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The Post Office Horizon IT Inquiry
Wednesday, 6 July 2022
(10.30am)
SIR WYN WILLIAMS: Good morning, everyone. By the reaction
of one or two people so far in the distance that I can
hardly see them, I guess you can hear me. Is that
corect? Good, Thank you very much.
We're going to embark today on the first of two
days of hearings, dealing with various compensation
issues.
There's been some misteporting about the extent of
what's going on in the next two days. So can I be clear
that there are two days devoted to discussions about
compensation issues, and I use the word discussions,
because essentially what we're going to have are oral
submissions from lawyers about those issues. We won't
be hearing oral evidence.
With that introduction, I should just also explain
why the two days are split apart. As you'd imagine, to
get so many lawyers into the same room at the same time
is not an easy business. So to facilitate all the
lawyers who needed to be here over these hearings
I agreed that we would schedule them on a day when their
advocate of choice could come to present their
submissions, so that's why we're having a hearing this
week and a hearing next week. The short delay between
1
Ms Gallafent QC on behalf of Post Office Ltd, from
Mr Mertens on behalf of UK Government Investments and
from Mr Stein QC on behalf of those core participants
represented by Howe & Co solicitors.
Your terms of reference, sir, require you, amongst
other things, to assess whether the comrritments made by
Post Office Ltd within the mediation settlement,
including the Historical Shortfall Scheme, have been
properly delivered. The reference there to the
mediation settlement is a reference to the settlement
deed of 10 December 2019
You had originally planned to address this issue
in phase 5 of your Inquiry, which is concemed with,
‘amongst other things, redress, access to justice, the
complaint review and mediation scheme, responding to the
scandal and compensation schemes.
In our concluded list of issues, we had isolated
the following issues in particular for consideration
within phase 5 of the Inquiry: issue 182, to what
extent, if at all, has Post Office Ltd properly
delivered upon the commitments which it made in the
mediation settlement to make improvements in its
relationships with subpostmasters and to bring finality
to all outstanding issues in respect of historic
shortfalls via the Historic Shortfall Scheme.
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INQ00001057
INQ00001057
6 July 2022
the hearings won't impede the Inquity's work in any way.
With that introduction, 'm about to hand over to
Mr Beer QC who will open the proceedings.
I do have one announcement. I was told in no
uncertain terms that I should not make any cricketing
analogies. In fact, I can't avoid it. Because this
evening there is a cricket match starting at the Oval
and that may begin in terms of its preparation at around
about 3.30 to 4 o'clock. I am hopeful ~ I am not
saying I am confident ~-I am hopeful that by that time
the submissions will be more or less complete. But if
they are not, we will have to compete with various
things going on around the cricket ground. Now, I'm
sorty I had to raise the word cricket but I do not think
I can be ciitcised for so doing in all the
circumstances
Mr Beer?
Submission by MR BEER
MR BEER: Thanks very much, sir. As you said, this is the
hearing of submissions by all participants on the issues
atising from the payment or non-payment of compensation
to subpostmasters at their families.
I appear as counsel along with Mr Blake today.
You will hear oral submissions later today in accordance
with the timetable that you have published from
2
483, to what extent, ifat all, has the creation
and implementation of the Historic Shortfall Scheme and
the interim compensation scheme provided an adequate
means for affected subpostmasters, managers, and
assistants to obtain financial redress for wrongs which
they have suffered
However, phase 5 of the Inquiry is presently
scheduled to occur in February and March of next year.
In the course of your human impact hearings in London
between 14 and 25 February, in Cardiff on 1 and 2 March,
in Leeds on 9 and 10 March, in Glasgow on 11 and 12 May,
and in Belfast on 18, 19 May, you heard from a number of
subpostmasters and members of their families about the
devastating financial consequences that the operation of
the Horizon IT system had and is having on them, the
financial consequences that civil proceedings brought
against them by the Post Office had and is having on
them, and the financial consequences that wrongful
conviction for criminal offences (including in some
cases resulting in imprisonment) had and is having on
them. This included significant accounts of penury,
precarious financial arrangements, bankruptcies, debt
management plans, loss of credit ratings, loans for
significant sums of money, and second mortgages, many of
which continue to this day.
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The Post Office Horizon IT Inquiry
The evidence also touched upon the operation,
effectiveness and speed of past and present compensation
schemes offered by the Post Office.
In the light of that evidence, you decided that
you ought not to wait until early spring of next year to
hear the evidence about past and present compensation
schemes. As you putit in a public announcement, some
of these issues, "needed to be addressed sooner rather
than later". So accordingly, on 9 May, you announced
that you would be conducting these hearings and
thereafter gave directions for the making of written
submissions and a timetable for delivering oral
‘submissions from the recognised legal representatives of
core participants
In terms of the factual background, although you,
sit, know the steps in the long and tortuous chronology
which brings us to this point in mid-2022, addressing
issues about the payment of compensation, to wronged
subpostmasters, there may be those listening or watching
the proceedings that do not. Therefore with your
permission I should like to spend a litle time
detailing some of the background which brings us to that
point today.
For present purposes itis sufficient to begin
with the litigation that commenced in 2017 between
5
litigation funding, ATE costs and other costs or other
relief claimed in the action. That was called the
settlement payment.
By clause 3 it was provided that none of the terms
of the Settlement Deed were to be construed as an
admission of liability on the part of the Post Office in
respect of any of the various claims made by the
claimants which were the subject of the litigation.
Clause 4.1 provided that the terms of the
settlement set out in the deed were to be in full and
final settlement of all claims made by the claimants,
save for the claims brought for malicious prosecution
which were defined as being brought by "convicted
claimants’
Clause 9.4 and schedule 6 of the deed laid the
foundation for the establishment of what is now known as
the Historical Shortfall Scheme or the HSS.
Approximately £10.5 milion of the £42 million set
aside as the settlement payment were shared between the
GLO claimants as compensation for the losses which they
claimed in the itigation, a very substantial proportion
of the settlement payment was therefore swallowed up in
litigation funding and other costs
Accordingly, most if not all ofthe claimants
received a sum by way of compensation which was
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INQ00001057
INQ00001057
6 July 2022
Mr Alan Bates and 554 other claimants against Post
Office Ltd, which is known as the group litigation
That is because it proceeded under a group litigation or
aGLo.
In this litigation the claimants brought claims
for compensation for alleged losses consequent on
breaches of contract and other wrongful acts arising out
of decisions made by the Post Office in reliance upon
information generated by the Horizon IT system.
Those proceedings were brought to an end by a deed
of settlement dated 10 December 2019. During the course
of the itigation the managing judge handed down six
judgments, two of those judgments, the common issues
judgment and the Horizon issues judgment, were itis
reasonable to suppose critical to the decision made by
the Post Office subsequently to offer terms of
settlement of the litigation.
The deed of settlement contains terms that are
relevant to the issues that arise today, including by
clause 2.1 the Post Office agreed to make settlement
payments are they as called which in aggregate amounted
to £57.75 milion. Of that sum £15 milion was
earmarked for the legal costs of the solicitors and
barristers who acted for the claimants in the group
litigation, 42 milion was paid over by way of damages,
6
substantially less than the alleged losses which they
had claimed in the group litigation
Pursuant to the deed the Historical Shortfall
‘Scheme was established in 2020. It is a remediation
scheme. Under its terms none of the claimants who had
been party to the Group litigation were eligible to seek
compensation under the scheme. The HSS was and is
intended to benefit all of those subpostmasters who
suffered loss as a consequence of Horizon but who were
not a part to the group litigation.
The scheme secondly identifies a number of
principles upon which compensation under it must be
assessed
Thirdly, the scheme includes detailed provisions,
dispute resolution procedures for resolving how claims
should be determined in the event that an applicant and
the Post Office cannot agree upon the compensation which
should be awarded
The scheme finally closed on 20 November 2020.
if you turn up in your bundle sir, tab 17, there
will be an update to these in a moment, you should see
figures published on 7 June 2020.
‘SIR WYN WILLIAMS: Sorry, Mr Beer. Is that occasional
banging disturbing you? Because if so I will try to get
something done about it
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The Post Office Horizon IT Inquiry
MR BEER: Moderately.
SIR WYN WILLIAMS: Somebody is going to try and suggest that
they should bang when we're having a break.
MR BEER: Thank you very much. I see somebody leaving from
the back. Very kind of you, sir.
You will see that at the foot of page 302 as at
7 June there were of the applications which had been
made 2,368 assessed to be eligible, 155 assessed to be
nnon-eligible. Which means that by 7 June if one adds
those two figures together, some 2,523 applications had
been made, so the scheme closed 27 November 2020, by
June 2022, 2,523 applications made.
On 21 July 2021 the Secretary of State for
Business, Energy, and Industrial Strategy announced that
funds would be made available to the Post Otfice so that
interim payments of compensation of up to £100,000 per
person could be paid to subpostmasters whose convictions
for dishonesty offences had been quashed. That
announcement was made in a statement in Parliament.
The announcement was followed up by a press
release the next day, which we have in your tab 8A of
the bundle. You will see itis dated 22 July 2021 and
is a press release on behalf of BEIS. Itis the second
page of that, page 217, to which I should draw attention
under the heading "Additional information", and it
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There remains the issue of final appointments for
those whose convictions were quashed. On
44 December 2021, the Minister, Paul Scully MP, made
a further statement which is relevant to the payment of
compensation to subposimasters whose convictions had by
then been quashed or would after then be quashed, and we
have that behind tab 8B, the statement of 14
December 2021
The relevant parts are the last two paragraphs on
page 219 where the Minister said:
"Lam pleased to confirm that today the Government
is making funding available to facilitate Post Office to
make final compensation payments to postmasters whose
convictions have been overtumed. We are working with
Post Office to finalise the arrangements that will
enable the final settlement negotiations to begin as
soon as possible. By providing this funding, Government
is helping Post Office deliver the fair compensation
postmasters deserve. With the Secretary of State's
status as sole shareholder in the Post Office my
department continues to engage actively with Post Office
Lid on this and will maintain strong oversight of the
compensation process."
(On 21 March 2022 you requested core participants
to respond to the Inquiry with written submissions on
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INQ00001057
INQ00001057
6 July 2022
reads:
“For final compensation the Post Office is
proposing altemative dispute resolution arrangements
Which aim to facilitate the swift quantification and
resolution of compensation claims. However, interim
payments announced today do not prevent people from
bringing civil claims through the courts.”
So the HSS had been set up. Then in July 2021 an
announcement of the payment of up to £100,000 per person
for each postmaster by way of interim payments, and
‘a proposal by the Post Office it was said to set up
alternative dispute resolution arrangements for
compensation to be paid finally to those whose
convietions had been overtumed.
As we understand it, in fact, no formal
remediation scheme was constituted thereafter, and
altemative dispute resolution has not occurred in
relation to those whose convictions have been quashed
In practice, those whose convictions have been quashed
have applied to the Post Office for an interim payment
and, in the main, the Post Office has made such a
payment within a very short time, ie., promptly, often
within weeks of the application being made. And the
information that the Inquiry has received suggests that
that interim scheme has operated well and effectively.
10
the availabilty of compensation for three discrete
subcategories of postmasters. I'm not going to outline
them as matters have moved on more broadly since then.
The next day, 22 March 2022, the Minister, Paul
Scully MP, made a further announcement in Parliament
which we have in our tab 8C, the relevant part of which
is in the second paragraph, where he said
“The Government has long considered unfair the
unequal treatment received by members of the GLO and
their non-GLO peers, I am therefore pleased to announce
that the Chancellor will make additional funding
available to give those in the GLO group compensation
similar to that which is available to their non-GLO
peers.”
You received submissions in response to your
request from the core participants represented by
Howe & Co and Hudgell solicitors and on 9 May 2022 you
issued a preliminary view in relation to compensation
schemes for subpostmasters.
(On 30 June 20202, so seven days ago, the Minister,
Mr Scully, made a further statement to the House and you
have that behind your tab 8D. I'm not going to read it
allout. The main elements of it were, firstly, in
relation to the GLO claimants. He said, firstly, that
the Government intended to make interim payments of
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The Post Office Horizon IT Inquiry
compensation to eligible members of the GLO cohort who
were not already covered by another scheme totalling
£49.5 million
Secondly, he said that the Government was working
towards delivering a final compensation scheme for the
GLO claimants and would be appointing Freeths Solicitors
to assess the data and methodology that they had
developed in relation to the 2019 settlement.
Third, that members of the GLO group would be able
also to claim reasonable legal fees as part of their
participation in the final compensation scheme
Then, secondly, in relation to those who
convictions had been quashed, the Minister announced
that a number of subpostmasters had agreed to refer the
issues of non-pecuniary damages to a process of early
neutral evaluation to be conducted by Lord Dyson.
So your request to core participants invited
submissions on 12 issues and they are set out in tab 2
of your bundle, which I would invite you to tum up
They are broadly divided into three categories: issues
arising from the existing Historical Shortfall Scheme;
issues concerning the compensation to be paid to those
subpostmasters whose convictions have been quashed; and
issues relating to the payment of fair compensation to
the Group litigation claimants.
3
195 to 202 you have the version that was extant from
June 2020. So that's the underlying material
It seems to us that the four issues which you had
previously identified in your document asking for
submissions remain fit for consideration by you along
with an additional issue identified by core
participants. I will describe the four issues
previously identified and fil them out a little by
reference to the submissions and then tum to the
additional issue, and do the same.
Issue 1 is the heads of loss which are recoverable
under the HSS and the reasons for any exclusions. That
on its face raises two separate issues, the heads of
recoverable loss and reasons for exclusions from the
scheme.
Dealing with heads of recoverable loss first, you
will have seen that despite its name which suggests that,
the focus of attention is shortfalls, the HSS in fact
allows in principle the payment by the Post Office of
much wider classes of compensation than the simple
repayment of sums of money wrongfully taken by the Post
Office from subpostmasters, or wrongly paid by
subpostmasters to the Post Office, or sums of money
wrongly treated by the Post Office as owing by
subpostmasters. That it includes, in principle, the
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INQ00001057
INQ00001057
6 July 2022
I would propose to identify by reference to those
three categories the issues that we have identified as
your counsel team as arising in the light of all of the
written material that has been lodged by the core
participants. I should state in that regard that we as
your counsel team will not be making positive
submissions as to outcome on any of those issues.
So category 4 or category A, issues arising under
the Historical Shortfall Scheme. You have in front of
you, sir, the core material in relation to the operation
by design of the Historical Shortfall Scheme. So in tab
44 you have the Terms of Reference of the HSS; in tab 15
you have the Terms of Reference for the Independent
Advisory Panel to the Historical Shortfall Scheme; in
tab 16 you have the eligibility criteria for the
Historical Shortfall Scheme; in tab 17 you have
a document called "Consequential loss principles and
guidance for the Historical Shortfall Scheme’; in tab 18
you have a questions and answers document published by
the Post Office as to the operation of the Historical
Shortfall Scheme.
Then going back to tab 7A, please, you have two
versions of application forms under the Historical
Shortfall Scheme, and so from page 188 to 194 you have
the version that was extant from May 2020, and then from
14
payment of much wider classes of compensation is not
clear from the Terms of Reference of the scheme at tab
414, which only refer to shortfalls, or the eligibiity
criteria at tab 16, which again only refer to
shortfalls
However, itis clear from the Terms of Reference
of the HSS Independent Advisory Panel at tab 15 that the
scheme does permit the payment of consequential losses,
and if I could invite you to tum that up please, tab 15
at page 285.
if one looks at paragraph 4A of the Terms of
Reference for the Independent Advisory Panel
consequential losses are defined to mean financial or
non-financial losses that are not shortfall losses,
shortfall losses being defined by paragraph 4D.
Then perhaps more significantly its also clear
from the consequential loss principles and guidance at
tab 17 that such consequential losses are in principle
recoverable. One can see that from paragraph 1.3 but
more significantly, from paragraphs 5.1 to 5.10 between
pages 291 to 295, one can just scan the headings there
which include claims for loss of earnings, loss of
profit, loss of property, loss of opportunity or loss of
chance, penalties, and incteased costs of financing,
bankruptcy and insolvency, legal and professional fees,
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INQ00001057
The Post Office Horizon IT Inquiry 6 July 2022
stigma and damage to reputation, and personal injury or
harassment. That a wide range, a very broad spectrum of
losses are in principle recoverable, providing that they
have been caused as a direct consequence of the Horizon
shortiall loss that is claimed
So it seems from those documents that the issues
which may arise are not ones of principle or theory, or
drafting in relation to the terms of the HSS, but at
‘a more practical level, as to whether the operation of
the scheme on the ground is such that subpostmasters are
put in the best position possible to recover such
consequential losses under the HSS.
Aside from the provision of legal assistance, to
make and pursue claims under the HSS, an issue that
I will address in a moment, the other issues which
appear to arise include the following: both Howe & Co
and Hudgell Solicitors who represent the vast majority
of subpostmasters in this Inquiry, state in their
submissions that in their experience when applications
have been made under the HSS by subpostmasters
themselves, heads of loss, especially these
consequential losses, have been routinely missed from
the applications, often meaning that significant sums of
money to which the subpostmasters are in principle
entitled have been left out.
17
defined to mean financial or non-financial loss that is
not a shortfall loss, which we have seen is obviously
correct by looking at the consequential loss and
guidance document -- sorry, consequential loss
principles and guidance document.
If we turn up the application form, which is the
next tab, using the May 2020 version, there is no
material difference between the May and the June version
in this regard, you will see from page 190 a series of
boxes for an applicant to complete, and on the second
page, on page 191, under the heading "Shortalls’, the
applicant is presented with the following statement:
“For each shortfall in respect of which you are
applying please specify’, and then there are six
subparagraphs setting out the information that is to be
given in relation to the shortfall.
Then question 19 ~ sorry, question 20, also
relates to shortfalls. Question 21 is about whether
there had been an audit into the relevant branch
Question 22 concems whether there was any other
investigation into the shortfall, Question 23 is
whether action was taken by the Post Office as a result
of the alleged shortfall. Then question 24 does ask the
broad question
"Have you experienced any other losses that are
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If that is right, you may wish to consider what it
is about the way in which the scheme is operated that
has caused such a result.
SIR WYN WILLIAMS: When you say itis missed out, if that's
the phrase you used, you mean it was never included in
the application form?
MRBEER: Yes.
SIR WYN WILLIAMS: Fine.
MR BEER: One point that is made, firstly, is whether the
application form itsetf was designed in a way which
actively encouraged subpostmasters to pursue these
claims for consequential losses or whether, like the
Terms of Reference and the eligibility criteria the
focus is too on shortfalls
The Post Ofice say in their submissions at tab 7
at page 172 to 173, i's the last line on 172:
"The HSS application form accordingly invited
postmasters to identify any such shortfall that the
applicant has repaid or is regarded by Post Office as
still owing [shortfall losses] as well as ‘any other
losses claimed by Horizon shortfall, namely
consequential losses", and a cross-reference in
footnote 7 is given to the consequential loss principles
and guidance document.
itis said, continuing, consequential loss is
18
directly related to the alleged shortills in respect of
which you would like to claim. If yes, please provide
the following details for each alleged loss: the nature
of the alleged loss, the dates of the alleged loss, how
the loss arose as a direct result of the alleged
shortfall, and the valuelsize of the loss."
Then there isa litte box for a person to include
that information
You may wish to consider whether that single
question, not mentioning consequential losses, not
mentioning the consequential loss principles and
guidance, has led to the issue that both Howe & Co and
Hudgell Solicitors have raised. And, if so, what is to
be done about it?
The second issue is whether the facility within
the scheme for a payment to a subpostmaster in the
interests of faimess, even though they cannot discharge
the burden of proving on the balance of probabilities
that they have suffered a loss, is in fact operating in
practice as a sufficient mechanism to ensure that
subpostmasters are properly compensated.
We can see the operation of that facility, the
faimess principle, written into the scheme in a number
of places. Can I invite you to tum up tab 17 please,
which is the consequential loss principles and guidance
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document.
Under paragraph 3.1 at the foot of page 289 under
the heading "Key principles", paragraph 3.1 is headed
"Burden of proof in relation to consequential losses",
and reads
"3.4.4. The burden of proof is on the postmaster
to provide sufficient evidence in support of their claim
to demonstrate that on the balance of probabilities,
i.e. a greater than 50 per cent likelihood, (a) such
losses have been suffered, and (b) as a consequence of
‘a Horizon shortfall as such are found in the common
issues judgment or the Horizon issues judgment. This
means evidencing the fact that a loss was incurred, the
‘amount of that loss, and that the cause of the loss was
due to Horizon shortfall.
"3.1.2 where the subpostmaster is unable to
satisty the burden of proof in relation to their claim,
their claim may nonetheless be accepted in whole or in
part if the scheme considers it to be fair in all the
circumstances."
Then under 3.2.3, which is under a cross heading
of "Evidence", the guidance document states:
"The need to provide evidence is particularly
important where a postmaster’s claim relates to matters
which are known only to the postmaster. While the
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So in those two places one can see that the scheme
and, in particular, the Panel are to be guided by broad
considerations of faimess, that the Panels discretion
is not confined solely to heads of loss claimed, and
that the Panel may take into account any facts and
matters which it considers will produce a fair result in
the circumstances of a particular case.
In terms of the operation of the scheme in
practice, there is no information that we have seen as
the Inquiry, no data in particular, and no explanation
as to the approach that's been taken, as to the
frequency with which this facility has been used, ie.
the faimess principle applied even though
‘a subpostmaster on evidence grounds has fallen short of
proving a loss on the balance of probabilities, nor
whether there are any examples of the initiative in fact
having come from the Panel to award a sum outside
a class of loss, a consequential loss claimed by the
subpostmaster, i.e. where the Panel has taken the
initiative and suggested to a subpostmaster it appears
on the facts that you have presented that there is
a category of loss or there are broader categories of
loss that you ought to have claimed. You should do so.
Or examples of where the Panel has made an award on the
basis of a broad consideration of what is fair, rather
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burden is on postmasters to provide sufficient evidence
to demonstrate their claim for consequential loss, the
scheme will also consider any relevant evidence Post
Office holds when assessing the claim. Any key
supporting documentation relied upon will be shared with
postmasters when they receive the outcome of their
claims to enable them to consider whether they wish to
accept the offers made to them."
I will come back to that in a moment.
The second place in which we can see the faimess
principle described is in tab 15, of your bundle which
is the terms of reference for the Independent Advisory
Panel o the HSS. tis at page 287 and clause 30, this
reads:
“In formulating its recommended offer the Panel
may recommend the making of an offer to the postmaster
if, guided by broad considerations of faimess, the
Panel considers that doing so would produce a fair
result in all the circumstances of the particular case.
For the avoidance of doubt, in doing so the Pane's
discretion will not be confined solely to the specific
heads of consequential loss claimed by the postmaster
but will take into account at any facts and matters
which the Panel considers will produce a fair result on
the facts of a particular case."
22
than the application of the legal principles of
remoteness, causation, mitigation, and quantum.
So the question which arises is whether this
faimess facility is operating in practice in
circumstances where for the reasons described by the
subpostmasters it's very likely that a high number of
them have not retained records from a decade or two
decades ago that are necessary to prove to the relevant
standard the losses that they have suffered. That's an
issue that you may wish to explore in particular with
the Post Office
Turning then to the reasons for exclusion. The
reasons for exclusion of certain classes of applicant
have been broadly explained in al of the submissions of
the core participants and I'm not going to rehearse
them. But an outstanding issue is the exclusion of
applicants who did not apply within the relatively short
window during which the scheme was open for
applications, which relatively short window was at the
height of the pandemic, and the approach that the Post
Office has taken after that closure of the window to
applications made out of time.
You will see in tab 7, at page 176, at paragraph
23, this is the Post Office submissions, the Post Office
say’
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(6) Pages 21-24
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“The scheme was initially open to applications
from 1 May to 14 August 2020. This deadline was
subsequently extended by 15 weeks until 27 November 2020
in order to enable further applicants to apply following
‘an amendment to the scheme's eligibility criteria, as
well as to accommodate difficulties in making
applications due to the Covid 19 pandemic."
Then this:
"Since closure of the scheme to applications, Post
Office has received in excess of 170 applications to
date, all of which Post Office is actively considering
how best to address", so you may wish to consider the
approach that the Post Office is taking to applications
made out of time and whether that statement, which is
"We're stil thinking about it’, is adequate in the
circumstances.
Issue 2, sir, under ths first category is whether
there has been delay and, if so, the causes of delay in
processing applications under the HSS. As we said,
after the 15-week extension period to 27 November 2020
the scheme was closed.
In terms of the number of applications made and
the awards made, if we can go back to tab 19, please,
which we looked at earlier, this time look at the second
page, page 303. Again, these are figures to 7 June this
25
issue that may arise for your consideration is what is
the cause of the delay that 19 months on only 50 per
cent of eligible claimants have had payments made to
them:
Sir, issue 3 is the provision which has been made
for applicants to obtain independent legal advice in
respect of their claims under the HSS and whether it has
been adequate. Sir, you know that the scheme makes
provision for the payment of a figure of either £400 or
£1,200 in respect of legal fees. That figure is
dependent on whether the Post Office offers to pay the
claim in full, in which case the former figure is paid,
or whether it does not, in which case the latter figure
may be paid
The scheme makes no provision for any other forms
of assistance, for example, fees for medical evidence to
be obtained to support a claim for consequential losses,
oF forensic accountancy services, again, to prove on the
balance of probabilities that losses which are
consequential on a shortfall have been suffered
You may wish to consider whether this approach is
adequate in circumstances where, firstly, the nature of
the consequential losses claimed are in many instances
likely to be complex; where the scheme, secondly,
requires losses to be evidenced by a range of
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year, so these are figures 19 months after the closure
of the scheme, it shows that settlement offers of the
eligible claims have been made in 1,483 cases, i.e
63 per cent, and payments have been made in 1,135 cases,
ite. 48 per cent, so less than half.
Last night the Post Office filed some additional
submissions to update these figures amongst other
things. The 63 per cent has gone up to 65 per cent,
ie, the number of eligible claims in which offers made,
and payments have been made in -- sorry, that's 67 per
cent, not 65. Payments have been made in 52 per cent of
eligible cases as opposed to the previous figure of
48 per cent. So still at around the half figure, and
we're 19 months after the closure of the scheme
Now, those numbers, those figures, obscure perhaps
the human stories that sit behind them. You may recall
Mr Baljt Sethi who I asked questions of in the human
impact hearings. He told you, sir, that although he had
received standard form acknowledgements from the Post
Office after he had made the claim, he waited for just
under two years before he received any substantive
reply. That was a couple of days before he gave
evidence to you.
There were other accounts of delays in any contact
at all from the Post Office in the HSS. So, sir, the
26
contemporaneous and other documentary material, material
which a lay person may not be used to collecting,
organizing and presenting; where, thirdly, the scheme
self evidently applies legal concepts such as
remoteness, causation, mitigation, and quantum that may
be unfamiliar to people; where, fourthly, further
difficult issues may arise in claims that arise
following bankruptcy, where the trustee-in-bankruptcy
must be involved and the consequential losses that are
properly recoverable may be complex; where, fifthly, tax
advice it's likely to be necessary in relation to
different elements of payments made under the scheme.
No provision is made for the payment of legal
costs when the dispute resolution procedure within the
scheme is triggered, including where a good faith
meeting is required or if the case goes to mediation
The point has been made by the subpostmasters that by
contrast the Post Office has appointed a law firm to
operate the scheme on its behalf and to prepare the
analysis which is then passed to the Independent
Advisory Panel, i.e. which appears to form the basis of
the material on which the Independent Advisory Panel
makes its decisions.
