: Can I be clear, sir, that it remains
the Department's position that postmasters
engaging in this scheme will be entitled to
recover reasonable legal expenses.
in the meantime, the Department has made
interim payments totalling over £16 million so
far, and covering 85 or over 85 per cent of
claimants.
It, of course, understands that interim
payments are really important, and especially so
for some GLO claimants. It continues its
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concerted work to resolve issues concerning
interim payments where they haven't already been
made. In relation to the 16 bankrupt GLO
claimants, who have not yet received an interim
payment, you've heard about the issues with one
insolvency practitioner in particular, which the
Department is seeking to resolve as soon as
possible.
We would encourage you, sir, to follow up on
your suggestion that you might take your own
legal advice on that issue, and we would be very
happy to set out in a little more particular
detail what precisely that issue is, in writing,
if that would be helpful.
SIR WYN WILLIAMS: Well, I think if I do decide that
it's appropriate for me to take legal advice,
I would probably ask my legal team to engage
with all the relevant lawyers as to the
appropriate questions to ask.
MR CHAPMAN: Yes, we'd certainly be happy to engage
in that process.
It may prove to be the case — it is hoped
that itll prove to be the case -- that it's
possible to resolve that issue, and to resolve
it shortly.
49
MR CHAPMAN: Yeah. I hope that addresses it.
SIR WYN WILLIAMS: Yes.
MR CHAPMAN: Can I briefly turn to a couple of other
related matters.
First, the Department is very pleased to
note that POL is committed to setting up
a compensation scheme to cover lost remuneration
caused by suspension and, indeed, any
consequential losses. The Government has
committed to providing the funding to the Post
Office to cover those payments and the
Department will oversee the process to ensure
it's delivered promptly.
The second point: the Government has
committed to legislating, at the earliest
opportunity, to exclude all Post Office and
Horizon related compensation payments from the
calculation of capital limits for means-tested
benefits and pension credits.
That is in addition to the announcement made
in September that no tax will be payable on
compensation payments made under the OHC scheme.
So to conclude, the Department believes that
compensation issues are now generally
progressing fairly well, but it would of course
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If it's not ~
SIR WYN WILLIAMS: The quicker you do it, the less
likely or the less need for me to engage in it.
MR CHAPMAN: Well, it is and, of course, we'll keep
you informed.
SIR WYN WILLIAMS: Yes.
MR CHAPMAN: {fit isn’t looking likely to resolve
it very quickly, then the Department will make
partial interim payments, which will not cause
the potential problems which full payments, full
interim payments might cause within the next
week.
Finally, most GLO members who were acquitted
of Horizon offences have already received more
in compensation than the £100,000 interim
payments which have been made to those who were
convicted. However, the Department has
recognised the force of the concer that you
raised in relation to the handful of GLO members
who are not in that position. They will receive
additional interim payments under the GLO
scheme, rather than being transferred to the
POL-administered OHC scheme.
SIR WYN WILLIAMS: Yes, and my concem there was
‘over the substance not the form.
50
welcome your views on any areas for improvement.
SIR WYN WILLIAMS: Thank you.
Right, I think we'll take a ten-minute break
not least to allow the transcriber to have
a break, and then we will continue with
Mr Moloney,
(14.58 am)
(Ashort break)
(12.13 pm)
Submissions by MR MOLONEY
SIR WYN WILLIAMS: Yes, Mr Moloney?
MR MOLONEY: Thank you, sir, these submissions are
‘on behalf of Hudgell Solicitors and Hudgell
Solicitors represent 72 claimants under the
Historic Shortfall Scheme, 71 persons whose
convictions have been overturned and six persons
in the group litigation scheme.
Our submissions identify and address some of
the specific practical issues arising in
connection with the different types of
‘compensation claims and we address them in the
following order, sir: compensation under the
Historic Shortfall Scheme; compensation for
subpostmasters with overturned historic
convictions; and compensation for Group
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Litigation claimants. I'l take those in order, 1 the good faith meeting stage, and a decision
sir. 2 then taken by the panel on whether or not to
Firstly, the HSS. We've sought to deal with 3 make a revised offer and, in each case, sir, the
our submissions by reference to your progress 4 experience of Hudgell Solicitors has been that
update, sir, and your -- this is dealt with at 5 an improved offer has been made and, in each
paragraph 133 to 152 of your update and we deal 6 case, there is evidence that the amount paid to
with just a few issues. 7 claimants can be significantly affected by the
Firstly, what were referred to in the 8 failure to identify appropriate heads of claim.
progress update, sir, as "independence issues”. 9 We have set out the details of those three
We raised a concem in July that heads of damage 10 cases in appendix A to our submissions, sir.
would were being missed by those operating the "1 I don't propose to take you to them because you
HSS, and raised questions as to how that might 12 have the details within the body of the
happen. We're very conscious that the Inquiry 13 submissions, in any event. But Case 1 -- and
intends to review the operation of the HSS in 14 these are of course anonymised, for obvious
stage 5, but what we say is, by way of update, 15 reasons - Case 1 initially received a net offer
sir, just to keep you abreast of the continuing 16 of £46,799.52 in December 2021. Hudgell
experience of Hudgell Solicitors, as matters 7 Solicitors served evidence in relation to their
proceed. 18 ‘case on 7 March 2022, and then some eight months
Of course, the only data we have is from the 19 later, on 10 November this year, sir, she
Hudgell Solicitors’ cohort as well, so we can't 20 received a revised net offer of £140,126.37
say this is in any way representative and, of 21 That, sir, is close to £100,000 and that
course, we've listened to what Ms Gallafent said 22 difference, that significant difference, was
this morning on behalf of Post Office Limited. 23 accounted for by compensation for loss of
But only three HSS applications where 24 ‘earings following resignation, which we say,
Hudgell Solicitors are instructed have reached 25 sir, should have been a very obvious head of
53 54
loss to have appreciated. 1 heads of damage which were not present in the
SIR WYN WILLIAMS: So that I understand your 2 original claim were identified and proceeded
criticism, am I right in thinking that, when the 3 with and an increased offer made.
lady presented her claim on her own, she hadn't 4 Those are the only three examples we have,
identified a loss of earnings, but you would say 5 sir, of cases dealt with by Hudgell Solicitors,
there obviously must have been one, which the 6 which have preceded to a good faith meeting
panel should have investigated; is that the 7 which, of course, is the next stage along from
point? 8 the offer, and then resulted in a decision on
MR MOLONEY: Should have asked the question 9 an offer, not simply a revised offer, but
basically, sir. The must have been, is what 10 a decision on an offer following that good faith
we'd say about that. Then Case 2, an offer of "1 meeting. There have been no other decisions on
£3,752.26 in January 2022. That was simply 12 offers, and so each time there's been an upward
a shortfall of £2,000 and associated interest. 13 revision of the offer when an offer has been
A good faith meeting took place in July 2022 14 made.
and the revised offer was received on 15 The identification of those heads of damage
17 November and that revised offer was greatly 16 has led to significantly increased offers,
increased to £63,331.89, and that included 17 which, of course, sir, has ~ it affects the
compensation for losses arising from resignation 18 wellbeing of the claimants who have suffered
and distress and inconvenience that had not been 19 some time ago, and that's the importance of it,
considered by the original panel. 20 sir, getting their lives back on track.
Then in Case 3, the applicant received a net 21 The second aspect we'd like to refer to,
offer of £21,691.23 in March 2022, a good faith 22 insofar as the HSS is concerned, is delays, sir.
meeting in June 2022, and a revised offer of 23 Now, one of the concerns of the Inquiry in the
£34,862.61, on 17 November, same day as Case 2 24 progress update was that no decision had been
and just a week after Case 1 and, again, two 25 made on whether to accept late applications into
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the HSS, and we've had an update from 1 beyond the stage of first offers. The
Ms Gallafent this morning as to what's happening 2 experience of Hudgell Solicitors is that a good
now, so far as those late applications are 3 faith meeting is usually only possible some
concemed, sir. 4 two months after the request for such a meeting.
But the position now, sir, is that late 5 The suggestion is that some delay may be
applications have only been provisionally 6 occasioned by the need to secure medical
accepted into the HSS. So you reported, sir, 7 expertise to the GFM, to the good faith meeting.
earlier this year, we're some months down the 8 Again, we're on a very limited sample, sir, but
line, they've been provisionally accepted into 9 the experience of Hudgell Solicitors is that, in
the HSS, reasons for the lateness of the 10 the number of GFMs that they have conducted,
applications have been requested, those reasons "1 there's been -- there have been no medical
have been supplied very quickly but, thus far, 12 experts present at those good faith meetings.
there's been no confirmation that any 13 You can see, sir, from the three cases we
application has been fully accepted into the 14 identified in appendix A, as it were, the
scheme and no first offers have yet been made in 15 timetable for the, first of all, setting of the
any of the cases. 16 GFM and then the making of the revised offer —
So we're encouraged by what was said this 7 and you can see, sir, from those three cases
morning, but it has to be seen, sir, and, of 18 that it was between four and seven months until
course, we hope this isn't a cheap point but, of 19 the revised offer is made after a GFM.
course, if these cases had been accepted into 20 Hudgells have conducted GFMs in 11 cases so
the scheme, then we might be some distance away 21 far -- these figures may now be out of date
from 95 per cent, rather than just four offers 22 because there have been a couple more over the
way from 95 per cent of all the applications. 23 past few days ~ and they're awaiting decisions
Additionally, sir, there have been 24 as to revised offers in nine cases, a further
significant delays in the operation of the HSS 25 16 GFMs are scheduled to take place from January
87 58
onwards and ten claimants have requested a date 1 As the Inquiry is aware, one major area of
for a meeting but are still awaiting one. So 2 concer was the significant delays in the making
there is some significant pendency so far as 3 of offers for compensation in claimants in the
these cases are concemed. 4 HSS scheme who have been declared bankrupt.
Only one Hudgell case has reached the stage 5 Offers in those cases have now begun to be made
where a mediation is to take place. That 6 but, regrettably and as predicted, most of the
mediation was requested on 21 September 2022, 7 damages, under the terms of such settlements,
and the reply with the proposed date was not 8 are being paid for the benefit of the Official
received until 24 October 2022 and the mediation 9 Receiver.
is now scheduled to take place in January 2023. 10 The Official Receiver is receiving first
So that again, sir, gives some indication of the "1 call on any compensation relating to financial
delays which are part of this system at the 12 losses and we have attached two examples to our
moment. 13 submissions, as Appendix B, sir, of letters from
Plainly, sir, the concern expressed by you 14 the HSS to applicants explaining what will
at paragraph 135 of the progress update, that 15 happen to the award that is made by the HSS to
the fulfilment of the targets that Post Office 16 them. Case 4 we've referred to -- the first
and BEIS had set themselves for making HSS 17 case we've referred to is Case 4
offers should not be achieved they expense of 18 The HSS panel decided on an award of
a proper and thorough appraisal of individual 19 £259,359, and the applicant has now been offered
applications before an offer of compensation is, 20 £8,000 of that award and the Official Receiver
made, is one that the Inquiry can retumn to at 21 is to receive 251,000 of the offer. That
stage 5 but we simply update the Inquiry today 22 applicant, sir, had run a successful business as
as to the experience of Hudgell Solicitors, and 23 a subpostmaster for 20 years, his business was
say, as well, sir, that we don't know the 24 ruined and he suffered with poor mental health
reasons for the delays. 25 after the shortfalls he experienced, and the
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£8,000 is intended to compensate him for his
distress, the rest is for the Official Receiver
because of property related matters. That's the
division that's being made, so far as damages
are concerned: personal damages, as it were, for
the claimant; property damages for the Official
Receiver.
Then the second case, Case 5, we've referred
to it as, out of an award of £24,999.32, the
applicant has been offered £4,500 whilst the
Official Receiver is to receive £20,400.32. The
Official Receiver has no authority, other than
to settle the debts of the bankruptcy in full,
and with the compensatory interest applying, the
likelihood is that any award for financial
losses will very often be completely swallowed
up when those debts are paid, and the issues
surrounding bankruptcy are often complex and
frequently require specialist legal assistance.
As currently appears to Hudgell Solicitors,
the HSS takes no account of whether the root
cause of bankruptcy was or may have been
shortfalls generated by Horizon software and
compensation is intended to put the claimant in
the position they would have been in, if they'd
61
correct me when I inevitably get this wrong but,
essentially, those offers would not have been
accepted but they are merely illustrative of the
division of the award, as it were, and —
SIR WYN WILLIAMS: So it's designed to persuade me,
if I needed persuasion, that there could be
a very significant amount of money at stake for
the individual involved on this bankruptcy
issue?
MR MOLONEY: That's it, sir.
SIR WYN WILLIAMS: Right, okay.
MR MOLONEY: Also, sir, just to elaborate upon that
point very briefly if I may, that, of course,
the purpose ~ and underlying that submission,
is, of course, that the purpose of compensation
is to attempt to put the person back in the
position that they would have been but for the
unreliable operation of Horizon software. So
many of the debts which were accrued by this
person, in the first place, which led to
bankruptcy, were caused by the shortfalls before
that and then the way their business then
collapsed and then, of course, people have
mortgage payments.
It's that litany, sir, that you've heard so
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not been adversely affected by the unreliable of
Horizon.
So, sorry, sir —
SIR WYN WILLIAMS: I was just, as you were speaking,
80 I'll ask you now ~ and if it's embarrassing
in any way to answer, then please say so ~ but
are these figures that you've mentioned, in
terms of the offer under the HSS, would they
have been acceptable as figures, if I can put it
in that way? Forget the split between the
Official Receiver —
MR MOLONEY: I've not had conduct of the cases, sir,
but ~
‘SIR WYN WILLIAMS: No, but what I'm trying to
establish, essentially, is whether these
figures -- if you remove the trustee for the
moment — would have been acceptable. That's
point number 1. If they're not, then there's
an ongoing issue under the HSS. If they would
have been acceptable, I imagine there's now
an ongoing dispute as to whether all this money
should be paid over to the Official Receiver.
So there are two aspects to it. That's what I'm
trying to get at.
MR MOLONEY: Indeed, sir, and Dr Hudgell will
62
many times during the course of the impact
hearings. With this outcome, what happens is
that all of the debts that they accrued, all of
the debts that led to the bankruptcy, whilst
essentially there's a compensation award given
to them, that gets swallowed up by the debtors,
rather than them, so they're not being put back
into the position that they would have been but
for the unreliable operation of the Horizon
software.
They're being left with, in Case 4, £8,000,
when, even on the assessment of the HSS, they
should have got £259,000.
Sir, we did make a point about the agreement
of reasonable costs but there's been progress in
relation to that, and we say nothing further
about that.
Then, finally, we've made a point about the
provision of medical assistance, assistance for
the commission of medical reports, and about how
that has not really been available in the
experience of Hudgell Solicitors, and Hudgell
Solicitors understand there is a need to deal
with claims expeditiously. The commissioning of
a medical report may delay the making of a first
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offer but it's also important that applicants 1 if Ijust, if I may, read what it says at
are properly compensated for any personal injury 2 page 77 of that document the reference you have:
they've suffered, and a broad-brush approach to 3 "Making good losses. If you have not
this issue, is a serious injustice again for 4 obtained authority to hold the loss within the
applicants. 5 suspense account, you will make good the
If we could just move very quickly, sir, to 6 discrepancy after the final stock unit has
the application process which you dealt with at 7 rolled to the CAP and then make good the loss
paragraphs 142 to 145 of the progress update, 8 involved, this involves placing the cash for the
and just really highlight, just for your 9 amount of the loss in your til.”
continuing consideration, sir, the problems that 10 So, sir, that's a process, a procedure,
have been experienced by claimants in the HSS. "1 which would not provide a ready audit trail for
The burden of proof is a difficulty for many 12 demonstrating the making-up of shortfalls.
claimants, and there have been deductions made 13 Equally, sir, so far as the application
from the award with -- in the experience of 14 process is concerned, in terms of calculating
Hudgell Solicitors -- what they see as no 15 loss of earnings’ claims and consequential loss
apparent basis and other than the principles of 16 rising, Post Office uses the Network
faimess. 7 Transformation scheme leavers payment, sir, and
One of the reasons for the frustration as to 18 that is a redundancy package based calculation
the reductions for the absence of documentation 19 of up to 27 months pre-cessation salary and
is just what they were encouraged by Post Office 20 takes into account that Post Office could have
Limited to do at the time at which these 21 terminated the applicant's contract with just
shortfalls were occurring. We've referred you, 22 three months’ notice. So within the terms of
sir, to a document that we've received during 23 the contract was the option for the Post Office
the course of the disclosure, and page 77 of 24 to terminate the contract with three months’
that. We don't ask for it to be brought up but 25 notice. That's taken into account.
65 66
Going back to Case 4 that we referred to, 1 before the holiday period, we understand, and
sir, the man who had run a successful business 2 that's a very happy situation for the people who
for 20 years, ended up being made bankrupt, 3 have been able to set up their non-pecuniary
there would have been no reason for him to have 4 claims.
been given three months’ notice and we say 5 The position in respect of respect for
that's an arbitrary consideration in the 6 claims for pecuniary losses is less happy but
circumstances that that can form part of the 7 it's not disastrous, sir. In our submissions,
assessment of the requisite compensation in 8 we identify delays that are occurring but there
an HSS application. We say that's not always 9 is progress and we're confident that that
appropriate, and can lead to a significant 10 progress will continue.
underpayment (unclear) true loss. "1 As you've heard, sir, two claims have been
Moving on, sir, if I may, to compensation 12 settled and paid in full, but they remain the
for subpostmasters with overtumed historic 13 only claims for pecuniary losses to have been
convictions. 14 settled.
We say that the early neutral evaluation 15 As far as four other cases are concerned,
conducted by Lord Dyson proved effective in 16 final settlement proposals have been awaited for
providing the parameters for settlement of 17 months and, in appendix E -- and there is no
non-pecuniary loss claims and, as Ms Gallafent 18 need to take you to appendix E, we've again
has outlined this morning, they have been 19 included the details within our written
progressing well since Lord Dyson provided his, 20 submissions -- they were submitted, previously
report 21 submitted in June this year and one in August.
We are happy to say that - as Ms Gallafent 22 There were requests by Post Office for further
has reported ~ the dialogue between Hudgells, 23 information, they were all dealt with
and Post Office solicitors has resulted in the 24 expeditiously and there have been significant
payment of an extra £63,000, and that will come 25 delays, we say, by Post Office at each stage,
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and still no substantive response to any of the
claims.
We hope that there will be a response to the
claims very soon and the reason for the delay in
Post Office making proposals for settlement is
not known to Hudgell Solicitors.
We had hoped and expected that the initial
six claims would provide an adequate and
appropriate framework for the process of the
remaining claims, in essence, a sort of parallel
to the early neutral evaluation process. But
the delay of months has meant that that
expectation hasn't materialised but there is
will on both sides for that to happen with these
cases and we hope that we will be able to
resolve that very soon.
In addition to difficulties encountered by
some bankrupt claimants under the HSS scheme
that we've referred to, problems have also
recently arisen in the Overturned Historical
Conviction cases in which bankruptcy is
a feature.
It's fine with those cases which fall under
the auspices of the Official Receiver; we've
managed to resolve that, with the Official
69
details if I were to say now, but we would be
happy to assist in any way we can, sir.
But it is the same principle in this way,
sir, that this compensation is designed to put
people in the place they would have been if they
hadn't suffered and, in particular, in these
cases, they hadn't been prosecuted and
convicted.
So that's what this compensation should try
and achieve and, plainly, if a large portion of
the damages is being taken from them, in the
same way that it is with the HSS, then that is
obviously significant injustice, we'd say, and
that, essentially, Post Office — if the
bankruptcies were caused by the actions in the
first place, it's incumbent on them to do all it
can to ensure that these people are put in the
position they would have been in but for the
unreliability of the Horizon software.
SIR WYN WILLIAMS: I'm not sure to what extent
I can, in truth, delve into these matters, but
since I'm having a bit of a go this morning, it
seems to me there's almost two different issues.
One is your assertion based on what BEIS and
Post Office have said, that there should be full
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1 Receiver indicating that they've no further
2 interest. But, as you've heard from Mr Chapman,
3 there are three other cases where they are being
4 dealt with by a different insolvency
5 practitioner.
6 Two of those people are Noel Thomas and
7 David Blakey, and the insolvency practitioner
8 initially relinquished any interest but then,
9 following advice from King's Counsel, they've
10 now claimed an interest in part of the damages,
"1 and this has held up payment of damages for
12 non-pecuniary losses.
13 So this is separate to the situation that
14 Mr Chapman has just indicated, because that
15 refers to the Historic Shortfall Scheme. This
16 the Overtumed Historical Convictions cases.
7 It's not a scheme, they are cases ~
18 SIRWYNWILLIAMS: Well, it's a different scheme,
19 but would the principles governing it be the
20 ‘same or not?
21 MRMOLONEY: No, they're not, sir. But we've
22 seen -- we're addressing it, and we've had no
23 assistance from Post Office until very recently,
24 but they are slightly different, sir, and it may
25 be that I might be revealing confidential
70
1 and fair compensation. Which is another way of
2 saying you should be put back into the position
3 if this had never happened to you.
4 On the other hand, there's the legal
5 position of a person who has been made bankrupt
6 to his trustee in bankruptcy, or her trustee in
7 bankruptcy. It's that latter point, I think,
8 that BEIS and POL were inviting me to dip my oar
9 in, so to speak, not the former point, if I can
10 put it in that way. What do you think about
"1 those issues, Mr Moloney?
12 MRMOLONEY: Sir, one solution, which might not be
13 attractive to BEIS and POL, is that the actual
14 level of compensation paid is increased so that
15 the debtors that are required to be satisfied by
16 the Official Receiver or the insolvency
17 practitioners can be paid, and the postmasters
18 can be put in the position that they would have
19 been in, but for the unreliability. That seems
20 to us to be the most straightforward way: that
21 both are taken care of.
22. SIR WYN WILLIAMS: The trouble is I'm not sitting
23 over the road; I'm sitting in a completely
24 different capacity
25 MRMOLONEY: Indeed, sir. But that seems to us the
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way through. It's more expensive, but it may be 1 and the resources available to process
that there are a limited number of cases of this 2 applications, but Hudgell Solicitors are pleased
nature which might mean that it didn't become 3 to see that a panel of independent people has
too onerous for POL and BEIS. 4 been appointed to oversee its work.