In its submissions of last night, the Post Office
stated that ithas contributed to the legal costs of 45
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(7) Pages 25 - 28
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applicants. If that is correct that means that it has,
made a contribution in 45 out of 1,242 cases in which
the payments have been made, a tiny proportion. It
follows that no appointments have been made in some
1,400 or so of the cases ~- sorry, 1,200 of the cases in
which compensation payments have been made.
In the same submissions the Post Office says that
its currently considering whether contributions to
legal fees or other professional costs can be made
available and that it will update the inquiry in due
course.
You may wish to consider whether that is
satisfactory in circumstances where the scheme has been
operating for 2 years and according to the Post Office
figures, half ofthe eligible applicants have already
been paid a sum of money and only 45 of them have had
their legal fees paid.
Issue 4, is the provision which has been made for
interim payments pending completion of the procedures
under the HSS. You will have seen that Hudgell & Co
suggest that the Post Ofice has refused to make interim
payments under the HSS in respect of losses which are
agreed whilst other species of loss are investigated,
and that Howe & Co have suggested that the making of an
interim payment under the scheme, such as the HSS ought
29
showing for example, a terminal ilness or old age, but
instead where some losses have been agreed and payment
of that sum should be effected, whilst argument
continues over other losses.
Sir, those are the four issues that arise under
the first category.
Howe & Co have raised an additional issue over the
operation of paragraph 3.2 of the consequential loss and
principles guidance. That is tab 17 at page 290
I mentioned it to you earlier. Tab 17, page 290, and
its 3.2.3 which I read out earlier. The point made on
behalf of Howe & Co is that subpostmasters are provided
under this scheme with the evidence that the Post Office
possesses at the stage and only at the stage when "they
received the outcome of their claim’, ie. they received
evidence from the Post Office after they had formulated
a claim and after receipt of an offer
So the burden is on the postmaster to prove his or
her claim without the material that the Post Office
itself possesses. It's suggested by Howe & Co that such
material as to the Post Office possesses as is relevant
to the claim that is made, ought to be disclosed at the
outset or at least in the course of the process and not
atits end
Can I turn more briefly to consider categories 2
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not to be seen as controversial or novel, but instead
the norm.
You may wish to consider whether this approach of
generally not making interim payments under the HSS has
placed pressure on subpostmasters to accept early
payments at undervalues or instead hold out for the
possibilty of a higher payment.
If we go to tab 7 again, the Post Office
submissions, at page 182, at the foot 182 and on to 183,
itis said, as noted in some previous submissions,
payments have been made on an interim basis prior to
a final offer of compensation, so those applicants to
the HSS whom Post Office understood to be in dificult
circumstances, who could be irredeemably impacted by the
time necessary fully to assess their claim and make
a fair offer. To date Post Office has made payments on
an interim basis to 25 applicants, including of
ciroumstances of severe financial hardship, terminal
illness, risk of personal hardship and old age
So interim payments made in 25 cases, and you will
recall that as of 7 June 1,482 offers of settlement have
been made, so interim payments in about 1.6/1.7 per cent
of cases. There appears to be a difference of desire or
of approach here. You may wish to consider whether
interim payments ought to be made irrespective of
30
and 3 or B and C. Category 2, back to tab 2, sir, final
compensation for subpostmasters with quashed
convictions. Issue 5 was the principles which are being
applied to the calculation of final compensation
schemes ~ sorry, final compensation payments; issue 6,
the mechanism which by which final compensation payments
are being calculated; issue 7, the provision, if any,
which is made for applicants to obtain independent legal
advise in relation to their claims; issue 8, the
procedures which are being adopted to resolve the
disputes about the value of compensation payments.
These are all about subpostmasters who have had their
convictions quashed
These issues do not address the question of
interim payments and that’s deliberately so. That's
because, as I mentioned already, the payment of sums of
money to subpostmasters in this category of claim appear
cn the information received by the Inquiry largely to
have worked well, with such payments generally being
made promptly.
In their May submissions the Post Office noted
that of the 73 men and women whose convietions have been
quashed, 69 had applied for interim payments and such
payments had been made by the Post Office in 66 of them,
The questions that we have instead raised relate to
32
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final payments. That's what questions five to eight
relate to.
The collective answer to all of those questions is
that there is no formal mechanism or scheme to value
claims or to administer claims. Instead, the claims are
being pursued through pre-action correspondence in the
hope that they will be resolved without recourse to yet
further itigation.
I's been said in the submissions both by BEIS and
the Post Office that the absence of a formal mechanism
or scheme was at the express request of the
subpostmasters themselves. Certainly in the submissions.
of Hudgell & Co there is no request for such a scheme to
be set up. Instead, the Hudgell & Co submissions to you
focus on the merits oftheir clients’ claims for certain
losses, a matter which I anticipate you will not wish to
address, the individual substantive merits of the claims
made.
However, there has been a further development in
that a number of subpostmasters represented by
Hudgell & Co have agreed that the issue of non-pecuniary
losses, which itis said was causing a particularly
difficulty to assess and to agree, should be referred to
early neutral evaluation, a process which by a valuer
who is respected expresses a non-binding conclusion,
33
proceeding satisfactorily,
Can I tum then to category 3, fair compensation
for the group litigation claimants. This raises issues
910 12 on your list, sir. These issues have been
overtaken by events. In particular, the announcement by
the Minister seven days ago about the payments by way of
interim payments to the GLO claimants with a fund of
£19.5 million set aside for that purpose and his
announcement that a new scheme for the payment of final
compensation was being developed. There are no details
yet available as to that scheme for the payment of final
compensation to the Group litigation claimants.
It seems to us that the issues which may arise
include whether the voice of all of the GLO claimants is
being heard and fairly represented in the development of
a scheme to administer payments, both interim and final,
for the group litigation claimants.
You will have seen that the Minister announced
seven days ago that the Government had engaged Freeths
Solicitors in the way that I have described and they
were of course the firm that represented the 555 GLO
claimants in the group itigation. Its fair to say
that the papers that the inquiry has received and some
of the evidence that it has seen, raise some issues as
to the extent to which all of the 555 GLO claimants knew.
35
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non-binding view, on the likely outcome were the matter
before him or her to proceed to court, and itis has
been announced by the Minister, Mr Scully, and in the
BEIS submissions of last night that Lord Dyson has
agreed to act as the evaluator.
So rather than looking individually at issues ~
SIR WYN WILLIAMS: Sorry, Mr Beer. Did you say BEIS
submissions of last night?
MR BEER: No, I meant Post Office of submissions of last
night
SIR WYN WILLIAMS: I thought you were in advance of me
that’s all.
MR BEER: No, the Post Office submissions of 8.59pm last
night
SIR WYN WILLIAMS: I know we all work late but I was
thinking when could they have come.
MR BEER: Yes. So the issue rather than individually
looking at points 5, 6, 7 and 8 that you may wish to
explore, in particular with counsel for the Hudgell & Co
core participants, who represent it seems 62 of these
claimants, ie. the vast majority of them, is whether
they are content for the current approach to continue.
That's a polite way of saying whether they, in
fact, ask you to butt out. Whether they wish you to
stand back and not interfere in arrangements that are
34
and understood in the course of and at the conclusion of
the litigation the extent to which any sums paid by the
Post Office would be lost in legal and other
professional fees, and issues as to the extent to which
their interests were represented in a structured and
transparent way by the JFSA.
The inquiry has not of course been a party to and
knows nothing about the negotiations which it seems have
taken place between BEIS on the one hand, the JFSA on
the other, and Freeths on the third part as to the sums
of money to be paid by BEIS, the scheme by which such
payments will be made on an interim and on a final
basis, or the principles that will apply under that
scheme to ensure fair and reasonable compensation for
all of the 555 GLO claimants.
In that regard, I would end by asking you look at
alletter written by Freeths Solicitors, which is in
tab 3 at page 21, a letter to the solicitor to the
Inquiry. It's the final paragraph about half way
through, where Freeths say
"On behalf of individual GLO claimants who choose
to instruct us, we are consulting with BEIS and JFSA in
order to collaborate on developing a scheme and
associated arrangements that work in the interests of
those of the GLO claimants who wil instruct us, so
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naturally Freeths Solicitors will only be acting in the
interests of those of the GLO claimants who instruct
us."
itis apparent that a number of the GLO claimants
are represented in the Inquiry by Howe & Co and so the
issue that you may wish to consider with representatives
of both BEIS and the Howe & Co core participants is what
mechanisms have been put in place to ensure that the
arrangements work in the interests of all of the GLO
claimants and not those simply represented by Freeths in
circumstances where issues have arisen in the past as to
the openness, transparency and organisation of decision
making in the group litigation itself.
In shor, this scheme, itis presumed, is designed
to put right what went wrong at the conclusion of the
Group Itigation. It will be unfortunate putting it
mildly if something similar was to happen again.
SIR WYN WILLIAMS: Can I say now, Mr Beer, so that there is
no misunderstanding about what's in my mind, that that
sentence that you just focused on “on behalf of
individual GLO claimants who chose to instruct us [past
tense]. We are consulting with BEIS and JFSA in order
to collaborate on developing a scheme and associated
arrangements that work in the interests of those of the
GLO claimants who will instruct us."
WT
of people here and when we have our break its very
tempting to have a chat with people. Let me tell you a
story about a crusty old judge who used to walk into
court dead on the appointed time regardless of who was
there. On one occasion I wasn't there and got a rocket
So from now on, if you want to have a chat outside
please do but I'm going carry on without you. All
right.
Ms Gallafent.
‘Submission by MS GALLAFENT
MS GALLAFENT: Sir, thank you. I would lke to state at the
outset that Post Office is grateful for the opportunity
to make both written and oral submissions on the issues.
you identified in your invitation of 10 May as well as
oral submissions on the matters set out in your
provisional view on compensation issues relating to
prosecuted subpostmasters of 9 May of this year.
We are conscious that so far as your invitation of
40 May is concemed, these hearings are only intended to
cover points that you consider should be addressed
sooner rather than later and are not intended as
a substitute for the full hearing on the issues of
financial and other sorts of redress which fall within
phase 5 of the Inquiry's work currently scheduled to
take place next spring. In these circumstances in
39
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I'm not quite sure how the past and the present
fits together there.
MR BEER: Yes, in particular where the ~
SIR WYN WILLIAMS: I am not asking you to answer. I am
throwing it out so that that puzzle in my mind can be
pondered on by those who may know the answer.
MR BEER: That's why I focused on that sentence in
particular, sir. Because, as I said, putting it mildly,
it may cause concems that the issues that unfolded in
December 2019 have the potential to repeat themselves
once again.
Sir, those are the only points that I raise for
your consideration.
SIR WYN WILLIAMS: Thank you very much.
Ms Gallafent, I think you are next up but I take
it we'd all ike a morning break so is this a convenient
moment to have it?
MS GALLAFENT: In your hands, si.
SIR WYN WILLIAMS: All right then, 10 minutes and then we
will start again,
(11.42 am)
(A short break)
(11.58 am)
SIR WYN WILLIAMS: Before I ask Ms Gallafent to make her
submissions, I appreciate that there is a large number
38
particular we have not treated today's hearing as the
appropriate point for Post Office to make its opening
statement generally, which we look forward to making at
the beginning of phase 2 in September.
So far as the content of our submissions today are
concerned could I make three preliminary points. First,
in line with the position adopted in our written
submissions we will primarily be focusing on the
specific questions asked by you rather than other issues
which may be raised in due course.
Secondly, in line with the indication in your
statement of 30 June of this year, we will be taking the
opportunity to highlight the aspects of the written
submissions made on behalf of other organisations and
persons with which we agree or disagree, and seeking to
explain the reasons for any disagreement.
Thirdly as, sir, we expect you will have
anticipated from our own written submissions, we intend
to focus on sections of A and B of your invitation and
that is questions 4 to 8 and leave section C to the
Secretary of State for BEIS to address in due course.
Can I start then with section A and Historical
Shortfall Scheme. Before I address the particular
questions, can I just make clear that we had not
ourselves understood or anticipated that the first
40
(10) Pages 37 - 40
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question concerning heads of loss, and which were
recoverable or not recoverable, would be read and
regarded as covering the rather wider question of the
functioning and application of the fairness principle
under the scheme and, in particular, the use of the
provisions under the Terms of Reference of the
Independent Advisory Panel when it comes to its
recommendations. We make no criticism in this respect
but we emphasise that is why, sir, you haven't to date
received data or analysis on the use of that faimess
principle.
Now, I can confirm that itis used regularly, and
we are happy to assist the Inquiry by providing some
data and analysis on that issue should it be of
assistance. But that is why we haven't done it so far
because we hadn't interpreted that issue in the way that
Mr Beer has indicated it may be read this morning
Can I move on to then the particular question
which is asked about recoverable heads of loss. We're
{fateful to Mr Beer for introducing in particular the
Terms of Reference of the Independent Advisory Panel and
the definition of shortfall loss and consequential loss,
consequential loss being there defined as financial or
non-financial loss that is not a shortfall loss.
Mr Beer also took you to, sir, the consequential
at
Horizon shortiall at the time which may be recoverable
as loss under the terms of the scheme, and any legal and
professional fees incurred by a postmaster in bringing
an application to the scheme. We say that simply
reflects the position in line with civil proceedings
generally, which is that the costs associated with the
bringing or making of an application or claim are
treated separately to actual losses flowing from
a relevant breach of contract or breach of duty that’s
relied upon on which the claim is founded.
The second point we make in this context in
relation to expert advice, is that every case will be
assessed by three members of the Independent Advisory
Panel, comprising one legal specialist, one forensic
accounting specialist, and one retail specialist. There
is therefore a very significant degree of expertise
already built into the process.
Thirdly, where a panel considers that it requires
expert assistance in order to make a recommendation, it
may recommend to Post Office that such assistance be
obtained at Post Office's cost. That's paragraph 27 of
the Independent Advisory Panel's terms of reference.
That's, sir, for your note page 286 in the bundle for
today. So it's open to any applicant to raise the
question of expert assistance being required and if the
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loss principles and guidance and went through at
section 5 the non-exhaustive lst of the types of loss
that can be claimed, assuming they meet the applicable
legal tests and noting there they must be linked clearly
back to Horizon shortfall
itis suggested by Mr Beer that effectively the
question as to what is or is not recoverable by way of
a consequential head of loss is pretty much settled,
that nothing is ruled out. At the risk of perhaps
raising questions that no longer arise can I just
address a couple of points that are made in the written
submissions of other core participants
The first one is in relation to expert advice, and
itis suggested by Howe & Co that the heads of loss
under the guidance are deficient in that there is no
provision to obtain expert guidance to support or
quantify claims under the heads set out in the guidance
We'd make four points in response. This is a point
raised in relation to heads of loss.
The first is that the guidance itself, and we say
rightly, expressly delineates ~ sir, for your note
that's paragraph 5.8.1, of course, the guidance itsetf
is tab 17, Ido not suggest you need to tum it up --
but it delineates between a claim for legal or
professional fees incurred in relation to dealing with
42
Panel agrees then it can recommend its obtained at no
cost to the applicant. So it would be unnecessary for
such an applicant in those circumstances themselves to
bring any claim or seek any reimbursement of any such
expenses. It would be Post Office who would be footing
the bill in that case
Sir, you might like to note that the Panel in the
past has asked Post Office to obtain expert evidence on
generic issues, including cardiac and mental health
issues to assist it in adopting an approach to claims
generally.
The fourth point I make in this context is that
the Panel's Terms of Reference also provide and, sir,
you have already been taken to this provision at Section
35, in relation to personal injury claims, where
insufficient evidence has been provided for a claim to
succeed, without further medical and/or expert evidence,
the Panel may nevertheless recommend the making of an
offer to the postmaster which the Panel considers fir.
Now, this provision is designed to be advantageous
to.an applicant. It enables an applicant who is not
potentially able to obtain expert evidence to prove and
support their claim, nevertheless to obtain
a recommendation from the Panel on the basis of
faimess,
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We're conscious also that an applicant may wish to
avoid the inconvenience and potential distress of
obtaining a report which may be a particularly acute and
sensitive concem in cases involving mental health
issues, but that the Panel has the power nevertheless in
the absence of such evidence to recommend an offer which
it considers to be fair.
In these circumstances we wouldn't agree that
there is any deficiency in the Historical Shortfall
Scheme in this respect.
The second head of loss that's flagged up again by
Howe & Co as potentially not being recoverable under
this scheme, is the question of aggravated and exemplary
damages, and what is said is that no reference to them
or provision for them in the guidance and the heads of
loss ate therefore deficient.
Now, Post Office's response so far as aggravated
damages are concemed is that where an applicant has
identified aggravation or stress that Post Office caused
when having to deal with shortfall issues, however that
claim is described by the postmaster, that is something
that would be fully taken into account when assessing,
recommending and making offers in that particular case.
Compensation for aggravation would be taken into
account in the round rather than being characterised or
45
a deficiency in respect of the question of aggravated or
exemplary damages either
SIR WYN WILLIAMS: Well, Ms Gallafent, you put it very
elegantly but I think the reality is that you take
a great deal of persuading, POL I mean, not you
personally of course, that a claim for exemplary damages.
should be entertained
MS GALLAFENT: Under the -
SIR WYN WILLIAMS: Because you say there is a problem with
the legal principles which underpin the award of
exemplary damages.
MS GALLIFANT: We wouldn't say its a problem with the legal
principles. We'd say they are the legal principles that
apply. That is what the Terms of Reference provide for
but of course we would carefully consider it were it to
be made. But I emphasised that the vast majority of
claims brought under the HSS by far are brought on the
basis of contractual obligations, so the question may
arise but not necessarily in claims that have been
brought so far.
SIR WYN WILLIAMS: So is this a fair representation of what
you are telling me: that if, as a matter of principle,
legal principle, a particular claim was made in which an
award of exemplary damages was possible as a matter of
legal principle, it would be carefully considered. But
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identified as such on the face of any decision as
aggravated damages. It would most likely be taken into
acoount when the Panel considers the issue of distress
and inconvenience.
The Panel's role of course is with a view to
recommending an offer which is fair overall, hence why
it isn’t specifically identified as such necessarily.
So although applicants may not have expressly
characterised their claim as including a claim for
aggravated damages, a number of offers have included an
element reflecting just such a claim where itis
justified on the facts of the case.
The position for exemplary damages is potentially
slightly different in principle. Were any claim to be
made it would be carefully considered along with all the
other claims that have been made. That said, POL's
initial view is that as a legal matter a claim for
exemplary damages does not naturally sit within the
scheme. It can't, strictly speaking, be said to be
alloss incurred by an applicant, or a type of damage
that's typically available for a breach of contract
claim. However, the Panel can and does consider overall
faimess when recommending offers to applicants and, as
I have said, any such claim would be carefully
considered. We therefore do not agree there is
46
if a particular claim was made in which, as a matter of
legal principle, exemplary damages was not to be
awarded, it wouldn't be carefully considered. It would
be rejected
MS GALLAFENT: Well, the claim itself would be carefully
considered in either of those events to work out
whether, as a matter of legal principle, it was
recoverable or not. So that's my starting point. It
wouldn't be rejected out of hand at all
Ofcourse, were then the Panel to reach
a conclusion and a recommendation based on saying, well,
exemplary damages are not recoverable in the
circumstances of this particular case, then of course
that could be a matter which is taken further in dispute
resolution process. I'm not seeking to rule out the
award of those damages, but I'm simply flagging up what,
we perceive to be the potential issues going forward,
and perhaps just to anticipate we do not take the view
that, as it were, exemplary damages have been missed in
previous cases because we do note that those are
primarily brought on a basis of a contractual obligation
and exemplary damages are not generally available for
a breach of contact.
‘SIR WYN WILLIAMS: And I should make clear, lest people
misunderstand what I am doing, I am simply seeking to
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understand what you are saying. I recognise the limits
of my Terms of Reference. Everyone should understand
that.
MS GALLAFENT: Thank you. Thank you, sir
Sir, can I move on to another category of loss
which itis suggested is not covered, which is third
party losses. Again, Howe & Co have suggested that the
heads of loss should reflect suffering caused to
children and family members and others in caring roles,
Can I emphasise that the Panel has throughout sort
to take an applicant-fiendly approach to compensation,
including for this issue. Whilst a family member's,
distress and inconvenience is not technically
recoverable from Post Office for a breach of contact
claim, such as in the scheme, in a number of cases the
Panel has nevertheless taken distress and inconvenience
of family members or others into account by considering
and having regard to the indirect impact of that on the
applicant when they are making recommendations. In
other words, when they feel itis fair to do so, so
practically speaking it will be taken into account where
itis justified to do so, despite the fact that our
position is itis not technically recoverable.
For completeness, I would note that the Panel has
also made recommendations for compensation for distress
49
Mr Beer noted that it doesn't there refer to
consequential losses. Indeed it doesn't, and we say
that the reason for that is simply because this form was
designed and anticipated to be completed by lay persons
rather than having to require explanation or advice from
a lawyer in order to understand the meaning of
consequential losses. So the description of losses
directly related to the alleged shortfalls we say is
adequate in all the circumstances.
A suggestion is made by Hudgells that this
question was, as they put it, potentially misleading
because it didn't signpost applicants to any of the
‘examples set out in the guidance. We do not accept the
form was misleading on this or any basis. It was
designed to strike a balance between being comprehensive
and being capable of being used by lay persons.
Now, the guidance was introduced on 1 October 2020
at which point Post Office wrote to all applicants to
the scheme at that stage to communicate that update and
the availability of the guidance. Post Office also
published a press release about the guidance. And
published it on the scheme website so any applicants who
hadn't applied by that point would be made aware of it
from the website itself.
So we do not say there is any fault or deficiency
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and inconvenience or personal injury for corporate
entities that are stress and inconvenience or personal
injury suffered by directors or shareholders.
Going back to my point which we do not consider it
to be technically recoverable, I will emphasise again
that it does not follow from the fact that claims may
not fal directly within the scheme that a claimant is
precluded from bringing a claim because of course it
remains open to a potential claimant to bring
proceedings in which the legal basis for any such claim
could be fully considered. Again, we therefore wouldn't
agree that there is a deficiency in the scheme in this
respect.
Those three points are, in our view, as it were,
the core points raised by other core participants on the
question of heads of loss themselves and what is or is
not recoverable. We do recognise that the submissions
from other core participants went rather more widely
than that and, in particular, the question of the
application form and question 24.
i's common ground that what was asked was, of an
applicant, whether they had experienced any losses that
were directly related to the alleged shortfalls in
respect of which they would like to claim and asked for
details of each such loss to be provided if so.
50
in not sign posting the guidance in the application
form. Sir, as you have heard from Mr Beer, the
application forms, of course, predate the guidance. But
POL took all reasonable and appropriate steps to flag up
the existence of the guidance to applicants and
potential applicants,
Moreover, of course, and you have been taken to
this part of the terms of the reference of the Panel as
well, they provide that the discretion of the Panel
making a tecommendation is not confined solely to
specific heads of consequential loss claimed by the
postmaster but will take into account any facts and
matters which the Panel considers will produce a fair
result on the facts of a particular case. That's
paragraph 30. Sir, you have it that tab 15, page 287.
‘SIR WYN WILLIAMS: _ I just wanted to check that I had marked
it. Thad.
MS GALLAFENT: I am grateful, thank you. We've already set
ut in our submissions that we put in in May for the
purpose of these hearings the proactive approach that is
being taken to assessing consequential loss. That
includes not just a proactive approach by the Panel, but
a proactive approach by those, as it were, the case
managers by virtue of the very detailed bespoke process
for requesting further information
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We emphasise that the bespoke request for further
information is designed to identify and ask further
questions of an applicant only when they arise from the
key facts of the individual case, provided on the
application form, so the case manager will be prompted
by the application form to identify potential further
questions and those questions will be asked, and
sometimes there will be number of them asked. But that
is all aimed to elicit information which may assist with
a claim for consequential loss.
Now, were such questions to have been asked as
‘a matter of course on the application form, which seems
to-us the logical consequence of what's being suggested,
then inevitably many of them would have been irrelevant
to any particular applicant for asking, for example,
saying do you think there are any stigma damages, do you
have any personal injury, and so forth.
Far from being of assistance we say that to have
effectively built in guidance or something akin to it
into the application form itself would have been
perceived as overly burdensome and a barrier to making
an application. We repeat, the guidance was available
and flagged up to applicants and potential applicants,
the form itself is not deficient in this respect
We also note that where an applicant having
53
relevant and a higher or lower reduction is appropriate
‘That's likely to depend on its view of there being a
greater or lesser degree of uncertainty on the question
of a particular element of consequential loss.
We say itis not just unnecessary but it would be
inappropriate to constrain the Panel's discretion in
this context, ie. to say you must only ever reduce
shortfall losses by 10 per cent rather than 20 or 30 per
cent, or whatever it might be. That would inevitably
lead to unfair outcomes in some cases and overly complex
rules, we say, to attempt to deal with every potential
permutations of circumstances.
The second suggestion made is that credit has been
given in some cases for heads of loss which haven't been
claimed, such at the time taken to deal with Horizon
shortfalls. I would again emphasise that the Panel does
not seek to hold applicants to and strict legal pleading
requirement. It will recommend an offer where it feels
itis fair to do so and in those cases where credit has
been given, that is because, on those cases, the Panel
feel on the facts its appropriate to do so, even though
ithasn't been claimed,
There is also, finally, a suggestion that there is
an absence of a consistent explanation as to how loss
for distress and inconvenience is quantified. The
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received an offer credibly says they did not appreciate
that they needed provide information earlier, which
would include matters of consequential loss, this would
be taken into account in the post offer process. So the
door is not closed in those circumstances to raising
‘a matter of consequential loss even after the offer has
been made
Another point that is raised, this time by
Hudgell, is that the guidance itself, the consequential
guidance, should be supplemented to ensure greater
clarity and consistency in decision making. We don't
accept that's necessary, not least as it's very clear
that every case will tum on its own facts, but it might
help to assuage concerns for me to address directly the
three examples given by Hudgell who obviously represent
a large number of the applicants that is suggested to
ive rise to inconsistent decision making,
First, its alleged that there is a difference
between the level of reduction applied to shortfall
losses where there is an absence of paperwork. Hudgell
identify that as being between 10 and 30 per cent. We
don't say that reflects something requiring greater
guidance. The fact that is that a change or a
difference of the level of reduction simply reflects on
the particular facts of that case the Panel feels are
54
answer to that is each offer letter explains the factors
taken into account, for distress and inconvenience.
There is not a separate loss to be quantified but it's
‘a matter that goes into faimess of the offer overall
So, again, we say so far as the suggestion that greater
guidance is required, we say that that is not the case
and there is not a deficiency in that respect.
Can I move to other points that are not directly
linked to the first question but are raised in this
context. The first, and Mr Beer lagged flagged it up,
isin relation to late applications to the scheme. That
is after the closing date from November 2020.
In our May submissions we noted that the Post
Office was actively considering how best to address
those applications. At the time in 2020 the Post Office
went to very considerable lengths to bring the deadline
to the attention of all potentially eligible
postmasters. It extended the initial 10-week period for
applications by a further 15 weeks, which took it to
November 2020, to take into account both the numbers of
applications that had already been made and the Covid 19
situation pertaining at the time.
Nevertheless itis common ground that, for
whatever reason, a number of postmasters didn't apply at
the time and I can confirm that Post Office has now
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received as at today's date a total of 186 applications
made after the deadline passed.
Post Office remains keen to ensure and wishes to
ensure that compensation is delivered to everyone
affected and it is sympathetic to those who could not,
for justifiable reasons, apply to the scheme in time,
Itremains the case that itis considering how best to
deal with such applications
SIR WYN WILLIAMS: You can see that I'm pondering that,
Ms Gallafent
MS GALLAFENT: I can indeed, sir.
Sir, may it assist if I put itn this context: in
our May submissions we made very clear that we do not
act alone, that Post Office is part of a wider mechanism
of governance and one of the reasons for the delay in
relation to the HSS scheme itself more generally are
questions of funding, so we cannot act unilaterally, if
I can put it that like, So the position remains that we
are carefully considering the position and remain
committed to ensuring that compensation is delivered to
everyone affected.
SIR WYN WILLIAMS: Well, there are two aspects to that that
Iiljust float my thoughts about. One, the governance
aspect. It surprises me that an issue of this kind
Would take quite so long,
57
close at a pretty slow pace
MS GALLAFENT: Sir, I hear what you say.
Can I pick up then, before I move off from
question 4, can I pick up three further points not
directly related but relevant we say.
The first is an issue raised by Hudgell in
relation to independent legal advice. That is whether
it be more appropriate for the Independent Advisory
Panel to have its own independent legal advice rather
than offers being made on the basis of legal advice and
analysis prepared by Herbert Smith Freehils.
Post Office doesn't consider this would be
necessary. There are five Queen's Counsel on the Panel.
The Panels free to accept or reject the analysis and
advice given by Herbert Smith Freehills. As we
previously indicated in the May submissions, there have
been no cases where Post Office has offered an applicant
less than the Panel has recommended. That remains the
position to date.
Moreover, were the Panel itself to consider that
it wished to take independent legal advice, then it
would be open to it, to recommend to Post Office that
such advice be obtained at Post Office's cost. Just as
itis under section or paragraph 27 of the Panel's terms
of reference in relation to any other expert assistance.
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The second is should POL be the final arbiter of
this in any event? In effect, i's akin to a limitation
provision, though I accept that there are differences,
I am not going to press that. But in most scenarios in
which a time limit is applied in one way or another, it
might surprise someone to hear that the alleged
wrongdoer is the final arbiter of whether atime limit
should apply
MS GALLAFENT: Could I putt like this, sir: the terms of
reference for the scheme provided for a deadline which
was, of course, subsequently extended. That principle
was one of the principles that had been discussed and
agreed as part of the deed of settlement with
representatives of postmasters. So in principle the
provision of a deadline was common ground
We are not acting unilaterally in saying we will
not take in to account late applications. We are
considering and continue to consider how to ensure that
compensation is delivered to everyone affected
Its not that we have shut the door on those late
applicants. Can I assure you, si, of that. We
continue to aim to ensure that those applicants are
treated fairy.
SIR WYN WILLIAMS: Well, I think we can leave this with my
observation that the door is moving either to open or
58
For the same reason we reject the suggestion that
the current scheme is not independent in the light of
the clear independence of the Panel and the procedure
followed thereafter, and I emphasise again no
recommendation has been rejected by the Panel and
a lower offer made, and some offers have been higher.
The second of the indirectly related issues to
question 1 is the evidential question. The way it was
put in the written submission of Howe & Co was that i's
unreasonable for the scheme to require contemporaneous
evidence of events from up to 20 years ago, particularly
in circumstances where postmasters may have been
deprived of access to their records at the point of
suspension and they may have been destroyed by Post
Office
But we emphasise and, sir, as you have seen and
been taken to, the guidance on consequential loss makes.
it clear that contemporaneous evidence is not required
it is not a bar not to have it, but greater weight may
be placed on it as well as the factual evidence that is
undisputed or verifiable. That's what the guidance
says. Of course, where an application is concemed
about the Panel's approach to an alleged lack of
contemporaneous evidence, that's a matter that can be
raised as part of a dispute process
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That point is connected to the third point, which
is the sharing of supporting information held by Post
Office. This was an issue flagged up by Mr Beer as
well
Howe & Co have suggested that a procedural flaw in
the scheme is that the sharing of supporting information
held by Post Office won't be until the point of
receiving the offer. They say that's a substantial
procedural flaw.
Can I just highlight first, the terms of reference
that you have for the scheme at tab 14. I don't
believe, sir, you were taken this particular element of
it, at paragraph 6, so it’s page 283 internally,
paragraph 6 provides:
"Once an application has been made either party
may write to the other to request relevant information,
The parties shall cooperate with each other in providing
any other information which the other party may
reasonably request. Information obtained and provided
in relation to each application should be proportionate
to the circumstances of that application.”
So there is express anticipation that an applicant
saying to Post Office, "I need this. Please provide me
with this’, and Post Office can equally say of an
applicant, "Could you please provide the following
61
SIR WYN WILLIAMS: I tin the outcome letter.
MS GALLAFENT: Yes
SIR WYN WILLIAMS: I tis not in any prior guidance.
MS GALLIFANT: No
SIR WYN WILLIAMS: So its at that point
MS GALLAFENT: Exactly, so taking different stages, at the
point of the application paragraph 6 of the terms of
reference emphasises the opportunity for the parties to
ask for information from each other. Then you get to
the point of the outcome letter and that is where the
applicant is expressly told - there is alist of al
the contemporaneous evidence that Panel assessed and
its told that it can ~- the applicant is told what they
can ask for and obtain
SIR WYN WILLIAMS: Right.
MS GALLAFENT: Yes
SIR WYN WILLIAMS: Right. I am with you.
MS GALLAFENT: Thank you. We say there is not any prejudice
to an applicant as a result of disclosure not
necessarily having been made earlier, if it has not been
requested. Again, if the applicant feels that the
material has been misunderstood or is incomplete that
can be raised at the good faith meeting
Can I leave, subject of course to any indication,
sir, from you that you would like to us to do a little
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maters and documents", so that's the starting point.
The second point is that number of postmasters
have made data subject access requests prior to or
during the course of making an application and, of
course, there they will be provided with all data that
falls within that access request
Turning then to the outcome letter, the outcome
letter lists all contemporaneous evidence which the
Panel assessed to make the recommendation and it
expressly explains that the applicant can request a copy
of any or all of those documents and pieces of evidence.
Applicants can also request a copy of the Post Office
investigation report, the Herbert Smith Freehills legal
case assessment, and a record of the Panel assessment
and recommendation.
Al of this data is provided in order to support
the applicant's consideration of the offer and, of
course, having considered it the applicant is free to
accept or reject the offer, following which a good faith
meeting can be held and, if necessary, disputes can be
escalated thereafter.
SIR WYN WILLIAMS: Sorry, this is my fault, but this
information about the documentation which an applicant
can obtain
MS GALLAFENT: _Is set out in the outcome letter.
62
bit of analysis and data collection on the question
of ~
SIR WYN WILLIAMS: Well I think I wll say now that rather
than going along trying to listen to you and formulate,
in inverted commas, rules and requests at the same time,
what may happen ~ and I stress may ~is that if there
is any data that I require from any party before I make
‘a written report in whatever form itis following these
hearings I will do it in writing after the hearings
rather than trying to do it as we are going along,
MS GALLAFENT: I certainly wasn't suggesting that, sir. If
you were to indicate that you would be open to the
provision of such data then we will crack on with that
and get that ready. But I'm certainly not anticipating
that you need to, as it were, tell me precisely what you
would like at this stage. It might be more helpful,
frankly, for us to provide you with an indication and
then it might assist you in understanding what more or
less you would want from us.
SIR WYN WILLIAMS: Well, as you know, Ms Gallafent, people
write to me at all times of the day or night in this
Inquiry providing me with information. Far be it for me
to stop you from doing the same.
MS GALLAFENT: We shall endeavour to do it perhaps a litte
eartler in the day on the next occasion, sir. Thank you
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for your patience with us.
Can I move then to the second of the questions
posed, sir, in relation to delay. I'm not going to seek
to repeat the explanation set out in the May submissions.
about the process between setting up the scheme and the
position reached by the time of those submissions.
You have our submissions on delay and I'm again
conscious, sir, of your indication in the note of
30 June that you have those well in mind and don't
require us to go through them again
I do though want to flag up the continuing
progress being made since those submissions which
demonstrates, we say, a clear and continuing positive
trajectory towards resolving all current applications
Now, we provided an update in the late night note, as it
may become referred to, yesterday but in fact as of
midnight yesterday I can confirm that further letters
have been sent out during the course of yesterday, which
take the number of eligible applicants who have been
sent offer letters up to 1,659 out of 2,370, which takes
Us to us a 70 per cent rate of offers from applications
SIR WYN WILLIAMS: So I'm trying to make a note on the
relevant pages of my bundle, so this all starts on
page 302 and then goes over to page 303. That was as at
7 June I think it was. Then Mr Beer gave me further
65
applicants with offer letters by the end of this
calendar year. You will see that again on page 302.
To date 115 applicants have formally engaged the
dispute resolution process. 31 of those, 27 per cent,
have now reached agreement on the amount of
compensation. Good faith meetings have taken place with
47 applicants, escalation meetings with seven
applicants, are there are a further 11 good faith
meetings scheduled for the coming weeks.
On delay there are a couple of particular points
raised by other core participants. The first is raised
by the National Federation of Subpostmasters who have
suggested it would be justifiable, sir, for you to ask
whether the non-renewal of a contract of the previous
head of historical matters resulted in there being
a significant period of time during which no individual
was responsible for driving the scheme forward.
The position is that the fixed term contract for
the previous head of historical matters ended on
23 July 2021. Prior to that, in May 2021, the
Government had announced that this Inquiry would be
moved on to a statutory footing. Asa result, the Chief
Executive Officer of Post Office, Mr Read, revised the
structure of the then existing historical matters team
to ensure that Post Office was appropriately set up to
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figures based upon what your statement said last night.
MS GALLAFENT: Yes, that was at the end of June.
SIR WYN WILLIAMS: Now we're getting up to midnight on
July 5 oF 6, whichever you prefer. Is that it?
MS GALLAFENT: That's exactly it
SIR WYN WILLIAMS: Fine, right, so if you tell me that
I will make a note on this document
MS GALLAFENT: 1,659, which takes the percentage of offers
to eligible applicants to come to 70 per cent.
SIR WYN WILLIAMS: All right
The figure that Mr Beer gave me, obviously, for
payments made is the same today as it was last night, so
I don't need to worry about that.
MS GALLAFENT: Yes
SIR WYN WILLIAMS: Right.
MS GALLAFENT: They would have been very speedy indeed if
they'd accepted it. Exactly.
You may note, just going back to page 302, of
course the information on progress and the anticipated
rate of progress to get us to 95 per cent by
December 2022 provides that the target was to reach 70
per cent by the end of July. We have actually reached
it(on 5 July which is why I emphasise a clear and
continuing positive trajectory, and Post Office remains
on course to provide at least 95 per cent of eligible
66
assist the Inquiry. That then resulted in
Mr Racaldin(?) becoming Historical Matters Director in
January 2022
However, in that period during which there was no
longer a head of historical matters before Mr Recaldin
took up his post the historical matters team continued
throughout to focus on matters arising from the group
litigation including the Historical Scheme.
We wouldn't accept that any delay arose as
a result of the reinstructing of Historical Matters
Scheme which was considered necessary and appropriate to
anticipate the needs of this Inquiry.
As I say, we've set out the reasons for the delay
in our May submissions and I don't repeat them here.
Hudgell also flags up the issue of bankruptcy
cases. We recognise and agree that bankruptey cases are
extremely complicated and may well take longer to
resolve. We are actively working to resolve the
challenges posed by such cases, including the issue of
the costs of the Official Receiver or
Trustee-in-Bankruptcy. In the meantime, Post Office
expects that the fist offer will be made to an
applicant in a bankruptcy case in the coming weeks.
Finally, Howe & Co have raised the case, and it
was identified by Mr Beer in his opening submissions, of
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Mr Sethi who of course was the first witness to give
evidence before you, sir, in the human impact hearings.
If the Inquiry were to consider it helpful and if
Mr Sethi were to consent we would be happy to provide
the Inquiry with a full timeline of the processing of
his application. But for today it may suffice for me
just to note that his application is one of the
particularly complex ones which has raised a number of
procedural issues in terms of representation
So far as the request for information that he
received shortly before he gave evidence is concemed,
for the avoidance of any doubt, the timing of that
request was in no way connected with the fact of his
giving evidence. Rather, it reflected that his
application had reached the request for further
information, that is the proactive request for
information designed to elicit further information,
particularly in relation to consequential losses stage
of the process.
Mr Sethi helpfully responded at the end of March
and his responses are currently being considered under
the scheme in the usual way.
Finally, there is a question of tax implications.
Itis not raised again in relation to the delay. But in
this context we have been asked to confirm what
69
of enabling an applicant to consider an offer made to
them, or £400 where the offer is to pay the applicant's
claim in full or largely in full. So far as we are
aware no request for a contribution for legal advice has
ever been refused. So the figures that you have seen of
the number of contributions made we say reflects the
number of request received
We do not consider that the absence of any
contribution to legal fees towards the making of the
application is itself unfair or inadequate. That's
suggested by Howe & Co.
This scheme has been designed to be simple and
user friendly, to avoid the need to incur such costs, as
set out in our May submissions. That's paragraph 39 for
your note.
In short, guidance is available to postmasters to
assist them in preparing an application. Sir, you have
seen a number of elements, key elements, of that
guidance.
Secondly, there is a presumption that a shortfall
was caused by a previous version of Horizon or a breach
of duty by Post Office in the absence of evidence to the
contrary
Thirdly, Post Office has agreed not to take any
limitation defence in relation to claims brought under
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provisions we have made for dealing with tax
implications on certain pecuniary heads of loss. That's
a request by Hudgell that it made in relation to
question 2.
i's common ground that shortfall compensation
does not attract tax, but Post Office is obliged to
deduct tax for the other heads of compensation. It does
so at the basic rate of 20% in accordance with the
Income Tax Act 2007 section 874, which as is explained
in outcome letters may result in POL, in Post Office,
deducting less or more tax than the applicant is
actually liable to pay.
Post Office notes that its the applicant's
responsibilty to ensure the correct amount of tax is
paid and that they may want to seek independent tax
advice, and the letter also points applicants towards
resources they might look to for further information on
this particular issue. In these circumstances, Post
Office does not consider it necessary or appropriate to
offer any indemnity for scheme applications
The third issue, if] may move on to the third
question, sir, in relation to independent legal advice.
Its availabilty. The Inquiry is obviously well aware
the scheme provides for a contribution currently of
£1,200 towards the cost of legal advice for the purpose
70
the scheme
Fourthly, as I have already identified the Panel
and case assessors act proactively to obtain further
information from applicants where appropriate
‘Again, sir, as you are also well aware, the Panel
has a full discretion take into account any facts and
matters which it considers will produce a fair result on
the facts of each particular case, including but not
limited to applicable legal principles.
‘As we set out in our further note and as Mr Beer
emphasised as well as paying applicants the contribution
towards legal fees at the offer stage, it has also paid
contributions towards costs incurred by applicants prior
to them receiving a compensation offer in two cases, for
example, in relation to the costs of providing medical
records in support of a claim for personal injury.
So far as the Post Office phase is concerned, Post
Office does recognise that there may be some cases in
which the current provision may be insufficient to
‘support an individual applicant to resolve their claim,
Itis currently considering whether contributions
towards further legal or other professional costs can be
made available to applicants to help resolve their
claims. We will obviously update the Inquiry as soon as
a decision has been reached on this issue.
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SIR WYN WILLIAMS: I mean, the impression I get and I do not
want to say this in any flippant sense, but many of the
offers which have been made and accepted are
comparatively easy to resolve. One is now getting to
the stage where there are likely to be much more
significant dificulties in resolving the applications.
MS GALLAFENT: Yes, and for the reasons we set out in the
May submissions that was because of the approach adopted
to the scheme by dealing with what we would characterise
as low value claims, and those were the ones that were
dealt with first. So the low value claim is a claim for
a shortfall up to £8,000, in some cases a claim for
distress and inconvenience, but not al, but not for any
other form of consequential loss,
So those block of cases were, I would entirely
agree, sir, they were on their face simpler to resolve
because of the presumption in relation to shortfall and
because of there being no issue in relation to
consequential loss apart from distress and
inconvenience
It may assist, sir, ifI then deal perhaps with
the statistics, because Howe & Co also suggested that we
should provide you, sir, with the percentage of
applicants who were and were not represented at the time
of the application, and the same percentages in relation
73
MS GALLAFENT: Ten of them were lower value claims. That's
my lack of articulacy, I apologise. I'm standing too
far away from the microphone, ten.
SIR WYN WILLIAMS: I'm busily writing a note, even though
Ihave a contemporaneous transcript. It's the habit of
allfetime
MS GALLIFANT: tis, itis. I'm grateful, thank you.
I hope that provides some context in which the
otherwise quite bald figures of representatives being on
record and contributions being made, as to why perhaps.
those figures are not quite so straightforwardly an
indication there has been any form of inadequacy when it
comes to legal costs at the point of offer.
Can I move to question 4, which is interim
payments. Its been suggested by Howe & Co that the
scheme should make provision for interim payments in all
cases, and it's unacceptable for Post Office to be able
to decide to whom such payments should be made. Itis
not clear whether that suggestion is made in the context
of pre offer interim payments or post offer payments.
Can I address each of those in turn.
‘As Mr Beer indicated, payments have been made on
an interim basis, prior to an offer being made, to those
applicants to the scheme who Post Office understood to
be in difficult circumstances who could be iremediably
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to accepting offers under the scheme. It is suggested
itis instructive to examine the level of offer or award
made to unrepresented applicants as opposed to
represented applicants.
The position as at midnight yesterday is 1,300
applicants have accepted settlement offers. Of those,
two applicants had legal representation. 92 applicants
have rejected settlement offers and of those 13
applicants had legal representation. Can I put some
context on those statistics by virtue of the question of
low value claims, sir, that I was just alluding to.
Of the 1,300 accepted offers, ust over half of
them, 678 for precision, were claims for shortfalls up
to £8,000 and no consequential loss, so potentially for
distress and inconvenience.
Of the 92 rejected offers ten of them were those
types of claims, what we have characterised as lower
value claims. So, sit, you anticipate entirely
correctly, which is there are more as it were rejected
offers where itis not a lower value claim
proportionately but there are roughly half and half when
it comes to acceptance of offers
SIR WYN WILLIAMS: Sorry, can you repeat that? Of the 92
rejected, on the [draft] transcript in front of me, the
number has not come up after that.
74
impacted by the time necessary to fully assess their
claim and make a fair offer. To date, 28 such payments
have been made, that includes circumstances of severe
financial hardship, terminal illness, risk of personal
hardship, and old age, where concerns have been raised
about the impact of the speed of progress on the
applicant. Some of those concerns have been raised by
the applicant. Others have been raised within Post
Office and a proposal for an interim payment made on
Post Office's recommendation
Where such appointments are made, itis expressly
explained to the applicants that they would not need to
repay any of the interim payment in the event that the
final offer is made for less, or that accepting an
interim payment would in anyway adversely impact their
claim. It wouldnt.
So far as the position post offer is concerned,
other than potential hardship interim payments, Post
Office's priority is to seek to resolve applicants
claims ina manner which is fair in al the
circumstances of the case.
That will we say typically be achieved by reaching
full and final settlements with the applicants rather
than on a piecemeal basis through interim and part
payments. As I have indicated at this stage offers have
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The Post Office Horizon IT Inquiry
been made to over two-thirds of applicants and of those
accepted by 80 per cent of those applicants
There is a structured and clear plan to work
through the dispute resolution process with those who
formally engaged it and to provide, as I've indicated,
at least 95 per cent of applicants with offer letters by
the end of this year.
ur position is it would be an unhelpful
divergence of resource and cost to set up some form of
sub-scheme within the Historical Shortfall Scheme by
which applicants could then apply for and interim offers
be made to them other than on hardship grounds
An additional factor for not making interim offers
is that the approach under the scheme is to reach an
overall offer, as you have heard me say on a number of
occasions, rather than break down the offer by
individual heads of loss. As already indicated it's
made on a number of applicant-friendly presumptions,
such as the presumption that a shortfall loss was caused
by Horizon. These presumptions would not apply were it
not possible to resolve the claim without the applicant
going to court. In that situation, its entirely
possible in principle that a postmaster would not obtain
compensation in the same sum as the offer, which offer
of course is built on those applicant-friendly
7
IR WYN WILLIAMS: I think my view is simply this,
Ms Gallafent, if you were to complete your submissions
within say 25 minutes that might be preferable, but if
that's not possible we'll have a break whenever it suits
you.
MS GALLAFENT: No, I'm confident I can do that.
‘SIR WYN WILLIAMS: Let's carry on until the end then.
MS GALLAFENT:
Before we do, just a variation on the theme of
interim payments, which I don't think you touched on.
‘The suggestion - and this might become more
a possibilty as the more complicated cases are dealt
with ~-that interim payments may be made about agreed
sums, not whether they need them, just if agreed, let's
get it over with and only discuss what's not agreed.
Have you got anything to say about that?
I do because that's goes back to the factor
I mentioned in relation to the applicant-friendly
premise of the offer. So when its an agreed offer, it
will be made on the basis that, you know, the shortfall
of (unclear) Horizon, no limitation, et cetera. So
again its a slightly different position to the position
under the final scheme or the interim or final scheme
for postmasters with quashed convictions, because
there's no such presumption. The approach under section
B, which I will come on to, is simply that the ordinary
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principles, and therefore potentially not in the same
‘sum as any interim payment which might have been made.
So we say that the position under the scheme is,
significantly different from the approach to interim
payments in relation to postmasters whose convictions
have been overturned when its considered by Post Office
and BEIS that all such persons were likely to receive
greater sums than the up to £100,000 in due course for
their claims.
‘As for the suggestion that it should not be Post
Office which decides when an interim payment should be
made, were an independent body such as the Panel to
determine such requests, there would inevitably be some
further delay in the process for applicants generally,
in order to accommodate such cases going to the Panel
not once but twice. In those circumstances, we do not
accept that the absence of an express provision for
interim payments under the scheme is unfair or
inappropriate
Sir, 'm going to move now to section B dealing
with final compensation for postmasters with quashed
convictions. I note the time. I am very happy to press
on with section B then I have very little to say on C
and a couple of other points, but if you would prefer me
to break now and come back --
78
principles apply to compensation. Here the ordinary
principles do not apply, so that's why you might be able
to agree in principle a particular element ofthe offer,
say the shortfall or some element but I emphasise again,
offers are made in the round, so you might be able to
agree in principle and say, well, we accept this or
that, but it wouldn't follow that then were there to be
no agreement overall, that the applicant would actually
obtain through civil ligation a sum anything lke the
amount that’s been offered based on the
applicant-friendly principles. So I do say it raises
very different and difficult questions that simply are
not there in the scheme in relation to ~ sorry, the
mechanism used in relation to postmasters with quashed
convictions.
‘SIR WYN WILLIAMS: All right. I will think about that.
MS GALLAFENT:
I thought you might.
Section B then, final compensation for postmasters
with quashed convictions. Mr Beer also emphasised and
we say itis important to emphasise as well. There is
no formal remediation scheme such as that established by
the Historical Shortfall Scheme for the payment of
compensation to such persons. All claims are being
dealt with through without prejudice negotiations. We
say that is an important distinction, because a number
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The Post Office Horizon IT Inquiry
of the submissions made by other core participants are
predicated on a scheme approach,
I's also important to emphasise that as at
3 July, Post Office has only received a total of six
largely fully quantified claims. So that’s where we are
in terms of final compensation
So far as the principles to be applied to the
calculation of final compensation payments are
concerned, some of those representing postmasters have
suggested that BEIS and/or ourselves should be invited
to clarify the approach to the general principles in
play in assessing liability and quantum.
I can confirm that Post Office agrees with Hudgell
Solicitors that the value of any individual claim must
be calculated applying the ordinary principles
applicable to the recovery of civil damages for
malicious prosecution. We also agree that such damages
may include aggravated and exemplary damages.
Mr Beer has already alluded to it but in applying
those principles its the issue of non-pecuniary damages
that’s proved particularly damaging in the negotiations
to date, There is case law in this area which indicates
what likely awards may look like but the current
circumstances of the particular postmasters involved are
unique, we say.
8
parties reaching an agreed resolution on the
non-pecuniary aspects of those claims and we hope that
that guidance may also be of wider use
In this context its also important for me to
‘emphasise that in no circumstances will Post Office be
the final arbiter of individual claims. That's
a suggestion made by Hodge Jones & Allen. If the
parties cannot resolve the claims themselves, whether
with the involvement of early evaluation, mediation, or
some other process, then the final arbiter of individual
claims will be the court. But would I would lke to
‘emphasise that Post Office remains wholly committed to,
seeking a negotiated outcome to all claims to avoid that
outcome if at all possible.
We also note the suggestion made by Hodge Jones
& Allen that the settlement deed is flawed, insofar as
it mits GLO claimants to claims of malicious
prosecution. It should be amended
Paul Marshall goes further. He argues and says
there are prima facie grounds for the view that Post
Office secured the settlement deed as a result of
misleading the claimants and the court. On that basis,
he and Hodge Jones & Allen seek to argue the approach to
the calculation of direct and consequential loss should
be carried out by reference to the approach to claims in
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Itis in order to find a way thorough that issue
that we agreed with a number of former postmasters
represented by Hudgell Solicitors that the issue of
non-pecuniary damages should be referred an early
neutral valuation. That of course is an expression of
a view on the likely outcome if the matter were to go to
court.
We emphasise that the fact that the process is,
without prejudice and is confidential allows a more open
and less formal process in that respect. We're very
grateful that the very eminent senior judge Lord Dyson
has agreed to act as the evaluator for that process. It
is anticipated that the evaluation will be concluded by
the end of this month.
The outcome is not of course binding on the
parties. But itis hoped that itwill allow these
issues to be resolved quickly.
We are also and separate to the early neutral
evaluation continuing to progress without prejudice
negotiations in relation to the first of two fully
quantified claims from the total of six that we have
largely quantified. Good progress has been made on
pecuniary loss claims to date. We anticipate that the
early neutral evaluation process to be conducted by Lord
Dyson will provide guidance that will facilitate the
82
fraud
I note Mr Beer didn't reference to this in his
‘opening, and I anticipate that's for the same reasons
that we say is simply isn't open to you, sir, to
consider it at this point. It goes way beyond the issue
identified in your invitation, which is the principles
that are being applied to the calculation of final
compensation payments, rather than the principles which
some of those representing postmasters suggest should
be.
It also doesn't appear to fall within the scope of
the Inquiry's Terms of Reference, but even were the
Terms of Reference to be amended in some way, itis,
obvious that any such argument could be not be fairly
considered far less in some way any view given on it at
this point of Inquiry, prior to the Inquiry having heard
or considered any of the evidence in relation to the
conduct of the group litigation. That's a matter also
due to be heard next spring
For the avoidance of any doubt, Post Office would
emphatically refute any suggestion that it behaved in
a fraudulent way or misled the GLO claimants or the
court in resolving those proceedings. The teims of the
settlement deed were negotiated and agreed in good
faith. But we do emphasise we say at this stage that
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one simply cannot consider or reach any view on those
submissions made by Mr Marshall and Hodge Jones & Allen
in that context.