SIR WYN WILLIAMS: All right. Well, I think I'm 5 So to conclude, sir, although the ENE
getting a feel for where the various roads might 6 process has facilitated significant progress in
lead 7 the Overtumed Historical Convictions
MR MOLONEY: Thank you, sir. 8 non-pecuniary loss claims, there has been some
Then finally and very briefly, sir, 9 delay with the pecuniary loss compensation, and
compensation for the Group Litigation claimants. 10 the position of bankrupt claimants is also of
Hudgell Solicitors don't represent many of "1 specific continuing concern, which has not been
the claimants in this scheme, and so we've very 12 properly addressed by Post Office or BEIS,
limited observations to make. 13 although they have begun to address it in the
SIR WYN WILLIAMS: Yes. 14 week leading up to this compensation hearing,
MR MOLONEY: But they've taken part in two 15 sir.
round-table meetings with Post Office and other 16 So we respectfully ask that the Inquiry
interested solicitors, and they are pleased to 7 continue to review the cases and review the
see the announcement yesterday. But as with 18 issues relating to compensation as proceedings
other subpostmasters, although they're not 19 continue through 2023. Whilst there have been
subpostmasters’ lawyers, but they're not as 20 difficulties, Hudgell Solicitors see no reason
invested in this as others, then they have 21 why most, if not all, current claims for
concems about the funding of this particular 22 compensation by their clients realistically
scheme. 23 cannot be resolved in the course of 2023, and
The biggest threat to the success of the 24 the Inquiry's continued attention to the issues
scheme at the outset is the size of the panel 25 around compensation can only help to ensure that
73 74
the desired closure is achieved. Thank you, 1 acceptability.
sir. 2 The second, which is inextricably entwined
SIR WYN WILLIAMS: Thank you, Mr Moloney. 3 with the first, is whether POL will accept that
Mr Henry, I'l give you a choice. You can 4 it deliberately denied, obstructed and delayed
have a quarter of an hour now, and we break at 5 appellate rights, needlessly, unjustly and
1.00, or we can break for lunch now and you can 6 wrongly prolonging the suffering of those that
have your continuous period of 40 minutes. 7 it had devastated, either by civil judgments and
MRHENRY: May I ask you, sir, if we break for lunch 8 bankruptcy, or criminal convictions.
now. 9 Wholly unjustified, iniquitous prolonging of
SIR WYN WILLIAMS: By all means. So we'll start 10 suffering which, without exaggeration, you might
again at 1.45, "1 ‘even compare to torture, because these are
(12.44 pm) 12 people who were destroyed by the legal system,
(The Short Adjournment) 13 as Professor Moorhead in his evidence before you
(1.45 pm) 14 expressed, as long ago as February, his concern
SIR WYN WILLIAMS: We're down to two this afternoon, 15 that this tragedy, these appalling injustices,
as you can see. Our colleague is unavoidably 16 had been facilitated and perpetrated by legal
having to go somewhere else. 17 services, and to deny people their Article 6
Yes, Mr Henry? 18 rights, both as to contesting the charges
Submissions by MR HENRY 19 against them -- and that is beyond question -—
MR HENRY: Thank you, sir. 20 but then to suppress and bury the very
There are two issues. The first is the 21 exculpatory material, the very information that
continuing and inexcusable delay in delivering 22 would allow them to go before a court and say,
compensation to the wronged, to the innocent, 23 “I was wrongly convicted, this judgment against
and that will also include whether the awards 24 me ought to be set aside", is a degree of
proffered are even remotely approaching 25 wrongdoing of such magnitude that it is without
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precedent 1 submitted this morning that she does not wish to
And BEIS is also, as we have submitted, 2 address them until Phase 5 of this Inquiry,
responsible. 3 these awards are going on now and there should
We come to the buzzword, the slogan: full 4 not be any further delay, such as the delay, for
and fair compensation. Well, of course, sir, as 5 ‘example, in argument that was expressed in
you well know, no amount of money can right the 6 Hamilton that "Oh no, you don't need to deal
wrong, undo the harm and heal the wounds caused 7 with ground 2 abuse, let ground 2 abuse be
by these terrible events. "Terrible" is indeed 8 resolved in the malicious prosecution hearings,
a strong word but it almost becomes 9 the malicious prosecution claims", and the court
an understatement, sir, if one adds to the 10 robustly, albeit belatedly, but robustly
appalling injustice of wrongful conviction or "1 rejected that approach
wrongful civil judgment, a deliberate and 12 So if I may, sir, with your permission,
malignant desire or policy to suppress the 13 I shall sit down and give way to Ms Gallafent to
truth, so that even the senior courts are 14 answer those two questions which arise from the
deceived, so that these appellate rights, which 15 argument that has been posed because it is
are sacred in our system of justice were 16 important that they are resolved as soon as
effectively destroyed for years. 7 possible, and that there should be no more
Now, an integrity test can easily be 18 pettyfogging or equivocation on the matter,
determined by POL's approach to these two 19 because this goes to the actual gravamen of what
questions: first, did the Post Office 20 is under consideration here: the wholesale
deliberately interfere with or obstruct 21 contamination of civil and criminal justice by
convicted defendants rights of appeal? Second, 22 a private prosecutor who had a trusted
if So, was its purpose in doing so improper? 23 reputation, was a public corporation, and
Sir, I invite you now to ask Ms Gallafent 24 historically an arm of the executive
those questions because, although she has 25 Such inequality of power, such a disparity
7 78
in status between the unfortunate agent and the 1 pernicious effect of delay, I want to come, if
oppressive master, allowed this to happen, 2 I may, to a central premise of the argument as
before 37 Crown Courts around the country, 3 to why we submit that deliberate denial of
37 Crown Courts, involving over 700 people, over 4 appellate rights for a malicious and malignant
a 20-year period, and that is why, sir, it ought 5 purpose is a live issue here.
to be resolved right now, right now, without any 6 As the CCRC noted, the Post Office's
more delay, dilatoriness or prevarication. 7 attitude towards disclosure tends to prove that
So, sir, I ask you to invite my leamed 8 the intransigence identified by the honourable
friend to answer those questions: deliberate 9 Mr Justice Fraser in the Post Office's conduct
interference for a wrongful purpose. 10 of the Horizon Litigation beset the manner in
SIR WYN WILLIAMS: Well, 'm not going to make any "1 which they conducted criminal prosecutions.
kind of direction, Mr Henry, as I'm sure you 12 It was as a consequence of an ineffectual GT
appreciate. Whether or not Ms Gallafent wants 13 (Grant Thornton) report commissioned by the
to say anything is a matter entirely for her at 14 CCRC, which relied on the transaction logs, that
this stage. 15 the CCRC then decided that that report was of
MS GALLAFENT: Thank you, sir. No. 16 little utility and they would have to await the
MR HENRY: Well, that may be a matter of profound 17 decision of Mr Justice Fraser in Horizon
regret, not of course for my leamed friend who 18 number 6.
acts on instructions, but it may be a matter of 19 The transaction logs themselves, sir, would
profound regret, and we shall see — by their 20 not reveal the bugs, errors and defects which
fruits you shall know them, sir. We shall see 21 would have been apparent from the ARQ data, and
whether this is performative breast beating or 22 of course, they were not aware of the PEAKs
an actual realisation of the enormity that has 23 So, therefore, at paragraph 47 of their
been done. 24 statement of reasons, they decided that they
Before addressing, in particular, the 25 would have to await the Horizon litigation,
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which they then described as revealing 1 pension"; the wrongful dismissal, the use,
a fundamental shift in understanding. 2 again, of the law to dismiss them.
Now, that is why, sir, we went into 3 The criminal conviction that followed
exhaustive detail in our document on 4 wholesale breaches and utter dereliction of the
compensation, on the extraordinary, almost 5 Criminal Procedure and Investigations Act, the
unbelievable conduct of that litigation, both 6 duty of disclosure, the Code for Crown
the common issues and also the Horizon 7 Prosecutors, the Attorney General's guidelines
litigation. Because, sir, it appears to be, 8 on disclosure, where the private prosecutor who
again, inextricably linked to the issue of 9 should act still as administer of justice,
openness, transparency and candour. Those 10 particularly when they are a public corporation
criminal appeals in Hamilton and others were "1 acted as an unscrupulous, ruthless and
literally hanging by a thread on the resolution 12 remorseless party.
of Horizon number 6. 13 Incarceration. Then the unjust judgments
But I now want to tum to the pernicious 14 that follow. I now actually involve those who
effect of delay in relation to a convicted 15 were not convicted, unjust civil judgments,
individual, leaving aside for this moment, of 16 bankruptcy, unjust property seizure. Damages,
course, that two of those with Ms Page and 7 confiscation, compensation to POL. All based on
Mr Schwarz, we are proud to represent, Ms Arch 18 entirely fictitious, utterly baseless
and Mr Castleton, were never convicted — never 19 ‘computer-generated losses.
convicted. But let's deal with a conviction. 20 The ruined health, both mental and physical
First of all, which would be common to 21 The intractable stress-related illness,
Ms Arch as well, the unjust shunning and 22 autoimmune disorders, PTSD. The impaired and
suspicion after they had been dismissed and the 23 shattered earning capacity. The fact that you
rumours circulate, the gossip, about "They've 24 don't get a job because, of course, under the
robbed our pensions, they've robbed our granny's 25 CRB and then the DBS, these matters are
81 82
disclosable. 1 she was.
You are effectively a convicted person, even 2 As she walked beside me today she nearly
though you are completely innocent. The 3 stumbled, and she limps and I asked her why.
pensions contributions that have never been 4 She has nerve damage from cervical vertebrae
made; the National insurance contributions that, 5 four downwards, she has neuropathy from
have not been made, and then the loss of perhaps 6 an autoimmune disease that struck her down in
capital, undoubtedly, both sunk into businesses 7 2008, after she'd been released from prison. Is
and also in property, replaced by poor housing, 8 it just a coincidence? Is it too remote? Is
caused by one’s reputational damage, consequent 9 there going to be some clever legal argument
as well upon one’s loss of liberty. 10 about causation? Some novus actus because some
Now, I've dealt with those in the abstract, "1 virus descended from the North Sea and landed in
the generic. I now want to transpose them on to 12 a cup of coffee in her house in Hull? Who
a living human being who is here today, Janet 13 knows.
Skinner, who was, from the time she started at 14 She was told she was never going to walk
the Post Office really the darling or the pet of 15 again. She limps and will always limp because
the Post Office, back in the early 1990s, and 16 of it
did phenomenally well, and was respected and 17 Her house was repossessed but, fortunately,
liked and admired by all of her colleagues, and 18 she secured a sale. But when she was released
then had it all taken away. 19 from prison, she couldn't find anywhere to live.
Of course, you know that she was charged 20 So she had to live in condemned housing —
with theft and false accounting. She was 21 ‘condemned housing -- with her then 14-year old
advised that, on the strength of the “evidence”, 22 ‘son, Matthew, who is now 31; her 17-year old
in inverted commas, she should plead guilty to 23 daughter Toni, who is now 35; living in
false accounting and did so, in the hope that 24 condemned housing. Those two children
she would not be sent to prison but, of course, 25 traumatised by the fact that their mother, as
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I said to you, refused to see them while she was 1 actually affects people at a cellular level.
in prison because she did not want to see them 2 It is now beyond question that mitochondria,
and she more importantly did not want them to 3 which are the actual driving force of human
see her in prison garb. 4 existence, providing energy and communication,
So she could get nowhere to rent and she 5 are badly affected by stress, and that is why,
hasn't worked because she can't work, since 6 sir, it is not a coincidence that, in the whole
2008. 7 history of this saga, you have people who have
Now, the emotional trauma visited on her 8 already died, who have committed suicide, and
children, will that be compensated, the fact 9 who alll have, as a group of people, an unusual
that they were living in condemned housing with 10 incidence of physical and psychiatric health
their mother? The fact that they were "1 issues.
traumatised by the fact that their mother was 12 That is because of the appalling suffering
taken away from them when one was 14, the other 13 to which they were needlessly subjected but,
17? They're now 31 and 35. They were asked to 14 more importantly in the context of this matter,
compose statements on the effect of this upon 15 it was inordinately and wrongly prolonged.
them and, as they did so, they wept. 16 Now with great humility, sir, you will
The trauma attenuates across time and space 7 realise that not even with the powers vested in
and it doesn't go away. It doesn't go away, as 18 you, you don't have the power to do anything to
Janet Skinner said to you, sir, in the impact 19 right that wrong. Your duty is to the truth,
hearings, "No amount of money is going to make 20 but these profound wrongs have affected these
this better’. These people have been changed. 21 people in ways that we may never understand, and
They have been changed in a way that not even 22 which also may not be legally recoverable, which
you or I can see, and one knows from medical 23 is why one really does make this submission,
science that that is right, that stress of this 24 that full and fair compensation should not be
profound nature, trauma of this profound nature, 25 a box-ticking exercise going through a tort
85 86
textbook but should actually reflect upon that 1 statement, the atrocious degradation and cruelty
vital question: where would these people be now 2 shown to his child, his daughter, by those who
had they never suffered this appalling 3 thought that they were better than her because
injustice, that the trajectory of their lives 4 her father was a thief.
had not been flattened or crushed by false 5 As I've said, the damage is extraordinary;
accusation and then the denial over many years 6 like a stain, it spreads. It was not contained
of a right of appeal? 7 for over 20 years and it may never be eradicated
That is why I really adopt Mr Moloney's 8 because of that, and that is why the full
point that, yes, the Official Receiver can 9 measure of damages is required and justified in
devour an award, but there wouldn't be creditors 10 affirmative answers in due course, from the Post
if these people had not been branded, shamed, "1 Office, and the paymaster, BEIS, to those two
convicted or otherwise destroyed in this 12 questions that have been posed: those two
inexcusable manner, by Britain's most trusted 13 questions, simple questions, sir, simple
brand. 14 questions which would reveal so much if they
That is what full and fair compensation 15 were answered, as opposed to that silence.
requires, sir. Not that the Official Receiver, 16 Or your question earlier today, sir, where
the trustee in bankruptcy, takes that which is 17 you were talking about artificial obstacles.
owed to the creditors, but to ask oneself why 18 You didn't use the word "pettyfogging” but the
Mr Castleton, who sank so much money into that 19 “unnecessary bureaucracy". I mean, that might
business, who had had a distinguished career 20 have been necessary if there was going to be
serving his country, then in the City, and then 21 a fight, you said, but did you get any
decided that he wanted a change of pace in his 22 categorical assurance from those representing
life and would become a subpostmaster, ended up 23 the Post Office?
being bankrupted, ended up being shunned and, as 24 "Oh no, no, it's not going to be a fight.”
you heard from me when I made an opening 25 You got this: “It's unlikely".
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We're not here to deal in likelihoods, sir 1 POL and also the UKGI to appear before you, and
We're here deal with addressing the reputational 2 for BEIS and POL to answer your questions and
damage, the mental health and physical health 3 explain what they claim to have done in
that has been scarred, the future earnings that 4 resolving this issue of compensation.
would have been missed, the opportunities that 5 But I still come back, sir, to those two
could have been grasped that never were, and all 6 questions which have not been answered, and they
unnecessarily prolonged by a decision at the 7 will be the test of whether this is more words,
highest level that they would rather preserve 8 words, words. Words, words, words, which you
commercial and reputational matters, as opposed 9 have read last night and words, words, words,
to doing justice to the victims. 10 which you have heard today. But still, some of
As you saw, sir, the Post Office was "1 the submissions heard this morning have the
receiving advice on compensation from the same 12 capacity to amaze.
Mr Simon Clarke who wrote the Clarke Advice in 13 I mean, what parallel universe does POL
2013. Why? Why did it take a further seven 14 inhabit when stating that the lack of a formal
years ~ eight, in fact, before the resolution 15 scheme has been no impediment to the settlement
by the Court of Appeal's judgment -- for the 16 of pecuniary losses? How so, particularly when
matter to be put beyond question? 7 Ms Felstead waited half her life to be cleared
Why in the interim, before that, was there 18 and had to wait until the 19 October to have the
that tooth and claw last-ditch stand before 19 unjust confiscation order made against her back
Mr Justice Fraser in those two trials where some 20 in 2002 repaid with interest?
extraordinary events occurred, which need not 21 So from the 23 April 2021 to 19 October
trouble us now because, of course, they're in 22 2022, that was not settled. It is interesting
the forefront of your mind. 23 to note, sir, that she had been convicted on
So I want to conclude, sir, by thanking you 24 26 April 2002 and had to wait until 23 April
for arranging this hearing, requiring BEIS and 25 2001 to be vindicated.
89 90
But I retum to her, Ms Skinner and also 1 and that is a matter that has destroyed families
Mrs Misra. With Mrs Misra as well, I would wish 2 ina way that can never be healed or
to say a few words now about the extraordinary 3 compensated.
suffering that she endured, together with her 4 But we come back to this annoying question,
husband and children. 5 or those two questions that have not been
Let us not forget, sir, that from 2005, they 6 answered and, again, before closing -- and
were trying to make their business work. In 7 I promise you, sir, that this is my last
2010, after sinking family money into the 8 submission -- Tracy Felstead, Janet Skinner and
business, to satisfy wholly fictitious 9 Seema Misra, against all the odds, and against
shortfalls, she was sent to prison, pregnant. 10 considerable opposition from all quarters,
From 2010 to 2021, she had to wait like "1 pursued ground 2. You will know, sir, from
Ms Felstead and Ms Skinner, and it is now nearly 12 submissions I've already made but also from the
2023 and, of course, a claim has not yet been 13 history of that case, that ground 2 was bitterly
submitted in her case but it is that long delay 14 opposed.
before her name was cleared that is a matter we 15 So itis, sir, that we respectfully submit
respectfully submit that ought to be taken into 16 that, notwithstanding the protestations to the
account: the impact on her children, the impact 17 contrary, what you have heard today is again
on her husband, who descended into alcoholism. 18 part of the disconnect between rhetoric and
Families get ripped apart. 19 reality. Retuming very briefly to the
Those who would normally be sometimes the 20 Historical Shortfall Scheme, the fact that POL
people to whom one would seek solace and 21 has published statistics that 75 per cent of
support, become ashamed because of the myth of 22 those claims have already been settled, causes
the Post Office's infallibility as a national 23 one justifiable concern, given the manner in
institution that their own flesh and blood had 24 which it has previously approached this matter,
acted with malign and clandestine dishonesty, 25 and one wonders if there may need to be now
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The Post Office Horizon IT Inquiry
a reopening of those awards, given the
penetrating analysis on behalf of Hudgells by
Mr Moloney about how the unrepresented can be,
again, taken advantage of.
So it is shameful, embarrassing and beyond
comprehension that those exemplars put before
you by Mr Moloney actually happened before
lawyers came in to resolve the matter. One asks
“Why is it so difficult? Why does it take so
ong to act with integrity?"
Why does it take so long to do the right
thing, particularly since these people were
subjugated, they were victims of effectively
state power, an agency or public corporation
that oppressed them, criminalised them, when
they'd served that institution with loyalty,
with kindness to their customers and with
integrity, and yet they were degraded in that
way and deprived of the means to clear their
names.
Itall started, even before the very
beginning. First, they were sloppy, they were
slow, they were incompetent. It was all their
fault. Then, of course, for that 1 per cent or
less who were subject to those latent bugs,
93
of this malignant culture of secrecy and
non-disclosure.
Those two questions, unanswered, will
continue to hang over the head of those who
represent the Post Office but, more importantly,
those who are the directing mind of the Post
Office. It is a profound shame to this country,
that, even after all that has been done wrong,
that silence, even today, persists
Those are our submissions, sir.
SIR WYN WILLIAMS: Can I just be clear that I've got
right in terms of the persons whom you
represent?
Ms Felstead, Ms Misra, Ms Skinner and
Mr Parekh fall to be compensated under the
Overturned Conviction scheme, as I understand
it
MRHENRY: Yes, that is correct, sir.
SIR WYN WILLIAMS: Mr Castleton and Ms Arch will
fall into the GLO scheme that Mr Chapman
referred to this moming ~
MRHENRY: Correct, sir
SIR WYN WILLIAMS: -- and Mr Shiju falls into the
Historical Shortfall Scheme --
MR HENRY: Correct, sir.
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errors and defects, and the remote tampering
with the system, they were lying, dishonest
thieves, and yet year on year, as this
irrefutable evidence built up, it was covered
up, it was buried and, with it, the Post Office
realised that they were burying them.
In conclusion, sir, if that is not taken
into account, and if that is not amply and
properly recognised and factored in to the
awards that are to be made, then this whole
compensation scheme or schemes will not be fit
for purpose.
This not benevolence, this not Lady
Bountiful giving alms. This is to restore
people to the position that they would have been
and might have been, what they would have
achieved -- a bright 19-year old, Tracy
Felstead, who lost her entire adult life through
the Post Office's malevolence.
So you can't just give them a sort of
mechanical or merely functional sum, based on
a box-ticking exercise. There has to be
a qualitative assessment of these people's
potential, the assets that they lost and the
opportunities that they were denied, all because
94
SIR WYN WILLIAMS: -- and is currently in the
process of going through that scheme.
MRHENRY: Yes.
SIR WYN WILLIAMS: Thank you.
MRHENRY: Thank you, sir
SIR WYN WILLIAMS: Thank you, Mr Henry.
Mr Stein. Mr Henry was correct almost to
the last minute in terms of his prediction, and
I'm just a bit concerned about the shorthand
writer.
Would you like a short break before Mr Stein
starts because I wouldn't want to interrupt him,
and he's likely to be about the same length of
time.
THE TRANSCRIBER: A short break would be great,
thank you
SIR WYN WILLIAMS: Fine, we'll have a short break
and then resume with Mr Stein.
(2.25 pm)
(Ashort break)
(2.35 pm)
SIR WYN WILLIAMS: Mr Stein.
Submissions by MR STEIN
MR STEIN: Sir, good afternoon. I will remain
seated as I have done for other submissions.
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throughout this Inquiry.
As you know, I represent, briefed by Howe+Co
solicitors, 156 Core Participants, as well as
supporting applications being made by other
subpostmasters, mistresses and managers within
the scheme.
Sir, one of the advantages, perhaps, of
going last today, not that I can just therefore
take the entire afternoon that's left, but —
SIR WYN WILLIAMS: You certainly cannot!
MR STEIN: -- one of the advantages is this: it's,
allowed us time to consider the various emails
and contacts that we've had from clients that we
represent, because they have been listening, now
that the live feed has been restored, and they
have been taking account of what has been said
by all of the parties who have made submissions
before you.
‘The summary answer from our client group as
to what they have heard, rather sadly, is they
hear that next week or in the New Year that
things are going to happen, that schemes will
change, that there will be something being done
about funding, there will be something being
done about individual compensation claims.
97
members, the litigation group members. What we
see as lacking in relation to the compensation
schemes variously being discussed today is
a lack of controlling mind, lack of cohesion,
lack of intelligence, being placed into these
schemes across the board
We shouldn't be in a situation whereby,
essentially, there are different choices and
different types of systems being put forward in
relation to people that have essentially the
same issues as subpostmasters, mistresses and
managers.
Of course we represent people who are right
now hurting. These are people who are finding
it very difficult and it’s irresistible to say
that we are looking towards a Christmas break or
holiday break, whereby people are thinking about
how they can finance that and how they can
manage through that period.
Now, the truth here is that the Post Office
has fought and fought and fought to prevent the
truth coming out, and against the fair provision
of compensation, to those that have been harmed
by this most public of IT scandals. My
instructing solicitors, Howe+Co, have worked
99
1 So, as an example, Sinead Rainey, who has
2 been mentioned today by Ms Gallafent, her
3 particular position is one that is very
4 difficult. She wasn't in fact, if you like, the
5 subpostmaster but she acted as in the position
6 of the subpostmaster, and that was recognised at
7 the time because the Post Office pursued a debt
8
against her.
9 Now, we hear today that her position will be
10 addressed in the next few weeks.
"1 So the difficulty that our client group has,
12 in the responses that we've had so far today, is
13 that they only hear "Delay, sometime later,
14 something will happen". They don't hear that,
15 work is ongoing. They don't hear about what has
16 happened in the background.
7 So, sadly, sir, we suggest that the product
18 of what we have had today, through the
19 compensation hearing that you arranged as part
20 of this Inquiry, has been, of course, useful but
21 not enough.
22 Yesterday, we saw a product arising out of
23 a lack of controlling mind across these
24 compensation schemes. We had served upon us in
25 the afternoon the proposed scheme for GLO.
98
1 tirelessly with campaigners to shame the Post
2 Office into recognise something that they must
3 compensate subpostmasters.
4 Regarding compensation, the standout issue
5 that has bedevilled the provision of timely
6 ‘compensation for those that have suffered so
7 much at the hands of the Post Office and BEIS
8 has been the failure to make provision for
9 reasonable financial costs of claimants, so that
10 they can have legal advice and representation.
"1 Sir, we're not just talking about a couple
12 of people who need help. These are hundreds of
13 subpostmasters with complex, compound claims
14 that can only be assessed and presented with the
15 support of expert solicitors with experience in
16 difficult compensation cases.
17 It seems to us and those we represent that
18 the Post Office and BEIS seek to wind back the
19 clock and pretend, like Bobby Ewing returning
20 from the dead in Dallas, from one episode to the
21 next, that it was all a bad dream.
22 Sir, 'm sure you remember Dallas very well
23 The Horizon System was defective.
24 SIRWYN WILLIAMS: Don't tempt me, Mr Stein!
25 MR STEIN: Sir, the Horizon System was defective.
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It's a reality. 1 discussed what is requiring. The client doesn't
We suggest, as we're learning through the 2 just fall in the door and you say, "Right, here
evidence in Phase 1 and Phase 2 of this Inquiry, 3 we go”.
that the true extent of the losses to 4 You establish essentially a meeting with the
subpostmasters, managers and their assistants 5 individual client to set out what is going to
are unlikely to be known for some time. We 6 happen. There then needs to be, within the
believe very strongly that we may, so far, have 7 rules that solicitors comply by, through the
only seen the tip of the iceberg. It will be 8 SRA, the Solicitors Regulation Authority, client
a matter for another time for us to assess and 9 care letters, letters that clearly set out
consider how much damage had been caused, as we 10 a case plan and letters that also deal with the
look at the range of factors which contributed "1 question of how cost is going to be dealt with
to the shortfalls and losses seen by 12 through the process.
subpostmasters. But it does seem very likely, 13 By the time that has happened and gone
from what we have heard in the evidence so far, 14 through, we're talking about an hour or two gone
that many subpostmasters will not have 15 already of solicitor's time
understood that the losses they suffered and 16 What is happening, therefore, is that, in
came to their door were not their fault but the 7 terms of setting out the schemes that, as
fault of the Horizon System. 18 an example -- we'll deal with it in more detail
Let me then tum to the position of BEIS and 19 in a moment -- under the GLO, there needs to be
the Post Office and we should say, for the 20 an understanding of what actually happens when
record, that part of the problem with BEIS and 21 you're dealing with people that have such
the Post Office is that they have no experience 22 complex needs through compensation.
of engaging with and compensating victims. 23 Unsurprisingly, we say, there may have been
Ms McMahon, who is an incredibly experienced 24 very few, if any, compensation schemes where the
solicitor who works at Howe+Co, she and I have 25 perpetrators call the shots and control the
401 402
process. BEIS, we suggest, does simply not 1 have this material, this is a public hearing and
understand that traumatised people do not 2 there needs to be a recognition on the public
appreciate prototype schemes being placed on 3 recording of the ongoing harm caused by the Post
websites without any advance notice and without 4 Office, and so I will summarise.
provision of the draft scheme to those who 5 Sir, in relation to the file we presented,
represent them. 6 you'll find this at page 2. I have it behind
In light of these recent events, we say that 7 tab 1 but, using the pagination bottom
you, sir, should recommend with an interim 8 right-hand comer, which is consistent
report that all schemes are overseen by 9 throughout the file, this is page 2. I will not
an independent person, with power to resolve 10 read of all entries but parts of some.
disputed issues between the parties, a trusted "1 Irefer to Peter Worsfold. He said in July
individual, such as Lord Dyson, who has overseen 12 that he had not been able to repay his 94-year
the recent neutral evaluation. 13 old mother. This month, December, he says he
The brutal reality is that, notwithstanding 14 has received interim compensation and it has.
progress that has been discussed today and 15 helped pay some debts. He is concemed that,
progress made mainly in relation to interim 16 receiving compensation in dribs and drabs means.
payments, subpostmasters continue to suffer as 17 that he and other subpostmasters cannot invest
they did in July. There has been a lack of 18 and receive income to look forward to in old
progress where progress is most urgently needed. 19 age. He has effectively lost 20 years of
Now, sir, you are aware from our written 20 business. Importantly, he instructs that the
submissions and from the file that we have 21 compensation he received did not touch the sides
presented to the Inquiry, that we have set out 22 of what he has lost.
within those submissions and schedules many 23 Virendra Bajaj
accounts of our clients, and I will not go 24 "My current financial position is worsening
through all of them. Nevertheless, whilst you 25 day by day and the whole cost of living is
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petering me off a cliff edge. I worry 1 able to heat our home and serve meals to our
constantly how I will be able to afford the 2 large family at the same time. The interim
bills. I can only pay off nominal amounts of 3 payment we were given will only last couple of
the debt, and I have been told it will take 4 months considering the rising energy bills and
100 years to pay it all back. Mentally 5 inflation overall.”
draining, stressful and exhausting.” 6 He discusses his older children who have
Robert Thomson: 7 started to hide their needs. His 13-year-old
“I've been fighting five years to get my 8 daughter had a tear in her school shoe:
name cleared. In that time, I've only had one 9 "She didn't tell us about it, and decided to
payment which was very beginning when this case 10 glue it needed to save money.”
was getting looked into. Does no one realise "1 Anonymous witness, I'll refer to by the last
the financial strain you're putting on me and my 12 three digits 293:
family?” 13 "My experiences regarding the compensation
Brent Whybro: 14 process and claims submission have been
“I feel that the inertia in the whole 15 difficult due to the length of time that has
process is extremely frustrating and alongside 16 elapsed. It has caused mental stress. My
the ongoing Inquiry this just as to the strain.” 7 financial pressures have affected by earning
Joanne Foulger: 18 capacity, unable to work full time and overtime
“Christmas is going to be a struggle. 19 as I used to. Applying for loans of high
Christmas dinner will be microwaved. 20 interest in order to get through this time and
Disappointment after disappointment is making 21 borrowing from friends and family members."
a hole so big that I feel I'l never be whole 22 James Withers:
again." 23 “There appears to be no thought or
Shala Ahmed and Faisal Aziz: 24 compassion for the victims from them, or how
"We're worried if this winter we will be 25 most of the victims are actually struggling
105 106
They seem to make it their mission to delay the 1 difficulty. The Government has agreed that the
outcome as much as they possibly can.” 2 bankruptcy should be paid back in full. The
Joan Bailey, the wife of the Core 3 only people in disagreement were the trustees.
Participant Lawrence Bailey: 4 However, because I'm in such a desperate
“Our financial circumstances are we still 5 financial state I had no choice but to accept
have a mortgage on our property, mortgage should 6 the 51 per cent I was offered. This had
have finished in 2021, and loans for the 7 a detrimental impact on my mental health as it
business. We're still paying out payments to 8 dragged up all the past trauma caused by the
the bank out of our pensions and we are looking 9 Post Office over the years."
forward to the day when final compensation is 10 Now, sir, later on we're going to be
paid. Only then we will feel it is over.” "1 referring to those as the 51 per cent cases, the
Victor Price: 12 bankruptcy cases, that have been dealt with like
“I have for many years had mental health 13 that,
issues I was not aware of, until I had lost 14 Thomas English:
everything. We agreed to sell everything and 15 "We were seriously abused by the management
just move into our caravan. This we did for 16 whose wages were contributed to by our
two years. We've been renting ever since. We 17 investments. The fact that I, as a retired
don't want charity, we just want some form of 18 police officer and former Royal Marine, could
compensation to make up for the years we have 19 have my reputation trashed by the management of
paid in rent.” 20 a supposed organisation that the pillar of the
Thomas Brown: 21 establishment, the thing really eats you up and
“The compensation process has been extremely 22 it does so now and I haven't had the suffering
unreliable. I was simply told that my case was 23 of others at the extreme end of this manner.”
complicated and they would be in touch. It once. 24 Donna Gosney:
again left me in a state of financial 25 “Iwas one of the many ex-subpostmasters
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forced into bankruptcy, solely due to the 1 would receive a significant sum by way of
scandalous, damning and bullying bestowed on me 2 interim payment. However, on the following
by the Post Office.” 3 Monday she was told that she would receive
Sir, those are some of the individuals, and 4 nothing because she is in an IVA. Ms Williams's
there are others that are mentioned within that 5 debt, in respect of the IVA, is less than 2,000.
schedule. 6 Ms Williams has very little money. Her
We mention that because we need to make sure 7 accounts with her electricity and gas providers
that, not just the Inquiry panel, not just the 8 are £2,000 in arrears. She is worried that her
Inquiry Team, but everybody understands that 9 power will be cut off. Consequently, she
this is ongoing suffering that is happening 10 doesn't heat her home. She often eats pot
right now and we're talking about the need to "1 noodles. Three weeks ago, Ms Williams had a bad
deal with people right now. 12 fall at home because she was tired and weak from
take you now to the written submissions we 13 not having eaten. During this time she says she
have put forward on behalf of our client group, 14 was in so much pain, cold and hungry and all
and tum, please, to pages 8 and 9 and 15 alone. She was unable to get up from the floor
coincidentally paragraphs 8 and 9., and I want 16 for over two days and she finally managed to
to touch on Heather Williams's case. 7 crawl to where her phone was but it was out of
Paragraph 8 of our written submissions. 18 charge. Luckily she could get to her charger
The effect that BEIS and POL's delay is, 19 and she was able to calll for an ambulance. She
having on our clients is starkly demonstrate, we 20 remains in hospital
suggest, by the case of Heather Williams. She 21 She is desperate to receive an interim
spoke to Mr Enright, my instructing solicitor, 22 payment, which she believes would sort out all
on 1 December 2022. She told Mr Enright that 23 of her problems, and she still received no
shortly after the announcement of the GLO scheme 24 compensation
she was informed by Freeths on a Friday that she 25 Subpostmasters need and deserve the support
109 410
of competent solicitors such as Howe+Co and 1 could have been referring to a situation as we
where required, advice from counsel, and input 2 have heard in the human impact hearings
from medical or other experts, in order to 3 He put it this way:
present their cases in the best possible light, 4 “An award of damages, while awarded with
and they should not have to do it on the cheap 5 a view to compensating the claimant for his loss
or be forced, as they are now, to go cap in hand 6 has regard to the injury to the plaintiff's
to the perpetrator for some type of time-to-time 7 proper feelings of pride and dignity,
funding. 8 humiliation, distress, insult or pain, caused by
Further, we say that all subpostmasters, 9 the circumstances of the defendant's conduct.”
whether within the Historic Shortfall Scheme the 10 We suggest, sir, that the situation of the
Overturned Historical Convictions scheme, or the "1 subpostmasters and mistresses who fall to be
Group Litigation scheme as proposed, should be 12 ‘compensated fall within that very highest
entitled to aggravated damages. Sir, you will 13 bracket.
be very familiar with the case law, the 1972 14 We often hear representatives of the Post
case of Broome v Cassell, where aggravated 15 Office and BEIS say the words that they are
damages were considered in relation to the 16 sorry on behalf of their client organisation,
following context: the high-handed malicious, 17 They do it in well delivered apologies when they
insulting or oppressive behaviour that would 18 have to. But we suggest that the way those
justify going to the top of the bracket, in 19 organisations have treated compensation and
terms of damages, and awarding as damages the 20 support for subpostmasters make those apologies.
largest sum that could be fairly regarded as 21 seem empty and bereft of compassion.
compensation. 22 In summary, and despite what has been said
Well, the judgment of Mr Justice Pumfrey, as 23 by the Post Office and BEIS in their written
he then was in Nottinghamshire Healthcare v 24 submissions and orally today, the current
‘News Group Newspapers in 2002, where frankly he 25 situation is this: there is no agreed scheme for
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the provision of compensation for those 1 firm of solicitors, Howe+Co, have not received
maliciously prosecuted. We have heard today 2 a penny from POL or BEIS for the work associated
that those who were prosecuted but acquitted 3 with attending meetings, canvassing their client
will be dealt with within the schemes the GLO 4 views and making detailed submissions at BEIS's
scheme and the people who have been prosecuted 5 request.
scheme. 6 The issue of funding for solicitors never
Even after yesterday's manoeuvring in 7 sits well with making submissions when you're
relation to the proposed GLO scheme, there is no 8 talking about compensation, but with this number
agreed GLO scheme. This is what has been set 9 of clients, firms such as Howe+Co must be funded
out by Government. 10 to have at least parity of ability to make
The original HSS scheme is questionable and "1 representations on part of the cases that they
we will remember the submissions that you 12 represent.
heard —- going now back in time when we were 13 On the other hand, of course, when Post
also, I think, able to watch the beginnings of 14 Office and BEIS reply, they do so via their
a cricket game through our windows across the 15 lawyers or via their team members, paid for out
place where we were sitting at the time — that 16 of their payroll, or instructed solicitors
the HSS scheme is questionable at best, in the 7 assisted, where needed, by counsel. On
way it sought to minimise compensation rather 18 17 November this year, the Minister announced
than ensuring that ancillary losses for pain and 19 that BEIS had spent £53.4 million on legal and
suffering are identified and provided for. 20 administrative costs for the HSS to date, with
Now, this has alll been hugely frustrating 21 £7 million spent and £31 million projected to be
for those who are trying to help the victims 22 spent on legal advice on the overturned
here. Howe+Co have worked tirelessly, 23 convictions.
I suggest, on these areas and have endlessly 24 There is, we suggest, strong evidence from
corresponded with POL and with BEIS. But my 25 that, if nothing else, that what is going on
113 114
here is a clear inequality in arms. 1 she started to look at what might be required
Yesterday, and confirming that the only way 2 for any individual case, and tried to start
that the Government, in whatever guise, BEIS or 3 putting it together so that she would have
its wholly-owned subsidiary, the Post Office, 4 an example of what may be needed, while putting
reacts to this continuing scandal, we had the 5 aside the starting point, which is client
announcement from BEIS and the Right Honourable 6 engagement letters, conversations at the start.
Grant Shapps MP standing up in Parliament 7 So far, in relation to one example, it led
stating that the GLO scheme had a particular 8 to something like 400 pages of disclosure from.
shape. 9 the Post Office, those include calll logs from
Never has there been a better illustration 10 EPOS, the EPOS part of the system, when working
that the Inquiry cattle prod touching the "1 as a subpostmaster.
backside of the state is the only way that 12 It includes consideration of the shortfalls,
progress is going to be made. 13 the reason why you need the call logs is because
Now, we know that the intention behind this 14 you need to argue what the shortfalls are and
announcement is that the members of the GLO will 15 they need to put the two together. HMRC records
have a scheme which will enable them, I quote, 16 is something like 20 pages. GP records,
“to receive similar compensation to their 17 100 pages. That's without, essentially,
peers’, 18 starting the case. That's just gathering the
This will require a calculation of their 19 materials.
losses and damages in just the same way as is 20 The Minister's press release yesterday
required for those who are being dealt with 21 states that what we are paid is £900 per
under any other of the frameworks or proposed 22 claimant to prepare a claim, covers, we think,
frameworks. Just as an example, Ms McMahon, who 23 something approximately like something in the
I mentioned earlier, an experienced solicitor at 24 region of two-and-a-half hours. This will not
Howe+Co, with experience of individual claims, 25 cover client conferences reviewing disclosure,
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taking a proof of evidence, investigating and 1 progress with the proposed GLO scheme.
supporting the claims, preparing instructions to 2 So it's going to be worthwhile, just for
experts, preparing schedules of loss, et cetera, 3 ‘a moment, to compare the announcements from BEIS
and this will not be sufficient for the 4 yet with the correspondence from the Post Office
instruction of counsel to provide an advice on 5 this week. Sir, you should have before you
quantum. 6 a letter dated 5 December, I'm very grateful.
It would assist, sir, and it would assist 7 Now, the letter is from the Post Office
this Inquiry, if you had clarity on payments of 8 dated 5 December, top right-hand corner, in
costs thus far to Herbert Smith Freehills. Sir, 9 correspondence, thanking Howe+Co solicitors for
you may find also useful information from 10 their letter and correspondence for 27 November.
Freeths who have referred in their letters to "1 This is titled "Compensation Claims”, and then
Government costs. 12 references to thanks for participation in
Then just after 2.00 pm yesterday, Howe+Co 13 meetings and the like.
were sent the email from Mr Brightwell, signing 14 Third paragraph, from Mr Recaldin, the
itself off as GLO Compensation Department for 15 Director of Historical Matters, Post Office
Business, Energy and Industrial Strategy, which 16 Limited
now sets out that the £900 is an initial 7 "We do not believe that your various
allowance, apparently determined by a cost 18 ‘comments regarding the payment of reasonable
draftsman with further cost allowance for the 19 fees in respect to of these matters claims is
remaining phases up to, including submissions of 20 correct. It has always been the position that
claims to be published in the next few weeks. 21 Post Office will meet the reasonable costs in
So we move on from £900 as a starting point, 22 relation to the compensation claims. Our only
to now this is an initial amount, an initial 23 concer is the question as to what is
allowance, and then further applications are 24 reasonable.
going to be need to be made in order to make 25 "You are correct in that it may indeed be in
417 118
the best interests of the subpostmasters that 1 still does not know what the right hand is
a set of defined fee parameters be agreed within 2 doing. Either way, this gives the impression of
the framework of the compensation process so 3 chaos. That chaos has not lifted since we were
that there can be clarity in this regard. We 4 back here in July, and so that is one of the
would therefore invite you to provide us with 5 good reasons why we need an interim report
a breakdown of your proposed costs so that we 6 There is, sir, nothing new or magical about
may open a dialogue and work towards 7 legal costs. Hourly rates are set by the court,
an agreement in respect of this issue.” 8 and in any civil litigation, if costs and
The one thing that we all agree on is the 9 disbursements are not agreed, they will be
principle that people within the GLO proposed 10 subject to taxation by a cost master or judge.
scheme, GLO claimants, be put in the same "1 It is perfectly standard for there to be a final
position as the other claimants with identical 12 independent arbiter on costs, issues, rather
claims arising out of the same scandal. Yet the 13 than the defendant keeping the matter to itself,
Post Office and their owners, the Department 14 dolling out sums where it says, and exercising
they report to, BEIS, are suggesting that 15 total control.
representation and reasonable payment for fees 16 Let me be clear. Howe+Co, and the other
should be allowed for in two different ways: one 17 firms acting on behalf of subpostmasters, are
tranche by tranche on application for each part 18 well-known firms who are very experienced in
as you move forward; and the other it seems by 19 acting on behalf of claimants in civil
an acceptance of reasonable fees, yet to be 20 proceedings. They know what needs to be done.
agreed within a framework. 21 They know what sort of costs will be incurred,
Now, this is either the Post Office or BEIS 22 and they are used to the costs taxation process
deliberately treating the GLO litigants less 23 We are not seeking to reinvent the wheel.
favourably than other SPMs who fall to be 24 We merely seek some level of parity of
compensated, or it shows that the left hand 25 representation with the Post Office and BEIS.
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‘Simply put: fairness for subpostmasters. 1 the debts, restore the credit ratings of
May I then refer, please, to the complex 2 subpostmasters so that they can begin to live
cases, those that are being made bankrupt, and 3 again.
IVA clients. 4 Just as a personal aside, a couple of days
Itis absurd that some of the most 5 ago I was sorting out some of my own insurance.
vulnerable victims of the Post Office are 6 issues that are left to be dealt with and
languishing at the back of the queue. There 7 finally got around to, and one of the things
should be no queue. Where cases are complex, or 8 that struck me was the question I was asked: had
involve bankruptcies or IVAs, BEIS should divert 9 lever been made bankrupt? The answer is no.
resources to dealing with those problems rather 10 One of the problems with bankruptey is it acts
than sidelining them. The unfeeling "1 alittle ike a conviction. It remains a stain
procrastination that has characterised the last 12 on your character as you try and move forward
few months must end. 13 and try and gain credit.
Another reason why the bankruptcy cases 14 Now, sir, you're aware of individuals in the
should not be sidelined is that it was the 15 position of Mr Sethi. You can see that in
actions of the Post Office that bankrupted our 16 relation to the details that we've set out in
clients. Mr Shapps, in Parliament yesterday, in 7 the Howe+Co submissions at page 12,
the points he was putting forward as he was 18 paragraphs 18 to 23. You'll remember his
addressing the introduction of the GLO scheme, 19 powerful testimony that you had before you on
accepted that there were those that had been 20 the first day of the human impact evidence on
bankrupted by the Post Office. 21 14 February 2002
Those actions, in bankruptcy or turning to 22 POL still has failed to progress Mr Seth's
an IVA, those individuals are part of a truly 23 claim or pay any compensation to him. Must he,
shocking public scandal, and the clear duty of 24 as he said in his evidence to you, die before
the Post Office and its owner, BEIS, is to clear 25 any compensation is received?
421 122
Ms Sue Palmer's case is a double whammy, and 1 So this is a response from BEIS in relation
you'll recall her position that BEIS originally 2 to her position, and the third paragraph tells
refused to implement your recommendation on 3 us what is being suggested.
providing compensation for subpostmasters who 4 From BEIS:
had been prosecuted and acquitted. Now in 5 "We recognise the need to get you some money
respect of the GLO scheme, her position is set 6 quickly, so we plan to agree to monies being
out amongst others at paragraphs 24-33 7 paid to you in line with the terms of the
BEIS suggests that the way forward is for 8 original assignment. You would have received a
her compensation to be paid 51 per cent to her, 9 portion of the interim payment which relates to
and 49 per cent to Moores, the administrators of 10 your personal losses. We will confirm with
her bankruptey. "1 Moore whether any of the initial £11,000 fee is
So I take you to the bundle if I can, 12 outstanding in each of your cases. Of the
please, again just briefly 13 remaining amount, you would receive 51 per cent
If you'll go to page 14 of the bundle, 14 and Moore will receive 49 per cent. This
bottom pagination, bottom right-hand corner. 15 decision only relates to your interim payment.