On the question of disgorgement which is raised by
Mr Marshall and Hodge Jones & Allen again, they have
raised the issue of the inclusion of sums received by
Post Office by way of compensation or confiscation post
conviction as being included as direct and consequential
losses. I can confirm that claimants can claim any sum
Post Office received through post conviction orders for
compensation of confiscation as losses directly
connected to their wrongly conviction, so that is
claimable
Moving to the mechanisms by which final
compensation payments are being calculated, to an extent
‘our response here overlaps with the question as to the
principles being applied, but three discrete issues have
been raised in this context.
First, Howe & Co have suggested that BEIS should
undertake - will undertake -- sorry, that BEIS should
undertake, that itwill undertake not to seek to claw
back any interim payment made to a postmaster. This is
a subject on which Post Office has been very closely
engaged with HMRC and we confirmed in our late night
note from yesterday that as of yesterday we had received
85
of a postmaster’s reasonable costs as part of the
negotiations.
Question 8 is about procedures adopted to resolve
disputes about the valuation of final compensation
payment. I have already highlighted in particular the
early neural evaluation process. But Post Office
remains open and supportive to the use of further such
processes or other alternative dispute mechanisms to
resolve other disputes in due course
SIR WYN WILLIAMS: Ms Gallafent, when Mr Beer was addressing
me, he suggested that I might wish to probe with the
representatives of this category of claimants to what
extent I should involve myself at all. He put it rather
more elegantly, I should butt out of it perhaps
MS GALLAFENT: He did
SIR WYN WILLIAMS: What's the Post Office view about that?
MS GALLAFENT: Sir, in response to the questions that you
have raised, our position is that there is no need for
you to intervene on those points. There is nothing that
would give you concem from what we have told you about
the concems that have been raised by the other core
participants, so that's our position
SIR WYN WILLIAMS: Fine, allright.
MS GALLAFENT: The other position though that's ~ the other
issue is the role of Post Office and this again it is
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confirmation from HMRC that the removal of the claw back
provisions will not affect the tax status on which the
payments are made. We wrote yesterday to all claimants
to communicate the position of HMRC iin this regard, so
that concern has been assuaged
Secondly, itis suggested that any disputes should
be referred to independent arbitration within an
appropriate arbitration scheme. That's also Howe & Co.
If particular representatives wish to raise that
option with Post Office they are obviously free to do so
and Post Office can assess with those claimants the best
way to resolve the cases. For example, arbitration or
early neutral valuation or mediation or even litigation
potentially were it to be regarded as being relevant for
precedential value.
Thirdly, Mr Marshall has suggested that Post
Office should make available to claimants data that it
holds on employees’ pay bands over time. I can confirm
Post Office already proactively offers and provides,
subject to the provision of necessary data protection
consents, the remuneration data that it holds to
claimants with quashed convictions.
Question 7 is the provision for applicants to
obtain independent legal advice. As we indicated in our
May submissions, Post Office will consider the payment
86
not a point flagged up by Mr Beer in his opening
therefore I anticipate it may not be a point that you
deal with directly, it's the role of Post Office in the
resolution of these claims
In their initial submissions Hodge Jones & Allen
submitted that what was required was a transparent
process operated by BEIS working with Herbert Smith
Freehills. In an annex they now argue that Post Office
should terminate its continuing retainer of Herbert
‘Smith Freehills and they say Herbert Smith Freehills
should be retained by BEIS with a consequential set of
agreements about duties of confidence and the like owed
to Post Office. So they say that Herbert Smith
Freehills would be retained by BEIS for both final and
further compensation claims. Further, by which I mean
you have identified in category C fair compensation
claimants
This argument again goes well beyond the
questions, sir, set out in your invitation and,
arguably, again beyond the Terms of Reference of the
Inquiry, but without prejudice to the position can
I make it clear the Post Office immediate view is there
is no justification at all for any such recommendation,
So far as final compensation for postmasters with
quashed convietions is concerned, itis clear we say
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from the information updates provided, that Post Office,
represented by Herbert Smith Freehills, is acting
promptly and reasonably in its approach negotiating
settlements with those that have brought fully
quantified claims and there is no reason to doubt that
it will continue to do so.
Certainly, we'd submit that the inherent and
obvious complications with any such rearrangement in
terms on legal representation and the entity with whom
negotiations take place, would very considerably
outweigh any perceived benefit, particularly in terms of
the speed of resolution of the claims.
Finally, can I just deal then with final
compensation, in that context where its suggested that
Post Office shouldn't be involved, Post Office has made
it clear that it has not been asked by Government to
deliver this type of compensation. This is, sorry, the
further or fair compensation. But it will of course
cooperate to the fullest extent possible with any scheme
‘or mechanism set up for that purpose and any request for
support from Government in that matter. So we say it's
wholly premature to raise any issue as to Post Office
involvement in any further or final compensation scheme
‘or mechanism.
As for that scheme or mechanism, as I indicated at
89
category 3 are concemed, so those are as it were the
public interest quashed convictions, paragraph 28 of
your provisional view, you indicated that faimess
demands that Post Office should not be the final arbiter
of whether an interim or a final payment should be made
to those postmasters.
Neither announcement by the Minister, neither the
December announcement nor the July announcement on
interim compensation, neither of those resulted in the
establishment of a remediation scheme such as HSS, so
ultimately the question of whether or not compensation
is payable falls to go to the court.
I confirm in the event of any dispute over payment
of compensation, whether on an interim or final basis,
POL, as with the scheme more generally, remains willing
to engage in mediation, arbitration, other forms of
alternative dispute resolution, to avoid if possible any
applicant having to bring civil proceedings.
I can also confirm that Post Office legal
representatives continue to liaise with the
representatives of the three named potential category 3
claimants set out in your provisional view on the
subject of whether they are or are not entitled to
compensation. Sir, we say that in no circumstances
would we be the final at arbiter.
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the outset, we leave it to BEIS to address the Inquiry
on those matters but, of course, if there is any issue
arising following BEIS's submissions next week on which
the Inquiry would like to hear from us then we're very
happy to do that in writing after the hearing next week.
Of course, more generally we're very keen to
ensure that we listen carefully to the points to be made
by other core participants who follow us later today and
next week and we will seek to pick up any further
matters which we consider we haven't already adequately
addressed so we can offer clarification or assistance as
soon as possible thereafter.
Finally, and very briefly, can I deal shortly with
your provisional view on compensation issues relating
prosecuted subpostmasters. Just for the avoidance of
any doubt we can confirm, as set out in your document on
compensation issue dated 9 May, we agree with your
provisional views, subject to two points. The frst is
we do not seek to make any submissions on BEIS's
position that persons in categories 1 and 2 were
eligible for claims for compensation under the December
announcement, that is predating the subsequent March
announcement. We have seen what BEIS says on the
subject. We don't say anything about that.
Secondly, so far as persons falling within
90
I.am going to glance over just to check that those
sitting behind me and behind me behind me, as it were,
have nothing further to add.
I.am very grateful. Those are our submissions.
As I said, we stand ready to assist in any other way we
can on these subjects.
SIR WYN WILLIAMS: Thank you, Ms Gallafent.
Allright. It's ime for another break. Can
I ask just ask Mr Mertens because I think you are next,
some kind of rough time estimate?
MR MERTENS: Very short, it will be five or ten minutes.
SIR WYN WILLIAMS: Right. Well, Mr Stein, Mr Enright
predicted you wouldn't need a full two hours and I will
ssay no more than that.
MR STEIN: Thank you, sir
SIR WYN WILLIAMS: Because of the likely timings this
afternoon it is now 1.08, according to this wonderful
machine I have in front of me, so I think we'll start at
2.05 and then we should finish comfortably before the
cricket begins. Thank you.
(1.40 pm)
(Luncheon adjournment)
(2.07 pm)
SIR WYN WILLIAMS: Yes, Mr Mertens.
Submission by MR MERTENS
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MR MERTENS: Good aftemoon. May I first ofall thank the
Inquiry for having been given the opportunity to provide
written submissions in relation to today's issues and
also for being given the opportunity to address you
briefly today. I make these submissions on behalf of UK.
Government Investments who I will refer to as UKGI
As indicated in its written submissions, UKGI is
very grateful to the Inquiry for being able to attend
and participate in these hearings concerning issues of
compensation to subpostmasters and others. It
recognises that the issues that you have identified are
very important issues for the Inquiry to examine now,
and it's ready to work with the Inquiry to assist in
anyway that it can,
UKG's role in relation to these issues is, as
described in our submissions, one of assisting BEIS with
its oversight of various of the arrangements that have
been put in place and providing challenge to POL on its
delivery of those arrangements, both at official level
and through the attendance of the shareholder
non-executive director on the Post Office board and
relevant subcommittee. It seeks to fulfl those
functions in ight of the clear objective of achieving
{ull and fair compensation delivered as promptly and as
effectively as possible.
93
bundle for today at tab 13
UKGI's role in supporting BEIS is also reflected
in BEIS's written submissions for these hearings and, to
the extent that they bear on UKGI's role, it notes and
endorses their submissions
UKGI, nevertheless, recognises that there is an
urgent and ongoing need to examine rigorously the
operation of the compensation arrangements in light of
the submissions of some of the Core Participants that
have been received, and of any interim conclusions which
the Inquiry may now decide to express in a report or any
other update following these hearings. Thank you for
the opportunity to address you.
SIR WYN WILLIAMS: Thank you, MrMertens. For those who may
not be as familiar as others with the aim and object of
these hearings, can I say in respect of UKGI that I'm
grateful for their explanation of their role and, for
present purposes, that is sulicient for me. But when
it comes to phase 5, I think itis, when there will be
‘a more detailed examination, including evidence, then
I would expect that UKGI would have a significantly
greater role.
MR MERTENS: Yes, of course.
SIR WYN WILLIAMS: Thank you.
MR MERTENS: Thank you very much
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Since the hearings began on 14 February, UKGI has
followed the Human Impact Hearings and Focus Groups
closely. It's been concerned to hear in many of the
aceounts that have been given, which are now reflected
in some of the submissions that the Inquiry has received
for these hearings, that compensation is not being
delivered effectively.
UKGI wants to ensure that it has as full an
understanding of these issues as it can so that it can
fulfil its functions most effectively. UKGI has
therefore referred each of the written submissions for
these hearings with care. It now attends these hearings
today and next week for the principal purpose of
listening, listening so as to hear clearly the
submissions made on behalf of all Core Participants,
including the responses that POL gives to the issues
that have been raised by others. In that way, the views
expressed by all concemed can be taken into account in
UKGI's delivery of its function of supporting BEIS, both
in terms of oversight and of challenge
As indicated in UKGI's written submissions,
additional detail concerning its involvement in the
compensation issues and arrangements have been set out
in the Government's response to the BEIS Committee's
report on Post Office compensation, which appears in the
94
‘SIR WYN WILLIAMS: The floor is yours. Mr Stein.
‘Submission by MR STEIN, QC
MR STEIN: Sir, good afternoon. Sir, as you know, I appear
with Mr Jacobs instructed by Howe & Co Solicitors.
Together we represent 153 subpostmaster,
subpostmistresses and Post Office manager Core
Participants involved in this Inquiry
Al of our clients have had lives devastated by
this scandal. All of our clients have had lives that
have been badly affected by the scandal. Within our
client group, we represent GLO litigants and I'lljust
explain that, so that we all understand what I mean. If
I refer to "GLO litigants" that means the individuals
that were part of the group litigation that took this.
matter and broke this scandal by taking that action at
the High Cour.
We also represent those threatened with criminal
action, those who were wrongly convicted, those who were
cautioned, those threatened with civil cases, and those
who are hounded by the Post Office to pay sums of money
for which subpostmasters were not at fault.
So you will recall through the evidence that has
been heard through the Human Impact Hearings that each
one of our client families have been affected, their
partners affected, their children's lives affected, and
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The Post Office Horizon IT Inquiry 6 July 2022
generally the family ife of those individuals derailed
by the actions of the Post Office, Fujitsu and BEIS.
So we have considered your statement of 30 June of
this year where you have stated that once you have heard
oral submissions, you will make a determination as to
whether to proceed to an interim report pursuant to
section 24(3) of the Inquiries Act 2005 or provide a
non-statutory progress update.
Can we strongly request that you issue an interim
report. Itis our submission that it will be important
you, sir, as the Chair of this Inquiry, having heard the
evidence from those people that have given evidence
before you within the Human Impact Hearings, having seen
all of the written representations that have been made
by the various bodies and institutions, to make findings
as to the position reached in relation to compensation
But the other value of an interim report will be
that within that report you can set out your
recommendations, recommendations which you will then be
able to consider and review during the lifetime of the
Inquiry
Now, we know the background to this. In relation
to the GLO litigants, itis that they played a crucial
role in exposing the Post Otfice Horizon scandal. We
also know that in 2019 much of the monies paid over as
97
would consider them, please, in such part of your
recommendations as you would be prepared to consider.
SIR WYN WILLIAMS: Mr Stein, will you give me those in
slightly slower fashion because, for whatever reason,
I'm not getting a simultaneous transcript now. I want
to make a careful note of what you are saying.
MR STEIN: Sir, not only will I do that but we will also
undertake to provide it in writing so that you have
those set out
There are six individual points that we ask you to
consider making. Firstly, that significant interim
payments are made immediately to all of those
subpostmasters who are outstanding,
Point 2, that as regards the recent press release
from BEIS that they are making available 19.5 milion as
an interim payment fund, that you, sir, are provided
with the principles to be used for the distribution of
these funds amongst the GLO litigants. Sir, that would
allow you to consider the faimess of payments amongst
the litigants and make any recommendations as may be
required
Point 3, that faimess demands that the
Post Office should not be the final arbiter of whether
an interim or final payment should be made in
compensation claims made by any individual in categories
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part of the settlement were swallowed in legal costs,
and we also know that the settlement described in its
terms a reference to "tigation funders". So itis
very clear that the Post Office has known for some time
that a lot of the money that would otherwise have been
paid over in a settlement was never going to go to the
GLO litigants. One of the points that we make,
therefore, in relation to this is the delay that has
taken place.
We have heard obviously on 22 March the Minister
announcing that additional funding would be made
available to give those in the GLO Compensation Group
compensation that is similar to that which is available
to non-GLO group members. One of the findings that we
would ask you to make, though, is this, that sinee March
of this year not one GLO group member has received any
compensation.
We do say that there has been obfuscation and
delay in dealing with these matters as should have been
appropriate by essentially what is @ public body: the
Post Office. We know itis privatised but itis owned
by the Government. Therefore, an interim report setting
out recommendations would provide a target list for the
Government and for the Post Office to then follow.
We ask for the following points to be made if you
98
in A, Bor.
Point 4, that BEIS should make provision for
reasonable legal costs all in stages of compensation
applications in all three categories that you have
identified, and that claimants are provided with proper
acoess to disclosure at all stages.
Point 5, that of the principles that you have
‘sought to discover for all compensation schemes, or
proposed schemes, there needs to be transparent and
disclosed settled precedents and comparables, allowing
for legal advice to be given to the Post Office's
Victims at their individual category of claim and
expected financial outcome
Finally, at point 6, a timetable be set out for
the establishment of the GLO Compensation Scheme capable
of being monitored and followed by all those involved
SIR WYN WILLIAMS: Can I just be clear with you, Mr Stein.
That last point, point 6, is clearly related solely to
I will cal them the GLO claimants. You call them GLO.
Point 1 to 5 apply to all categories, so that Im clear,
A,BandC.
MR STEIN: Sir, yes.
SIR WYN WILLIAMS: A,B and C, 1 to 5, 6 is specific to GLO.
MR STEIN: Sir, yes.
SIR WYN WILLIAMS: Okay.
100
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MR STEIN: Sir, we recognise, as has already been made in
passing comment this morning, this is not a court. This
is not the High Court. Your powers are limited to
making statements, recommendations, and putting forward
findings. Itis, though, nevertheless possible for you
to set out what you would regard as being within the
range of reasonable responses that could be made by
setting out a timetable and, of course, that can then be
reconsidered if there is any attempt, if you lke, or
any suspicion that such a timetable is not being
followed. It would be an indication, in other words.
The reason why we say that such recommendations
are required is because, in our submission, the approach
of the Post Office and BEIS to compensation replicates,
past behaviour. We suggest that what is happening is.
that the Post Office is continuing to attempt, and
actually succeeding, in siloing subpostmasters, keeping
them ignorant of what is happening in relation to
compensation claims as regards to one to another. There
is a limitation being provided on access to full egal
advice. The onus of proof point has been made already,
but the onus of proof point is that despite the fact
that many Post Office business papers and accounts were
removed, or over the years have gone, that the burden of
proof is nevertheless placed upon the applicants within
404
assistance.
The interim report that we ask you, sir, to make
does not relate to recent events. The Post Office and
its sole shareholder (the Department for Business,
Energy and Industrial Strategy, BEIS) which monitors the
performance of the Post Office through UK Government
Investments, has been firmly aware of the failings of
the Horizon system for many years.
There were the two judgments by Mr Justice Fraser
in 2019 that demonstrated that the Post Office had
failed to ensure that its operating system, Horizon, was
fit and reliable for the purposes of its systems and as
‘a basis for any type of legal case. Nevertheless, the
Post Office throughout those proceedings fought the case
tooth and nail thorough the High Court, even seeking at
one stage to remove from Mr Justice Fraser from the
case.
Not one of the Horizon system. The Horizon system
is nota sentient being. The Horizon system did not
pick its vietims. The Horizon system did not decide
which of the Post Office offices individual balances it
would disturb and infect with its bugs. The Horizon
system is a product of the negligence and lack of care
of the people who operated and owned it. In fact, we
suspect, as the Inquiry progresses we're going to find
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these schemes. We say that the collection of those
issues is causing the same problem that you have heard
through the Human Impact Hearings, that each one of the
subpostmasters in their individual post offices was left
in ignorance of what going on elsewhere without
information that would have assisted them in dealing
with the Post Office.
Now if, sir, you are able to follow that request
and put forward an interim report, it would assist in
providing us with a way forward because one of the
things that has been apparent this week, and indeed up
until today, is that the sands have been moving in the
background. We have heard very submissions coming in
late. The submission that you referred to as the one
last night, in fact, I think my instructing solicitors
received it at 8.30 this morning, as it was passed on by
the Inquiry ~ we're grateful for that ~ and so we
didn't even have it at the 9.50 last night that it
otherwise might have been available. We know that what
has been happening is behind the scenes letters have
been sent to many of the people that we represent and,
therefore, there is a problem that exists which is a
shifting sands of position that is hard to grasp, which
is why, sir, an interim report setting out what you
Would regard as being the way forward would be of real
402
that all post offices had some problems. The question
is: to what degree?
The Post Office should never have thought to
preserve its reputation at all costs by fighting the
High Court case. But what it did do, by doing so, was
at the cost of further harm to the lives, financial
health, and mental wellbeing of those we represent. The
Post Office is in, in effect, a public organisation and
should have immediately told the truth to its
Post Office workers. Instead, what has happened in
relation to compensation it has set about putting in
place complicated schemes run by corporate lawyers to
provide access to some compensation for some its
vietims.
Sir, on 8 November last year I addressed you at
the first hearing of this Public Inquiry after it had
been put on a statutory basis. I set out then that many
ex-subpostmasters face imminent financial ruin and that
people will lose their homes unless something is done
urgently to assist them. I added then that some may not
survive the lifetime of the Inquiry due to
stress-related illnesses. Indeed, since the Inquiry has
started hearings in February of this year, I am sad to
say that I have been informed that another of those
affected by the Post Office in this scandal has died
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The Post Office Horizon IT Inquiry
We don't, of course, forget such individuals as Marian
Holmes husband Peter, a proud and distinguished
ex-police officer who went to his grave with a wholly
undeserved conviction recorded against his name
The obfuscation and denial that I have referred to
has continued since the time of the High Court hearings.
On 4 December 2021, BEIS wrote to two of our clients and
told them a full and final settlement was reached
between the claimants in the GLO and the Post Office.
There is nothing further the Department can do at this,
time.
(On 6 December last year, Mr Enright, partner at
Howe & Co Solicitors, wrote to Mr Scully and stated
that:
“Neither you nor your Government's hands are tied
by the settlement in the Group Litigation. Its
entirely open to your department and your Government to
acknowledge the widely accepted fact that claimants in
the Group Litigation performed a vital public service.”
Without their action, for which they paid a very
high price, the greatest miscarriage of justice in
British legal history would never have been uncovered
In November, I asked you, sir, as Chair, to use
your wide powers to require the production of evidence
that the Inquiry believes is relevant to the terms of
405
his five children.
‘Susan Hazzleton, who you will recall as you asked
questions in relation to her particular circumstance
She says that she is I years old in December and she
still works four days a week as she can't afford to
retire, and she has just had to put her house on the
market.
Geoffrey Pound says.
"Our house and business were repossessed back in
would need to live until about 150 years
old to repay in full”
Shazia Siddiq:
“The ounce of dignity I thought was remaining is
being eroded daily. 1am so tired. At the age of =}
Heel lke a pensioner. The effect of Post Orfice
Limited actions have destroyed me."
All these Core Participants are GLO litigants and
there are obviously many other examples that we could
provide. These are the very people who risked
everything to expose the scandal. Some you heard from
Some, like Gareth Etheridge, received sums as litle as
£1,800 from the Group Litigation, which is why we go
back to the point we're making in relation to
recommendations.
Sir, you've asked for the principles to be
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its reference and issues to compel the Post Otfice and
BEIS to disclose an up-to-date clarification on
compensation.
Of course, all of our cients have asked me to
convey their gratitude to you and your team at this
Inquiry for acknowledging and prioritising this
important issue through conducting these hearings today
and nextweek. But it may assist you to know that many
of our clients have found it helpful to give evidence in
the Human Impact Hearings, finding the experience
cathartic and giving them a degree of closure.
But the harm which the Post Office has caused to
ur clients is ongoing and is made manifest in the their
desperate financial consequences. Let me give you some
examples of what has been said. Marion Drydale says
"Lhave sold my jewellery, used my inheritance,
cashed in my pension. Every day is filled with
uncertainty, a dread of more bills I cannot pay."
Peter Worsfold says that he has still not been
able to repay hist==+year-old mother for bailing him out
when the Post Office demanded money for shortfalls in
2002. He visits the supermarket at 4 p.m. when they
have put short-dated items out at reduced prices,
Faisal Aziz is on the verge of declaring
bankruptcy. He worries that he will not be able to feed
106
expressed in relation to groups A, Band C. We need to
know, looking forward, what are the principles that are
going to be used in relation to the setting out of
compensation in the future for the GLO group.
Now, sit, we have had comment today about the
responses made in the institutions to this Inquiry. Can
we set out our disappointment at the responses from the
Post Office Limited and BEIS to the questions that you
have asked, particularly, may we say, si, in relation
to the issue of fair compensation for the Group
Litigation claimants. You called, sir, for specific
answers at questions 1 to 12 on 10 May of this year,
nearly two months ago. Your direction was this, this is
on9 May:
“Although the Minister’s announcement of 22 March
2022 was no doubt very welcome to the claimants in the:
Group Litigation, it is extremely important that effect
is given to the announcement as expeditiously as
possible. No doubt these two issues will be the subject
of detailed submissions at the hearing which I have
decided to convene."
On 10 May, you set out with considerable clarity
the questions you invited answers to as regards the GLO
litigants, setting them out of at paragraphs 9 to 10,
fair compensation for the Group Litigant claimants. The
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principles which we apply to the calculation of further
compensation payments.
40. The mechanism or mechanisms by which further
compensation payments will be calculated
41. The provision, if any, which will be made for
applicants to obtain independent legal advice in
relation to their claims.
42. The procedure or procedures which will be
adopted to resolve disputes about the value of further
compensation payments.
Yet the Post Office responded in six lines at
paragraph 58 ofits written submissions to say that:
“Until further information is released by
Government, Post Orfice is unable to assist the Chair
further in relation to issues 9 to 12."
Well, BEIS went one better and responded in two
paragraphs. At paragraphs 38 and subsequently 39 of
their submissions dated 31 May, they have said that they
convened a working group, that decisions have been made,
and, whilst the Department has a strong desire to begin
payments as soon as possible, the Department hopes to be
able to provide a further update to the Inquiry at the
hearing in July
So we are at a loss to understand why BEIS has
failed to answer your questions. They were simple
409
questions.
The view that our clients takes is that BEIS has
to be dragged kicking and screaming by my instructing
solicitors Howe & Co and this Inquiry into finally
agreeing to at least move in the right direction. Is it
actually possible to believe that the Post Office and
BEIS are so incapable of understanding, even now, that
they have victimised their own staff?
‘So what does this mean? Our clients are now
aware, and ths is all it means to them, that the
Government announcement means that they may be receiving
some interim compensation. Now, of course, this
position should have been reached a very long time ago
and we stil have no clear time-frame for a matter that
is urgent. This is not a gift. The people we represent
are not a charity. They deserve adequate immediate
compensation, as we have said many times, for their huge
actual and reputational losses.
The BEIS news story says that Ministers are to
provide a 19.5 milion interim compensation package to
the postmasters who played a crucial role in exposing
the Horizon scandal. The news story contains next to no
detail, There is nothing setting out the date by which
that will be set out. My clients do not know who will
be eligible, what the application process is, and the
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questions, setting out the need for simple answers,
targeted at what is required by the Group Litigation
individuals.
Our clients do not wish to wait to hear BEIS
proposals such as they may be on the next occasion that
we meet in relation to this Inquiry.
May I make a note now that, because of the
timetabling (of which I make no complaint whatsoever),
that we would ask if points arise that we need to deal
with that we may need to then return to make some
submissions in response after hearing from BEIS on the
next occasion
Sir, what is more concerning is that on 30 June,
instead of complying with your requests for information,
BEIS decided to issue a press statement on its website
entitled
"New Story 19.5 milion interim compensation
package for subpostmasters who helped uncover Horizon
scandal."
This isa terrible and heartrending scandal. It
should not be an opportunity for a Government department
to seek to score public relations points through the
Media. Nor should BEIS seek to disregard the Inquiry
process and embark on a frolic of its own, particularly
when directed by the Chair to answer particular
110
basis upon which the funds will be apportioned. These
matters need to be clarified so that the representatives,
of the Core Participants and my instructing solicitors
and others can consider them and comment upon them, if
necessary, on the next occasion
May I also add at this point that the lack of
trust between my client group and the Post Office,
Fujitsu and BEIS is so extreme that they doubt the
reality of the interim compensation package and, given
the track record of the Post Office and BEIS, who can
blame them? Putit this way: there are not many
ex-subpostmasters who are holding their breath,
Sir, as you know from the hearings, some people
who are before you and before this Inquiry, are facing
ruin, absolute ruin, right now staving off people coming
to their door demanding money. So we do ask for a
commitment from BEIS to making immediate -- looking this
up to make sure we know what it means. It mean do at
once, instantly, get this done, hardship payments to
those SPMs who are facing hardship as a consequence of
the scandal.
We've heard Ms Gallafent today speak about
hardship payments in relation to the Group A group or
class A group. But what we would respectfully invite
you to accept, sir, is that this appears to have been
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done at the will of the Post Office when it feels that
it should do so in particular circumstances that it's
notified of. No system, no settled way ahead, no
application process.