You'll see this is a letter dated 30 November to 16 How payments are treated under stage 2 of the
Laura Pickering at Moores, the trustees in 17 scheme are yet to be determined.”
bankruptcy: 18 Page 11. Ms Pickering, again from Moore, to
“Hi Laura, is there still no update? Please 19 Ms Palmer:
put me out of my misery. I need to know one way 20 "Dear Suzanne,
or another. Tomorrow is 1 December, 25 days 21 "No update at the moment, unfortunately.
until another miserable Christmas.” 22 However, we are having a call with BEIS on
Page 12, Thursday December 1, 2022 at 11.02. 23 Monday to discuss this matter further."
Message from Freeths Solicitors to Ms Palmer: 24 Seeing the emails in relation to the subject
“Dear GLO postmaster’, et cetera 25 today, nothing further has happened. That
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1 remains the basic position 1 previously ~ or discharged bankrupt
2 Can we, on her behalf and on behalf of those 2 Of those in an IVA, their debts must be paid
3 others that are stuck in this logjam in relation 3 by BEIS-POL and the IVA discharged. The notion
4 to these bankruptcies, can we ask why? Why is 4 of Ms Palmer's compensation being split is
5 the suggestion that the compensation to 5 unreasonable, unless it can be assured that for
6 Ms Palmer will be split between her and her 6 present purposes, her part of the split to the
7 trustees in bankruptcy? Well, of course we know 7 administrators will never count against her, or
8 the answer, as lawyers, but as someone 8 be deducted at a later stage from her overall
9 registered as a bankrupt, her administrators 9 ‘compensation once BEIS and Post Office have
10 manage her finances and are appointed to use 10 settled the bankruptcy.
ca monies that come to her for the benefit of her "1 Sir, we are aware of the difficulties that
12 creditors, but the Post Office and BEIS put her 12 the position of those that are in this situation
13 there. 13 pose to the Post Office and to BEIS. But the
14 What must happen is one of two choices. For 14 position is in fact, to a large extent,
15 Ms Palmer and others in her situation, they must 15 illusory. These individuals have been known
16 be funded to pay for legal representation to 16 about for some time, and we are here discussing
7 annul their bankruptcies. Because of the highly 7 this on the hearing that you have convened to
18 unusual circumstances of her bankruptcy, the 18 consider what is going on just before Christmas
19 bankruptcy order should not have been made. 19 2012, so long after these events have taken
20 Or, all her debts and bankruptcy fees must 20 place. If they have caused it, they need to
a be paid or secured -- in other words 21 solve it. They need to resolve it, and they
22 guaranteed ~ by a third party: BEIS and POL. 22 need for these individuals to be move forward
23 And her bankruptcy must be annulled in order to 23 and be paid.
24 for her to be able to move forward without that 24 Now, we've had discussions in the margins of
25 hanging over her head as a registered or 25 these hearings today with Mr Brightwell, and
125 126
1 I know he is willing to meet and try and discuss 1 Hang on.
2 the individual circumstances, and try and find 2. MRSTEIN: Sir, 'm dealing with the document that
3 a way forward. And we know that essentially 3 was served yesterday, described as being the
4 there is a will to pay, but the will to pay must 4 additional compensation for GLO members scheme
5 be a will, 'm afraid, to pay those individuals 5 process.
6 more than they might get otherwise in order to 6 SIRWYNWILLIAMS: Yes.
7 find their way through these bankruptcies. What 7 MRSTEIN: Paragraph 13:
8 must not happen is that their compensation 8 “The taxonomy will need to pay special
9 should be split for something that has been at 9 attention to cases where technical difficulties
10 the cause of Post Office or BEIS. 10 can be expected, such as bankrupt or deceased
ca So we suggest, sadly, that the Post Office "1 claimants, company claimants, claimants whose
12 and BEIS have created chaos, and that is adding 12 partners are also claiming under this or other
13 to the suffering. There is a need for an urgent 13 schemes, or claimants lacking capacity and no
14 interim report from you, sir. The situation of 14 legally appointed representative.”
15 so many of our clients is intolerable. BEIS has 15 Well, sir, that's the mention of those
16 had a chance to resolve matters in July, but it 16 individuals in those particular positions, in
17 did not take that chance. 17 other words "We'll work it out sometime’.
18 Now, sir, we've not had sufficient time to 18 Now within this, if you then go, please, to
19 evaluate the details of the prototype scheme 19 the references at page 21
20 that has been put forward. We do note that in 20 SIRWYN WILLIAMS: Page or paragraph?
a relation to this scheme, that there are various 21 MRSTEIN: Page, please, sir. Bottom right-hand
22 issues. 22 corner of the pagination, page 21
23 Sir, very briefly, I don't know whether you 23. SIRWYN WILLIAMS: Yes.
24 have this to hand, but I can read it if not. 24 MRSTEIN: "Consequential loss claims:
25 SIR WYN WILLIAMS: I think I may have it to hand. 25 "The panel should apply the scheme
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consequential loss principles and guidance which 1 number.
are included at appendix 1." 2 MRSTEIN: 34, sir.
Well, sir, there is no appendix 1. The 3 SIRWYN WILLIAMS: Hang on. “The panel should
review and approval at paragraph 36: 4 apply’, yes, fine.
“The version of the terms of reference was 5 MRSTEIN: "... the consequential loss principles
approved by the historical remediation committee 6 and guidance that are included in appendix 1."
on 20 June 2014." 7 SIRWYNWILLIAMS: And there is no appendix 1, yes,
Sir, we know this a cut-and-paste document 8 Ihave that.
from earlier schemes that have been put forward. 9 MRSTEIN: If you have paragraph 36:
We know that because, if you go to page 22, you 10 “The version of the terms of reference was
can see the heading is "Historic Shortfall "1 approved by the historical remediation committee
Scheme Consequential Loss Principles and 12 on 20 June 2014."
Guidance". 13 Then, if you turn over the page, you then
SIR WYN WILLIAMS: Sorry, my page 22 is headed 14 see the "Historical Shortfall Scheme
“Consequential Loss Claims" 15 Consequential Loss Principles and Guidance",
MR STEIN: Yes, sir 16 which I strongly suspect in fact is what is
SIR WYN WILLIAMS: -- and my page 23 is headed 7 meant by appendix 1. But if you then glance
“Historical Shortfall Scheme". I just want to 18 through the number of pages that refer to
be sure I'm in the right place, that's all 19 consequential loss and the principles applied,
MR STEIN: Yes, it's being suggested it may just be 20 which then takes us through from page 22 to
the way it has been printed off. 21 page -- yes, it goes to page 31. Glancing
SIR WYN WILLIAMS: Yes, quite possibly. Could you 22 through that, sir, you will see, which, sir,
just go back to the -- you made a point about -- 23 your own work in the past, these are the
MR STEIN: Yes, sir. Well, wait, we have it. 24 principles set out for pain and suffering, loss
SIR WYN WILLIAMS: If you give me the paragraph 25 of amenity that we will find if we were to turn
129 130
our minds to it 1 referred you to a few minutes ago from the Post
These are complicated matters that require 2 Office, the current position, as regards
considerable attention to detail. They require 3 restorative justice, is that the Post Office
individuals to have representation that can 4 suggest that they can be left to deal with
cover these details from the earliest possible 5 meeting arrangements with subpostmasters, our
stages of meetings, reasonable costs must be 6 clients, and that solicitors are not required.
paid 7 Unfortunately, we have to say that the Post
All our clients are actually asking is that, 8 Office simply has not been listening to our
bearing in mind they've waited decades to 9 clients in the Phase 1 hearings.
receive fair treatment, they want the ability to 10 Ex-subpostmasters, mistresses and managers don't
instruct solicitors to process their claims in "1 trust the Post Office and for very good reason,
the normal way, without having to go cap in hand 12 with the way that they've been treated for so
to the perpetrators of this scandal. Now, sir, 13 many decades.
we've set out in detail, and I won't repeat 14 The years of denial of responsibility
orally, the recommendations we sought in our 15 throughout those last 20 years are a good reason
written submissions. They concer the 16 for the lack of trust and as, we suggest, is the
resolution of the complex cases or bankruptoy 17 hurt from the continuing response to
issues and the like. 18 compensation issues.
Let me now tum just very briefly to 19 All our clients want is for them to have
restorative justice. 20 their lawyers, who they do trust, discuss terms
SIR WYN WILLIAMS: This is your page 33 of your 21 for restorative justice with the Post Office and
written submissions? 22 for their lawyers to be paid reasonable costs
MR STEIN: Sir, yes. 23 for doing so. They should not have to be made
SIR WYN WILLIAMS: Fine. 24 to do otherwise.
MR STEIN: Now, in the same letter that I've 25 Now, we have also suggested, at page 34 of
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our written submissions, how restorative justice
might look, including such an idea as
an entrepreneur's fund and bursaries for the
families of subpostmasters. Our clients’ lives
have been torn apart. They started businesses
that they expected to see them through into
their retirement, looking after their families,
children that would have been brought up within
subpostmaster branches and offices, where they'd
been learning the value of small businesses,
often torn apart by the actions of the Post
Office.
Restorative justice is also about making
sure that, in this particular matter, that the
Post Office has actually learned lessons, and so
far, rather sadly, it seems that the Post Office
has not even started at school.
So enough is enough, sir. We suggest that
there is a need for an interim report under
Section 24.3 of the Inquiry Act and, sir, we ask
you to carry through the suggestion you made
that you made that you may do.
Sir, two last points. We ask that the
process of compensation hearings in this Inquiry
continues. We know it seems that it's the only
133
So there is a process and it doesn't involve
the CCRC.
Sir, forgive me for one moment. (Pause)
Sir, nothing else. Thank you, sir.
SIR WYN WILLIAMS: Thank you. Right. Well, I think
that concludes the oral submissions to
supplement the written submissions that I've
received. I will go away and think about them,
and decide what to do about them. So there we
are.
(3.20 pm)
(The hearing adjourned)
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8 December 2022
way to make sure that anything is done and
I join with Mr Moloney in his submissions, which
is to ask the Inquiry to ensure that it is able
to continue oversight, in these individual
hearings, of the compensation process as we move
forward.
Second point: you've dealt with this largely
by discussing matters with Mr Moloney regarding
convictions and the progress of matters being
dealt with at the Court of Appeal and I agree
entirely with what he said. ll just add one
small point.
The way the Court of Appeal is dealing with
matters, sir, for your information, is that when
subpostmasters or individuals come to them who
are caught within this particular scandal, the
Court of Appeal registrars’ office is contacting
solicitors that have acted on behalf of those
individuals in the past and are ensuring that
they have representation, and we then go through
the process -- either Mr Moloney or myself or
our teams -- of considering the information,
advising as to whether there is, in fact,
a potential for the appeal to go further, and
then putting forward grounds.
134
INDEX
Submissions by MS GALLAFENT .. . 6
Submissions by MR CHAPMAN 42
Submissions by MR MOLONEY .. 52
Submissions by MR HENRY 75
Submissions by MR STEIN .........
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96/15 114/18 25 [2] 2/21 123/21 I 67/25
BEER ITT I THE USHER: [3] 1/3I17-year [1] 84/22 I251,000 [1] 60/21 {63,331.89 [1] 55/17
MRBEER: [1] 3/17. I 45 1120 18 [1] 122/18 259,000 [1] 64/13 I66 [1] 15/18
MR CHAPMAN: [13]
2119 42/17 42/21 45/7I4 19 [3] 9/3 29/8 39/19 I259,359 [1] 60/19 [68 claims [1] 15/20
49 October [2] 90/18 I26 April [1] 90/24
wong 4010 Sova 50/7I IDecember [3] 90/21 26 of [1] 29/7 re
51/1 51/3 24/16 109/23 123/21 I19-year [1] 94/17 I27 [2] 16/3 66/19 —_I7 March 2022 [1]
MR HENRY: [9] 2/23/1 Percent [1] 93/24 I1972 [1] 111/14 27 November [3] I 54/18
75/8 75/20 ae 1,804 [1] 8/8 1990s [1] 83/16 14/17 16/9 118/10 I7 million [1] 114/21
1.00 [1] 75/6 —— 28 days [1] 29/10 I7.2[1] 7/7
95/18 95/22 95/25 2
1.45 [2] 75/11 75/14 29 [3] 12/5 13/21 7.3 [2] 13/16 14/15
Toe OOP ONEY: tay I1@November [1] [2,000 [3] 55/13 110/8} 2016 7.975 million [1]
2/21 38/19 39/7 52/12 #19 ‘10/8 293 [1] 106/12 23/19
2/21 36/19 3017 ©2112 49 October [2] 19/15 I2,240 [1] 7/21 3 700 [1] 79/4
panoesno roby I 204 2.00pm[t} 117/13 [3d 74 2) 34/8 52/15
63/10 O34 TOIT 40.00 [1] 1/2 2.25 [1] 96/19 3,752.26 [1] 58/12/72 [2] 39/12 52/14
rene 10.02 [1] 1/9 2:35 [1] 96/21 3.1 million [1] 29/20 I74 million [1] 8/6
MR STEIN: [19] 2/25)1270 [11 16 20 [1] 129/7 3.20 [1] 138/11 75 per cent [1] 92/21
3/4 4/21 5/16 96/24 10.15 [1] 1/11 20 claimants [1] 30 [2] 39/21 123/16 I77 [3] 23/6 65/24
aoe elec soe (10-16 [1] 1/17 24/12 30 minutes [1] 3/8 I 66/2
128/7 128/21 128/24 [10-30 [1] 1/15 20 June 2014[1] {30,000 [1] 21/5 79 cases [1] 23/6 _
129/16 129/20 129/24) 10-33 [1] 1/19 130/12 31 [3] 84/22.85/14 Ie
10.35 [1] 3/12 20 pages [1] 116/16 I 130/21
ree sotoe 100 [2] 12/13 13/19 I20 years [5] 60/23 I31 million [1] 114/21 I8 December 2022 [1]
__ I100 pages [1] 116/17I 67/3 88/7 104/19 I33 [4] 28/25 29/16 I 1/1
MS GALLAFENT: — I499 years [1] 105/5 I 132/15 123/7 131/21 8 million [1] 23/19
[27] 2/16 6/2 9/8 60/20 61/1
10/11 10/14 13/20 100,000 [2] 50/15 20,400.32 [1] 61/11 I34[2] 130/2 132/25 I8,000 [3]
54/21 2001 [1] 90/25 34,862.61 [1] 55/24 I 64/11
13/24 14/6 14/11 18/6) 44 19) 58/20 124/18 I2002 [4] 90/20 90/24 I35 [2] 84/23 85/14 [80 [1] 8/9
16/12 18/20 18/22 I 44 million [1] 24/6 I 111/25 122/21 36 [2] 129/4 130/9 [82 [1] 23/1
24/1 2713 27/7 27/10 I44 November [1] I2005 [1] 91/6 37 [1] 79/3 83 [2] 22/24 34/9
32/8 32/16 32/21 24/22 2008 [2] 84/7 85/7 I37 Crown [1] 79/4 I85[1] 48/21
Osea aod 44,000 [1] 124/11 I2010 [3] 38/791/8 I; 85 per cent [1] 48/21
40/n2 14.00 [1] 3/14 gut oo .
14.02 [1] 123/23 2012 [1] 126/19 «4,500 [1] —_______
SIR WYN WILLIAMS: 4 4'58 i 52/7 dost 89/14 4.23 million [1] 29/3 I900 [3] 116/21
Fe eee ig 12 [2] 122/17 123/28 I2014 [2] 129/7 40 [1] 2/23 AA7/17 117/22
ne ea eno. 15/42 months [1] 7/12. I 130/12 40 minutes [1] 75/7 93 late [1] isi 8
Too 1012 13/17, [12 October [1] 15/10/2020 [6] 7/19 14/17 I400 pages [1] 116/8 ogee cen Mie
fapt ian tang (2131 62/9 15/7 16/9 16/16 19/11]43 [1] 28/24 -year [1]
12.44 [1] 75/12 2021 [4] 54/16 90/21 I43 claimants [1] 95 [1] 8/2
17/24 18/9 18/17 = 43 (4) 128/7 91/11 107/7 28/21 95 per cent [3] 7/24
18/21 23/23 26/24 {] ill
13-year-old [1] 106/7 I2022 [41] 1/154/18 I44.5 million [1] 8/13 I 57/22 57/23
27/4 27/8 32/1 32/15 433 14] 53/6 55/12 55/14 55/22/45 [4] 2/25 98 per cent [1] 8/11
32/19 37/24 38/17 I 1434 [2] 8/159/10 I 55/23 59/7 59/9 90/22/45 minutes [1] 2/16 [pS
39/3 40/7 40/11 40/13) 435 14] 59/15 109/23 123/23 46,799.52 [1] 54/16 I ___
42111 42/15 42/20 I 44/194 95/13 123/14 I2023 [4] 59/10 74/19 I47 [1] 80/23 ability [3] 21/18
45/1 45/9 45/13 48/2 144 February 2002 [1] I 74/29 91/13 49 [4] 124/14 114/10 131/10
48/10 49/15 50/2 50/6) 499/21 21 [3] 12/14 128/19 I49 per cent [1] able [18] 4/24 9/9
50/24 51/2 52/2 52/11 4 year (ay eaio1 I 128/22 123/10 11/24 22/20 25/25
55/2 62/4 62/14 63/5 I449/496.37 [1] 54/20 I21 September 2022. I= 34/24 36/16 36/20
63/11 70/18 71/20 [aot oss 1 eo 5 46/20 68/3 69/15
72122 7315 73/14 75/3) 445 14 65/8 211691.23 [1] 55/22 I5 December [2] 104/12 105/2 106/1
75/10 75/15 79/11/45 August [1] 6/15/22 [3] 129/10 129/14 I 118/6 118/8 1Ort9 113/14 125/24
95/11 95/19 95/23 _ 459 14) 53/6 130/20 50 per cent [1] 21/16) 134/3
96/1 96/4 96/6 96/17 J456 [4] 97/3 23 [2] 122/18 129/17 I51 per cent [4] 108/6I about [41] 1/5 1/6
96/22 97/10 100/24 46 14] 49/3 23 April [1] 90/24 I 108/11 123/9 124/13 I 9/10 14/4 16/17 18/3
127/25 126/6 128/20 I4¢ Gems [1] 58/25 I23 April 2021 [1] __I53.4 million [1] 27/14 32/20 33/17
128/23 129/14 1289/17/46 million [1] 48/20 I 90/21 114/19 39/10 43/7 49/5 55/11
129122 129/26 13013 I16990 r3} 24/11. I230 [1] 15/5 I 64/14 64/17 64/18
130/7 131/21 131/24 I Sean 24 October 2022 {11 I© 64/20 72/10 73/22
4135/5 47 [2] 24/17 85/14 I 59/9 6 December [2] 81/24 84/10 88/17
THE 47 November [4] I24,999.32[1] 61/9 I 29/17 39/12 91/3 93/3 96/9 96/13
TRANSCRIBER: [1] ‘36/7 55/16 55104 I24°3 [1] 133/20 63,000 [2] 24/15 I 97/24 97/25 98/15
(35) MR BEER: - about
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A action [2] 39/15 43/9 I 111/2 114/22 1177/5 Ialbeit [1] 78/10 ambitious [1] 44/8
spout 1491 90/17 Iactions [4] 71/15 alcoholism [1] 91/18 Iambulance [1]
oot foaha too I 12116 121/22 1391 alerting [1] 38/21 I 110/19
109/11 114/8 120/6 [active [1] 33/16 advisory [6] 9/4 9/16 Iall [56] 3/3 3/10 15/4 Iamended [1] 16/11
426/16 129/23 133/13) acts [2] 79/19 122/10 10/4 16/11 17/12 18/21 24/25 28/8 amenity [1] 130/25
1435/8 135/9 actual [4] 72/13 47/10 28/23 30/12 33/21 amongst [2] 22/6
above [1] 31/3 78/19 79/23 86/3 affected [8] 36/16 34/22 35/8 37/14 40/1) 123/7
abreast [1] 53/16 actually [8] 82/14 41/4 41/10 54/7 62/1 I 44/5 45/8 45/17 49/18) amount [11] 2/6 21/9
absence [5] 17/22 86/1 87/1 93/7 102/20) 86/5 86/20 106/17 51/16 57/23 58/15 24/4 48/4 54/6 63/7
34/11 34/15 41/19 106/25 131/8 133/15 Iaffects [2] 56/17 86/1) 62/21 64/3 64/3 68/23) 66/9 77/6 85/20
65/19 actus [1] 84/10 affirmative [1] 88/10 I 71/16 73/5 74/21 117/23 124/13
absolutely [2] 38/19 add [2] 46/10 134/11 Iafford [1] 105/2 75/10 81/21 82/17 I amounts [2] 8/11
40/15 added [1] 18/7 afraid [2] 3/17 127/5 I 83/18 83/19 86/9 89/6] 105/3
abstract [1] 83/11 adding [2] 17/11 after [21] 4/8 11/16 I 92/9 92/10 93/21 amply [1] 94/8
127/12 14/4 14/16 15/6 16/9 I 93/23 94/25 95/8 analysis [1] 93/2
absurd [1] 121/5
abuse [2] 78/7 78/7
abused [1] 108/15
addition [8] 23/13 55/25 58/4 58/19 97/17 100/21 103/9 Iancillary [1] 113/19
30/23 36/14 36/22 60/25 66/6 81/23 84/7I 103/25 104/10 105/5 Iannounce [2] 1/16
! 39/20 45/23 51/20 I 91/8. 95/8 105/21 I 108/8 110/14 110/22 I 47/2
pened OTe tiosI 69/17 109/24 113/7 117/13 I 111/9 113/21 119/9 Iannounced [4] 20/25
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acceptability [1] 76/1 19/23 23/14 44/18 afternoon [4] 75/15 I 132/19 announcement [9]
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57/24 again [35] 1/16 8/13 I 117/19 117/24 115/6 115/15
see tac UAL oo. address (7] 2019 I 10/3 10/6 10/7 11/6 allowed [4] 42/13 announcements [2]
27/12 43/15 52/18 12/15 13/8 19/13 79/2 97/12 119/17 48/14 118/3
acceptances [1]
29/18 52/21 74/13 78/2 24/20 25/21 27/22 Ialmost [4] 71/23 77/9I annoying [1] 92/4
accepted [22] 8/9 addressed [2] 74/12 I 28/21 29/4 29/21 81/5 96/7 annul [1] 125/17
12/23 14/20 17/6 18/5 98/10 30/11 34/21 39/23 alms [1] 94/14 annulled [1] 125/23
18/15 19/9 21/6 22/7 addresses [1] 51/1 I 55/25 58/8 59/11 65/4Ialone [2] 17/23 anonymised [1]
23/6 24/17 26/17 addressing [4] 70/22I 68/18 75/11 81/9 82/2I 110/15 54/14
28/15 29/6 44/20 45/4 79/25 89/2 121/19 84/15 92/6 92/17 93/4I along [2] 3/24 56/7 I Anonymous [1]
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access [1] 46/15 adjourn [1] 5/1 against [10] 36/23 already [14] 26/17 72/1 101/9 121/14
accomplished [1] adjourned [1] 135/12I 37/9 76/19 76/23 28/12 29/5 29/8 32/24) 123/21 123/22
30/10 adjourning [1] 4/18 I 90/19 92/9 92/9 98/8 I 35/5 37/3 41/12 49/2 I answer [10] 5/5
account [7] 61/21 Adjournment [1] 99/22 126/7 50/14 86/8 92/12 15/14 36/16 62/6
66/5 66/20 66/25 75/13 age [1] 104/19 92/22 102/15 78/14 79/9 90/2 97/19)
91/17 94/8 97/16 administer [1] 82/9 Iagency [1] 93/14 also [32] 2/5 4/5 4/5 I 122/9 125/8
accounted [1] 54/23 administered [4] agent [1] 79/1 5/17 9/13 15/10 16/2 Ianswered [3] 88/15
accounting [2] 83/21 43/17 43/25 47/7 agents [1] 36/15 21/15 23/20 24/7 35/1I 90/6 92/6
83/24 50/23 aggravated [2] 36/9 40/12 44/23 answers [2] 16/20
accounts [2] 103/24 administrative [1] 111/13 111/15 63/12 65/1 69/19 88/10
1017 114/20 ago [5] 56/19 76/14 I 74/10 75/24 77/2 81/7I anticipate [4] 8/3
accrued [2] 63/19 administrators [3] 110/11 122/5 132/1 I 83/8 86/22 90/1 91/1 I 18/6 18/20 22/11
64/3 123/10 125/9 126/7 Iagree [6] 5/5 19/24 I 92/12 102/10 113/14 I anticipating [1]
accusation [1] 87/6 admired [1] 83/18 36/24 119/9 124/6 117/10 128/12 132/25] 26/24
achieve [1] 71/10 admit [1] 5/6 134/10 133/13 anxious [1] 18/10
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75/1 94/17 adopted [1] 9/17 32/6 32/12 33/14 alternatives [1] 16/7 17/21 18/25 19/4)
acquiring [1] 48/8 ADR [2] 47/7 47/12 I 33/21 35/20 107/15 I 34/14 19/5 19/8 21/20 26/11
acquitted [7] 25/24 adult [1] 94/18 108/1 112/25 113/9 Ialthough [8] 2/2 4/17I 30/16 31/25 34/19
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across [4] 85/17 advantage [1] 93/4 I 45/3 always [5] 43/10 57/13 57/16 60/11
98/23 99/6 113/15 advantages [2] 97/7 Iagreement [4] 20/12 I 43/14 67/9 84/15 61/15 62/6 65/2 69/1
act [5] 7/3 82/5 82/9 97/11 20/16 64/14 119/8 118/20 70/8 71/2 78/4 79/6
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89/12 89/13 100/10 Iaims [1] 35/22 amaze [1] 90/12 42/6 79/14 86/18
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sport [3] orig 133/5 I 44/16 44/19 53/24 arranged [1] 98/19 I 75/11 79/14 80/23 I B46 oois guit9 onid
pant 56/25 57/3 57/6 57/11Iarrangements [4] _I 83/14 86/1 89/7 98/6 I {oo/ag xosys 1081
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Pea I 130/19 arrears [1] 110/8 I 114/4 114/10 115/24 IPacKground
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apparently {1] 130/4 Article [1] 76/17 I 123/23 124/21 126/8 ad 1?