Now, aside from our criticisms of the delay and
the BEIS failure to follow your directions, the
announcement of 30 June may represent some progress but
it needs to be made reality now, not at some later
stage. We need a timetable and we need that now.
May I set out then and move on to the particular
positions in relation to the points that you have asked
Sir, you have made it very clear that you have read all
the written submissions and that indeed we interpret, in
fact, the need of this Inquiry for these particular
hearing purposes as being more directed towards the
institutions to see what they are saying about it as
well as the points that we make on their submissions
Sir, can we set out our concerns with the HSS.
I wonder who came up with that tile? Our first point
is this in relation to the burden of proving losses
Post Office Limited and BEIS as responsible for this
scandal. They should not be treating the issue of
compensating vietims as anything akin to litigation or,
indeed, what appears to be adversarial litigation. The
HSS scheme requires that SPMs, subpostmasters, establish
113
all applicants for compensation, to bear a burden of
producing documents which Post Office Limited have
seized and destroyed, in effect directing hurdles that
no horse could jump.
itis no answer, we suggest, to our concems for
Post Office Limited BEIS to rely on the statements in
the guidance to the effect that where the postmaster is
unable to satisfy the burden of proof in relation to
their claim, their claim may nonetheless be accepted in
whole or in part if the scheme considers it to be fair
in all the circumstances. What does that mean? What
are the principles being used for such a determination?
Essentially, this has been, and remains, an
enormous and far-reaching public scandal. Our clients
should not have to go cap in hand to the perpetrators of
that scandal when applying for compensation to ask for
indulgences or some form of largesse.
The heads of loss within the HSS scheme. Whilst
the heads of loss in the HSS are non-exhaustive and
generic, itis problematic that they do not reflect the
full range of harm caused by the Post Office in this
scandal,
Now, Post Office Limited states at paragraph 11 of
its written submissions that there is no form of loss
that cannot be taken into account. This approach is
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causation and prove each and every loss, preferably with
contemporaneous evidence.
Many people we represent, and I'm sure many people
who have suffered at the hands of the Post Office,
endure victim fatigue and some may well be suffering
from undiagnosed PTSD. This system that is put forward
isa system in which people who are already finding it
difficult to manage their lives and look after their
families then have to go through this rather difficult
process. You will remember that the evidence is that in
many, if not most, cases the Post Office seized the
paperwork of subpostmasters and their records when
suspending them.
The Post Office now seeks to place the burden on
subpostmasters to produce the very records that POL (the
Post Office) took from them. This is wrong-headed and
badly thought out and well look at the details been
moment.
Ms Linnell (Kay Linnell will be, we suspect, an
important witness in the later phases of this Inquiry)
tells us that during the mediation scheme a senior
Post Office offical told Sir Anthony Hooper during the
mediation scheme that Post Office Limited destroys all
records after six years. If that is right, then Post
Office Limited requires HSS applicants, and presumably
114
wrong. The scheme should be tailored to reflect the
consequences of Post Office's actions and include:
suffering to children and family members; the roles that
family members have played in caring for traumatised
subpostmasters; and the fact that many subpostmasters.
have been required to work long into what would
otherwise have been a planned retirement, and, sir, you
have heard evidence that relates to such matters
Well, the administration of the compensation
scheme has been described by Post Office Limited. They
say it's designed to be simple and user-friendly to
avoid the need to incur costs of legal representation
Well, we suggest that the scheme is neither simple nor
user-friendly. I's beset with problems. You will
recall the evidence of Mr Sethi, the Inquiry’ first
witness, who received a request from the HSS for answers
to 68 questions which included a number of sub-accounts,
which brought the total to approximately 100 questions.
Mr Sethi expressed considerable frustration while giving
evidence that he has being asked to consider questions
in relation to matters that had occurred some 20 years
previously, in respect of which much of information was
still being held by the Post Office
Nor, we suggest, is the scheme necessatily being
administered fairly. Subpostmasters have said that they
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received offered from the HSS that have been derisory.
Fiona Elliot gave evidence on 19 May 2022. Ms Elliott
said that she had lost just over a £1 milion but had
been offered instead £24,000. BEIS's assertion at
paragraph 21 of their written submissions is that -
sorry, the Post Office Limited is on track to issue at
least 95 per cent of offers by the end of this year.
It seems to us, and even having listened to
carefully to what Ms Gallafent has said today, that
given the difficulties and the restrictions in
application process, that there may well be a number of
people who have already had offers, and in fact accepted
them, through settlements, that could well have put
forward further matters that relation to consequential
losses. I's a matter of grave concern, we suggest that
at paragraph 25 of the Post Office Limited's written
submissions that they are saying that the vast mortality
of offers have been accepted. We say that those offers
may well have been made within a scheme where applicants
are not able to receive legal advice or disclosure in
relation to their possible claims. It is quite likely,
we say, that there will be many subpostmasters who
received offers in a similar derisory way to that
received by Ms Elliot and who, in the absence of legal
advice, have accepted those offers.
7
aware of any previous scheme where an abuser institution
awards punitive damages against itself.
The further disturbing feature of the HSS scheme
you've already dealt with today in discussion with
Ms Gallafent and Mr Beer, Queen's Counsel, is that there
is a denial before an application is made of access to
documents disclosed by Post Office Limited at those
intial stages. We have submitted in our written
‘submissions that there is therefore a substantial
procedural flaw in the HSS scheme. We say that that is
wholly unacceptable
Now, as to legal representation during the
compensation process, we saw in the BEIS news story of
30 June a comment that is made there which says,
"Postmasters will be able to claim reasonable legal fees.
as part of participating in the final compensation
scheme." Well, we hope that the wording of the
Ministerial Statement reflects acceptance by POL and by
BEIS that postmasters simply cannot be expected to
‘embark upon a complex procedure involving detailed and
historic claims without legal representation and access
to experts, if necessary.
Its important to highlight (although the data is
still not, we suggest, entirely clear) that it appears
that when we were drafting these oral submissions we
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There's a danger, we suggest, of there being
a scandal within a scandal about the compensation and
the way itis being handled by the Post Office
Sir, you have questioned already the sign or the
lack of sign of independence in the running of the
scheme. At paragraph 34 of the submissions filed on
behalf of Post Office Limited, itis stated that HSS
claims will be first assessed an assessor from Herbert
Smith Freehills and then by a team of reviewers at
Post Office. The assessment is then reviewed again by
the case assessor before being looked at by a so-called
Independent Advisory Panel. Ultimately, itis the
Post Office which decides the outcome with the benefit
of the Panel's assessment and recommendation
We suggest, and we agree with the provisional view
that you have set out, that faimess demands that the
Post Office Limited should not be the final arbiter of
whether an interim or final payment of compensation
should be made in accordance with the Minister's
announcements in July and December last year, and that
any disputes should be determined therefore by an
independent person. In particular, it would be
inappropriate for Post Office Limited to play any part
in the determination of aggravated or exemplary damages
which will be claimed by subpostmasters. We are not
118
worked it out as being 4 per cent of applicants to the
HSS scheme were legally represented. In fact, having
looked at the documentation again and considered what
has been said for us this moming, it looks as though
its 3 per cent of those applying to HSS have had some
type of legal representation.
Now, it may be therefore useful to briefly go to
the application form itself. Sir, can I take you to the
bundle, please. At page 192 ~ you have been directed
to already by Mr Beer ~- sir, this is a form that we
learn from Ms Gallafent — and I hope I quote her
correctly, just after midday today ~ this is designed
not to refer to the consequential losses and that is
done to help lay persons who are making an application.
Well, therefore it seems we're being told that it
was quite deliberate that this form didn't have a
reference to consequential losses. You've been directed
to paragraph, I think, 24 by Mr Beer. Can I take you to
paragraph 193. Sorry, page 193 which is paragraph 29
In the bundle, page 193 and it's paragraph 29 of the
form. Let's see what it says here.
"Please provide an explanation as to why you
believe you have not been treated faily by the
Post Office. In doing so, you should set out what you
would like the Post Office to do to remedy the situation
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and why.”
Well, there are a number of answers to that I'm
sure that many of my clients would like to give in
relation to what the Post Office can do with itself.
But otherwise, why is the Post Office setting out there
‘a suggestion of what has happened as a result of the
unfair treatment but itis not dealing in any way with
the consequential losses and the effect upon and the
stigma of having been dealt with by the Post Office in
a particular way of regarding people's character or what
has happened to them by way of their own experiences,
their mental health or their medical health.
We have also been directed to the guidance that is
set out at page 303 as being guidance that might assist,
It doesn't take but a moment to look at the pages that
have been referred to already to realise that these are
complex matters, dealing with heads of loss, in terms of
loss of earnings, loss of profits, loss of property,
loss of opportunity, loss of chance (these are legal
terms), penalties, general or increased costs of
financing, bankruptcy, insolvency, and so on,
We listened carefully to Ms Gallafent who did her
very best in, we would suggest, rather dificult
circumstances to defend the Post Office's actions. This,
form is wholly inadequate. tis not that it doesn't
124
individuals to perform with, one would hope, the
faclity of a trained lawyer and that, we suggest, is
continuing unfaimess.
Now, itis quite clear that Post Office Limited
views the compensation process as litigious. I mention
Ms Elliott again, Fiona Eliot, She applied to the HSS.
and on 26 June Ms Eliott attended a good faith meeting,
accompanied by Mr Enright, a partner at Howe & Co who is
handling these matters, and that was because she had
rejected an offer that had been made to her. Now,
attending at that meeting, which was conducted by
a banrister instructed or employed by Herbert Smith
Freehills, it was pure good fortune that Mr Enright was
present. At the start of the meeting, it was explained
to Ms Elliot that the meeting was to be conducted on
a without prejudice basis. Well, it seemed to us, on
her behalf, that a good faith but without prejudice
meeting is absurd and this, yet again, has all the
trappings of litigation
We hope that Post Office Limited and BEIS accept
that the provision in the HSS scheme, which probably is.
going to be asked for or attempted to be replicated in
the other schemes, for legal assistance of perhaps three
hours work and only after an offer has been made is
wrong, itis untenable, itis unfair, and designed to
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make much by way of reference to consequential losses:
it makes no reference to it
We take away our legal qualifications and put
ourselves in the position of the distressed
subpostmaster who is trying to deal with such a form in
awkward circumstances such as this thinking about, no
doubt, the time that they've got to get i in otherwise
that door is going to be closed. What we say is, in
effect, a form that appears to be designed not to help
lay people make the application but, in fact, to avoid
particular types of losses.
You will have seen, si, that the HSS scheme only
provides for contribution of 1200 or 400, depending on
the scope of the dispute, taken in relation to an offer
in relation to legal costs or legal expenses. And POL
(Post Office Limited) states in its written submissions
that its made payments of legal expenses in 35 cases
where requested to. This should have been built into
the scheme. People that are making such applications
that really have to be told, as we learned today from
Ms Gallafent, that what they should do is look at this
application form and look at guidance, make sure that
they put in a separate document setting out their answer
to these heads of damages in relation to consequential
damages. The Post Office is essentially asking for
422
disadvantage subpostmasters.
Now, we understand that Post Office Limited and
the Department of Business are considering using Freeths
Solicitors to assist eligible subpostmasters in relation
to compensation claims that were brought in the Group
litigation. Now, we can provide some further update in
relation to that as being contact to clients of ours by
Freeths in a letter that's essentially called Freeths
facts. Again, going back to the fast-moving pace of
matters, this is yesterday. Freeths write to
subpostmasters:
"Please note that you are not obliged to
reinstruct Freeths. If you do not instruct us, this
means that we will not be able to represent you in stage
1 of the process and we will not be able to pay your
interim payment to you."
Freeths, therefore, have already acknowledged —
and, sir, you've considered the wording of their
communication to the Inquiry already ~ that not all
individuals will necessarily be wishing to instruct them
within this process.
Now, Mr Enright of Howe & Co Solicitors recently
had a meeting with BEIS and it has been accepted by BEIS.
that other representatives of subpostmasters before this
Inquiry will be included in the further discussions
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about how the scheme for the GLO litigants will be put
together and its terms. So moving forwards, it seems as
though there is acceptance by BEIS that Howe & Co, and
no doubt other firms of solicitors, will be involved in
that process.
Now, we welcome that. It will enable discussions
about funds being distributed to be discussed openly and
transparently and that will be capable of being shared
with the Inquiry as the Inquiry makes it progress.
Nevertheless, the work that will need to be done
within those discussions and in making the applications
in the future must be properly funded to put those
applicants within the GLO litigation on the same basis,
as the Post Office in terms of legal representation
Can I then deal with interim patients themselves.
This is interim payments for those who underwent
prosecutions, not convicted. We have submitted that
there should be no distinction between those who are
entitled to interim payments having had their
convictions overtumed and to those who are prosecuted
and acquitted at trial or where prosecutions were
discontinued or cautions accepted
We understand that BEIS's position as stated in
their written submissions is that any subpostmaster who
Was acquitted or otherwise prosecuted and cautioned or
125
cases in these hearings.
Can I deal immediately with a point that's already
been subject fo some discussion. We know that there are
discussions ongoing that include a reference to
Lord Dyson who, as we understand, has agreed to come in
and consider these particular category of cases. We go
back to our primary submission which is that you, si,
should have answers to what are the principles being
‘employed in relation to such determinations. We were
pleased to hear the possibilty set out today that the
comparables or the precedents or the determinations made
by Lord Dyson may well be available so that people can
see what has happened one to another with such
applications.
We do not wish to make any further submissions on
this particular point because we would like to consider
what has have be said so far between now and the next
hearing, but our main consideration being that
principles need to be open, need to be transparent, need
to be capable of being examined by subpostmasters and
our representatives remain in relation to al of those,
including those individuals who otherwise might go
through what may be described as the altemative scheme
‘employing the good services of Lord Dyson. But the
principles upon which decisions should be made should be
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not convicted can apply through the HSS scheme.
Presumably BEIS will say that any subpostmaster who was
acquitted and who was a member of the GLO can apply
under the new, but as yet unparticularised, scheme.
ur position is that those subpostmasters who were
acquitted fall between the mechanisms and should be
transferred into the category B cohort of cases and
should have the facility to receive up to £100,000 in
interim compensation in accordance with that process,
This would remove the unacceptable position reflected in
the evidence of Ms Hamilton and Ms Palmer, that those
who are convicted are at least eligible for conviction
whereas those who were acquitted were not.
We hope that the announcement of 30 June that
Ministers are to provide a 19.5 milion compensation
package for all GLO litigants will assist in practical
terms. But the distinction should be made. However,
basic mathematics suggest that acquitted subpostmasters
will stil receive substantially less in interim relief
than those who were convicted,
Can we deal with the compensation questions that
relate to subpostmasters with quashed convictions. The
subpostmasters with overtumed convictions who we
represent would wish that BEIS clarify their position in
relation to how it will proceed in this category of
126
open and clear to others.
SIR WYN WILLIAMS: Mr Stein, you probably heard Mr Beer
suggest that I might want to enquire of the affected
Core Participants to what extent I should butt out or in
in relation to this particular issue. I asked
Ms Gallafent what she thought and she answered me. Am
I butting in or out or somewhere in between on what you
say?
MR STEIN: Well, sir, naturally of course, we are asking you
to stay somewhat in the doorway.
The position that we are asking you to adopt is
this: that itis important that the principles for
compensation are established, are known, are transparent
and accessible. We also don't wish to interfere in
anyway with any current application or anything that we
put forward delay compensation being provided. So on
that basis, and subject to further thought between now
and the next occasion in this rather rapidly moving
situation, we suggest that the way forward will be for
your to stand in that doorway and say that the process
needs to have some level of oversight and needs to be
transparent and to request, if all parties agree, that
the Lord Tyson principles, can I put it that way, be
made available. That would seem to us to be,
respectfully, a halfway house that would be acceptable
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at this time.
SIR WYN WILLIAMS: I mean, I'm looking at this from
a practical point of view as well. You invited me in
the strongest terms to provide an interim report. In
the very nature ofthis things that would probably mean
‘a greater length of time between these hearings elapsing
than if I were to just provide a progress update
because, as you will appreciate, an interim report has
to be laid before Parliament and all the rest of it
MR STEIN: Yes.
SIR WYN WILLIAMS: If it happened to be the case that
Lord Dyson's work was --I think someone suggested that
he may complete part of his work by the end of July, who
knows what then might follow from that. So I think the
probability is that instead of us talking to each other
sideways about doors open and shut, I should just ~ the
very great likelihood is that Lord Dyson might pronounce
before I certainly provide and interim report and my
interim report, if that's what itis, will then no doubt
take great account of what transpires. Does that sound
reasonable?
MR STEIN: Sir, yes. It does seem to us to be a practical
way forward. Being blunt, it may well be that
Lord Dyson will hear of this hearing, may well pay
attention to it, and may want to consider contact with
129
them in making claims."
It also stated that the Department was concerned
to avoid a situation whereby postmasters were forced to
engage expensive litigation funders and end up with
their compensation reduced as a result, as happened of
course with the Group Litigation,
The need for interim payment is such that that is
required to allow people to get their heads above water,
not for such luxuries as legal costs. Legal costs
should be paid for by BEIS and we suggest that there
stil is a failure of understanding by BEIS and the
Post Office that the subpostmasters were, and are, their
victims. They have created this problem. They have
created the need for subpostmasters to have legal
assistance at all
Now, there appears to be some conflict with
submissions made by the Post Office at paragraph 56 of
its written submissions, that as part of the
negotiations Post Office will consider the postmasters’
reasonable legal costs. So it seems that BEIS will need
to reconsider its position based upon the way that the
Post Office has set matters out
Effectively, BEIS is saying that they don't want
legal costs to eat into subpostmasters' final
compensation awards, so those costs should be taken from
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the Inquiry and in such contact, the Inquiry may be
prepare, I know not, to accept that he would be prepared
to set out the general nature of his considerations.
We don't, in any event wish, to put anything
forward that delays any compensation going to anyone.
There have been enough delays and enough obfuscation and
that that cannot be done. So we accept the problem and
we accept also, therefore, the solution
Now, we understand that as regards the claw-back
position that this is one of the matters that has
changed. For us, we learnt about this this morning
We're told in the correspondence that was received last
night, that we saw I think at 8.30 this moming, that
there would be no attempt now to claw that back. That
is progress at least in relation to those payments.
We note that Post Office Limited has made that
concession in relation to paragraph 43, we think, ofits
written submissions. BEIS has now confirmed, it seems,
that it agrees with that position
Now, I tum then to paragraph 33 of the written
submissions from BEIS which states this:
"One reason for the Department providing funding
to Post Office Limited to enable claimants to receive an
interim payment of up to 100,000 was to make ensure that
they could secure independent legal advice to assist
430
the postmasters at source and deducted from interim
payments at the outset.
The money is needed right now to solve people's,
immediate problems, to get them out of the financial
hole created by the Post Office. What are those
individuals to do? To receive an interim payment, put
some rather unspecified sum of money aside which they
can't touch to use for legal costs. At the heart of
this suggestion, itis badly wrong that those
individuals are being deprived of the ability to
properly have fully funded legal assistance
BEIS will know that the aim of compensation is to
tty to place postmasters back in the position where they
would have been but for the scandal. Costs are a
separate issue.
Of course, BEIS may pay the reasonable legal costs
associated with making claims under the scheme. It
appears to have agreed to do so in relation to category
C, the GLO litigants. It cannot, we suggest, reasonably
fail to do likewise in respect of HSS applicants and it
should not try to short change those who are convicted
unlawfully as a result of Post Office's abusive
prosecutions. It is obvious that Post Office or BEIS
never has to worry about the cost of its own legal
representatives: Government is paying for that.
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ur clients are very grateful, sir, that these
hearings have been convened in what we all know is an
early stage of the inquiry process. But sadly it seems
that itis only by repeated correspondence from my
instructing solicitors and others, and by this Inquiry
taking upon itself the need to have these hearings, that
BEIS and the Post Otfice are having their feet held to
the fire in order to make them pay up.
There is still a very, very long way to go.
Alarge number of subpostmasters remain in highly
precarious situations. The HSS scheme itself is riven
with problems. No doubt for those people that have made
applications already and we suggest that it's very
likely that many people, if they are prepared to listen
to the representations we have made and others, will be
wanting to go back to the Post Office and say, "Well, we
didnt realise the consequential losses could be
claimed”
It would also be helpful to have it confirmed for
all of those people out there that might be in a
position, who having heard what is being said by
Ms Gallafent regarding the potential for there being an
‘open door to making a claim within the HSS scheme, for
that door to be made clear that itis open and that the
application system is stil present. It needs more than
133
money that I had in the house, tuppences, Sps,
everything went into the bucket.”
She explained that her mummy and daddy arrived.
She didn't know it until that point but Darren, her
husband, had phoned them and they went to Ballymena and
withdrew as much money as they could out of their own
bank accounts but they couldn't get enough. So they
rang two of the uncles and they did the same
"My sister, when she was on the way to her shop to
lodge het own takings, she gave me her takings. So
I don't know the exact figure because I never got a
receive but somewhere in the region of £42,000 was in
that bucket.”
Counsel to the Inquiry asked Sinead:
“Where did that bucket go?”
Sinead said
“Lcouldn't drive at that stage. So I got my
sister to drive me down to the shop and I carried that
bucket in and the auditors made me stand there and watch
them count it. And they tutted, made me feel so lousy
for bringing them all these pennies but I brought them
whatever I could."
I mentioned Fiona Elliott. She gave evidence on
19 May. Two auditors arrived at the office. The
auditors told Fiona, "There's a shortfall here of £6,000
135,
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6 July 2022
counsel on behalf of the Post Office that says that that
is being considered. It needs to be said that the door
is open and applications can be made.
Let's compare briefly y the evidence that you have
heard, what's happened in the past to what is happening
now. Sinead Rainey's evidence heard in Belfast in the
Human Impact Hearings, transcript 18 May (lust for your
note) at page 43, lines 12 onwards. You will remember
that she spoke of an audit which take place on 1 May
2019 and she had just dropped her children off at
school ~ small children. Sinead said that when the
auditors had finished tallying up, they came to her and
they called her into the office and they said, "Sinead,
have you got any more money belong beginning to the
Post Office?" The auditors explained, "There's a
discrepancy here of £63,000". The auditor said,
"Sinead, you've got an hour to get as much money into
that safe. I'l be locking that safe in an hour and
you've got an hour to get as much money in there as you
possibly can. Whatever money you can put in there will
be deducted off the total discrepancy’.
So Sinead says this
"Well, I got into the car. I drove home and
Ilifted a bucket in my house and I emptied my wee'uns
moneyboxes into them and I emptied my own purse and any
134
showing in the system. We need to get that £6,000 now
or you'll have a criminal offence.” Well, she said,
"Where did that £6,000 come?” She said, "m constantly
putting money here all the time, hundreds of pounds a
week and never showed up that huge amount. What will
I do now?" They said, "You'll have to pay it”. She
hadn't gotitin the shop. "So I ended up by saying can
I go to the bank?" The bank was closed. They said no,
"So I couldn't leave and go that far. They wouldn't
wait on until the bank was going to open in the
afternoon. She tried to offer the Post Office official
acheque. They wouldn't accept that.
And Ms Elliott said to you, Fiona said to you.sir:
“Then I went and my brother owned a car business
in the village as well and I asked him would he have any
cash on him and he said, ‘Aye, there's cash there’. So
I got the cash off him and gave it to the Post Office
I never got a receipt for it"
These are just two examples but you have heard
scores of witnesses when the Post Office wanted their
money, they wanted it there and then under threat of
criminal prosecution. However, when we see the failings
of the Horizon system and the Post Office's conduct is.
uncovered repeatedly and starkly, and they are called
upon to properly compensate the victims, we suggest
136
(34) Pages 133 - 136
eye aroen a
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The Post Office Horizon IT Inquiry
there has been delay, obfuscation and basically these
issues being kicked into the long grass. They make
statements to Parliament, they issue press releases,
they do everything but pay up promptly.
I go back to where I started. Our clients simply
asks that compensation schemes are drawn up in such
‘a manner that indications are given as to the amounts
they are likely to receive by way of final compensation.
That requires precedence, it requires comparables, it
requires a way of accessing what itis that they might
be able to receive by way of the application. Schemes
should be transparent. They should provide indications,
of ikely quantum in a banding format. This would
assist in removing the unfortunate litigious elements
that the schemes currently contain and provide a measure
of certainty and facilitate targeted representations
ur clients, for very good reason, do not trust
the Post Office nor BEIS, the department of Government
which owns the Post Office. On 22 March, the Minister
made an announcement in Parliament accepting that the
Government has long considered unfair the unequal
treatment received by members of the GLO litigation
group and their non-GLO litigation peers. The Minister
said
“I'm therefore pleased to announce that the
137
current compensation schemes and what little is known
about the GLO compensation proposals and that we ask you
do that within the format of an interim report.
Sir, those are our submissions this aftemoon.
I hope I have dealt with them reasonably so that if
cricket is about to start that people might start to
tum out to the windows to their side and watch that.
I finish with this: its troubling that in order
to get BEIS and the Post Office to come to arrangements
that relate or explanations that relate to the HSS
scheme or to answer questions that you have set out,
that all of the expense that is required to set up such
hearing has been done. Its troubling that the
Post Office does not seem to have been able to
understand that individuals that have been affected by
the Post Office's actions, Post Office being wholly
owned by BEIS, need support and need assistance. Itis
troubling that all of those matters have been behind the
scenes to a large extent and that, right up until the
day of this hearing, including today (and I am quite
sure whilst I have been on my feet), that further
changes have been taking place.
So I ask, sit, that you indulge us if need be on
the next occasion by the ability, if required, to make
further short submissions in relation to what happens
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6 July 2022
Chancellor will make additional funding available to
give those in the GLO group compensation similar to that
which is available to their non-GLO peers.”
And accepting that, because they had signed a full
and final settlement of the court case in 2019,
postmasters in the group were ineligible to apply to the
Historical Shortfall Scheme.
"So despite winning the case [the Minister went on
to say] the group was left worse off than other affected
postmasters for whom they had blazed the trail”
In your announcements on 9 May, you refer to the
fact that in their written submissions both Post Office
Limited and BEIS suggest that claimants in the group
litigation faling within categories 1 and 2 will be
eligible to claim compensation for malicious prosecution
by virtue of the Minister's announcement of 22 March
You go on to say this:
“Itis also [your] provisional view, however, that
Post Office Limited and BEIS are correct to suggest that
claimants in the Group Litigation who fall within
categories 1 and 2 can claim compensation for malicious
prosecution in reliance upon the Minister's
announcement.”
So itis for these reasons that I have set out
today that we invite you to set out your view on the
138
between now and then and after having had a litle bit
more and more time to think of some of the submissions
that have been made today. I will make a promise that
it will be a short series of submissions targeted at
only those issues itself, and no more than that, and
obviously after hearing from others that set out their
submissions on that day
SIR WYN WILLIAMS: Thank you, Mr Stein. I think that
I would be remiss in not making some reference to what
might happen on the next occasion and so Ill do it
In the notice which I published on 30 June,
I anticipated that these hearings would produce a flurry
of activity. I didn't use those words but that was what
was in my mind and I'm not disappointed. I am quite
sure that between now and 13 July there may be further
activity, in which case I will give people an
appropriate opportunity to deal with what occurs. What
is appropriate will depend on what occurs. So I'm not
going to promise anyone that they can make any further
submissions (although I don't rule it out) and, as
I say, an appropriate opportunity will be available to
everyone to respond to this shifting process
Thank you all very much for the economy with which
you've addressed me and for accepting my invitation to
deal with things which were controversial rather than to
140
(35) Pages 137 - 140
eye aroen a
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The Post Office Horizon IT Inquiry
major on what you thought were your good points.