ippare applying [3] 26/3 [Article 6 [1] 76/17 I 127/9 128/19 1292 I tay sei
appeal [15] 2205 I 61/14 106/19 artifical [1] 68/17 I 12974 132/25 13917 I pany WA Se
35/4 35/10 38/8 38/10/4PPointed [3] 74/4 jas [217] 134/10 4107/4
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134/10 134/13. 194/17) appreciate [3] 48/10 I 81/16 116/5 122/4 attached [1] 60/12 Ipanprn Uh ne
tayoa 79/13 103/3 ask [14] 21/11 49/17 attempt [1] 63/16 [pang tl Hoe
Appea’s [1] 89/16 IAPPreciated [1] 55/1 I 49/19 62/5 65/25 attend [1] 13/2 Pees ar
aeeeicdity 38/6 [aPPreciation [1] 74/6 75/8 77/24 79/8Iattending [1] 114/3 I 75 car4g 413
aeeals Io asia I 42/12 87/18 125/4 133/20 attention [4] 21/20 I {> 6 a9019 49611
appes approach [10] 9/17 I 139/23 19479. 7ai24 12819 19118 I 26/10
11 '5/16I asked [6] attenuates [1] 7 5
appear [3] 6/3 42/3 I 33/18 41/9 65/3 77/19) 39/10 5519 84/3 85/14 attitude [1] 807 IPankruptcies [5]
appears [4] 25/20 I 78/11 12/8 Attorney [1] 82/7 I 495/17 12717
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aan I approaching [1] _ aspect [1] 56/21 audit [1] 66/11 Borie 3019 40rs
appendix [10] 54/10 I 75/25 aspects [2] 31/8 August [2] 6/15 61/13 61/18 61/22
58/14 60/13 68/17 [APPropriate [8] 11/5 I 62/23 88/21 63/8 63/21 64/4 69/21
ba/18 1292 129/3 I 11/8 12/1 49/16 49/19] assertion [1] 71/24 auspices [1] 69/24 I So), Co" aia One
1430/6 130/7 130/17 54/8 67/10 69/9 assess [3] 10/20 authority [3] 61/12 87/17 108/2 108/12
appendix 4 [5] 129/2 I@PProval [2] 48/3 I 33/9 101/9 86/4 102/8 4109/1 121/14 121/22
12913 130/6 130/7 I 129/4 assessed [4] 15/20 [autoimmune [2] 422/10 123/11 123/18
1307 approved [2] 129/6 I 21/23 47/18 100/14 I 82/22 84/6 tary 195/18 195/19
Appendix B [1] 60/13] 130/11 assessing [1] 20/14 I availability [1] 22/3 I 495/09 125/23 126/10
applicant [16] 10/19 approximately [8] assessment [4] available [5] 4/23 131/17
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29/3 29/20 39/20 94/23 74/1 pted [3]
15/13 16/7 16/22 17/4 1 121/16 121/21
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55/21 60/19 60/22 April [3] 90/21 90/24 Iassignment [1] await [2] 80/16 80/25 based [4] 66/18
81/10 site [3] 25/14 soci [6] 2/9 12/5 awaiting rey Sure. I 128 82/17 94/24
a 5 arbiter assist awaiting
aprons bay 862" I 25/19 120/12 24/1 74/2 117/7 117/7I 58/23 59/2 ieee ale
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Tart tore teria tare Arch [3] 81/18 81/22 I 64/19 64/19 70/23 I 61/15 63/4 64/5 65/14 PASI [1A] OS It
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gon tag tata {arising [4] 52/19 I 15/19 18/23 2116 I 36/11 oe Yate wBv19
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96/12 97/14 98/7 124/1 124/4 124/22 I 75/6 75/8 96/11 96/15I 70/21 70/24 71/1 71/3) 128/13
108/4 109/7 110/4 125/12 125/22 126/3 I 96/17 96/20 99/16 71/18 71/21 72/19 capital [2] 51/18 83/7
126/9 126/13 127/10 I 99/17 72/25 73/1 73/15 caravan [1] 107/16
tort 116/13 125/17) 97112 427/15 breakdown [1] 119/6I 73/18 73/20 74/2 care [2] 72/21 102/9
become [3] 73/3 BEIS's [2] 14/25 breast [1] 79/22 76/20 77/9 78/10 career [1] 87/20
87/23 91/22 114/4 Brent [1] 105/14 79/19 81/14 81/20 I carefully [1] 45/9
becomes [1] 77/9 IBEIS-POL [1] 126/3 [brief [1] 1/21 83/25 84/17 84/18 I caring [1] 16/18
bedevilled [1] 100/5 Ibelatedly [1] 78/10 I briefed [1] 97/2 86/13 86/20 87/1 carry [1] 133/21
been [181] believe [2] 101/7 _I briefly [7] 51/3 63/13 I 87/10 87/18 88/18 _I carrying [1] 5/22
Beer [2] 3165/12 I 118/17 73/9 92/19 123/13 I 88/21 90/5 90/10 91/1I case [42] 8/17 9/18
before [34] 7/18 7/24 [believes [3] 43/12 I 127/23 131/19 91/14 92/4 92/12 95/5) 12/17 17/24 18/10
12/7 13/17 14/1 2219 I 51/23 110/22 bright [1] 94/17 97/9 98/5 98/20 21/23 21/23 23/3 30/5I
24/18 30/2 37/24 38/6I benefit [4] 9/23 30/18I Brightwell [2] 117/14) 101/13 101/17 104/7 I 38/16 44/25 49/22
43/19 47/20 59/20 I 60/8 125/11 126/25 104/10 108/5 109/9 I 49/23 54/3 54/6 54/13
63/21 68/1 76/13 benefits [2] 35/25 I bring [2] 38/13 46/19I 110/17 112/18 113/3 I 54/15 54/18 55/11
76/22 79/3 79125 51/19 bringing [1] 34/12 I 113/25 114/8 125/8 I 55/21 55/24 55/25
89/15 89/18 89/19 /Penevolence [1] Britain's [1] 87/13 I 125/12 126/13 127/4 I 59/5 60/16 60/17
90/1 91/15 9216 93/6 I 94/13 broad [1] 65/3 127/16 127/24 130/17I 60/17 61/8 61/8 64/11
93/7 93/21 96/11 bereft [1] 112/21 broadly [3] 8/19 buzzword [1] 77/4 67/1 91/14 92/13
97/18 118/5 122/19 [beset [1] 80/10 33/16 43/13 C. I 102/10 105/10 107/23}
122/24 126/18 beside [1] 84/2 Broome [1] 114/15 I¥ __I 409/17 109/21 111/14
began [1] 12/14 best [4] 33/18 111/4 Ibrought [2] 65/25 calculating [1] 66/14) 111/15 116/2 116/18
begin [5] 5/13 43/1. I 119/17 119/1 133/8 calculation [4] 33/18 I 123/1
47/20 47/23 122/2 bestowed [1] 109/2 IBrown [1] 107/21 51/18 66/18 115/19 ICase 4 [2] 54/15
beginning [4] 6/7 better [5] 4/18 42/21 Ibrush [1] 65/3 call [6] 60/11 102/25 I 55/25
18123 93/22 105/10 I 89/21 88/3 115/10 I brutal [1] 103/14 110/19 116/9 116/13 ICase 2 [2] 55/11
beginnings [4] between [10] 11/8 Ibugs [2] 80/20 93/25 I 124/22 55/24
1143/14 12/20 45/5 58/18 building's [1] 3/21 Icallback [1] 36/21 ICase 3 [1] 55/21
62/10 67/23 79/1 built [1] 94/4 calls [1] 36/18 Case 4 [4] 60/16
begun [2] 60/5 74/13 I
behalf [15] 6/3 26/25 92/18 103/11 125/6 Ibullying [1] 109/2 Icame [2] 93/8 101/17) 60/17 64/11 67/1
39/25 41/15 42/23 beyond [8] 41/25 bundle [2] 123/12 campaigners [2] Case 5 [1] 61/8
52/13 53/23 93/2_—I 42/3. 48/7 58/1 76/19 I 123/14 47/16 100/1 cases [59] 8/11 9/3
109/14 112/16 120/17) 86/2 89/17 93/5 burden [1] 65/12 [ean [74] 3/7 4/8 5/14 I 9/6 9/14 10/8 11/19
120/19 125/2 125/2 Ibig [1] 105/22 bureaucracy [2] 8/19 9/12 12/1 13/3 I 12/19 17/3 20/13 23/2
134/18 biggest [1] 73/24 I 18/11 88/19 13/15 13/17 14/7 _I 23/6 23/9 23/10 23/15
behaviour [1] 111/18 ills [2] 105/3 106/4 Iburied [1] 94/5 14/12 19/6 19/12 20/7I 23/16 25/4 25/6 25/17I
behind [2] 104/6 [bit [4] 2/17 45/1 bursaries [1] 133/3 I 20/16 22/11 23/23 I 25/19 29/5 29/22
115/14 71/22 96/9 bury [1] 76/20 26/23 27/2 31/10 31/20 38/3 38/11
i i i 32/23 37/22 38/12 I 38/20 44/14 47/20
being [35] 6/19 26/1 bitterly [1] 92/13 burying [1] 94/6
46/2 46/5 46/23 46/25) Blakey [1] 70/7 business [11] 42/24 I 42/5 42/18 42/20 54/10 56/5 57/16
47/21 48/9 50/22 [blood [1] 91/24 60/22 60/23 63/22 I 46/10 46/16 48/15 _I 57/20 58/13 58/17
53/11 60/8 61/4 64/7 [board [2] 47/10 99/6 I 67/2 87/20 91/7 91/9 I 51/3 54/7 58/13 58/17/ 58/20 58/24 59/4 60/5
84/11 67/3 70/3 71/11IBObby [1] 100/19 I 104/20 107/8 117/16 I 59/21 62/9 67/7 67/10] 62/12 68/15 69/15
83/13 87/24 87/24. Ibody [2] 35/15 54/12 Ibusinesses [3] 83/7 I 71/2 71/17 71/21 72/9I 69/21 69/23 70/3
boils [1] 2/8 133/5 133/10 72/17 72/18 74/25 70/16 70/17 71/7 73/2
oe aoe rosa. 99/3 borrowing [1] 106/21) but [124] 1/24 2/9 3/9I 75/4 75/6 75/6 75/16 I 74/17 100/16 108/11
115/21 1214/3 124/3 [both [12] 27/24 27/25I 3/25 5/45/12 5/14 I 77/6 77/18 85/23 87/9) 108/12 111/4 114/11
1424/6 126/4 128/3 35/6 40/5 45/17 47/14) 5/20 9/8 9/9 9/21 92/2 93/3 95/11 97/8 I 121/3 121/8 121/14
1429/20 134/9 69/14 72/21 76/18 10/10 11/20 13/8 99/18 99/18 100/10 I 124/12 128/9 131/17
BEIS [53] 26/20 81/6 82/20 83/7 14/23 15/4 17/11 100/14 105/3 107/2 Icash [1] 66/8
26/21 30/9 31/16 bottom [4] 104/7 18/17 19/4 20/4 21/13) 119/4 122/2 122/15 ICassell [1] 111/15
35/14 41/20 43/19 123/15 123/15 128/21] 24/13 26/10 26/21 123/12 125/2 125/4 I Castleton [3] 81/19
Bountiful [1] 94/14. I 27/1 32/1432/16 I 126/5 127/24 128/10 I 87/19 95/19
Tied Gore Tart yaya Box [2] 86/25 94/22 I 32/19 36/1 38/15 I 129/11 131/4 132/4 I eategorical [1] 88/22
reg 7218 7219 73/4 bracket [2] 111/19 I 40/22 42/10 43/13 Iean't [4] 5/15 53/20 Icategories [1] 8/20
roe doo scoy I 112/13 43/25 48/12 51/25 I 85/6 94/20 category [4] 9/13
400/18 101/19 101/21 branch [2] 22/15 53/15 53/24 54/13 candour [1] 81/10 9/20 10/5 10/16
Wort woote 1ia/te I 22/16 55/5 56/9 57/5 57/12 \cannot [5] 17/4 28/16Icattle [4] 115/11
112/23 113/25 114/2 IPranches [1] 133/9 I 57/18 57/19 58/8 59/2 74/23 97/10 104/17 Icaught [1] 134/16
414/14 114/19 115/3, [brand [2] 36/4 87/14 I 59/22 60/6 62/6 62/13Icanvassing [1] 114/3I causation [1] 84/10
4115/6 118/3 119/15 IPranded [1] 87/11 I 62/14 63/1 63/3 63/17Icap [4] 45/15 66/7 I cause [4] 50/9 50/11
breaches [1] 82/4 I 64/8 64/15 65/1 65/25) 111/6 131/12 61/22 127/10
(88) because... - cause
INQ00001055
INQ00001055
Cc 123/22 126/18 clarified [1] 33/25 34/19 128/4 132/18 133/24
caused 113) 34/5 IChristopher [1] clarify [1] 16/20 commencing [1] 134/5
caused [13] 34/6 4714 clarity [2] 117/8 34/17 compensatory [1]
71/15 77/7 83/9 circulate [1] 81/24 119/4 comments [1] 61/14
101/10 104/3 106/16 circumstances [13] IClarke [2] 89/13 118/18 competent [1] 111/1
1408/8 112/8 126/20 4/17 8/24 10/21 16/21I 89/13 commercial [1] 89/9 Icomplete [3] 15/19
26/6 33/11 37/14 claw [1] 89/19 commission [4] 38/4I 16/3 16/4
causes [1] 92/22
CCRC [8] 35/7 37/2 45/23 67/7 107/5 clear [15] 6/23 10/9 I 38/12 38/21 64/20 completely [4] 2/15
38/22 38/25 80/6 112/9 125/18 127/2 I 16/12 26/14 31/2 commissioned [1] 61/16 72/23 83/3
Citizens [7] 35/21 32/14 34/10 44/12 80/13 completeness [1]
coiling (1) Sar 36/3 36/8 36/11 36/13] 48/15 93/19 95/11 commissioning [1] I 11/11
cellular [1] 86/1 36/18 37/5 115/1 120/16 121/24 I 64/24 completing [1] 36/21
cent [17] 7/22 7/24 City [1] 87/21 121/25 commitment [1] 43/2) complex [9] 19/19
8/2 8/9 8/11 21/16 civil [6] 76/7 77/12 Icleared [3] 90/17 committed [4] 51/6 I 22/18 33/8 61/18
48/21 57/22 57/23 78/21 82/15 120/8 91/15 105/9 51/10 51/15 86/8 100/13 102/22 121/2
92/21 93/24 108/6 120/19 clearly [2] 46/4 102/9Icommittee [3] 35/14 I 121/8 131/17
408/11 123/9 123/10 Iclaim [18] 9/14 11/2 Iclever [1] 84/9 129/6 130/11 complexities [1] 8/21
424/13 124/14 15/22 16/8 21/12 client [10] 97/19 common [2] 81/7 complexity [1] 8/18
central [1] 80/2 24/14 25/16 25/25 98/11 102/1 102/5 81/21 complicated [2]
certainly [3] 40/2 28/11 28/13 31/8 54/8) 102/8 109/14 112/16 Icommunication [1] I 107/24 131/2
49/20 97/10 55/4 56/2 90/3 91/13 I 114/3 116/5 116/25 I 86/4 comply [1] 102/7
cervical [1] 84/4 116/22 122/23 clients [14] 2/25 4/21Icompany [2] 39/21 Icompose [1] 85/15
cessation [1] 66/19 claimant [6] 28/12 74/22 97/13 103/24 I 128/11 compound [1]
cetera [2] 117/3 33/17 61/6 61/24 109/20 114/9 121/4 Icompare [2] 76/11 100/13
123/25 112/5 116/22 121/17 127/15 131/8 I 118/3 comprehension [1]
Chair [1] 1/21 claimants [48] 24/12 I 132/6 132/9 132/19 Icompassion [2] 93/6
chaired [1] 47/11 24/25 25/23 26/17 clients’ [1] 133/4 106/24 112/21 computer [1] 82/19
challenged [1] 37/1 27/17 27/25 28/6 28/7 I cliff [1] 105/1 compensate [2] 61/1 Icomputer-generated
challenging [1] 36/6 28/9 28/10 28/15 clock [1] 100/19 100/3 [1] 82/19
chance [2] 127/16 28/18 28/21 28/22 close [1] 54/21 compensated [6] concern [10] 50/18
127/17 29/3 30/13 30/17 closing [1] 92/6 65/2 85/9 92/3 95/15 I 50/24 53/10 59/14
change [2] 87/22 33/11 33/14 34/23 closure [2] 44/20 112/12 119/25 60/2 74/11 76/14
97/23 44/6 45/18 46/16 47/3I 75/1 compensating [2] 92/23 118/23 131/16
changed [2] 85/21 47/22 48/22 48/25 Co [19] 22/12 22/20 I 101/23 112/5 concerned [12] 6/17
85/22 49/4 52/14 53/1 54/7 I 34/4 34/7 34/14 40/18Icompensation [97] I 7/10 33/5 33/21 56/22
56/18 59/1 60/3 65/11) 41/16 97/2 99/25 6/6 6/8 7/10 25/25 57/4 59/4 61/5 66/14
channels [1] 36/12 I 65143 go/18 73/10 I 101/25 111/1 113/23 I 26/7 26/13 27/14 68/15 96/9 104/15
chaos [3] 120/3
1420/3 127/12 73/12 74/10 100/9 114/1 114/9 115/25 I 29/21 31/3 31/9 33/19] concerning [4] 8/21
Chapman [9] 2/13 I 119/11 119/12 120/19) 117/13 118/9 120/16 I 37/20 40/20 43/4 43/8) 25/4 44/15 49/1
42/15 42/16 42/20 128/11 128/11 128/11] 122/17 43/15 43/23 46/1 concerns [4] 11/14
45/1 70/2 70/14 95/20 128/13 Co's [1] 36/24 47/19 50/15 51/7 43/7 56/23 73/22
1436/3 claimants' [1] 47/24 ICode [1] 82/6 51/17 51/22 51/24 concerted [1] 49/1
character [1] 122/12 claimed [1] 70/10 coffee [1] 84/12 52/21 52/22 52/23 conclude [3] 51/23
characterised [2] claiming [1] 128/12 Icohesion [1] 99/4 52/25 54/23 55/18 74/5 89/24
37/13 121/12 claims [62] 9/19 12/7I cohort [2] 28/5 53/20I 59/20 60/3 60/11 concluded [1] 4/9
charge [1] 110/18 15/20 17/14 19/18 coin [1] 4/25 61/24 63/15 64/5 67/8I concludes [1] 135/6
charged [1] 83/20 20/11 27/20 28/3 coincidence [2] 84/8 I 67/12 71/4 71/9 72/1 Iconclusion [7] 4/2
charger [1] 110/18 28/20 29/1 29/7 29/9 I 86/6 72/14 73/10 74/9 18/13 20/19 25/13
charges [1] 76/18 I 29/23 30/4 30/7 30/14/coincidentally [1] I 74/14 74/18 74/22 I 27/12 37/6 94/7
charity [1] 107/18 30/20 31/6 31/23 109/16 74/25 75/23 77/5 81/5) conclusions [6] 6/14
cheap [2] 57/19 32/23 33/2 33/7 34/1 Icold [1] 110/14 82/17 86/24 87/15 6/16 6/19 16/6 22/9
4144/5 34/7 34/13 34/19 collapsed [1] 63/23 I 89/12 90/4 94/11 37/9
checks [1] 16/2 34/23 46/6 46/13 colleague [1] 75/16 I 97/25 98/19 98/24 condemned [4]
Chief [1] 46/25 46/17 46/19 47/17 colleagues [1] 83/18 I 99/2 99/23 100/4 84/20 84/21 84/24
child [1] 88/2 47/24 52/21 64/24 combined [1] 23/17 I 100/6 100/16 102/22 I 85/10
children [6] 84/24 66/15 67/18 68/4 68/6Icome [13] 1/7 1/25 I 102/24 104/14 104/16] conduct [4] 62/12
85/9 91/5 91/17 106/6I 98/11 68/13 69/2 69/4) 10/1 10/14 23/10 104/21 106/13 107/10 80/9 81/6 112/9
133/8 69/8 69/10 74/8 74/21) 30/13 67/25 77/4 80/1 107/19 107/22 110/24I conducted [4] 58/10
choice [2] 75/4 108/5 78/9 92/22 97/25 90/5 92/4 125/11 111/22 112/19 113/1 I 58/20 67/16 80/11
choices [2] 99/8 100/13 106/14 115/25I 134/15 113/18 114/8 115/17 I conferences [1]
125/14 117/2 117/21 118/11 Icoming [4] 1/22 7/25 I 117/15 118/11 118/22] 116/25
Christmas [6] 30/2 I 118/19 118/22 119/13] 32/11 99/22 119/3 122/23 122/25 I confidence [2] 20/2
99/16 TOS/19 105/20 I 128/24 129/15 131/11]commas [1] 83/23 I 123/4 123/9 125/5 I 46/17
clandestine [1] 91/25I commenced [1] 126/4 126/9 127/8 I confident [1] 68/9
(89) caused - confident
INQ00001055
INQ00001055
Cc contacts [1] 97/13 118/8 123/15 128/22 Icredit [2] 122/1 dead [1] 100/20
confidential 4) [contain [2] 15/18 corporation [3] 78/23] 122/13 deadline [5] 7/19
confidential a 82/10 93/14 creditors [3] 87/10 I 14/17 15/7 16/25
confirm [4] 19/7 42/6 correct [7] 63/1 87/18 125/12 19/11
44/17 124/10 containing [2] 7/3 95/18 95/22 95/25 credits [1] 51/19 deal [11] 53/3 53/6
confirmation [4] 37/16 96/7 118/20 118/25 cricket [1] 113/15 64/23 78/6 81/20 89/1
15/25 44/19 44/24 contamination [1] corresponded [1] criminal [10] 26/8 89/2 102/10 102/18
57/13 78/21 113/25 38/3 38/11 38/20 76/8) 109/12 132/4