I ook forward to seeing many, if not all, of you
again next week
(3.22 pm)
(The hearing adjourned until Wednesday, 13 July at 10.30 am)
144
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6 July 2022
INDEX
Submission by MR BEER ... . 2
‘Submission by MS GALLAFENT ...........0000e 39
Submission by MR MERTENS 92
‘Submission by MR STEIN, QC 96
442
(36) Pages 141 - 142
INQ00001057
INQ00001057
4,200 [3] 27/10 29/5 [17 [7] 62014116 I 56/20 3.22 [1] 14114
Se aecR Taj oie I 70/25 16/18 2024 31/9 20202 [1] 12/20 3.30 [4] 29
Breer larg (11242 [1] 2912 31/10 42/23 2024 [8] 9/13 9/22 I30 [12] 12/20 22113
Bart Baty Sea gary (10300 [2] 745 74/12 I170 [1] 25/10 10/8 11/3 11/8 67/20 I 40/12 52/15 64/21
MR MERTENS: [4] (1482 [1] 30/21 472 [2] 18/16 18/16 I 67/20 105/7 55/8 97/3 110/13
ott ear asa. (1.483 [1] 26/3 173 [1] 18/16 2022 [10] 111 5/17 I 4113/7 119144 126/14
osios 4,659 [2] 65/20 66/8 I176 [1] 24/23 9/42 11/24 12/4 12117I 140/44
MR STEIN: (9) 92/15 18001] 107722 I48)9] 4/12 1418 I 66/21 68/3 108/16 [30 June [1] 65/9
96/3 99/7 100/22 (I 1-08 [1] 92/17 134/7 4117/2 302 [4] 9/6 65/24
Toone to1rt tag [tO [1] 92/24 482 [3] 3/19 30/9 30/9I21 [4] 11/24 19718 I 66/18 67/2
409/10 129129 4:3 [1] 16/19 483 [2] 4/1 30/9 I 36/18 117/5 303 [3] 25/25 65/24
MS GALLAFENT: I 1-6/4.7 [1] 30/22 186 [1] 57/1 24 July [1] 9/13 121/44
129) aaite govt’ a7ieI*-7 (11 30/22 488 [1] 14/24 217 [ft] 9/24 31 [3] 67/4 109/18
eoeaoia sorte sig (10 8] 4/11 38/19 [19 [9] 19/17 257 249] 14/10 11816
39/14 54/21 108/12 I 25/23 26/1 26/14 27/2 I22 [5] 19/2098/10 I 33 [1] 130/20
9819 5012 62/25 63/2 108/22 108/24 109/3 I 56/21 117/2 135/24 I 108/15 137/19 138/16 I35 [2] 44/15 122/17
anne alot aor 66/5 I19 December 2019 [2]I19 May [1] 4/12 22 July [4] 9/22 38 [2] 107/14 109/17
66/8 66/14 66/16 73/7 I 3/11 6/11 19.5 [1] 35/8 22 March 2022 [1] [39 [2] 74/14 109/17
75/1 79/6 79/16 80/17 I 1 May [1] 39/19 19.5 million [5] 13/3 I 12/4 OO
B75 87/7 87/04 (10 percent [1] 55/8 I 99/15 110/17 111/20 232] 19/21 24/24 I*#____
MS GALLIFANT: [3] I*0-week [1] 56/18 I 126/15 23 July 2024 [1] 4 o'clock [1] 2/9
ATIN2 63/4 T5I7 10.30 [1] 141/5 190 [1] 19/9 67/20 4.4 [4] 7/9
SIR WYN WILLIAMS; I 19:30am [1] 1/2 194 [1] 19/11 24 [4] 19/2350/20 400 [3] 27/9 71/2
[58] 4/3 8/23 9/2 18/4) 105 million [1] 7/18 I192 [1] 12019 97IT 120/18 122/13
48/8 34/7 34/11 34/15 I 100 [1] 116/18 193 [3] 120/19 120/19I24,000 [1] 117/4 42 million [2] 6/25
37/18 38/4 38/14. I 100,000 [5] 9/16 10/9 I 120/20 25 [3] 30/17 30/20 I 7/18
38/19 38/24 4719 4719I 78/8 1268 130/24 194 [1] 14/24 117/16 42,000 [4] 135/12
47/21 48/24 52/16 I11 [4] 4/11 67/8 109/5)195 [1] 15/1 25 February [4] 4/10 I43 [2] 130/17 134/8
57/9 57/22 58/24 115/23 2 [25 minutes [1] 79/3/45 [3] 26/25 29/2
62/22 63/1 63/3 63/5. I11-42 [1] 38/21 <________I26 [1] 123/7 29/16
63/15 63/17 64/3 11.56 [1] 38/23 2March [1] 4/10 I 27 [5] 9/14 25/3 43/24/47 [1] 67/7
64/20 65/22 66/3 66/6 I 115 [1] 87/5 2,368 [1] 9/8 59/24 67/4 48 [1] 26/5
66/10 66/15 73/1 12 [6] 13/1835/4 ‘2,370 [1] 65/20 27 November [1] 48 per [1] 26/13
74/23 7514 79/1 79/7 I 108/12 10918 109/15 2,523 [2] 9/109/12 I 25/20 4a [1] 16/11
gortea7iio are I 34/8 2.05 [1] 92/19 282] 7ez9t2 ADIN} 1615
g7iz3.oai7 922 I12May i] 4112.07 [1] 82/283 283 [1] 641/13 5
gaie 92/24 95/14 I1200 [1] 122113 2-1 [t] 6/20 285 [1] 16/10 Say Ti) SDS
95/24 96/1 99/3 43 [4] 74/8 95/1 20 [6] 8/19 19/17 55/8] 996 [4] 43/23 5 uly DT 8
400/17 100/23 100/25 I 140/15 1441/5 60/11 70V8 116121 [287 (2) 2a/135215 IB NT 1820
48/2 1292 129/11 I14 [7] 4/10 11/7 14/12/2002 [1] 108/22 289 [1] 21/2 Pa pe
14018 16/3 25/2 61/11 94/1 I2005 [1] 97/7 29 [2] 120/19 120/20 I5-8:1 [1]
as dt December 2021 [1]I2007 [1] 70/9 290 [2] 31/9 31/10/90 (2) 21/9 2712
' 1113 2008 [1] 107/10 294 [ft] 16/21 82 i ron
‘any (t) 18/20. (157) 14/12 16/7 16/9/2017 [1] 5/25 295 [1] 16/21
‘aye tH ‘Gere ail 25/3.52/15 _I2019 [8] 3/11 6/11 295 [1] 1621 555 £3) 36/21 36125
I 56/19 438381097125 «IS I 8/5
1 45 million [4] 6/22 I 103/10 134/10 138/5 I3 July [1] 84/4 56 [1] 134/17
1 May [4] 25/2 15-week [1] 25/20 I202[1] 15/1 3.4 [2] 21/221/3 [57.75 million [1] 6/22
1 October 2020 [1] I150 [1] 107/10 2020 [14] 8/48/19 3.1.1 [1] 21/6 58 [1] 109/12
5117 153 [1] 96/5 8/22 9/11 14/25 15/2 I3.1.2 [1] 21/16 Sps [1] 135/1
4,100 [1] 29/5 155 [1] 9/8 19/7 25/2 25/3 25/20 I3.2 [1] 31/8
1,135 [1] 26/4 16 [2] 14/15 16/4 51/17 56/12 56/15 I 3.2.3 [2] 21/21 31/11
(37) MR BEER: - 6,000
INQ00001057
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6 119/15 124/14 124/15 Iaccompanied [1] _ actually [5] 66/22 I 117/25 130/25
e2qy oama0 I 197/11 139/14 123/8 70/12 80/8 101/17 advise [1] 32/9
63 [1] 26/8 about [53] 1/10 1/12 Iaccordance [4] 2/24 I 111/6 Advisory [12] 14/14
63 per [1] 26/4 1/15 2/2 219 4/13 5/6 I 70/8 118/19 126/9 acute [1] 45/3 16/7 16/12 22/12
63,000 [1] 134/16 I 91188125 18/2 19/18 according [2] 29/14 Jadd [2] 92/3 11216 I 28/21 28/22 44/7
5 2] 2682611 I 20/1425/15 30/22 I 9217 added [1] 104/20 I 41/21 43/13 43/22
66 [t} 32/24 32/11 32/12 35/6 36/8 Iaccordingly [3] 5/9 additional [10] 9/25 I 59/8 118/12
67 [ft] 26/10 36/19 37/19 39/3 I 7/24 18/17 42/11 15/6 15/10 26/6 Iadvocate [1] 1/23
678 [1] 74/13 44/49 51/21 57/23 account [16] 22/23 I 31/777/1394/22 _Iaffect [4] 86/2
68 [i] 116/17 60/23 62/23 65/5 I 23/5 45/22 45/25 46/3I 98/11 138/41 affected [12] 4/4 57/5
69 [2] 32723 10714 I 6613 76/6 7912 I 40/17 4ova1 S212 address [14] 3/12 I 67/21 58/19 96/10
a Wel See et I 79/15 80/16 87/3 87/4 I 54/4 56/2 56/20 58/17 I 17/15 25/12 32/14 I 96/24 96/25 96/25
7 87/16 87/20 88/12 I 72/6 94/18 115/25 I 33/17 40/21 40/23 I 104/25 128/3 138/9
T June [6] 8/22 977 I 90/24 104/11 107/10 I 129/20, 42/11 54/14 56/14 I 139/15
9/9 25/25 30/21 65/25I 108/5 109/9 112/22 jaccountancy [1] 75/21 90/1 93/4 95/13 Iafford [1] 107/5
70 [3] 65/21 66/9 I 113/16 118/2 12216 I 27/18 addressed [5] 5/8 after [22] 11/6 24/21
66/21 125/1 125/7 129/16 Iaccounting [1] 43/15 I 39/20 90/11 104/15 I 25/20 26/1 26/14
73 [1] 32/22 130/11 132/24 139/2 Iaccounts [6] 4/21 I 140/24 26/20 31/16 31/17
74 [1] 107/10 139/6 26/24 94/4 101/23 addressing [2] 5/17 I 54/6 56/12 57/2 64/9
7A [A] 14/22 above [1] 134/8 116/17 135/7 87/10 74/25 90/5 104/16
absence [8] 33/10 achieved [1] 76/22 adds [1] 9/9 110/41 114/8 114/24
8 45/6 54/20 55/24 71/8 achieving [1] 93/23 Iadequate [6] 4/3 I 120/12 123/24 140/1
8,000 [2] 73/12 74/14 I 71/22 78/17 117/24 Iacknowledge [1] I 25/15 27/8 27/22 51/9I 140/6
8.30 [2] 102/16 absolute [1] 112/15 I 105/18 111/16 afternoon [5] 92/17
130/13 absurd [1] 123/18 Iacknowledged[1] adequately [1] 90/10 I 93/1 96/3 136/11
8.59pm [1] 34/13 abuser [1] 119/4 424/17 adjourned [1] 141/5 I 139/4
80 per [1] 77/2 abusive [1] 132/22 [acknowledgements adjournment [1] again [32] 16/4 25/25
874 [1] 70/9 accept [16] 22/8 30/5 I [1] 26/19 92/22 27/48 30/8 37/17
8A [1] 9/24 51/13 54/12 58/3 Iacknowledging [1] _Iadminister [2] 33/5 I 38/11 38/20 45/11
8B [1] 11/7 59/14 62/19 68/9 106/6 35/16 49/7 50/5 50/11 55/16
8C [1] 12/6 78/17 80/6 112/25 Iacquitted [6] 125/21 Iadministered [1] 56/5 60/4 63/21 65/7
8D [1] 12/22 123/20 130/2 130/7 I 125/25 126/3 126/6 I 116/25 65/10 67/2 69/24 72/5
9. I $308 136/12 126/13 126/18 administration [1] I 79/21 80/4 85/5 87/25
Y______acceptable [1] 128/25lact [7] 34/5 57/14 I 116/9 88/18 88/20 118/10
9 May [3] 5/9 12/17 acceptance [3] 74/22 I 57/17 70/9 72/3 82/12 Iadmission [1] 7/6 I 120/3 123/6 123/18
90/17 119/18 125/3 97I7 adopt [1] 128/11 12419 14113
9.4 [1] 7/15 accepted [13] 21/18 Iacted [1] 6/24 adopted [5] 32/10 against [4] 4/17 6/1
9.50 [1] 102/18 66/17 73/3 74/6 74/12 Iacting [3] 37/1 58/16 I 40/7 73/8 87/3 109/9 I 105/4 119/2
92[3] 74/7 74/16 I 7/2 105/18 115/9 I 89/2 adopting [1] 44/10 age [4] 30/19 31/1
74/23 117/42 117/18 117/25 Iaction [6] 7/2 19/22 Iadvance [1] 34/11 I 76/5 107/14
94-year-old [1] 124/23 125/22 33/6 96/15 96/18 advantageous [1] I aggravated [7] 45/13
106/20 accepting [5] 74/1 I 105/20 44/20 45/17 46/2 46/10 47/1
95 [2] 66/20117/7 I 76/14 137/20 138/4 actions [5] 97/2 adversarial [1] 81/18 118/24
95 per [2] 66/25 77/6 I 140/24 107/16 116/2 121/24 I 113/24 aggravation [2] 45/19
A access [9] 3/14 60/13) 139/16 adversely [1] 76/15 I 45/24
I §2/3 62/6 100/6 actively [5] 11/21 advice [22] 27/6 aggregate [1] 6/21
ability [2] 132/10 I 494/20 104/13 11976 I 18/11. 25/1156/14 I 28/11 42/13.43/12 ago [7] 12/20 24/8
139/24 419/24 68/18 51/5 59/7 59/9 59/10 I 35/6 35/19 60/11
able [17] 13/9 44/22 I accessible [1] 128/14/ activity [2] 140/13 I 59/15 59/2159/23 I 108/13 111/13
75/17 80/2 80/5 93/8 I accessing [1] 137/10 I 140/16 70/16 70/22 70/25 agree [14] 8/17 33/23
97/20 102/8 106/20 accommodate [2] _Iacts [1] 6/7 71/4 86/24 100/11 I 40/15 45/8 46/25
106/25 109/22 117/20 I 25/6 78/15 actual [2] 43/8 111/18I 101/21 109/6 117/20 I 50/12 68/16 73/16
(38) 62 - agree
INQ00001057
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A 135/21 136/4 139/12 I 128/6 139/20 140/14 Iany [105] 2/1 2/5 7/7 I 18/49 19/10 19/12
agree... [6] 80/3 80/6 139/18 140/23 141/2 I 141/5 14/7 15/12 18/18 24/13 43/24 44/2 44/3
81/17 90/17 119/15 [alleged [13] 6/6 8/1 amended [2] 83/18 I 19/20 19/25 22/3 22/4 I 44/21 44/21 45/1
128/22 19/23 20/1 20/3 20/4 I 84/13 22/23 23/5 23/16 45/18 46/20 49/11
agreed [19] 1/22 6/20 20/4 20/5 50/23 51/8 Iamendment [1] 25/5 I 26/21 26/24 27/15 49/19 50/22 53/3
13/14 29/23 31/2 54/18 58/6 60/23 amongst [5] 3/5 3/14 I 32/7 36/2 40/16 43/2 I 53/15 53/25 59/17
33/21 34/5 58/13 Allen [6] 83/7 83/16 I 26/7 99/18 99/19 43/24 44/4 44/4 44/4 I 61/22 61/25 62/10
71/24 79/12 79/13 83/23 85/2 85/5 88/5 Iamount [5] 21/14 45/9 46/1 46/14 46/24 I 62/18 62/23 63/11
79/14 79/18 82/2 allow [3] 82/16 99/19 I 67/5 70/14 80/10 50/10 50/22 51/12 63/13 63/19 63/21
82/12 83/1 84/24 1341/8 136/5 51/14 54/22 51/25 68/23 70/11 71/1
4127/5 132/18 allowing [1] 100/10 jamounted [1] 6/21 I 52/12 53/15 53/16 72/20 76/7 76/8 77/18
agreeing [1] 111/5 allows [2] 15/19 82/9 jamounts [1] 137/7 I 53/17 58/2 59/25 77/21 77/25 79/17
agreement [2] 67/5 alluded [1] 81/19 analogies [1] 2/6 61/18 62/11 63/3 80/8 80/11 91/18
80/8 alluding [1] 74/11 analysis [6] 28/20 I 63/18 63/24 64/7 64/7 Iapplicant's [3] 62/17
agreements [1] 88/12 alone [1] 57/14 41/10 41/14 59/11 68/9 69/12 70/20 71/8 I 70/13 71/2
agrees [3] 44/1 81/13 along [5] 2/23 15/5 I 59/14 64/1 71/24 72/6 73/2 73/13 Iapplicant-friendly [5]
130/19 46/15 64/4 64/10 annex [1] 88/8 75/12 76/13 78/2 49/11 77/18 77/25
ahead [1] 113/3 already [25] 13/2 announce [2] 12/10 I 81/14 84/14 84/15 79/17 80/14
aim [4] 10/4 58/22 29/15 32/16 43/17 137/25 84/17 84/20 84/21 applicants [58] 24/17
95/15 132/12 44/14 52/18 56/21 announced [7] 5/9 I 85/1 85/9 85/22 86/6 I 25/4 27/6 29/1 29/15
aimed [1] 53/9 72/2 77/17 81/19 9/14 10/6 13/13 34/3 I 88/23 89/8 89/11 30/12 30/17 32/8 46/8
akin [3] 53/19 58/2 86/19 87/5 90/10 35/18 67/21 89/19 89/20 89/22 46/23 51/12 51/18
113/23 104/41 101/21 114/7 jannouncement [21] I 89/23 90/2 90/9 90/16 I 51/22 52/5 52/6 53/23
Alan [1] 6/4 417/12 118/4 119/4 I 2/4 5/7 9/19 9/20 10/9I 90/19 91/13 91/17 53/23 54/16 55/17
all [94] 1/20 2/15 2/20 120/10 121/16 124/17 I 12/5 35/5 35/9 90/22 I 92/5 95/10 95/11 58/21 58/22 62/12
3/20 3/24 4/1 7/14 124/19 127/2 133/13 I 90/23 91/7 91/8 91/8 I 98/16 99/20 99/25 65/19 66/9 67/1 67/3
7/24 8/8 12/23 14/3 also [43] 1/17 5/1 108/15 108/18 111/11 I 1014/9 101/10 103/13 I 67/7 67/8 70/16 72/4
24/19 22/19 24/14 13/10 16/16 19/17 113/7 126/14 137/20 I 109/5 118/21 118/23 I 72/11 72/13 72/23
25/41 26/25 32/12 22/3 41/25 44/13 45/4 I 138/16 138/23 1149/1 121/7 125/24 I 73/24 74/3 74/4 74/6
33/3 34/12 34/15 49/25 51/20 53/25 announcements [2] I 126/2 127/15 128/15 I 74/7 74/7 74/9 75/24
35/14 35/25 36/15 55/23 62/12 68/15 118/20 138/11 130/4 130/5 134/14 I 76/12 76/19 76/23
37/9 38/16 38/19 39/7 I 10/16 72/5 72/12 announcing [1] 98/11] 134/25 136/15 140/19 I 77/1 77/2 77/6 7/11
46/15 48/9 51/9 51/18 I 73/22 80/19 81/3 another [8] 13/2 49/5 Ianyone [2] 130/5 78/14 86/23 101/25
81/17 82/18 83/3 83/4 I 54/8 58/5 92/8 101/19 I 140/19 109/6 114/25 115/41
ae Conte 83/15 84/11 84/18 104/24 127/13 anything [6] 79/15 I 117/419 120/4 125/13
63/11 64/21 65/14 86/8 91/19 93/4 95/2 Ianswer [9] 33/3 38/4 I 80/9 90/24 113/23 132/20
65/23 66/10 73/13 96/17 97/25 98/2 99/7 I 38/6 56/1 109/25 128/15 130/4 application [41]
75/16 76/20 78/7 1412/6 121/13 128/14 I 110/25 115/5 122/23 Ianyway [3] 76/15 10/23 14/23 18/6
80/16 80/23 83/13 130/8 1314/2 133/19 I 139/11 93/14 128/15 18/10 18/17 19/6 24/1
83/14 86/3 87/13 138/18 answered [1] 128/6 Iapart [2] 1/18 73/19 I 41/4 43/4 43/7 50/20
87/23 88/23 92/8 93/1 alternative [6] 10/3 [answers [7] 14/19 apologise [1] 75/2 I 52/1 52/3 53/5 53/6
94/15 94/18 96/8 96/9 10/12 10/17 87/8 108/12 108/23 110/1 Iapparent [2] 37/4 53/12 53/20 53/22
96/12 97/14 99/12 91/47 127/23 116/16 121/2 127/8 I 102/11 60/22 61/15 61/20
4100/3 100/4 100/6 although [6] 5/15 Anthony [1] 114/22 Iappear [5] 2/23 17/16] 61/21 62/4 63/7 69/6
400/8 100/16 100/20 26/18 46/8 108/15 anticipate [7] 33/16 I 32/17 84/11 96/3 69/7 69/15 71/10
4104/4 104/4 106/4 119/23 140/20 48/18 68/12 74/18 appears [10] 23/20 I 71/17 73/25 111/25
407/47 144/10 113/42 I2™ [24] 2/9 2/9 2/10 I 82/23 84/3 88/2 28/21 30/23 94/25 1413/4 117/11 119/6
414/23 115/1 115/11 I 2/10 11/11 12/10 38/4 janticipated [6] 40/18 I 112/25 113/24 119/24 I 120/8 120/14 122/10
123/18 124/19 126/16 38/4 38/21 38/23 40/25 51/4 66/19 4122/9 131/16 132/18 I 122/22 128/15 133/25
127/24 128/22 129/9 48/25 48/25 52/18 82/13 140/12 applicable [3] 42/3 I 137/11
134/45 133/2 133/20 58/4 63/17 78/22 92/1 Ianticipating [1] 64/14] 72/9 81/16 applications [31] 9/7
92/4 104/23 107/14 anticipation [1] 61/22Iapplicant [42] 8/16 I 9/10 9/12 17/19 17/23
(9) agree... - applications
INQ00001057
INQ00001057
A 83/6 83/10 91/4 91/25 I 128/9 128/11 attract [1] 70/6 balances [1] 103/21
applications... [26] 99/23 118/17 asks [1] 137/6 audit [2] 19/19 134/9 Ibald [1] 75/9
arbitration [4] 86/7 aspect [1] 57/24 auditor [1] 134/16 I Baljit [1] 26/17
sae oatooag 29/7 86/8 86/12 91/16 aspects [3] 40/13 auditors [5] 134/12 Ballymena [1] 135/5
25/19 25/22 56/11 \are [187] 57/22 83/2 134/15 135/19 135/24 I banding [1] 137/13
56/15 56/19 56/21 —-I reat] 81/22 assertion [1] 117/4 I 135/25 bands [1] 86/18
57/4 57/8 58/17 65/14 arguably [1] 88/20 Iassess [6] 3/6 13/7 IAugust [1] 25/2 bang [1] 9/3
65/21 70/20 73/6 argue [2] 83/23 88/8 I 30/15 33/23 76/1 August 2020 [1] 25/2 Ibanging [1] 8/24
argues [1] 83/19 86/11 availability [3] 12/1 Ibank [4] 135/7 136/8
ri aaad la argument [3] 31/3 assessed [7] 8/13 9/8] 51/20 70/23 136/8 136/10
applied [11] 10/20 84/14 88/18 9/8 43/13 62/9 63/12 Iavailable [21] 9/15 I bankruptcies [1] 4/22
23/13 32/4 32/23 arise [12] 6/19 17/7 I 118/8 14/12 12/12 12/13 bankruptcy [9] 16/25
51/23 54/19 58/5 91/7 I 17/16 27/1 28/7 28/7 assessing [4] 22/4 I 29/10 35/11 46/21 28/8 28/8 68/15 68/16
84/7 85/17 123/6 31/5 35/13 42/10 45/22 52/21 81/12 48/22 53/22 71/16 68/21 68/23 106/25
applies [1] 28/4 47/19 53/3 110/9 assessment [4] 62/14) 72/23 86/17 98/12 121/21
arisen [1] 37/11 62/14 118/10 118/14 I 98/13 99/15 102/19 Ibar [1] 60/19
app al ite arises [1] 24/3 assessor [2] 118/8 I 127/12 128/24 138/1 I barrier [1] 53/21
57/6 5818 77/11 77/20 Iatising [7] 2/24 6/7 I 118/14 4138/3 140/21 barrister [1] 123/12
80/1 80/2 100/20 13/21 14/3 14/8 68/7 assessors [1] 72/3 Iavoid [8] 2/6 45/2 barristers [1] 6/24
foot 126 13613 I 903 assist [19] 41/13 I 7113.8313.91/17 I based [4] 48/11 66/1
1386 arose [2] 205 68/9 I 44/1053/957/12 I 116/12 122/10 131/3. I 0/10 131/21
applying [5] 19114 @found [3] 26 2/13 I 64/1868/1 71/17 avoidance [4] 22/20 basic [2] 70/6 126/18
enatisie I 20113 73/21 92/5 93/13 I 69/12 84/20 90/15 I basically [1] 137/4
4120/5 arrangements [13] 102/9 104/20 106/8 award [6] 23/17 23/24) basis [22] 23/25
appointed [2] 2ete I 422.108 10112 1418] toart4 121/14 12614 I a7/to47izg 4e't6 I 28/21 30/11 30rt7
Ha 34/25 36/24 37/9 I 126/16 130/25 137/14I 74/2 36/13 44/24 47/18
37/24 93/17 93/19 —_jassistance [14] 17/13Iawarded [2] 8/18 48/3) 48/21 50/10 51/14
appointing [1] 15/6 I o4io3 g5/8 1309 I 271641154319 Iawards [4] 25/23 I 50/10 75123 76/24
appointments [3]
11/4 29/4 76/14 arrived [2] 135/3 43/20 43/25 53/18 81/23 119/2 131/25 I 79/419 83/22 91/14
apportioned [1] 112/4 135/24 59/25 90/11 103/1 aware [7] 51/23 70/23) 103/13 104/17 112/1
appreciate [3] 38/25 articulacy [1] 75/2 123/23 131/15 132/11 I 71/4 72/5 103/7 123/16 125/13 128/17
54/1 129/8 as [256] 139/17 114/10 119/1 Bates [1] 6/1
approach [24] 23/11 asImentioned [1] jassistants[1] 4/5 I away [2] 75/3 122/3 I be [295]
24/20 25/13 27/24 32/16 assisted [1] 102/6 Iawkward[1] 122/6 Ibear [2] 95/4 115/1
30/3 30/24 34/22 aside [5] 7/19 17/13 assisting [1] 93/16 IAziz[1] 106/24 _I because [31] 1/14 2/6
44/10 49/11 52/20 35/8 113/5 132/7 associated [4] 36/24 B 6/3 8/24 32/16 38/8
52/22 52/23 60/23 ask [18] 19/23 34/24 I 37/23 43/6 132/17 I —— a 44/16 47/9 48/20 50/8
73/8 77/14 78/4 79/24 38/24 53/2 63/9 63/14 jassuage [1] 54/14 [back [22] 9/5 14/22 I 51/3 54/12 56/20 73/8
81/2 81/11 83/23 67/13 92/9 92/9 98/15 Ijassuaged [1] 86/5 22/9 25/23 32/1 34/25 I 73/17 73/18 73/22
83/25 89/3 101/13 98/25 99/10 103/2 assuming [1] 42/3 I 42/5 50/4 66/18 78/25 I 79/16 79/23 80/25
415/25 110/9 112/16 115/16 jassure [1] 58/21 79/16 85/22 86/1 92/9 92/16 99/4
appropriate [13] 40/2 139/2 139/23 ATE [4] 7/1 107/9 107/23 124/9 I 404/13 102/10 110/7