confirmed [4] 21/10 contesting [1] 76/18 Icorrespondence [3] I 78/21 80/11 81/11 dealing [8] 2/5 5/21
23/3 23/11 26/21 context [11] 10/1 118/4 118/9 118/10 I 82/3 82/5 24/4 38/25 102/21
confirming [1] 115/2 11/6 11/11 26/14 cost [6] 20/10 102/11Icriminalised [1] 121/10 128/2 134/13
confirms [1] 16/13 31/14 34/3 40/6 40/24) 104/25 117/18 117/19) 93/15 dealt [16] 13/15 27/2
confiscation [2] 42/2 86/14 111/17 120/10 criteria [1] 21/8 27/5 53/5 56/5 65/7
82/17 90/19 contingency [2] costs [22] 19/17 20/3Icriticism [1] 55/3 68/23 70/4 83/11
confused [1] 45/1 27/11 27/13 20/15 45/17 47/25 Crown [3] 79/3 79/4 I 102/11 108/12 113/4
connection [4] 52/20 continue [8] 25/10 47/25 48/7 48/7 64/15I 82/6 115/21 122/6 134/7
connectivity [4] 3/21 52/5 68/10 74/17 100/9 114/20 117/9 Icruelty [1] 88/1 134/10
conscious [2] 46/11 74/19 95/4 103/17 117/12 118/21 119/6 Icrushed [1] 87/5 Dear [2] 123/25
53/13 134/4 120/7 120/8 120/12 Iculture [1] 95/1 124/20
consequence [1] continued [1] 74/24 I 120/21 120/22 131/6 Icup [1] 84/12 debt [3] 98/7 105/4
80/12 continues [4] 13/9 132/22 current [5] 19/1 110/5
consequent [1] 83/9 27/19 48/25 133/25 Icould [16] 2/10 15/2 I 74/21 104/24 112/24 I debtors [2] 64/6
consequential [10] continuing [7] 13/12 I 24/2 26/17 37/1 37/12) 132/2 72/15
15/9 51/9 66/15 53/16 65/10 74/11 63/6 65/6 66/20 85/5 Icurrently [6] 8/15 debts [9] 61/13 61/17
428/24 129/1 129/12 75/22 115/5 132/17 I 89/6 108/18 110/18 I 26/3 30/18 39/16 63/19 64/3 64/4
429/15 130/5 130/15 continuous [1] 75/7 I 111/21 112/1 129/22 I 61/20 96/1 104/15 122/1 125/20
1430/19 contract [3] 66/21 couldn't [1] 84/19 customers [1] 93/17 I 126/2
Consequently [1 I 66/23 66/24 counsel [4] 70/9 _Icut [2] 110/9 129/8 Idecades [2] 131/9
1410/9 contrary [1] 92/17 111/2 114/17 117/5 >-.UO~C 132/13
consider [12] 11/4 contributed [2] count [1] 126/7 —__________Ideceased [1] 128/10
19/22 21/3 21/15 101/11 108/16 country [3] 79/3 Dallas [2] 100/20 deceived [1] 77/15
24/24 31/23 35/4 35/9I Contributions [2] 87/21 95/7 100/22 December [11] 1/1
41/1 97/12 101/10 83/4 83/5 couple [5] 51/3 58/22Idamage [8] 53/10 24/16 29/17 39/12
126/18 control [2] 102/25 100/11 106/3 122/4 I 56/1 56/15 83/9 84/4 I 54/16 104/13 109/23
considerable [2] 120/15 course [46] 3/10 3/17I 88/5 89/3 101/10 118/6 118/8 123/21
92/10 131/3 controlling [2] 98/23 I 6/20 7/12 10/3 10/15 Idamages [19] 30/25 I 123/23
considerably [1] }9/4 18/12 21/23 22/3 29/2) 31/5 46/6 46/12 60/7 I December 1 [1]
7/11 convened [1] 126/17 I 37/17 37/19 38/12 61/4 61/5 61/6 70/10 I 123/23
consideration [8] conversations [1] 39/15 41/25 48/23 70/11 71/11 82/16 decide [3] 3/22 49/15
414/12 17/13 33/22 116/6 50/4 51/25 53/19 88/9 111/13 111/16 I 135/9
34/1 65/10 67/6 78/20 convicted [20] 9/22 I 53/22 54/14 56/7 111/20 111/20 112/4 I decided [6] 24/9
116/12 9/25 10/10 26/8 35/3 I 56/17 57/19 57/20 115/20 60/18 80/15 80/24
considerations [1] 35/8 38/1 38/7 38/24 I 63/13 63/15 63/23 damning [1] 109/2 87/22 106/9
44/9 50/17 71/8 76/23 64/1 65/24 74/23 77/5I darling [1] 83/15 decision [10] 11/9
considered [6] 6/20 77/22 81/15 81/19 79/18 80/22 81/17 data [3] 46/16 53/19 I 16/10 17/8 54/1 56/8
19/6 31/15 47/17 81/20 82/15 83/2 82/24 83/20 83/25 80/21 56/10 56/24 80/17
55/20 114/16 87/12 90/23 88/10 89/22 91/13 date [18] 5/2 5/2 8/5 I 89/7 124/15
considering [5] 9/17 conviction [8] 38/2 I 93/24 98/20 99/13 9/2 12/5 15/1 16/16 I decisions [2] 56/11
10/4 18/24 106/4 43/18 69/21 77/11 114/13 125/7 17/15 19/21 22/25 I 58/23
134/22 81/20 82/3 95/16 court [11] 7/3 38/10 I 24/5 27/17 33/8 34/20I declared [1] 60/4
considers [1] 17/9 122/11 38/24 39/1 76/22 78/9I 58/21 59/1 59/8 declined [3] 16/22
consist [1] 23/9 convictions [24] 10/3I 89/16 120/7 134/10 114/20 17/16 25/5
consistent [1] 104/8 22/10 22/22 22/24 134/13 134/17 dated [4] 6/15 118/6 I dedicated [1] 36/8
consistently [1] 26/2 27/21 28/24 courts [3] 77/14 79/3I 118/8 123/16 deducted [1] 126/8
48/13 30/17 31/14 34/9 79/4 dates [1] 13/2 deduction [2] 8/7
constantly [1] 105/2 35/16 35/19 36/25 cover [4] 51/7 51/11 Idaughter [3] 84/23 8/14
constructively [4 I 43/22 46/1 52/16 116/25 131/5 88/2 106/8 deductions [1] 65/13
25/11 52/25 67/14 70/16 covered [1] 94/4 David [1] 70/7 deemed [1] 17/21
consultation [1] 47/3 74/7 76/8 111/11 covering [2] 27/24 Iday [5] 55/24 104/25 I defective [2] 100/23
contact [1] 36/25 114/23 134/9 48/21 104/25 107/10 122/20] 100/25
contacted [1] 35/9 copies [1] 15/15 covers [1] 116/22 days [6] 29/10 29/13 I defects [2] 80/20
contacting [2] 16/4 Core [4] 4/12 41/16 Icrawl [1] 110/17 58/23 110/16 122/4 I 94/1
134/17 97/3 107/3 CRB [1] 82/25 123/21 defendant [1] 120/13
corner [4] 104/8 created [1] 127/12 IDBS [1] 82/25 defendant's [1]
(40) confidential - defendant's
INQ00001055
INQ00001055
D desire [1] 77/13 directly [3] 26/20 I 86/18 99/11 103/2 IE
FolondanFen yay [desired [1] 75/1 41/4 47/8 1911/5 112/17 114/14 I
defendant's...[1] I esperate [2] 108/4 IDirector [1] 118/15 I 118/17 127/20 132/20I°ach [9] 7/14 21/21
112/9 ‘ 43/15 54/3 54/5 56/12
110/21 disagreement [2] _ I 132/24 133/22 135/9
defendants [1] 77/22 2 68/25 119/18 124/12
despite [1] 112/22 I 44/25 108/3 document [8] 6/22 <
defer [1] 38/15 ., * earlier [4] 57/8 88/16
deferred [1] 1/15 destroyed [4] 76/12 Idisappointment [2] I 15/14 17/19 65/23 115/24 129/9
TINT 87/12 92/1 105/21 105/21 66/2 81/4 128/2 129/8
defined [1] 119/2
definitely [1] 2/16
degradation [1] 88/1
earliest [3] 31/5
51/15 131/5
early [10] 9/19 10/7
detail [6] 11/19 49/13I disastrous [1] 68/7 Idocumentation [1]
81/4 102/18 131/3 disbursements [1] 65/19
131/14 12019 documents [1] 15/15
peered detailed [2] 6/9 114/4I discharged [3] 32/4 Idoes [13] 37/17 on Gece
dens [20] 3/7 10/23. [details [7] 54/9 54/12] 126/1 126/3 39/17 40/25 78/1 33/16
y 68/19 71/1 122/16 _Idisclosable [1] 83/1 I 86/23 90/13 93/9 :
14/19 20/8 34/5 58/5 , earning [2] 82/23
127/19 131/5 disclosure [7] 65/24 I 93/11 101/13 103/1
64/25 69/4 69/12 74/9 , 106/17
determine [1] 7/1 I 80/7 82/6 82/8 95/2 I 105/11 108/22 120/1 :
75/22 78/4 78/4 79/7 i ' earnings [3] 54/24
determined [3] 77/19] 116/8 116/25 doesn't [7] 18/1
80/1 81/15 91/14 ! 55/5 89/4
117/18 124/17 disconnect [1] 92/18I 40/21 85/18 85/18 oe
98/13 107/1 109/19 12 i earnings’ [1] 66/15
delayed [3] 1/10 31/9 determining [2] discrepancy [1] 66/6 I 102/1 110/10 135/1 easier [2] 20/10
76/4 14/19 17/10 discuss [6] 3/5 11/24/ doing [4] 77/23 89/10I fe48
delaying [1] 31/21 [detrimental [1] 108/7I 19/23 124/23 127/1 I 120/2 132/23 easily [1] 77/18
devastated [1] 76/7 I 132/20 dolling [1] 120/14
delays [9] 12/12 13/3 . 316 ldon’ ya 3oo1 eaten [1] 110/13
S002 57/25 59/12 [development [4] _Idiscussed [5] 31/16 Idon't [16] 9 eats [2] 108/21
30/24 34/4 35/12 31/16 99/3 102/1 45/7 54/11 59/24
59/25 60/2 68/8 68/25I 110/10
‘ 45/21 103/15 65/25 73/11 78/6
deliberate [3] 77/12 . edge [1] 105/1
developments [5] discusses [1] 106/6 I 82/24 86/18 98/14
79/9 80/3 : ‘ effect [8] 4/19 19/15
deli 6/5 6/8 6/10 14/24 _I discussing [2] 98/15 100/24 107/18
leliberately [3] 76/4 21/18 32/6 80/1 81/15
31/25 126/16 134/8 127/23 132/10
77/21 119/23 : ; 85/15 109/19
deliver [2] 7/2267 [devour [1] 87/10 Idiscussions [3] done [12] 20/24 effective [1] 67/16
: dialogue [2] 67/23 I 33/17 33/21 126/24 I 33/15 36/25 43/11 ‘
delivered [3] 26/20 1419/7 di 4] 84/6 79/24 90/3 95/8 96/25 effectively [5] 22/14
51/13 112/17 isease [1] 77/17 83/2 93/13
did [15] 10/12 27/1 Idishonest [1] 94/2 I 97/23 97/25 120/20
64/14 77/20 83/17 dishonesty [1] 91/25 I 134/1
83/24 85/2 85/3 85/16) dismiss [1] 82/2 Donna [1] 108/24
104/19
delivering [2] 37/15
75/22 eight [2] 54/18 89/15
dopo eeteate TH 88/21 89/14 103/18 Idismissal [1] 82/1 Idoor [2] 101/17 eignt months [1]
tomer 104/21 107/16 127/17Idismissed [1] 81/23 I 102/2 either [14] 12/8 13/1
demonstrated (1) IAldn't [7] 16/17 21/24] disorders [1] 82/22 Idouble [1] 1201 ISoeol Aoi ar
ten 23/3 38/8 73/3 88/18 Idisoriented [1] 2/15 Idown [6] 29 1713 I 44/9 eyo 4ig/00
demonstrating (1) I 125/9 disparity [1] 78/25 I 57/8 75/16 78/13 84/6 aq saajoq
on die [1] 122/24 displayed [1] 3/24 Idownwards [1] 84/5 I \aporate {1} 63/12
died [1] 86/8 dispute [9] 13/10 IDr [1] 62/25
dental {3] 80/3 87/6 I differ [1] 32/8 21/14 21/21 32/13 IDr Hudgell [1] 62/25
denied [2] 76/4 94/25I‘ifference [2] 54/22 I 32/14 32/15.41/11 Idrabs [1] 104/16
deny (ty y6/17 54/22 45/18 62/21 draft [4] 103/5 ets
Department [24] different [11] 5/20 Idisputed [1] 103/11 draftsman [1] 117/19) 4), ibility [3] 15/21
P 32/9 52/20 70/4 70/18Idisputes [2] 25/10 Idragged [1] 108/8 I°"'9
42/24 43/1 43/6 43/12] gg 15/25 21/8
70/24 71/23 72/24 I 27/14 draining [4] 105/6 I 1
44/1 44/3 44/9 44/16 d eligible [5] 7/16 7/22
99/8 99/9 119/17 dissolved [1] 39/21 Idrawn [1] 21/19
45/14 45/20 461 ee ei 40/8 I dleewnde ty aoe2. (a tenor, I 19/2 19/9 24/26
46/10 46/14 46/17 I difficult [7] issuade [1] ream [1] else [3] 75/17 114/25
elapsed [1] 106/16
electricity [1] 110/7
element [2] 28/11
93/9 98/4 99/15 distance [1] 57/21 Idribs [1] 104/16
47/22 48/19 4917 50/8) soo/16 106/15 distinguished [2] _Idriving [1] 86/3 135/4
50/17 51/5 51/12 O0/18 email [1] 117/14
31/23 117/15 119/14 (difficulties [6] 21/2 I 47/15 87/20 due [8] 6/20 10/3 /eerciting [1] 4/21
31/13 69/17 74/20 distress [4] 35/18 I 10/15 21/22 35/18 9
Department's [2] emails [2] 97/12
126/11 128/9 55/19 61/2 112/8 _I 88/10 106/15 109/1
deprived {1} gag _ [difficulty [5] 39/4 ditch [1] 89/19 during [5] 7/12 12/8 Saeee esi 2
depattction ft} gaia I 398 65/12 98/11 divergence [2] 45/5 I 64/1 65/23 11013 I anpearassing
Secwenea yay earn I 1081 45/8 duty [3] 82/6 86/19 I OOo oy 6/1
tesa digits [1] 106/12 _Idivert [1] 121/9 121/24 mot
, dignity [1] 112/7 _ I division [2] 61/4 63/4I dwindling [1] 9/11 ,
See ctbed py 2606 dilatoriness [1] 79/7 Ido [32] 1/7 3/2 3/9 IDyson [3] 67/16 emphasise [5] 11/20
Tee ey eo? laitigently [1] 44/17 I 3/20 3/22 5/23 6/21 I 67/20 103/12 sie
dinner [1] 105/20 I 9/5 13/17 22/20 26/3 IDyson's [2] 23/21
Gecigved by aa/aa dip [1] 728 30/17 30/22 34/24 I 24/8 met 1 ori
designed directing [1] 95/6 I 37/24 49/15 50/2 aroha are 46/18
direction [1] 79/12 I 65/21 71/16 72/10
(41) defendant's... - enable
INQ00001055
INQ00001055
E 116/10 11/24 19/10 27/7 76/14 78/5 101/18
nla 141 145/46 Iequally [2] 42/2 27/10 41/15 extended [2] 7/19 favourably [1]
enable...[1] 115/16 I Gei43 exaggeration [1] 15/1 119/24
enables [1] 13/13
encountered [1]
69/17
encourage [2] 34/22
49/9
encouraged [4] 35/9
44/4 57/17 65/20
encouragement [2]
30/12 35/3
encourages [1]
46/18
end [12] 6/11 7/23
24/19 25/2 29/25 30/4
30/6 44/6 44/14 47/21
108/23 121/13
endeavoured [1]
endeavours [1]
29/12
ended [3] 67/3 87/23
87/24
endlessly [1] 113/24
endured [1] 91/4
ENE [8] 28/1 28/5
28/9 28/10 28/19 29/3
34/8 74/5
energy [4] 42/24 86/4
106/4 117/16
engage [4] 35/17
49/17 49/20 50/3
engaged [2] 38/1
43/8
engagement [4] 48/1
48/5 48/7 116/6
engaging [2] 48/17
101/23
English [1] 108/14
enormity [1] 79/23
enough [3] 98/21
133/18 133/18
Enright [2] 109/22
109/23
ensure [9] 13/12
24/25 30/19 31/8 35/8
51/12 71/17 74/25
134/3
ensures [1] 19/25
ensuring [4] 19/4
43/2 113/19 134/19
enter [1] 21/20
entire [2] 94/18 97/9
entirely [4] 36/23
79/14 82/18 134/11
entitled [3] 11/13
48/17 111/13
entrepreneur's [1]
133/3
entries [1] 104/10
entwined [1] 76/2
episode [1] 100/20
EPOS [2] 116/10
equivocation [1]
78/18
eradicated [1] 88/7
error [1] 26/19
errors [2] 80/20 94/1
especially [2] 38/5
48/24
essence [1] 69/10
essentially [10] 4/10
62/15 63/2 64/5 71/14
99/8 99/10 102/4
116/17 127/3
establish [5] 8/23
39/18 41/20 62/15
102/4
established [2] 34/2
43/25
establishing [1] 20/9
establishment [3]
41/6 41/23 108/21
estate [1] 32/9
estates’ [1] 31/23
estimates [3] 3/7
3/11 6/10
et [2] 117/3 123/25
et cetera [2] 117/3
123/25
evaluate [1] 127/19
evaluation [5] 23/22
28/2 67/15 69/11
103/13
evaluations [1] 24/9
even [16] 3/4 3/11
9/7 44/11 64/12 75/25
76/11 77/14 83/2
85/22 86/17 93/21
95/8 95/9 113/7
133/17
event [2] 27/15 54/13
events [4] 77/8 89/21
103/7 126/19
ever [2] 107/17 122/9
every [2] 12/17 40/13
everybody [1] 109/9
everyone [3] 1/3 27/9I
42/20
everything [2]
107/15 107/15
evidence [13] 5/18
48/8 54/6 54/17 76/13
83/22 94/4 101/3
101/14 114/24 117/1
122/20 122/24
evidential [1] 33/5
Ewing [1] 100/19
ex [3] 26/19 108/25
132/10
ex gratia [1] 26/19
ex-subpostmasters
[2] 108/25 132/10
exactly [6] 10/14
76/10
example [10] 10/22
10/25 15/23 16/16
78/5 98/1 102/18
115/23 116/4 116/7
examples [2] 56/4
60/12
exceeded [1] 7/15
Excellent [1] 24/1
exceptional [1] 34/5
exclude [3] 28/21
29/2 51/16
excludes [1] 29/4
excluding [1] 29/21
exculpatory [1]
76/21
executive [1] 78/24
exemplars [1] 93/6
exercise [2] 86/25
94/22
exercising [1] 120/14)
exhausting [1] 105/6
exhaustive [1] 81/4
existence [1] 86/4
existing [1] 41/11
expectation [3]
44/12 47/19 69/13
expected [4] 30/8
69/7 128/10 133/6
expects [4] 9/18 10/6
17/20 30/3
expedited [1] 30/21
expeditiously [3] 2/5
64/24 68/24
expense [1] 59/18
expenses [3] 45/16
48/13 48/18
expensive [1] 73/1
experience [11] 36/5
53/17 54/4 58/2 58/9
59/23 64/22 65/14
100/15 101/22 115/25
experienced [5]
60/25 65/11 101/24
115/24 120/18
experiences [1]
106/13
experiencing [1]
21/2
expert [3] 47/12 48/8
100/15
expertise [2] 33/9
58/7
experts [3] 58/12
111/3 117/3
explain [4] 2/10 5/18
16/14 90/3
explained [3] 19/14
25/7 30/15
explaining [1] 60/14
expressed [3] 59/14
extent [3] 71/20
101/4 126/14
extra [1] 67/25
extraordinary [4]
81/5 88/5 89/21 91/3
extreme [1] 108/23
extremely [2] 105/16
107/22
7
fa
facilitated [2] 74/6
76/16
facing [1] 46/11
fact [14] 3/24 11/14
82/23 84/25 85/9
85/11 85/12 89/15
92/20 98/4 108/17
126/14 130/16 134/23)
factored [1] 94/9
factors [1] 101/11
factual [1] 3/15
failed [1] 122/22
failure [3] 44/22 54/8
100/8
fair [11] 9/17 10/5
19/5 43/3 45/12 72/1
77/5 86/24 87/15,
99/22 131/10
fairly [4] 10/20 13/14
51/25 111/21
fairness [3] 11/10
65/17 121/1
Faisal [1] 105/24
faith [21] 11/22 12/8
12/12 12/16 12/24
12/25 13/7 13/11
13/14 13/19 14/1 14/1
14/4 54/1 55/14 55/22)
56/6 56/10 58/3 58/7
58/12
fall [10] 8/19 40/22
69/23 95/15 95/20
102/2 110/12 112/11
112/12 119/24
falls [2] 5/22 95/23
false [3] 83/21 83/24
87/5
familiar [1] 111/14
families [4] 91/19
92/1 133/4 133/7
family [4] 91/8
105/13 106/2 106/21
far [16] 7/9 32/1
48/21 57/3 57/12
58/21 59/3 61/4 66/13,
68/15 98/12 101/7
101/14 116/7 117/9
133/16
father [1] 88/4
fault [3] 93/24 101/17
fate [1] 46/13
feature [1] 69/22
February [3] 35/13
76/14 122/21
fee [3] 20/7 119/2
124/11
feed [4] 2/3 2/8 4/11
97/15
feedback [1] 42/18
feel [4] 73/6 105/15
105/22 107/11
feeling [1] 40/7
feelings [1] 112/7
fees [5] 20/5 118/19
119/16 119/20 125/20)
feet [1] 9/9
Felstead [5] 90/17
91/12 92/8 94/18
95/14
few [11] 3/4 17/20
42/9 53/7 58/23 91/3
98/10 102/24 117/21
121/13 132/1
fictitious [2] 82/18
91/9
fight [4] 18/18 18/19
88/21 88/24
fighting [1] 105/8
figure [2] 9/6 28/23
figures [5] 29/2
58/21 62/7 62/9 62/16
file [3] 103/21 104/5
104/9
final [12] 17/8 21/5
25/14 25/19 27/14
27/24 29/20 32/25
66/6 68/16 107/10
120/11
finalise [1] 31/2
finalised [2] 28/17
48/9
finalising [2] 6/24
31/7
finally [6] 45/20
50/13 64/18 73/9
110/16 122/7
finance [1] 99/18
finances [1] 125/10
financial [11] 15/1
21/2 60/11 61/15,
100/9 104/24 105/12
106/17 107/5 107/25
108/5
find [8] 37/21 39/6
84/19 104/6 117/10
127/2 127/7 130/25
finding [1] 99/14
findings [2] 23/21
24/8
fine [4] 69/23 96/17
130/4 131/24
finished [1] 107/7
(42) enable... - finished
INQ00001055
INQ00001055
F 58/18 68/15 84/5 —_IGeneral's [1] 82/7 I 102/13 102/14 57/1 57/20 59/17
firm [4] 1141 {four months [1] 7/14 Igenerally [1] 51/24 I good [34] 1/3 6/2 I 60/22 62/12 67/2 69/7
firmly [1] 37/4 framework [3] 69/9 Igenerated [2] 61/23 I 11/22 12/8 12/12 70/22 72/3 76/7 76/16
firms [3] 114/9 119/3 119/21 82/19 12/16 12/24 12/25 I 78/22 81/23 83/19
120/17 120/18 frameworks [2] generic [1] 83/12 13/7 13/11 13/14 84/20 87/3 87/5 87/11
first [23] 2/13 716 I,115/22 115/28 gentlemen [2] 1/12 I 13/19 14/1 14/4 14/4 I 87/20 87/20 90/18
8/20 37/23 39/8 40/25Ifrankly [1] 111/25 I 1/20 27/19 44/11 45/13 I 90/23 90/24 91/11
43/21 47/25 51/5 IFraser [3] 80/9 80/17 Iget [15] 5/2 5/9 38/2 I 46/24 54/1 55/14 91/24 97/13 98/12
57/15 58/1 58/18 89/20 62/24 63/1 82/24 85/5I 55/22 56/6 56/10 58/2I 98/18 98/24 101/10
60/10 60/16 63/20 _—IFreehills [1] 117/9 I 88/21 91/19 105/8__I 58/7 58/12 66/3 66/5 I 104/12 105/9 106/8
64/25 71/16 75/21 IFreeths [3] 109/25 I 106/20 110/15 110/18) 66/7 96/24 120/5 107/13 107/14 108/5
76/3 77/20 81/21 117/11 123/24 124/5 127/6 132/11 132/15 108/6 108/22 110/11
93/22 122/20 frequently [1] 61/19 Igets [1] 64/6 Gosney [1] 108/24 I 114/19 115/5 115/8
Firstly [2] 53/3 53/8 [Friday [1] 109/25 —_I getting [5] 39/4 42/18] gossip [1] 81/24 117/8 121/20 122/8
fit [1] 94/11 friend [2] 79/9 79/18 I 56/20 73/6 105/11 {got [7] 13/18 14/3 I 122/19 123/5 126/24
five [1] 105/8 friends [1] 106/21 IGFM [3] 58/7 58/16 I 40/7 64/13 88/25 127/16 127/18
five years [1] 105/8 Ifuits [1] 79/21 58/19 95/11 122/7 hadn't [4] 24/3 55/4
flag [1] 30/23 frustrating [2] GFMs [3] 58/10 governing [1] 70/19 I 71/6 71/7
flattened [1] 87/5 I, 105/16 113/21 58/20 58/25 Government [6] 51/9Ihalf [3] 12/19 90/17
flesh [1] 91/24 frustration [1] 65/18 I give [5] 3/15 75/4 I 51/14 108/1 113/10 I 116/24
flexible [1] 41/10 {fulfilment [1] 59/16 I 78/13 94/20 129/25 I 115/3 117/12 Hamilton [3] 38/13
floor (1] 110/15 full [15] 27/23 32/25 Igiven [7] 5/20 44/23 IGP [4] 116/16 78/6 81/11
flowing [1] 9/15 43/3 47/19 50/10 64/5 67/5 92/23 93/1 Igranny's [4] 81/25 Ihand [12] 72/4 104/8
focus [1] 14/18 50/10 61/13 68/12 I 106/3 Grant [2] 80/13 115/7I 111/6 114/13 118/8
focusing [1] 6/16 I 71/25 77/4 86/24 gives [2] 59/11 120/2IGrant Thornton [1] I 119/25 120/1 123/15
follow [4] 3/3 47/7 I 87/15 88/8 106/18 Igiving [3] 2/6 32/6 I 80/13 127/24 127/25 128/21
49/9 82/14 10/2 94/14 grasped [1] 89/6 I 131/12
followed [1] 82/3 fully [1] 57/14 glance [1] 130/17 I grateful [4] 6/4 40/15Ihanded [1] 111/17
following [10] 12/19 {functional [1] 94/21 IGlancing [1] 130/21 I 42/10 118/6 handful [1] 50/19
34/8 44/20 47/2 52/22Ifund [2] 41/21 133/3 I glitch [1] 1/14 gratia [1] 26/19 hands [1] 100/7
54/24 56/10 70/9 [fundamental [1] 81/2/GLO [34] 10/13 26/8 Igravamen [1] 78/19 Ihang [3] 95/4 128/1
1140/2 114/17 funded [2] 114/9 26/17 26/19 27/2 27/5I great [5] 2/2 18/1 130/3
follows [1] 27/23 125/16 27/6 47/3 48/25 49/3 I 18/7 86/16 96/15 Ihanging [2] 81/12
force [2] 50/18 86/3 Ifunding [7] 41/24 I 50/13 50/19 50/21 I greater [1] 2/4 125/25
forced [2] 109/1 44/18 51/10 73/22 I 95/20 98/25 102/19 I greatly [1] 55/16 —_ I happen [9] 53/13
1116 97/24 111/8114/6 I 109/24 113/4 113/8 Iground [4] 78/7 78/7 I 60/15 69/14 79/2
forefront (1) 89/23. [further [27] 5/2 15/12I 113/9 115/8 115/15 I 92/11 92/13 97/22 98/14 102/6
forget [2] 62/10 91/6 I 17/1 19/6 22/19 23/16] 117/15 118/1 119/10 Igrounds [2] 17/22 I 125/14 127/8
forgive [1] 135/3 24/15 28/20 30/3 119/11 119/23 121/19] 134/25 happened [6] 14/4
form [9] 10/12 1519 I 30/23 33/1 37/18 123/6 123/25 128/4 Igroup [21] 6/24 7/18 I 72/3 93/7 98/16
15/14 18/8 27/1 36/21I 37/22 40/16 42/6 I glue [1] 106/10 9/14 10/8 25/24 26/3 I 102/13 124/25
50/25 67/7 107/18 I 9/24 64/16 68/22 Igo [27] 2/12 3/24 5/5 I 26/6 43/20 43/23 happening [3] 57/2
formal [7] 34/11 70/1 78/4 89/14 111/9I 8/1 11/19 15/15 18/2 I 46/21 46/22 52/17 —_I 102/16 109/10
34/15 34/17 41/6 117/19 117/24 124/23] 25/8 40/4 42/3 46/4 I 52/25 73/10 86/9 —_Ihappens [2] 64/2
41/22 44/15 90/14 I 124/25 134/24 71/22 75/17 76/22 I 97/19 98/11 99/4 102/20
formation [1] 35/14. {future [3] 24/10 34/1 I 85/18 85/18 102/3 I 109/14 111/12 111/25I happy [6] 49/12
former [3] 41/13 72/9] 894 103/24 111/6 123/14 Igroups [1] 9/11 49/20 67/22 68/2 68/6
108/18 G I 128/18 129/10 12/23/67 [1] 80/12 7112
forth [1] 18/2 > ______I 131/12 134/20 134/24] guaranteed [1] hard [1] 30/10
fortunately [1] 84/17 gain [1] 122/13 135/8 125/22 hardship [1] 45/23
forward [19] 20/11 Gallafent [19] 2/14 I goes [3] 41/25 78/19 Iguarded [1] 45/4 hare [1] 38/18
30/13 30/21 46/19 I 1246/1 9/5 18/1 130/21 guidance [6] 15/10 harm [2] 77/7 104/3
99/9 104/18 107/10 I 18/18 23/25 45/2 going [34] 4/23 8/4 I 37/18 129/1 129/13 Iharmed [1] 99/23
109/14 119/19 121/18I 40/10 46/3 53/22 57/2) 12/7 14/18 18/2 18/4 I 130/6 130/15 has [135] 1/14 6/17
420/12 123/8 125/24 I 07/18 87/22 7/24 I 20/11 37/25 39/8 45/3 quide [1] 36/1 7/13 7/15 7/20 8/23
426/22 127/3 127/20 I 78/13 79/13 98/2 45/18 67/1 78/3 79/11I guidelines [1] 82/7 I 9/14 10/23 11/17 14/4
12919 13416 134/25. I 1362 84/9 84/14 85/20 —I guilty [1] 83/23 15/4 15/17 15/20
fought [3] 99/21 game [1] 113/15 86/25 88/20 88/24 I guise [1] 115/3 16/19 16/22 19/7
99/21 99/21 garb [1] 85/4 96/2 97/8 97/22 102/5}, I 19/16 19/21 2016
Foulger [1] 105/18 /928, [11 110/7 102/11 105/19 108/10/" I 20/12 20/24 21/10
found [1] 39/3 gathering [1] 116/18 I 111/19 113/13 114/25Ihad [62] 1/24.5/18 I 21/13 23/11 23/13
four [9] 7/14.8/1 9/3 I9ave [1] 31/13 115/13 117/25 118/2 I 7/11 12/4 12/9 15/1 I 24/18 25/7 26/11
23/8 29/14 57/22 I\9eneral[2] 20/14 I 126/18 28/1 29/24 38/23 27/23 28/7 28/12
43/12 gone [4] 24/2 35/6 I 48/12 55/19 56/24 I 28/19 28/25 29/19
(43) firm - has
INQ00001055
INQ00001055
H health [10] 10/23 Hi [1] 123/19 63/18 64/9 71/19 hurting [1] 99/14
has... [101] 3011 10/25 21/3 60/24 hide [1] 106/7 80/10 80/17 80/25 —_I husband [2] 91/5
31/14 33/4 34/4 34/11 82/20 86/10 89/3 89/3Ihigh [3] 31/15 106/19] 81/7 81/13 100/23 91/18
35/6 35/20 37/2 37/10 107/13 108/7 111/17 100/25 101/18 I
39/9 43/7 44/1 44/2 IHealthcare [1] high-handed [1] horribly [4] 24/2
44/3 44/11 45/16 111/24 111/17 hospital [1] 110/20 Il accept [1] 17/25
45/21 46/14 47/22 [Rear [10] 3/14/14 Ihigher [1] 19/19 hour [3] 2/20 75/5 I agree [1] 134/10
47/24 48/3 48/19 42/19 42/20 97/21 highest [2] 89/8 102/14 lalso [1] 5/17
50/17 51/9 51/14 54/4! 98/9 98/13 98/14 112/12 Hourly [1] 120/7 lam [1] 18/10
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27/25 31/22 33/7 7/9 11/9 21/4 21/15 I 24/11 27/11 35/16 membership [1]
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55/18 60/12 61/16 58/16 59/17 60/2 37/18 37/21 38/4 39/5I mental [6] 60/24
66/3 68/6 68/13 70/12I 64/25 66/3 66/12 69/5I 39/21 40/16 41/2 42/9I 82/20 89/3 106/16
ing [1] 15/13
list [1] 17/2
listen [1] 41/5
listened [2] 43/7 82/19 90/16 101/4 105/21 114/4 114/7 I 49/22 58/5 58/21 107/13 108/7
53/22 101/12 101/16 113/19] 133/13 61/22 63/13 64/25 Mentally [1] 105/5
listening [2] 97/14 115/20 124/10 making-up [1] 66/12 I 66/1 67/12 70/24 73/1I mention [2] 109/7
132/8 lost [6] 51/7 94/18 I malevolence [1] 75/8 78/12 79/17 128/15
litany [4] 63/25 94/24 104/19 104/22 I 94/19 79/19 80/2 86/21 mentioned [5] 5/12
107/14 ious [4] 78/8 86/22 88/7 92/25 62/7 98/2 109/5
literally [4] 81/12
litigants [1] 119/23 I/ovalty [1] 93/16
litigant Luckily [1] 110/18
litigation [18] 6/25
25/24 26/4 26/6 43/20I!Unch [2] 75/6 75/8 Im
0/4 111/17 101/7 102/23 116/4 115/24
jously [1] 113/2I 117/10 118/25 119/7 Imerely [3] 63/3 94/21
in [1] 91/25 121/2 127/25 129/20 I 120/24
lying [1] 94/2 malignant [3] 77/13 I 133/22 Message [1] 123/24
ans eae um I 80/4 95/1 McMahon [2] 101/24 Imet [2] 21/7 48/2
80/10 80/25 81/6 81/8; = = Iman [1] 67/2 115/23 microphone [1]
99/1 111/12 120/8 IMade [88] 3/23 4/5 _Imanage [2] 99/19 _Ime [32] 2/9 9/9 11/19] 42/17
little [6] 2/17 2a/19 I 7/16.7/18 7/20 8/2 8/5) 125/10 17/25 27/9 34/5 39/7 I microsite [1] 36/8
49/12 80/16 11016 I &9.8/10 9/3 9/14 9/23I managed [2] 69/25 I 42/17 42/18 42/19 _I microwaved [1]
422/11 11/17 12/1 12/3 12/11] 110/16 45/3 49/16 50/3 63/1 I 105/20
live [13] 2/3 2/8 4/10 14/16 14/16 16/8 19/2I management [2] 63/5 71/23 72/8 76/24I might [20] 5/19 10/20
23/1 23/12 23/13 24/5I 108/15 108/19 84/2 87/25 100/24 I 11/25 17/3 18/18
4/23 5/12 5/18 23/24 I 56/09 98/8 28/16
36/7 80/5 84/19 84/20 managers [4] 97/5 I 101/19 105/1 105/12 I 32/20 49/10 50/11
97/15 122/2 28/25 29/5 29/8 29/17] 99/12 101/5 132/10 I 107/25 109/2 120/16 I 53/12 57/21 70/25
lives [3] 56/20 87/4 29/19 29/22 29/24 _I manner [4] 80/10 122/8 123/20 129/25 I 72/12 73/3 73/6 76/10}
1433/4 30/6 32/3 32/13 33/6 I 87/13 92/23 108/23 I 131/19 135/3 88/19 94/16 116/1
living [4] 83/13 84/23 34/3 34/6 34/20 39/19] manoeuvring [1] meals [1] 106/1 127/6 133/2
85/10 104/25 40/18 41/1 44/13 113/7 mean [3] 73/3 88/19 I million [41] 8/6 8/13
loans [2] 106/19 I 44/16 .45/21 46/2 46/5Imany [15] 9/6 37/3 I 90/13 23/19 23/19 24/6 29/3
107/7 46/25 47/1 48/19 49/3] 39/5 41/13 63/19 64/1Imeaning [1] 8/18 29/20 48/20 114/19
logjam [1] 125/3 50/16 51/20 51/22 I 65/12 73/11 87/6 —_Imeans [6] 4/11 34/16I 114/21 114/21
logs [4] 80/14 80/19 54/5 56/3 56/14 56/25] 101/15 103/23 107/13] 51/18 75/10 93/19 —_Imind [8] 1/24 5/7
116/9 116/13 57/15 58/19 59/21 108/25 127/15 132/13I 104/16 37/25 89/23 95/6
long [9] 2/1 2/7 2/10 60/5 60/15 61/4 64/18IMarch [2] 54/18 means-tested [1] 98/23 99/4 131/9
Mrs yea 9114. I 05/13 67/3 72/5 83/5 I 55/22 51/18 mindful [1] 11/7
93/10 93/11 126/19 I 83/6 87/25 90/19 margin [1] 42/12 meant [2] 69/12 minds [1] 131/1
longer [4] 2/17 8/23 92/12 94/10 97/4 margins [1] 126/24 I 130/17 minimise [1] 113/18
9/21 42/13 97/17 103/16 115/13 IMarine [1] 108/18 Imeantime [1] 48/19 I minister [3] 7/2
look [6] 13/9 42/5 117/25 121/3 122/9 I master [2] 79/2 measure [1] 88/9 37/15 114/18
104/11 104/18 116/1 I 129/19 129/23 132/23} 120/10 mechanical [1] 94/21IMinister's [1] 116/20
1433/2 133/21 133/22 material [2] 76/21 Imedia [1] 36/12 terial [1] 43/5
looked [4] 105/11 magical [1] 120/6 104/1 mediation [4] 25/9 I minute [2] 52/3 96/8
looking [5] 33/13 [Magistrates [1] materialised [1] 59/6 59/7 59/9 minutes [8] 1/5 2/16
50/7 99/16 107/9 38/24 69/13 medical [9] 11/1 13/4I 2/19 3/4 3/8 42/9 75/7I
133/7 magnitude [1] 76/25 I materials [1] 116/19 I 58/6 58/11 64/19 132/1
loosely [1] 48/12 mainly [1] 103/16 I matter [20] 14/22 64/20 64/25 85/23 I miserable [1] 123/22
Lord [6] 23/21 24/8 Imaintain [1] 33/10 I 17/7 22/4 28/4 40/16 I 111/3 misery [1] 123/20
47/13 67/16 67/20 IMaintained [1] 7/13 I 42/3 78/18 79/14 meet [4] 41/3 44/10 IMisra [4] 91/2 91/2
103/12 Majesty's [1] 31/17 I 79/17 79/19 86/14 118/21 127/1 92/9 95/14
Lord Dyson [2] 67/20 major [1] 60/1 89/17 91/15 92/1 meeting [20] 11/22 Imissed [3] 4/7 53/11
103/12 majority [1] 47/6 92/24 93/8 101/9 12/9 12/16 12/24 89/5
Lord Dyson's [2] make [37] 1/21 9/18 I 120/13 124/23 133/14I 12/25 13/7 14/1 14/2 Imissing [3] 4/10 16/5
23/21 24/8 10/6 13/8 16/11 22/4 I matters [21] 6/17 14/5 54/1 55/14 55/23] 16/24
loss [30] 11/15 15/9 24/11 26/14 27/19 10/17 24/20 31/1 33/5I 56/6 56/11 58/3 58/4 Imission [1] 107/1
33/2 33/14 34/2 34/5] 31/2 32/11 32/17 36/6 37/11 47/12 51/4I 58/7 59/2 102/4 132/5I mistresses [4] 97/5
54/23 55/1 55/5 66/4 I 22/19 37/22 40/23 I 53/17 61/3 71/21 meetings [10] 12/12 I 99/11 112/11 132/10
86/7 66/9 66/15 66/15) 41/9,41/22 42/23 82/25 89/9 118/15 I 12/13 13/11 13/19 I mitochondria [4]
67/11 67/18 74/8 74/9) 44/22 50/8 54/3 64/14) 118/19 127/16 131/2 I 41/9 58/12 73/16 86/2
83/6 83/10 112/5 66/5 66/7 73/13 79/11] 134/8 134/9 134/14 I 114/3 118/13 131/6 Imodel [1] 47/7
117/3 128/24 129/1 I 89/20 86/23 91/7 Matthew [1] 84/22 Imembers [12] 4/11 IMoloney [13] 38/15
429/12 129/15 130/5 I 100/8 107/1 107/19 Imay [57] 3/4 5/8 6/20] 26/8 36/5 41/3 50/13 I 38/17 52/6 52/10
109/7 112/20 114/10 I 7/5 12/2 12/12 13/25 I 50/19 99/1 99/1 52/11 72/11 75/3 93/3
losses’ teal S715 viza 117125 134/41 14/22 18/7 18/22 106/21 114/15 115/15] 93/7 134/2 134/8
making [20] 6/25 7/7 I 19/22 20/1 21/1 22/14I 128/4 134/21 136/4
(47) linking - Moloney
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M 75/18 75/19 79/12 95/14 95/19 98/2 nearly [2] 84/2 91/12 I 74/20 77/6 78/6 78/17
Moloney’s [1] 87/8 _ 80/9 80/17 81/18 101/24 110/4 110/6 Inecessarily [1] 5/4 I 79/16 85/20 88/24
moment [7] 59/13 81/19 87/8 87/19 110/11 115/23 123/1 Inecessary [5] 22/1 I 88/24 90/15 101/22
62/17 81/16 102/19 I 89/13 89/20 93/3 93/7) 123/24 124/18 124/19) 43/9 44/3 48/9 88/20 I 105/11 106/23 108/5
118/3 124/21 135/3 I 95/15 95/19 95/20 125/6 125/15 126/4 necessitating [1] 110/23 112/25 113/8
95/23 96/6 96/7 96/7 I 136/2 417 121/8 12/9 123/19
Monday [21 11] 83!10) o6/11 96/18 96/22 IMs Arch [3] 81/18 Ineed [29] 1/43/4 I 124/21 128/13 129/3
Noa. 96/23 100/24 109/22 I 81/22 95/19 30/22 42/6 48/11 50/3) 130/7
money [9] 62/21 63/7I 109/23 111/23 117/14 Ms Felstead [3] 58/6 64/23 68/18 78/6INoel [1] 70/6
118/14 121/17 122/15] 90/17 91/12 95/14 89/21 92/25 100/12 _Inominal [1] 105/3
Te eon toa 122/22 126/25 134/2 IMs Gallafent [17] 109/7 109/11 110/25 Inon [21] 9/24 24/14
monies [2] 124/6 134/8 134/21 136/3 I 2/14 5/24 9/5 18/1 116/13 116/14 116/15] 26/25 27/25 28/3 28/8
425/11 136/4 136/5 136/6 —_I 18/18 23/25 45/2 117/25 120/5 123/20 I 28/11 28/13 28/20
month [4] 7/14 7/24 IMr Beer [2] 3/16 5/12) 45/10 46/3 53/22 57/2I 124/5 126/20 126/21 I 30/4 30/20 30/24 31/5
29/25 104/13 Mr Brightwell [2] 67/18 67/22 77/24 I 126/22 127/13 128/8 I 31/22 34/7 46/6 67/18