52/4 55/1 §5/21 59/8 I@8Ked [22] 26/17 40/9Iattempt [4] 55/11 127/7 130/9 130/14 I 423/9 127/16 129/8
68/11 70/19 72/4 86/8 I 41/19 44/8 50/21 101/9 101/16 130/14 I 132/13 133/16 137/5 I 135/11 138/4
98/20 140/17 140118 I 90/24 53/7 53/8 53/11 Iattempted [1] 123/22 Ibackground [4] 5/15 Ibecome [2] 65/16
440/21 69/25 89/16 105/23 attend [1] 93/8 5/22 97/22 1023 I 79/40
appropriately [1] 106/4 107/2 107/25 attendance [1] 93/20 Ibadly [3] 96/10 becoming [1] 68/2
67/25 108/9 113/11 116/20 attended [1] 123/7 I 114/17 132/9 been [163]
approximately [2] 123/22 128/5 135/14 jattending [1] 123/11 Ibailing [1] 106/20 I Beer [29] 2/3 2/17
TAB 116/18 136/15 attends [1] 94/12 Ibalance [5] 20/18 =I 2/18 8/23 34/7 37/18
arbiter 8] 58/1 5817 /28King [7] 15/4 36/16 /attention [4] 9/24 21/8 23/15 27/19 AAIN7 41/20 41/25
38/4 53/15 122/25 I 15/18 56/17 129/25 I 51/15 42/6 51/1 52/2 56/10
(40) applications... - Beer
INQ00001057
1N@Q00001057
B 132/10 133/21 133/22 Ibills [1] 106/18 built [4] 43/17 53/19 I 81/15 85/15 109/4
Beer..[i6) 61 I 94/2 197/2 139/16 [binding [3] 33/25 I 77/25 122/18 calculation [5] 32/4
65/26 66/11 68/25 I BEIS [69] 9/23 33/9 I 34/1 82/15 bundle [9] 8/20 9/22 I 81/8 83/24 84/7 109/1
73/10 75122 aorta I 24/4.34/7 36/9 36/11 bit [2] 64/1 140/1 I 13/19.22/11 43/23 calendar [1] 67/2
81/19 84/2 87/10 Bait I 36/22 37/7 37/22 Blake [1] 2/23 65/23 95/1 120/9 call [2] 100/19 100/19
4495 120/10 120/18 I 40/21 78/7 8110 blame [1] 112/11 I 120/20 called [8] 6/21 7/2
4128/2 142/2 85/19 85/20 88/7 blazed [1] 138/10 burden [14] 20/18 I 14/17 108/11 116/11
before [20] 26/21 I 88/11 88/1490/1 block [1] 73/15 21/4 21/6 21/17 22/1 I 124/8 134/13 136/24
26122 34/0 39/24 I 90/23-93/16.94/19 —_Iblunt [1] 129/23 I 31/18 104/24 113/20 came [2] 113/19
40/23 89/9 64/7 ais I 24/24 95/2 97/2 99/15 board [1] 93/21 114/14 115/1 115/8 I 134/12
69/2 69/11 79/8 92/19 100/2 101/14 103/5 Ibodies [1] 97/15 burdensome [1] can [99] 1/4 1/5 1/11
97/13. 112/14 112114 I 105/7 106/2 108/8 body [2] 78/12 98/20 I 53/21 2/15 16/19 16/21
148/11 1196 124/24 I 109/16 109/24 110/4 both [11] 17/16 20/12Ibusily [1] 75/4 20/22 20/24 22/10
429/9 129/18 410/11 110/15 110/23 I 33/9 35/16 37/7 39/13I business [7] 1/20 I 23/1 25/23 29/9 31/25
began [1] 94/1 1114/2 144/7 11119. I 56/20 88/14 93/19 I 9/14 101/23 103/4 I 35/2 37/18 38/5 40/22
begin [4] 2/8 5/24 I 112/8 112/00 112/17 I 94/19 138/12 4107/9 124/3 136/14 I 40/24 41/12 41/18
14/16 109/20 113/6 113/21 115/6 [box [1] 20/7 but [90] 2/11 2/14 8/9] 42/3 42/10 44/1 46/22
beginning [2] 4014. I 119/13 119/19 123/20 Iboxes [1] 19/10 16/19 17/8 22/23 I 49/5 49/10 56/8 56/25
134/14 124/23 124/23 125/3 Ibranch [1] 19/19 I 24/16 30/1 31/1 34/15] 57/9 57/11 57/18
begins [1] 92/20 126/2 126/24 130/18 Ibreach [6] 43/9 43/9 I 38/15 39/7 41/9 41/15 I 58/21 58/24 59/3 59/4
behalf [14] 3/1 3/2 3/3 130/21 131/10 131/11 I 46/21 48/23 49/14 42/24 45/5 47/4 47/15 I 60/24 61/10 61/24
9/23 28/19 31/12 131/20 131/23 132/12 I 71/21 47/16 47/19 47/25 62/10 62/12 62/20
36/21 37/20 40/14 132/16 132/23 133/7 Ibreaches [1] 6/7 48/16 52/3 52/12 62/20 62/24 63/13
93/5 94/15 118/7 137/18 138/13 138/19 I break [8] 9/3 38/16 I 52/22 53/8 54/13 55/5 I 63/14 63/23 63/24
423/17 134/41 139/9 139/17 38/22 39/1 77/16 56/3 56/9 58/4 59/5 I 65/2 65/17 72/22 74/9
behaved [1] 84/24 BEIS's [5] 90/3 90/19 I 78/25 79/4 92/8 60/16 60/19 62/22 74/23 75/14 75/21
behaviour [1] 101/15 95/3 117/4 125/23 breath [4] 112/12 64/14 65/16 69/6 79/6 81/13 85/9 85/9
Belfast [2] 4/12 134/6 I briefly [5] 31/25 69/24 70/6 72/8 73/2 I 86/11 86/18 88/21
behind [8] 11/7 12/22
26/16 92/2 92/2 92/2 believe [3] 61/12 90/13 93/5 120/7 73/13 73/13 74/24 89/13 90/11 90/13
102/20 139/18 111/6 120/23 134/4 78/16 78/24 79/3 80/4 I 90/16 91/19 92/6 92/8
being [74] 7/13 10/23 believes [1] 105/25 bring [5] 3/23 44/4 I 80/7 81/19 81/23 93/14 94/9 94/9 94/18
16/15 32/3 32/7 32/10 IDelong [1] 134/14 50/9 56/16 91/18 82/16 83/11 84/12 95/16 97/9 97/18
32/19 33/6 35/10 benefit [3] 8/8 89/11 I bringing [5] 10/7 43/3I 84/25 85/17 87/6 100/17 101/8 105/10
35/15 41/23 43/25 118/13 43/7 50/8 135/21 88/21 89/18 90/2 108/6 112/4 112/10
45/12 45/25 51/15 [beset [1] 116/14 brings [2] 5/17 5/22 I 95/18 97/17 98/21 113/18 120/8 120/18
51/16 51/16 52/24 bespoke [2] 52/24 {British [1] 105/22 99/7 101/22 104/5 121/4 124/6 125/15
53/13 53/18 54/24 53/4 broad [5] 17/2 19/24 I 106/8 106/12 112/24 I 126/1 126/3 126/21
55/2 59/10 65/12 best [6] 17/11 25/12 I 22/17 23/2 23/25 113/7 117/3 121/5 127/2 127/12 128/23
67/15 69/21 73/18 56/14 57/7 86/11 broader [4] 23/22 121/7 121/15 122/10 I 134/3 134/20 134/20
75/9 75/10 75/23 121/23 broadly [3] 12/3 123/17 126/4 126/17 I 136/7 138/21 140/19
80/23 84/7 85/8 85/15 I better [1] 109/16 13/20 24/14 127/18 127/24 132/14 Ican I be [1] 1/11
85/17 86/14 93/4 93/9 IDetween [22] 1/25 I broke [1] 96/15 133/3 135/4 135/7 I Can I invite [4] 20/24
94/6 100/16 101/6 4/10 5/25 7/19 16/20 Ibrother [1] 136/14 I 135/12 135/21 136/19 ICan I turn [4] 31/25
401/10 101/20 102/25 I 19/8 36/9 42/24 51/15 brought [14] 4/16 6/5 I 137/4 140/13 can't [4] 2/6 46/19
403/19 107/14 113/45 54/19 54/21 65/5 6/10 7/12 7/13 47/17 Ibut I do [1] 2/14 107/5 132/8
415/42 116/20 116/23 I 105/9 112/7 125/18 I 47/17 47/20 48/21 butt [3] 34/24 87/14 Icannot [10] 8/17
Hepa tien ia I 12616127117 1287 I 71125 894 116/18 I 12814 20/17 57/17 83/8 85/1
tari 4201 20g I 129/17 12916 14011 I 4124/6 136/24 butting [1] 128/7 I 106/18 115/25 119/19
42g 24/7 ta5i7_ I 140/18 bucket [8] 134/24 jy [238] 130/7 132/19
t25/8 12718 127118 [Beyond [3] 84/5 88/18] 136/2 136/13 135/15 I cap [1] 115/15
427/20 128/16 129/23 I 88/20 135/19 capable [4] 51/16
bill [1] 44/6 bugs [1] 103/22 calculated [4] 32/7 I 100/15 125/8 127/20
(41) Beer... - capable
INQ00001057
INQ00001057
Cc causation [3] 24/2 I 134/11 84/22 85/9 86/3 86/11 I 66/23 75/19 77/3
carlo) 134/93 136/14 I 20/9 114/1 children's [1] 96/25 I 86/17 86/22 87/12 88/22 88/25 89/16
cade ft] dak cause [3] 21/14 27/2 Ichoice [1] 1/23 88/17 91/22 100/5 93/23 98/4 100/17
Cardiff [1] 4/10 38/9 choose [1] 36/21 100/19 105/9 105/18 I 100/20 111/14 113/12
care [2] 94/12 103/23 caused [8] 17/4 18/3 Ichose [1] 37/21 108/11 108/16 108/25 I 119/24 123/4 128/1
careful [1] 99/6 45/19 49/8 71/21 chronology [1] 5/16 I 130/23 138/13 138/20 I 133/24
carefully [10] 46/15 77/19 106/12 115/21 I circumstance [1] claimed [16] 7/2 7/21 Iclearly [3] 42/4 94/14
46/24.47/15 47/25 Ioauses [1] 25/18 107/3 8/2 17/5 18/21 22/22 I 100/18
48/3 48/5 57/19 90/7 [causing [2] 33/22 circumstances [32] I 23/4 23/18 23/23 client [3] 96/11 96/24
4417/9 121/22 102/2 2/16 21/20 22/19 23/7 I 27/23 42/3 52/11 12/7
caring [2] 49/9 116/4 cautioned [2] 96/19 I 24/5 25/16 27/22 55/15 55/22 118/25 _ clients [16] 96/8 96/9
carried [2] 83/25 125/25 29/13 30/14 30/18 133/18 105/7 106/4 106/9
135/18 cautions [1] 125/22 I 37/11 39/25 44/3 45/8 Iclaims [63] 6/5 7/7 106/13 110/4 111/2
carry [2] 39/7 79/7 cent [24] 21/9 26/4 I 48/13 51/9 54/5 55/12I 7/41 7/12 8/15 10/5 I 111/9 111/24 115/14
case [35] 22/19 22/25 26/5 26/8 26/8 26/11 I 60/12 61/21 70/18 10/7 16/22 17/14 121/3 124/7 133/1
23/7 27/12 27/13 26/11 26/13 27/3 75/25 76/3 76/21 18/12 22/7 26/3 26/9 13715 137/17
28/16 43/12 44/6 30/22 54/21 55/8 55/9 I 78/16 81/24 83/5 27/7 28/7 32/9 33/5 I clients‘ [1] 33/15
45/23 46/12 48/13 65/21 66/9 66/20 91/24 113/2 115/11 I 33/5 33/5 33/15 33/17 Iclose [1] 59/4
66/22 66/25 67/4 77/2 I 121/24 122/6 42/17 44/10 44/15 Iclosed [6] 8/19 9/11
a ie oe ae 77/6 1417/7 120/4 civil [7] 4/16 10/7 46/16 47/17 47/19 25/21 54/5 122/8
62/14 68/23 68/24 120/5 43/5 80/9 81/16 91/18I 50/6 71/25 72/24 136/8
72/3 72/8 76/21 81/22 Icettain [3] 24/13 96/19 73/10 74/11 74/13 Iclosely [2] 85/23 94/3
403/13 103/14 103/17 I 33/15 70/2 claim [59] 13/10 20/2 I 74/17 74/18 75/1 closing [1] 56/12
404/5 118/11 129/11 Icertainly [5] 33/12 I 21/7 21/17 21/18 76/20 78/9 80/23 81/5 Iclosure [5] 24/21
4138/5 138/8 140/16 I 94/11 64/14 89/7 21/24 22/2 22/4 26/20I 82/21 82/23 83/2 83/6 I 25/9 26/4 26/14
129/18 27227117 3018 I 83/8 83/1183/13 I 106/11
cases [af] we 78 certainty [1] 137/16 I 31/15 31/17 31/19 I 83/17 83/25 88/4 —-ICo [32] 3/4 12/17
99/8 30/20 aoin3 asia (eetera 1] 79120 I 31/2232/17 42124 I aariSag/sgart2 — I 17/46 20/12 29/20
‘apo aonessio (chair [4] 97/11 43/7 43/10 44/4 44/16I 90/21 99/25 101/19 I 29/24 34/7 31112
55/14 55/19 55/20 105/23 109/14 110/25 I 44/23 45/21 46/9 46/9 I 109/7 117/21 118/8 I 31/20 33/13 33/14
59/17 68/16 68/16 challenge [2] 93/18 I 46/11 46/14 46/17 119/21 124/5 1314/1 I 33/21 34/19 37/5 37/7
68/19 72/14 72/18 94/20 46/22 46/24 47/6 132/17 42114 45/12 49/7 60/9
73/12 73/15 75/17 challenges [1] 68/19 I 47/23 48/1 48/5 49/15 Iclarification [2] 90/11] 61/5 68/24 71/11
78/15 79/11 86/12 chance [2] 16/24 50/8 50/10 50/24 106/2 73/22 75/15 85/19
96/19 114/11 122/17 1214/19 53/10 71/3 72/16 clarified [1] 112/2 86/8 96/4 105/13
4126/7 127/1 127/6 Chancellor [2] 12/11 I 72/20 73/11 73/11 clarify [2] 81/11 1141/4 123/8 124/22
cash [3] 136/16 138/1 73/12 74/20 76/2 126/24 125/3
136/16 136/17 change [2] 54/23 76/16 77/21 81/14 clarity [2] 54/11 cohort [2] 13/1 126/7
cashed [1] 106/17 132/21 85/9 100/12 115/9 108/22 collaborate [2] 36/23
categories [10] 13/20 changed [1] 130/11 I 115/9 119/15 133/23 Iclass [2] 23/18 37/23
44/2 23/22 31/25 changes [1] 139/22 I 138/15 138/21 112/24 collecting [1] 28/2
90/20 99/25 100/4 character [1] 121/10 Iclaimable [1] 85/13 Iclasses [3] 15/20 collection [2] 64/1
400/20 138/14 138/21 characterise [1] 73/9 Iclaimant [2] 50/7 50/9) 16/4 24/13 102/1
category [18] 14/8 characterised [3] claimants [50] 6/1 6/5Iclause [5] 6/20 7/4 _I collective [1] 33/3
14/8 23/22 25/17 31/6 45/25 46/9 74/17 6/24 7/8 7/44 7/14 7/9 7I15 22/13 come [11] 1/23 22/9
32/1 32/17 35/2 49/5 charity [1] 111/16 7/20 7/24 8/5 12/24 I claw [4] 85/21 86/1 I 23/17 34/16 66/9
87/12 88/16 91/4 chat [2] 39/2 39/6 13/6 13/25 27/3 34/21 I 130/9 130/14 74/25 78/25 79/25
91/21 100/12 1267 [check [2] 52/16 92/1 I 35/3 35/7 35/12 35/14 Iclaw-back [1] 130/9 I 127/5 136/3 139/9
126/25 127/6 132/18 \cheque [1] 136/12 35/17 35/22 35/25 clear [27] 1/11 16/2 Icomes [4] 41/7 74/22
category 3[1] 91/21 Chief [1] 67/22 36/15 36/21 36/25 16/6 16/16 40/24 75/13 95/19
cathartic [1] 106/11 children [5] 49/9 37/2 37/4 37/10 37/21 I 48/24 54/12 57/13 comfortably [1] 92/19)
107/1 116/3 134/10 I 37/25 83/17 83/22 60/3 60/18 65/13 coming [4] 67/9 68/23
(42) car - coming
INQ00001057
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Cc 80/23 81/6 81/8 84/8 I 94/3 94/18 131/2 14/17 16/8 16/13 consistency [1] 54/11
coming... [2] 102/13 85/7 85/11 85/15 87/4 Iconcerning [5] 13/22 I 16/17 16/18 17/12 _ Iconsistent [1] 55/24
142/15 - 88/15 88/16 88/24 41/1 93/9 94/22 17/22 18/12 18/22 constantly [1] 136/3
89/14 89/17 89/18 110/13 18/23 18/25 19/3 19/4 Iconstituted [1] 10/16
commas [1] 64/5
commenced [1] 5/25
comment [4] 101/2
108/5 112/4 119/14
89/23 90/14 90/17 Iconcerns [8] 19/20 I 20/10 20/11 20/25 _Iconstrain [1] 55/6
90/21 91/9 91/11 38/9 54/14 76/5 76/7 I 21/4 22/2 22/22 23/18 Iconstrued [1] 7/5
91/14 91/24 93/10 87/21 113/18 115/5 I 27/17 27/20 27/23 I consulting [2] 36/22
; 93/24 94/6 94/23 I concession [1] 28/9 31/8 41/22 41/23I 37/22
cmmment iW 94/25 95/8 97/16 I 130/17 41/25 42/8 51/2 51/7 Icontact [6) 26/24
commitments [2] 36 I 26/12 98/13 98/17 concluded 2] 3/17 I 52/11 52/21 53/10 I 48/23 49/14 124/7
a 99/25 100/3 100/8 I 82/13 54/3 54/6 54/9 55/4 I 129/25 130/1
committed [2] 57/20 I 100/15 101/14 101/19 leonclusion [4] 33/25 I 60/17 69/18 73/14 [contain [1] 137/15
wD 404/11 104/13 106/3 I 36/1 37/15 48/11 I 73/19 74/14 83/24 [contains [2] 6/18
Committee's 1] I 198/4 198/10 108/25. conclusions [1 85/8 88/11 117/14 I 111/22
Oa 409/2 10914 109110 I 95/10 120/13 120/17 121/8. Icontemporaneous [8]
common (6) 613 I {10/7 114/12 111/17 jeonduct [2] 64/18 I 122/1 120/24 133/17 I 28/1 60/10 60/18
Mt sobi seng I 112011219 1181 I 136123 consider [37] 18/1 I 60/24 62/8 63/12 75/5
58/18 7015 115/16 116/9 1182 I conducted [4] 13/16 I 20/9 2213 22/7 25/12 I 114/2
communicate 2 I 118/18. 119/13 119716] 82724 129711 129/15 I 27/24 2912 3018 content [2] 34/22
M19 80/4 4123/5 124/5 126/9 I conducting [2] 5/10 I 30/24 31/25 37/6 I 4015
communication 1] I 126/15 126121 126/13) 106/7 39/20 46/22 47/15 I context [13] 43/11
D9 128/16 130/5 131/5 confidence [1] 88/12 I 50/4 58/18.59/12 I 44/12 55/7 56/10
comparables [3] I 131/25 132/12 13716 Ieonfident [2] 2/10 59/20 6918 70/19 74/1] 87/12 69125 74/10
4137/8 138/2 138/15 I 79/6 71/8 84/5 85/1 86/25 I 75/8 75/19 83/4 85/3
100/10 127/11 137/9
comparatively [1] 138/21 139/1 139/2 confidential [1] 82/9 I 90/10 97/20 99/1 99/2 I 85/18 89/14
compete [1] 2/12 confined [3] 22/21 99/11 99/19 112/4 continue [6] 4/25
complaint [2] 3/15 I 23/4 52/10 116/20 127/6 127/16 I 34/22 58/18 58/22
110/8 confirm [11] 11/11 129/25 131/19 89/6 91/20
complete [4] 2/11 41/12 56/25 65/17 considerable [3] continued [2] 68/6
19/10 79/2 129/13 69/25 81/13 85/9 56/16 108/22 116/19 I 105/6
completed [1] 51/4 I 86/18 90/16 91/13 considerably [1] continues [2] 11/21
compare [1] 134/4
compel [1] 106/1
compensate [1]
136/25
compensated [1]
20/24 completeness [1] 91/19 89/10 31/4
compensating [1] 49/24 confirmation [1] 86/1 Iconsideration [7] continuing [8] 18/25
113/23 completion [1] 29/19 Iconfirmed [3] 85/24 I 3/18 15/5 23/25 27/1 I 65/11 65/13 66/24
compensation [135] complex [6] 27/24 130/18 133/19 38/13 62/17 127/18 I 82/19 88/9 101/16
418 1/13 2/21 3/16 4/3 28/10 55/10 69/8 confiscation [2] 85/7 Iconsiderations [3] 123/3
5/2 5/6 5/18 6/6 7/20 119/20 121/17 85/11 22/17 23/3 130/3 contract [5] 6/7 43/9
7/25 8/7 8/12 8/17 complicated [3] conflict [1] 131/16 Iconsidered [18] 12/8 I 46/21 67/14 67/18
9/16 10/2 10/5 10/13 68/17 79/11 104/12 Iconnected [3] 61/1 I 46/15 46/25 47/25 contractual [2] 47/18
14/5 14/13 14/18 complications [1] 69/13 85/12 48/3 48/6 50/11 62/18 I 48/21
41/23 12/4 12/12 89/8 conscious [3] 39/18 I 68/11 69/21 78/6 contrary [1] 71/23
42/18 13/4 13/5 13/41 complying [1] 110/14/ 45/1 65/8 84/15 84/17 97/3 contrast [1] 28/18
43/22 13/24 15/20 comprehensive [1] Iconsent [1] 69/4 120/3 124/18 134/2 contributed [1] 28/25
16/1 29/6 30/12 32/2 51/15 consents [1] 86/21 I 137/21 contribution [6] 29/2
comprising [1] 43/14 consequence [5] 8/9 Iconsidering [9] 25/11] 70/24 71/4 71/9 72/11
pn a oa a concepts [1] 28/4 17/4 21/10 53/13 29/8 49/17 56/14 57/7 I 122/13
36/14 39/16 45/24 Iconcern [4] 45/4 86/5) 112/20 57/19 58/18 72/21 _I contributions [5]
49/41 49/25 57/4 87/20 117/15 consequences [5] 124/3 29/8 71/6 72/13 72/21
57/20 58/19 67/6 70/5 [concerned [14] 3/13 I 4/14 4/16 4/18 106/14] considers [11] 21/19 I 75/10
70/7 72/14 77/24 39/19 40/6 45/18 116/2 22/18 22/24 23/6 controversial [2] 30/1
60/22 69/11 72/17 consequent [1] 6/6 I 43/18 44/19 45/7 46/3 I 140/25
78121 80/1 80/18 76/17 81/9 88/25 91/1 Iconsequential [53] I 52/13 72/7 115/10 Iconvene [1] 108/21
(43) coming... - convene
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~——_______ I 16/9 30/14 34/16 40/6 Icritical [1] 6/15 Ideadline [5] 25/2 _ [deficiency [5] 45/9
convened [2] 109/19 I 5/14 50/11 57/5 58/9 criticised [1] 215 I S816 57/258/10 I 47/1 50/12 51/25 5617
61/25 75/25 77/11 criticism [4] 41/8 I 58/15 deficient [3] 42/15
convenient [1] 38/16 Pan
convey [1] ne 84/14 101/7 107/18 criticisms [1] 113/5 Ideal [16] 45/20 47/5 I 45/16 53/24
convicted [7] 7/13 115/4 117/13 130/25 Icross [2] 18/22 21/21 I 55/11 55/15 57/8 defined [5] 7/13 16/13
96/18 125/17 126/1 I 139/17 135/6 135/22 Icrucial [2] 97/23 73/21 88/3 89/13 16/15 19/1 41/23
couldn't [3] 135/7 111/21 90/13 110/9 122/5 definition [1] 41/22
conviction (61 we 135/17 136/9 crusty [1] 39/3 125/15 126/21 127/2 Idegree [4] 43/16 55/3
85/8 85/10 85/12 counsel [8] 2/23 14/3 Icurrent [7] 34/22 60/2) 140/17 140/25 104/2 106/41
4105/4 126/12 14/6 34/19 59/13 65/14 72/19 81/23 dealing [10] 1/8 15/16Idelay [17] 1/25 25/18
119/5 134/4 135/14 I 128/15 139/4 42/25 70/1 73/9 78/20 I 25/18 27/2 57/15 65/3
coors eal ir count [1] 135/20 currently [6] 29/8 I 98/19 102/6 121/7__I 65/7 67/10 68/9 68/13
44/2 11/5 11/14 13/13 ICouple [4] 26/22 39/24 69/21 70/24 124/17 69/24 78/14 98/8
13/23 32/3 32/13 42/11 67/10 78/24 72/21 137/15 dealt [6] 73/11 79/11 I 98/19 113/5 128/16
course [45] 4/9 6/11 80/24 119/4 121/9 137/1
86/22 88/25 91/2 36/1 36/7 40/10 40/21 I daddy [1] debt [1] 4/22 130/5 130/6
42/22 46/5 47/6 47/15 Idaily [1] 107/14 decade [1] 24/7 deliberate [1] 120/16
cooperate 2 ae 48/10 48/13 50/8 52/3 Idamage [2] 17/1 decades [1] 24/8 —_Ideliberately [4] 32/15
89/19 52/7 53/12 58/11 ‘I 46/20 December [12] 3/11 Idelineates [2] 42/21
copy [2] 62/10 62/12 I 60/22 62/4 62/5 62/18 damages [27] 6/25 I 6/11 11/3 11/8 38/10 I 42/24
core [25] 313 sii4 I 68/24 65/1866/19 I 19/1545/14 45/18 I g6r21 e0I21 91/8 deliver [2] 11/18
Td 42/16 13/17 I 06/25 69/1 77/25 7/8 I 46/2 46/10 4613 I 05/7 105/12 107/4 I B9/t7
82/5 82/15 87/9 89/18 I 46/18 47/2 47/6 47/11 I 118/20 delivered [7] 3/9 3/21
14 14/10 1516 24/15) oo9 aos 95123 10118 47124 4812 48/12 [December 2019 [1] I §7/4 57120 58/19
50/15 50/15 50/18 I 1054 106/4 114/12 I 48/16 48/19.48/22 I 38/10 93/24 94/7
67/11 81/1 87/21 90/8I 128/9 1341/6 132/16 I 93/16 81/16 81/17 [December 2021 [2] delivering [2] 5/12
94/15 95/9 96/6 court [15] 34/2 39/4 I 81/18 81/20 82/4 11/8 105/7 13/5
407/17 112/3 1028/4 I 77/22 82/7 83/11 118/24 119/2 122/24 IDecember 2022 [1] I delivery [2] 93/19