months [13] 7/12 I 117/14 126/25 78/13 79/13 98/2 133/19 68/3 70/12 74/8 95/2
7/14 12/15 37/3 54/18I Mr Castleton [3] Ms McMahon [2] _Ineeded [5] 63/6 non-disclosure [1]
57/8 58/4 58/18 66/19 81/19 87/19 95/19 101/24 115/23 103/19 106/10 114/17I 95/2
68/17 69/12 106/4. [Mr Chapman [9] 2/13IMs Misra [1] 95/14 I 116/4 non-pecuniary [18]
121/13 42/15 42/16 42/20 IMs Page [1] 81/17 Ineedlessly [2] 76/5 I 9/24 27/25 28/3 28/8
months' [3] 66/22 45/1 70/2 70/14 95/20IMs Palmer [4] 86/13 28/11 28/13 28/20
66/24 67/5 136/3 123/24 124/19 125/6 Ineeds [7] 21/13 30/4 30/20 30/24 31/5
Moore [3] 124/11 [Mr Enright [2] 125/15 102/6 102/19 102/22 I 31/22 34/7 46/6 67/18
124/14 124/18 109/22 109/23 Ms Pickering [1] 104/2 106/7 120/20 I 68/3 70/12 74/8
Moores [2] 123/10 Mr Henry [6] 2/22 124/18 negotiated [1] 27/15 Inone [1] 12/9
123/17 75/4 75/18 79/12 96/6IMs Skinner [3] 91/1 Inerve [1] 84/4 noodles [1] 110/11
Moorhead [1] 76/13 I 99/7 91/12 95/14 net [3] 54/15 54/20 Inormal [2] 4/7
more [26] 3/11 4/1. IMrJustice [2] 89/20 IMs Sue [1] 123/1 55/21 134/12
8/1 8/3 12/19 15/22 I 111/23 Ms Williams [2] Network [4] 66/16 Inormally [1] 91/20
15/23 19/19 20/9 IMr Justice Fraser [2] 110/6 110/11 neuropathy [1] 84/5 INorth [1] 84/11
21/14 30/16 33/16 I 80/9 80/17 Ms Williams's [1] [neutral [6] 23/22 _I North Sea [1] 84/11
45/2 45/4 49/12 50/14] Mr Moloney [13] 110/4 24/8 28/2 67/15 69/11I not [144]
58/22 73/1 78/17 79/7I 38/15 38/17 52/6 I much [12] 1/7 3/11 I 103/13 note [14] 11/11 12/2
85/3 86/14 90/7 95/5 I 52/10 52/11 72/11 I 29/12 42/8 43/11 45/4 never [16] 26/22 38/6I 12/13 15/16 15/21
102/18 127/6 75/3 93/3 93/7 134/2 I 87/19 88/14 100/7 —_I 72/3 81/19 81/19 83/4) 23/20 24/7 34/3 34/18
Moreover [1] 21/12 I 134/8 134/21 136/4 I 101/10 107/2 110/14 I 84/14 86/21 87/3 88/7I 45/9 45/14 51/6 90/23}
morning [11] 1/3 6/2 IMrMoloney’s [1] I musing [1] 32/19 I 89/6 92/2 105/22 127/20
7/25 53/23 87/2 57/18) 87/8 must [16] 5/6 36/25 I 114/6 115/10 126/7 I noted [4] 7/10 32/24
67/19 71/22 78/1 Mr Parekh [1] 95/15 I 55/6 55/10 100/2 _Inevertheless [2] 44/7 80/6
90/14 95/21 Mr Recaldin [1] 114/9 121/13 122/23 I 40/23 103/25 notes [1] 40/18
mortgage [3] 63/24 I 118/14 125/14 125/15 125/20Inew [4] 31/18 33/25 Inothing [7] 18/19
107/6 107/6 Mr Schwarz [1] 125/23 126/2 127/4 I 97/21 120/6 64/16 110/4 114/25
most [11] 44/13 81/18 127/8 131/6 New Year [3] 31/18 I 120/6 124/25 135/4
47/2050/13 60/6 IMr Sethi [1] 122/15 _Imy [37] 2/3 4/16 4/22) 33/25 97/21 notice [5] 15/11
72/00 74/21 87/13 Mr Sethi's [1] 122/22I 5/6 5/9 9/9 11/18 INews [1] 111/25 66/22 66/25 67/5
99/24 103/19 106/25 IMr Shapps [1] 32/20 33/3 37/8 37/25INews Group [1] 103/4
121/5 121/17 39/4 39/9. 41/2. 42/5 I 111/25 notion [1] 126/3
mother [4] 84/25 IMrShiju [1] 95/23 I 42/10 49/17 50/24 I Newspapers [1] Nottinghamshire [1]
85/11 85/12 104/13 IMr Simon [1] 89/13 I 72/8 79/8 79/18 92/7 I 111/25 111/24
move [11] 26/23 Mr Stein [9] 2/24 99/24 104/24 105/8 next [13] 9/19 10/7 Inotwithstanding [2]
27/11 32/23 65/6 4/20 96/7 96/11 96/18] 105/12 106/13 106/16} 12/15 16/1 20/19 30/8) 92/16 103/14
107/16 117/22 119/19I 96/22 96/23 100/24 I 107/23 108/7 108/19 I 47/21 50/11 56/7 November [15] 6/11
136/6 109/22 113/25 122/5 I 97/21 98/10 100/21 I 7/19 14/17 15/7 16/9
Tait? 125/24 126122 wy 2) 112.9112 I 123/20 129/14 129/17I 117/24 16/16 19/11 24/22
Moving [3] 14/14 IMrs Misra [2] 91/2 myself [1] 134/21 Inight [1] 90/9 36/7 54/19 55/16
ee 91/2 myth [1] 91/22 nine [1] 58/24 55/24 114/18 118/10
MP D2} aria 11517 IMs [42] 2/14 5124 6/1 I Ino [48] 3/3 3/3 13/24 I 123/16
Me igi 21322 I 95 18/1 18/18 23/26 IN__I t7ni5 19/7 31/21 I November 2020 [4]
2/24 3/16 4/20 5/12 I 45/2 45/10 46/3 53/22) name [2] 91/15 105/9) 34/11 38/19 42/13 I 7/19 15/7 16/16 19/11
38/15 38/17 42/15 I 97/2 67/18 67/22 names [1] 93/20 51/21 56/11 56/24 —_Inovus [1] 84/10
sorte aaido agit sole) 77/24 78/13 79/13 [national [3] 10/25 I §7/1357/15 58/11 Inow [81] 1/14 3/5
POO BOT I I 81/17 81/18 81/22 I 83/5 91/23 61/12 61/21 62/14 I 8/16 8/23 9/23 12/11
sora vartt yea 75/4} QO17 91/1 91/12 I nature [3] 73/3 85/25] 65/15 67/4 68/17 69/1I 15/4 16/13 20/24
91/12 95/14 95/14 I 85/25 70/1 70/21 70/22 I 23/24 29/19 35/20
(48) Moloney’s - now
INQ00001055
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N 8/19 11/5 11/17 12/17) 120/4 122/7 122/10 I 94/21 97/21 99/16 109/14 109/18 109/20)
now... [69] 37/4 38/9 12/23 13/22 13/24 123/20 125/14 134/11) 102/14 106/23 106/24I 113/15 118/22 121/16}
41/18 43/13 45/2 21/13 21/16 24/17 135/3 1114/3 111/6 111/11 I 127/15 131/1 1341/8
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Bors 60/19 62/5 62/20I 5/11 55/15 55/16 oneself [4] 87/18 I 115/22 119/22 119/25] 134/22
FOO 71/4 Tele 76/0 I 35/22 55/23 56/3 56/8I ongoing [9] 14/12 I 120/6 120/10 121/8_ out [36] 6/10 8/1 8/4
F519 77118 77/24 78/3} 26/9 56/9 56/10 56/13I 39/17 39/24 62/19 I 121/9 121/22 122/28 I 14/6 14/8 27/17 35/5
Joe 79/6 B13 B1/14 I 56/13 58/16 58/19 I 62/21 98/15 104/3 I 123/21 125/20 125/21] 37/7 38/9 48/11 49/12
gorid 83/11 B3/12 I 89/20 60/21 62/8 65/1) 105/17 109/10 125/25 126/1 126/7 I 54/9 58/21 61/9 98/22
34/22 84/23 85/8 (Offered [8] 12/25 _Ionly [29] 23/7 23/9 I 127/10 128/10 128/12I 99/22 102/5 102/9
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92105 97/14 98/9 (Offering [1] 19/16 I 53/19 53/24 56/4 57/6 oral [6] 6/13 33/22 I 113/10 114/15 117/17
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108/10 108/22 109/14} 7/16 7/20 7/21 8/1 8/3] 98/13 100/14 101/8 orally [2] 112/24 I 122/16 123/7 123/20
tO912 109/13 111/6 I 8/5 8/8 912 9/18 10/6 I 105/3 105/9 106/3 I 131/15 128/17 130/24 131/14)
41313. 113/21 115/14) 12/1 12/3 12/6 23/7 I 107/11 108/3 115/2 order [20] 2/12 5/8 outcome [4] 21/6
THTIM7 447/93 14077 I 28/8 28/25 29 29/4 I 115/12 118/22 124/15] 10/20 11/25 22/2 25/9] 21/12 64/2 107/2
tor22 120/14 123/5 I 29/6 29/21 29/23 30/1] 133/25 27/12 31/22 33/9 41/4I outlined [1] 67/19
126/24 127/18 128/18) 30/6 33/6 33/11 34/20Ionwards [1] 59/1 I 46/13 52/2253/1__I outset [1] 73/25
131/13 131/19 131/25] 39/19 44/5 44/13 open [2] 33/3 119/7 I 90/19 106/20 111/3_ outside [1] 36/19
132/25 56/12 56/16 57/15 opening [10] 6/6 117/25 125/19 125/23] outstanding [3]
nowhere [1] 85/5 57/22 58/1 58/24 18/22 19/15 20/20 127/16 10/22 10/24 124/12
number [10] 9/12 59/18 60/3 60/5 63/2 I 25/7 30/15 33/6 41/2 I organisation [2] over [22] 8/9 12/15
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73/2 80/18 81/13 Office's [11] 11/21 Iopenness [1] 81/10 Iorganisations [1] 48/20 48/21 50/25
114/8 130/1 130/18 24/21 30/12 31/20 operating [1] 53/11 I 112/19 58/22 62/22 72/23
number 1 [1] 62/18 35/2 36/9 41/14 80/6 I operation [4] 53/14 I original [6] 7/19 79/4 79/4 87/6 88/7
number 6 [2] 80/18 80/9 91/23 94/19 57/25 63/18 64/9 16/25 55/20 56/2 95/4 107/11 108/9
81/13 officer [1] 108/18 Opinions [1] 32/8 113/11 124/8 110/16 125/25 130/13)
aa offices [4] 133/9 opportunities [2] _ originally [1] 123/2 Ioverall [2] 106/5
fe) Official [15] 9/2 60/8 I 89/5 94/25 other [35] 4/25 11/25 I 126/8
oar [1] 72/8 60/10 60/20 61/2 61/6I opportunity [9] 6/4 I 13/3 16/6 17/13 20/17I overseas [1] 16/18
observations [1] 61/11 61/12 62/11 17/1 25/1 30/11 30/20) 28/14 29/14 29/15 oversee [2] 51/12
73/13 62/22 69/24 69/25 31/6 35/1 42/9 51/16 I 38/6 39/5 46/22 51/3 I 74/4
obstacles [1] 88/17 I 72/16 87/9 87/16 opposed [3] 88/15 I 56/11 61/1265/16 —_I overseen [3] 47/9
obstruct [1] 77/21 Ioften [5] 61/16 61/18 I 89/9 92/14 68/15 70/3 72/4 73/16) 103/9 103/12
obstructed [1] 76/4 I 110/10 112/14 133/11] opposition [1] 92/10 I 73/19 85/13 96/25 oversight [1] 134/4
obtain [1] 20/1 Oh [3] 2/14 78/6 oppressed [1] 93/15 I 97/4 104/17 111/3 overtime [1] 106/18
obtained [1] 66/4 88/24 oppressive [2] 79/2 I 114/13 115/22 119/12I overturned [23] 10/2
obvious [2] 54/14 IOHC [3] 40/5 50/23 I 111/18 119/19 119/24 120/16] 22/10 22/21 22/25
54/25 51/22 option [2] 4/18 66/23 I 125/21 128/12 128/17I 26/2 27/20 28/23
obviously [9] 2/9 {kay [2] 42/19 63/11 options [2] 35/4 36/9 others [8] 32/10 30/17 31/14 34/10
5/15 14/15 14/21 old [6] 84/21 84/22 Jor [109] 6/25 8/22 I 73/21 81/11 108/23 I 38/2 43/18 43/22
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i older [1] 106/6 13/4 13/5 14/2 14/5 otherwise [5] 10/18 I 74/7 95/16 111/11
Sea ag lon [152] 14/16 14/20 16/1 17/5I 38/25 87/12 12716 I 114/22
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54/15 54/20 55/15 I 1233 110/20 122/11 125/1 Irequests [4] 10/24 [resulted [2] 56/8
55/21 59/9 65/23 regard [4] 6/21 37/6 Iremediation [2] 20/5 20/7 68/22 67/24
104/14 104/21 110/23I 112/68 119/4 129/6 130/11 require [7] 19/22 _ Iresume [2] 3/9 96/18
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60/9 60/10 60/20 61/2I"egards [1] 132/2 82/12 18/15 34/16 44/18 31/10 46/15 59/21
61/7 61/11 61/12 region [1] 116/24 remote [2] 84/8 94/1 I 72/15 88/9 111/2 91/1
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125/25 75/25 requires [2] 41/6 100/19
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BIN rumours [1] 81/24 I 41/6 43/18 43/19 100/18 120/24 58/18
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review [14] 18/14 ITunning [2] 22/14 I 43/24.43/24 46/21 I 49/7 120/23 Shala [1] 105/24
20/22 21/14 38/4 38/18 46/23 47/2 47/6 47/9 Iseem [4] 18/1 101/13) shall [8] 1/15 38/7
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saa 74/17 7417 Ig ~~ *(ONIT 81/22.52/15 I Seema [1] 92/9 79/20 79/21 79/21
SI 52/17 52/23 57/15 I seems [9] 22/14 40/8} shame [2] 95/7 100/1
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129/4
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118/8 123/15 128/21 IS [2] 89/11 98/22 I 133/17 service [4] 10/25 110/22 110/23 116/1
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NS 77122 BOI 38/7 40/21 42/2 53/15Iscope [2] 40/22 42/4 Iserving [1] 87/21 I shied [1] 44/2
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41/22. 54/25 55/7 55/9 70/24 67/24 69/6 73/11 spoke [1] 109/22 streamline [2] 13/10
59/18 62/22 64/13 slogan [1] 77/4 73/17 74/2 74/20 97/3Ispreads [1] 88/6 14/12
74/9 71/25 72/2 78/3 IS!opPy [1] 93/22 99/25 100/15 102/7 Isquarely [1] 39/4 strength [1] 83/22
78/17 82/9 83/23 slow [3] 6/24 37/13 I 102/8 111/1 114/1 SRA [1] 102/8 stress [4] 82/21
86/24 87/1 101/20 93/23 114/6 114/16 118/9 Istage [12] 15/19 85/24 86/5 106/16
103/8 107/6 108/2 slower [3] 8/18 10/8 I 123/24 131/11 132/6 I 45/18 53/15 54/1 56/7I stress-related [1]
4115 111/12 1189/5 I 10/17 134/18 58/1 59/5 59/22 68/25I 82/21
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421/15 125/19 127/9 small [2] 133/10 solution [1] 72/12 stage 5 [2] 53/15 strictly [1] 3/11
134/12 solve [2] 40/11 59/22 striking [1] 11/8
choua't[t} ws Smith [1] 117/9 126/21 stages [2] 12/9 131/6I strong [2] 77/9
shown [1] 88/2 so [124] 1/14 1/22 Isome [34] 15/21 stain [2] 88/6 122/11 I 114/24
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nest 44/11 45/9 46/16 I 111/7 120/24 12175 Istarkly [1] 109/20 subject [7] 19/3
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senna OT Sang, [73274157416 I sometime [2] 98/13. I 117/22 5/21 5/25 6/13 11/13
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sir [171] 127/15 132/12 132/23) 113/18 131/15 136/6 136/6
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sit [1] 78/13 135/9 speak [3] 2/1 32/5 I still [12] 17/4 59/2 24/13 34/10 80/3
sits [2] 39/18 114/7 social [1] 36/12 72/9 69/1 82/9 90/5 90/10 I 91/16 92/15
sitting [3] 72/22 software [4] 61/23 Ispeaking [2] 5/8 62/4I 107/5 107/8 110/23 Isubmitted [7] 6/9
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situation [9] 68/2 IS0lace [1] 91/21 specialist [1] 61/19 Istock [1] 66/6 78/1 91/14
7013 9/7 112/1 solely [1] 109/1 specific [6] 7/48/17 Istop [1] 23/23 subpostmaster [6]
412/10 112/25 125/15} solicitor [4] 39/9 15/13 37/16 52/19 straight [1] 39/1 60/23 87/23 98/5 98/6
126/12 127/14 101/25 109/22 115/24I 74/11 straightforward [1] I 116/11 133/9
six [4] 28/9 33/2 solicitor's [1] 102/15 I specifically [2] 21/19) 72/20 subpostmasters [28]
52/16 69/8 solicitors [43] 4/22 I 48/4 strain [2] 105/12 43/3 46/12 52/24
11/12 20/13 23/2 25/8Ispeed [2] 11/9 44/4 I 105/17 67/13 73/19 97/5
size [1] 73/25 25/11 26/15 33/4 41/8I spent [3] 114/19 _IStrategy [1] 117/16 I 99/11 100/3 100/13
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taitt 142/20 119/1 {Sunk [1] 83/7 100/11 102/14 109/11] 5/23 8/17 14/22 42/21] there [99] 2/2 2/14
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substance [2] 22/7 I 47/24 91/22 100/18 taxation [2] 120/10 I 17/3 17/5 26/16 27/18) 32/14 32/16 32/16
SOE 110/25 112/20 120/22 28/11 28/13 30/13 I 39/12 39/20 43/10
substantial [2] 44/18 ISUPPorted [2] 37/4 Itaxonomy [1] 128/8 I 30/20 34/23 35/4 I 45/5 46/4 48/10 50/24
WIS ati team [4] 41/12 49/17 I 35/18 38/2 40/19 I 54/6 55/6 56/11 57/24
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sot 36/5 97/4 117/2 teams [1] 134/22 I 46/18 46/19 47/4 I 62/23 63/6 64/23
success [1] 73/24 ISUPPosed [1] 108/20 Itear [1] 106/8 47/22 54/17 56/20 _I 65/13 67/4 68/8 68/17
successful [2] 60/22 [SUPPFess [2] 76/20 Itechnical [3] 1/14 I 63/22 68/3 74/22 I 68/22 68/24 69/3
SI 7713 3/18 128/9 76/17 79/20 80/23 I 69/13 70/3 71/25 73/2
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to 43/3 18/12 16/25I 21/22 71/20 79/12 _ tell [3] 9/9 17/25 87/4 91/7 91/24 93/17) 78/17 84/9 87/10
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foarte 108/4 11171 I 130/16 39/20 52/3 59/1 119/14 125/17 126/2 I 119/4 120/6 120/11
i149 128/10 13372 (Suspense [1] 66/5 Iten days [1] 29/13 I 127/7 127/8 131/11 I 121/7 121/20 123/19
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suffer [1] 103/17 [Suspicion [1] 81/23 terminate [1] 66/24 I 133/7 127/21 129/3 130/7
suffered [7] 56/18 ISUZanne [1] 124/20 Iterminated [1] 66/21 Ithem [48] 4/8 8/10 _I 133/19 134/23 1365/1
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76/6 76/10 86/12 91/4 41/10 60/7 62/8 66/14 66/22I 43/8 44/2 52/21 54/11I 56/12 57/13 58/11
108/22 109/10 113/20ISystem [8] 59/12 95/12 96/8 102/17 I 60/16 64/6 64/7 71/11I 62/18 62/20 64/5,
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sufficient [5] 16/24 I 100/23 100/25 101/18) 130/10 132/20 78/2 79/21 82/2 83/12I therefore [6] 17/12
17/18 44/21 17/4 I 116/10 terrible [2] 77/8 77/8 I 85/1 85/2 85/3 85/13 I 20/10 80/23 97/8
127/18 systems [1] 99/9 _Itest [2] 77/18 90/7 I 85/16 93/1593/15 I 102/16 119/5
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