corporate [2] 50/1 I 83/22 84/23 91/12 122/25 66/21 94/19
404/12 96/16 101/2 1014/3 Idamaging [1] 81/21 Idecide [3] 75/18 demanded [1] 106/21
correct [5] 1/6 19/3 I 103/15 104/5 105/6 danger [1] 118/1 95/11 103/20 demanding [1]
29/1 70/14 138/19 I 1938/5 Darren [1] 135/4 I decided [3] 5/4 112/16
correctly [2] 74/19 ICourts [1] 10/7 data [14] 13/7 23/10 I 408/21 110/15 demands [3] 91/4
420/12 cover [1] 39/20 41/10 41/14 62/3 62/5 I decides [2] 78/11 I 99/22 118/16
correspondence [3] Iovered [2] 13/2 4916 62/16 64/1 64/7 64/13 I 418/13 demonstrate [2] 21/8
33/6 130/12 133/4 [covering [1] 41/3 I 86/17 86/20 86/21 decision [6] 6/15 22/2
cost [7] 43/21 44/2 ICovid [2] 25/7 56/21 119/23 37/12 46/1 54/11 demonstrated [1]
59/23 70/25 77/9: \erack [1] 64/13 date [12] 25/11 30/16 I 54/17 72/25 103/10
404/6 132/24 created [3] 131/13 I 41/9 56/12 57/1 59/19] decisions [4] 6/8 [demonstrates [1]
costs [30] 6/23 711 I 134/14 132/5 67/3 76/2 81/22 82/23 I 28/23 109/19 127/25 I 65/13
71 7/23 16/24 28/14 ISreation [1] 4/1 106/2 111/23 declaring [1] 106/24 I denial [2] 105/5 119/6
credibly [1] 54/1 dated [5] 6/11.9/22 I deduct [1] 70/7 department [11]
Tea aoa oe lereait (3) 4/23 55/13 I 90/17 106/23 109/18 deducted [2] 192/1 I 11/21 10/4 105/10
72122 75/13 87/1 98/1 I 5/19 dates [1] 20/4 134/21 105/17 109/20 109/21
4003 104/4 116/12 (ticket [5] 2/7 2/13 day [9] 1/22 4/25 9121I deducting [1] 70/11 I 110/21 124/3 130/22
424/20 122/15 131/9 I 2/14 92/20 1390/6 12/4 64/21 64/25 deed [11] 3/116/10 I 131/2 137/18
434/9 131/20 131/24. (ticketing [1] 2/5 106/17 139/20 140/7 I 6/18 7/5 7/10 7/15 8/3 Idepend [2] 55/2
434/25 132/8 132/14. Iotiminal [4] 4/19 days [9] 1/8 1/11 1/12) 58/13 83/16 83/21 140/18
430/16 96/17 136/2 136/22 I 1/18 12/20 26/22 35/6 I gaja4 dependent [1] 27/11
criteria [4] 14/15 16/4] 35/19 107/5 defence [1] 71/25 Idepending [1] 122/13
(44) convened - depending
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D devoted [1] 1/12 100/6 117/20 50/17 51/13 51/25 128/20
danrived (9) 40/13 \did [11] 24/17 34/7 I discontinued [1] 53/16 53/16 55/19 doubt [12] 22/20
deprived 2] 6013 Psa 87/15 10319 I 125/22 55/21 57/13 63/25 I 69/12 84/20 89/5
derailed [1] 97/1 103/20 104/5 121/22 Idiscover [1] 100/8 I 64/9 64/10 64/24 90/16 108/16 108/19
derisory [2] 117/1 135/8 135/15 136/3 I discrepancy [2] 65/11 71/8 73/1 78/16 I 112/8 122/7 125/4
117/23 didn't [8] 51/12 56/24 I 134/16 134/21 79/6 79/8 79/16 80/2 I 129/19 133/12
describe [1] 15/7 84/2 102/18 120/16 Idiscrete [2] 12/1 80/11 84/25 86/10 down [3] 6/12 77/16
described [8] 22/11 133/17 135/4 140/13 I 85/17 89/6 90/5 90/19 98/18 I 135/18
24/5 35/20 45/21 died [1] 104/25 discretion [5] 22/21 I 99/7 104/5 105/10 draft [1] 74/24
93/16 98/2 116/10 difference [4] 19/8 23/3 52/9 55/6 72/6 I 110/4 111/24 112/16 I drafting [2] 17/8
127/23 30/23 54/18 54/24 discuss [1] 79/14 412/48 113/2 115/20 I 119/25
description [1] 51/7 [differences [1] 58/3 Idiscussed [2] 58/12 I 120/25 121/4 122/21 Idragged [1] 111/3
deserve I] 11/19 different [6] 28/12 125/7 124/13 127/15 132/6 Idraw [1] 9/24
111/16 46/14 63/6 78/4 79/21 Idiscussion [2] 119/4 I 132/18 132/20 136/6 Idrawn [1] 137/6
design [1] 14/11 80/12 12713 137/4 137/17 139/3 Idread [1] 106/18
designed [12] 18/10 difficult [7] 28/7 discussions [6] 1/12 I 140/10 drive [2] 135/17
37/14 44/20 51/4 30/13 75/25 80/12 1/13 124/25 125/6 document [11] 14/17 I 135/18
51/15 53/2 69/17 114/8 114/9 121/23 I 125/11 127/4 14/19 15/4 18/24 19/4 Idriving [1] 67/17
F412 116/11 120112 ICifficulties [3] 25/6 Idisgorgement [1] I 19/5 21/1 21/22 66/7 Idropped [1] 134/10
42219 123/25 73/6 117/10 85/4 90/16 122/23 drove [1] 134/23
desire [2] 30/23 difficulty [1] 33/23 {dishonesty [1] 9/18 Idocumentary [1] 28/1/Drydale [1] 106/15
409/20 dignity [4] 107/13 dispute [13] 8/15 10/3Idocumentation [3] I due [9] 21/15 25/7
desperate [1] 106/14 direct [4] 17/4 20/5 I 10/12 10/17 28/14 22/5 62/23 120/3 29/10 40/10 40/21
despite [4] 15/17 83/24 85/8 48/14 60/25 67/4 77/4 Idocuments [5] 17/6 I 78/8 84/19 87/9
49/22 101/22 138/8 directed [5] 110/25 I 87/8 91/13 91/17 62/4 62/11 115/2 104/21
destroyed [3] 60/14 113/15 120/9 120/17 I 122/14 119/7 during [10] 6/11
10716 11513 124/13 disputes [7] 32/11 Idoes [17] 16/8 19/23 I 24/18 62/4 65/18
destroys [1] 114/23 directing [1] 115/3 62/20 86/6 87/4 87/9 I 27/13 46/18 46/22 67/16 68/4 97/20
detail 2 94/22 direction [2] 108/13 I 109/9 118/21 50/6 55/16 70/6 70/7 I 114/21 114/22 119/12
111/23 1114/5 disregard [1] 110/23 I 70/19 72/18 103/3 duties [1] 88/12
detailed [5] 8/14 directions [2] 5/11 [distance [1] 1/4 1411/9 115/11 129/20 I duty [2] 43/9 71/22
52/24 95/20 108/20 113/6 distinction [3] 80/25 I 129/22 139/14 Dyson [9] 13/16 34/4
419/20 directly [9] 20/1 50/7 I 125/18 126/17 doesn't [6] 51/4 51/2 I 82/11 82/25 127/5
detailing [1] 5/22 50/23 51/8 54/14 56/8 I distinguished [1] 59/12 84/11 121/15 I 127/12 127/24 129/17
details [4] 20/3 35/10 59/5 85/11 88/3 105/2 121/25 129/24
50/25 114/17 director [2] 68/2 distress [10] 45/2 doing [7] 2/15 22/18 IDyson's [1] 129/12
determination [3] 93/21 46/3 49/13 49/16 22/20 48/25 64/23 E
97/5 {18/12 119/04 (directors [1] 50/3 I 49/25 55/25 56/2 I 104/5 120124 E
disadvantage [1] I 73/13 73/19 74/15 —_Idon't [44] 54/11 54/22Ieach [15] 10/10 19/13
4124/1 distressed [1] 122/4 I 61/11 65/9 66/13 I 20/3 50/25 56/1 61/17
disagree [1] 40/15 distributed [1] 125/7 I 68/14 79/9 90/24 I 61/20 63/9 72/8 75/21
distribution [1] 99/17I 105/1 128/14 130/4 I 94/11 96/23 102/3
determinations [2]
127/9 127/41
determine [1] 78/13 di tr
determined [2] 8/16 I“’Sagreement [1]
118/21 40/16 disturb [1] 103/22 I 131/23 135/11 140/20] 114/1 129/15
devastated [1] 96/8 I disappointed [1] disturbing [2] 8/24 Idone [10] 8/25 20/14 Iearlier [6] 25/24
devastating [1] 4/14 I 140/14 4119/3 41/15 104/19 112/19 I 34/10 31/11 54/2
developed [2] 13/8 I“’Sappointment [1] divergence [1] 77/9 I 1143/1 120/14 125/10 63/20 64/25
35/10 108/7 divided [1] 13/20 130/7 139/13 early [11] 5/5 13/15
developing [2] 36/23 I discharge [1] 20/17 Ido [64] 2/4 2/14 5/20 Idoor [8] 54/5 58/20 30/5 33/24 82/4 82/18
37103 disclose [1] 106/2 I 10/6 15/10 23/23 58/25 112/16 122/8 I 82/24 83/9 86/13 87/6
development [2] disclosed [3] 31/22 I 32/14 39/7 42/23 133/23 133/24 134/2 I 133/3
33/19 35/15 100/10 119/7 46/25 48/18 48/20 {doors [1] 129/16 [earmarked [1] 6/23
disclosure [3] 63/19 I 49/20 49/22 50/4 doorway [2] 128/10 Iearnings [2] 16/22
(45) deprived - earnings
INQ00001057
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earnings... [4] 121/18
easy [2] 1/20 73/4
eat [1] 131/24
economy [1] 140/23
effect [8] 58/2 104/8
107/15 108/17 115/3
115/7 121/8 122/9
effected [1] 31/3
effectively [7] 10/25
42/6 53/19 93/25 94/7
94/10 131/23
effectiveness [1] 5/2
eight [1] 33/4
either [5] 27/9 47/2
48/6 58/25 61/15
elapsing [1] 129/6
elegantly [2] 47/4
87/14
element [5] 46/11
55/4 61/12 80/3 80/4
elements [5] 12/23
28/12 71/18 71/18
137/14
elicit [2] 53/9 69/17
eligibility [4] 14/15
16/3 18/13 25/5
eligible [18] 8/6 9/8
9/9 13/1 26/3 26/9
26/12 27/3 29/15
56/17 65/19 66/9
66/25 90/21 111/25
124/4 126/12 138/15
Elliot (1] 123/15
Elliott [8] 117/2 117/2
117/24 123/6 123/6
123/7 135/23 136/13
elsewhere [1] 102/5
embark [3] 1/7
110/24 119/20
eminent [1] 82/11
emphasise [15] 41/9
49/10 50/5 53/1 55/16
60/4 60/16 66/23 80/4
80/20 81/3 82/8 83/5
83/12 84/25
emphasised [3] 47/16
72/11 80/19
emphasises [1] 63/8
emphatically [1]
84/21
employed [2] 123/12
12719
employees’ [1] 86/18
employing [1] 127/24
emptied [2] 134/24
134/25
enable [5] 11/16 22/7
25/4 125/6 130/23
enables [1] 44/21
enabling [1] 71/1
encouraged [1] 18/11
end [13] 6/10 31/24
36/16 66/2 66/22 67/1
69/20 77/7 79/7 82/14
117/7 129/13 1341/4
endeavour [1] 64/24
ended [2] 67/19 136/7I
endorses [1] 95/5
endure [1] 114/5
Energy [2] 9/14 103/5
engage [3] 11/21
91/16 131/4
engaged [4] 35/19
67/3 77/5 85/24
enormous [1] 115/14
enough [3] 130/6
130/6 135/7
enquire [1] 128/3
Enright [5] 92/42
105/12 123/8 123/13
124/22
ensure [14] 20/20
36/14 37/8 54/10 57/3
57/4 58/18 58/22
67/25 70/14 90/7 94/8
103/11 130/24
ensuring [1] 57/20
entertained [1] 47/7
entirely [5] 73/15
74/18 77/22 105/17
119/24
entities [1] 50/2
entitled [4] 17/25
91/23 110/16 125/19
entity [1] 89/9
equally [1] 61/24
eroded [1] 107/14
escalated [1] 62/21
escalation [1] 67/7
especially [1] 17/21
essentially [5] 1/14
98/20 115/13 122/25
124/8
establish [1] 113/25
established [3] 8/4
80/21 128/13
establishment [3]
7/16 91/10 100/15
estimate [1] 92/10
et [1] 79/20
et cetera [1] 79/20
Etheridge [1] 107/21
evaluation [7] 13/16
33/24 82/13 82/19
82/24 83/9 87/6
evaluator [2] 34/5
82/12
even [11] 20/17 23/13
54/6 55/21 75/4 84/12
86/13 102/18 103/15
111/7 117/8
evening [1] 2/7
event [5] 8/16 58/2
76/13 91/13 130/4
events [4] 35/5 48/6
60/41 103/3
ever [2] 55/7 71/5
every [5] 43/12 54/13
55/41 106/17 114/1
everyone [6] 1/3 49/2
57/4 57/21 58/19
140/22
everything [3] 107/20
135/2 137/4
evidence [48] 1/16
5/1 5/4 5/6 24/7 21/22
21/23 22/1 22/3 23/14
26/23 27/16 31/13
31/16 35/24 44/8
44/16 44/17 44/22
45/6 60/11 60/18
60/20 60/24 62/8
62/11 63/12 69/2
69/11 69/14 71/22
84/17 95/20 96/22
97/12 97/12 105/24
106/9 114/2 114/10
116/8 116/15 116/20
117/2 126/11 134/4
134/6 135/23
evidenced [1] 27/25
evidencing [1] 21/13
evidential [1] 60/8
evidently [1] 28/4
ex [3] 104/18 105/3
112/12
ex-police [1] 105/3
ex-subpostmasters
[2] 104/18 112/12
exact [1] 135/11
exactly [3] 63/6 66/5
66/17
examination [1]
95/20
examine [3] 74/2
93/12 95/7
examined [1] 127/20
example [5] 27/16
34/4 53/15 72/15
86/12
examples [7] 23/16
23/24 51/13 54/15
106/15 107/18 136/19 I explanations [4]
excess [1] 25/10
exclusion [3] 24/12
24/13 24/16
exclusions [2] 15/12
15/14
executive [2] 67/23
93/21
exemplary [13] 45/13] 61/22 78/17 95/11
46/13 46/18 47/2 47/6 Iexpressed [3] 94/18
A7I11 47/24 48/2
48/12 48/19 48/22
81/18 118/24
exhaustive [2] 42/2
115/19
existence [1] 52/5
existing [2] 13/21
67/24
exists [1] 102/22
expect [2] 40/17
95/21
expected [2] 100/13
119/19
expects [1] 68/22
expeditiously [1]
108/18
expense [1] 139/12
expenses [3] 44/5
422/15 122/17
expensive [1] 131/4
experience [2] 17/19
106/10
experienced [2]
19/25 50/22
experiences [1]
421/11
expert [9] 42/13
42/16 43/12 43/19
43/25 44/8 44/17
44/22 59/25
expertise [1] 43/16
experts [1] 119/22
explain [3] 1/17 40/16
96/12
explained [6] 24/14
70/9 76/12 123/14
134/15 135/3
explains [2] 56/1
62/10
explanation [6] 23/10
51/5 55/24 65/4 95/17
120/22
139/10
explore [2] 24/10
34/19
expose [1] 107/20
exposing [2] 97/24
111/21
express [4] 33/11
108/1 116/19
expresses [1] 33/25
expression [1] 82/5
expressly [5] 42/21
46/8 62/10 63/11
76/11
extant [2] 14/25 15/1
extended [3] 25/3
56/18 58/14
extension [1] 25/20
extent [12] 1/10 3/20
4/1 35/25 36/2 36/4
85/15 87/13 89/19
95/4 128/4 139/19
extreme [1] 112/8
extremely [2] 68/17
108/17
F
face [4] 15/13 46/1
73/16 104/18
facie [1] 83/20
facilitate [5] 1/20 10/4
41/12 82/25 137/16
(46) earnings... - facilitate
INQ00001057
INQ00001057
F 84/11 126/6 138/20 final [50] 7/11 10/2 _ /firstly [5] 12/23 12/24I 122/22
facility [6] 2015 fallen [1] 23/14 44/4 11/43 11/16 13/5 I 18/9 27/22 99/11 formal [5] 10/15 33/4
20/22 23/12 24/4 falling [2] 90/25 13/44 30/12 32/4 32/4 Ifit [2] 15/5 103/12 33/10 80/21 82/10
4123/2 126/8 138/14 32/5 32/6 33/1 35/9 I fits [1] 38/2 formally [2] 67/3 77/5
facing [2] 112/14 falls [2] 62/691/12 I 35/11 35/16 36/12 _ [five [4] 33/159/13 I format [2] 137/13
412/20 familiar [1] 95/45 36/19 58/1 58/7 76/14I 92/11 107/1 139/3
fact [23] 2/6 10/15 families [4] 2/22 4/13 I 76/23 78/21 79/22 _Ifixed [1] 67/18 former [2] 27/12 82/2
15/18 20/19 21/13 96/24 114/9 79/22 80/18 81/6 81/8 Iflag [2] 52/465/11 [forms [4] 14/23 27/15
family [6] 49/9 49/12 I 83/6 83/10 84/7 85/14 Iflagged [5] 45/11 52/3 91/16
23/16 34/24 49/22 49/17 97/1 116/3 87/4 88/14 88/24 53/23 56/10 61/3 88/1 Iformulate [1] 64/4
ae oe ote 1416/4 89/13 89/23 91/4 91/5 I flagging [1] 48/16 formulated [1] 31/16
102/45 103/24 105/18 far [22] 1/4 39/18 40/5) 91/14 91/25 99/23 flags [1] 68/15 formulating [1] 22/15
113/44 1146/5 117/12 41/15 45/17 47/17 99/24 105/8 118/17 I flaw [3] 61/5 61/9 forth [1] 53/17
4120/2 122/10 138/12 47/20 53/18 56/5 118/18 119/16 131/24 I 119/10 fortune [1] 123/13
factor [2] 77/13 79/16 64/22 69/10 71/3 137/8 138/5 flawed [1] 83/16 forward [15] 40/3
factors [1] 56/1 72/17 75/3 76/17 81/7 finalise [1] 11/15 flippant [1] 73/2 48/17 67/17 1041/4
facts [14] 22/23 22/25 84/15 88/24 90/25 finality [1] 3/23 float [1] 57/23 102/9 102/10 102/25
23/5 23/21 46/12 115/14 127/17 136/9 /finally [9] 8/19 10/13 Ifloor [1] 96/4 108/2 114/6 117/14
52/12 52/14 53/4 far-reaching [1] 55/23 68/24 69/23 flowing [1] 43/8 128/16 128/19 129/23
54/13 54/25 55/24 115/14 89/13 90/13 100/14 flurry [1] 140/12 130/5 141/2
7216 72/8 124/9 fashion [1] 99/4 1141/4 focus [6] 15/18 18/14 Iforwards [1] 125/2
factual [2] 5/15 60/20 fast [1] 124/9 financial [19] 4/5 4/14] 33/15 40/19 68/7 94/2 Ifought [1] 103/14
fail [1] 132/20 fast-moving [1] 124/9I 4/16 4/18 4/22 16/13 Ifocused [2] 37/20 found [2] 21/11 106/9
failed [2] 103/11 fatigue [1] 114/5 16/14 19/1 19/1 30/18) 38/7 foundation [1] 7/16
109/25 fault [3] 51/25 62/22 I 39/23 41/23 41/24 focusing [1] 40/8 founded [1] 43/10
failings [2] 103/7 96/21 76/4 100/13 104/6 follow [7] 50/6 80/7 Ifour [5] 15/3 15/7
136/22 feature [1] 119/3 104/18 106/14 132/4 I 90/8 98/24 102/8 31/5 42/18 107/5
failure [2] 113/6 February [4] 4/8 4/10 Ifinancing [2] 16/24 I 113/6 129/14 fourth [1] 44/12
134/14 94/4 104/23 121/21 followed [5] 9/20 60/4Ifourthly [2] 28/6 72/2
fair [27] 11/18 13/24 Federation [1] 67/12 Ifind [2] 82/1 103/25 I 94/2 100/16 101/11 /frame [4] 111/14
24/49 22/18 22/24 feed [1] 106/25 finding [2] 106/10 following [12] 3/18 Ifrankly [1] 64/17
23/6 23/25 30/16 35/2 feel [4] 49/20 55/21 I 114/7 17/16 19/12 20/3 25/4 I Fraser [2] 103/9
35/22 36/14 44/19 107/15 135/20 findings [3] 97/15 28/8 61/25 62/19 64/8 I 103/16
45/7 46/6 47/21 49/20 feels [4] 54/25 55/18 I 98/14 101/5 90/3 95/12 98/25 fraud [1] 84/1
52/13 55/19 72/7 76/2 63/21 113/1 Fine [3] 18/8 66/6 follows [1] 29/4 fraudulent [1] 84/22
76/20 88/16 89/18 fees [12] 13/10 16/25 I 87/23 foot [3] 9/6 21/2 30/9 Ifree [3] 59/14 62/18
93/24 108/10 108/25 27/10 27/16 29/9 finish [2] 92/19 139/8 Ifooting [2] 44/5 67/22] 86/10
115/40 29/17 36/4 42/25 43/3 Ifinished [1] 134/12 Ifootnote [1] 18/23 I Freehills [10] 59/11
fairly [5] 35/15 58/23 71/9 72/12 119/15 I Fiona [5] 117/2 123/6 Ifootnote 7 [1] 18/23 I 59/15 62/13 88/8
84/14 116/25 120/23 Ifeet [2] 133/7 139/21 I 135/23 135/25 136/13 Iforced [1] 131/3 88/10 88/10 88/14
4 fifthly [1] 28/10 [fire [4] 133/8 forensic [2] 27/18 I 89/2 118/9 123/13
es fighting [1] 104/4 firm [2] 28/18 35/21 I 43/14 Freeths [13] 13/6
333 23/13 aura 244 Ifigure [8] 26/12 26/13 firmly [1] 1037 _Iforget 1] 105/1 35/19 36/10 36/17
sao ans dens, I 2719 27/10 27/12 firms [1] 125/4 form [29] 18/6 18/10 I 36/20 37/1 37/10
27/13 66/11 135/11 first [25] 1/7 15/16 I 18/17 19/6 26/19 124/3 124/8 124/8
il 99/19 99/22 figures [11] 8/22 9/10) 25/17 31/6 40/6 40/25 I 28/21 50/20 51/3 124/10 124/13 124/17
Faisal [1] 106/24 25/25 26/1 26/7 26/15 I 42/13 42/20 54/18 51/14 52/2 53/5 53/6 Ifrequency [1] 23/12
faith [8] 28/15 62/19 29/15 66/1 71/5 75/9 I 56/9 56/10 59/6 61/10 I 53/12 53/20 53/24 _—Ifriendly [8] 49/11
75/11 67/41 68/22 69/1 64/8 73/14 75/12 77/9 I 71/13 77/18 77/25
seed omer 84/2 filed [2] 26/6 118/6 I 73/11 82/20 85/19 115/17 115/24 120/8 I 79/17 80/14 116/11
fill [1] 15/8 90/18 93/1 104/16 120/10 120/16 120/21 I 116/14
fall [5] 39/23 50/7 filled [1] 106/17 113/19 116/15 118/8 I 121/25 122/5 122/9 _Ifrolic [1] 110/24
(47) facility - frolic
INQ00001057
INQ00001057
F 1341/4 79/14 112/19 122/7 I 64/4 64/10 65/3 66/18 I 12/12 13/9 13/25 35/3
from [91] 1/15 2/21 funding [9] 7/17/23 I 13/8 132/4 134/17 I 77/22 78/15 78/20 35/12 35/17 35/22
2/05 3/1 3/3.4/12 5/13) 11/12 11/17 12/14 134/19 135/7 136/41 I 92/1 98/6 102/5 37/13 37/16 68/7
14 1016 12116 13/21 I 97/17 98/11 130/22 I 139/9 103/25 108/3 122/8 I 84/18 96/11 96/14
14/24 14/05 14/25 I 1386/4 getting [3] 66/3 73/4 I 123/22 124/9 130/5 I 98/12 98/14 98/16
45/1 15/14 15/22 16/2 Ifunds [4] 9/15 99/18 I 99/5 136/10 140/19 105/16 105/19 107/22
46/6 16/17 16/19 1412/1 125/7 gift [1] 114/15 gone [2] 26/8 101/24 I 108/4 108/10 108/17
16/20 17/6 17/13 further [51] 11/4 12/5 Igive [11] 12/12 54/17 Igood [17] 1/3 1/6 108/25 109/19 110/2
17/22 19/9 23/17 24/7 12/21 25/4 28/6 33/8 I 69/1 87/20 98/12 99/3I 28/15 62/19 63/23 112/7 112/23 112/23
25/2 26/19 26/25 33/19 44/17 48/14 106/9 106/14 1214/3 I 67/6 67/8 82/22 84/24 I 112/24 124/5 131/6
31/16 39/6 40/18 43/8 52/25 53/1 53/2 53/6 I 138/2 140/16 93/1 96/3 123/7 137/23 138/2 138/6
44/24 49/14 50/6 50/8 56/19 59/4 65/17 given [16] 18/23 123/13 123/17 127/24 I 138/9 138/13 138/20
50/18 51/5 51/24 52/2 65/25 67/8 69/15 19/16 54/15 55/14 137/17 144/ groups [2] 94/2 108/1
53/3 53/18 56/12 59/3 I 09/17 70/17 72/3 55/20 59/15 84/15 I got [12] 39/5 79/15 I guess [1] 1/5
60/11 63/9 63/25 64/7 I 72/10 72/22 78/14 93/2 93/4 94/4 97/12 I 122/7 134/14 134/17 I guidance [40] 14/18
64/19 64/23 65/21 83/19 87/7 88/15 100/11 108/18 112/9 I 134/19 134/23 135/11 I 16/17 18/24 19/4 19/5
88/15 89/18 89/23 117/40 137/7 135/17 136/7 136/17 I 20/12 20/25 21/22
an eet eae ont 90/9 92/3 104/6 gives [1] 94/16 136/18 31/9 42/1 42/15 42/16
87/20 89/1 89/21 90/4 I 109/10 109/14 109/3 Igiving [3] 69/14 governance [2] 57/15) 42/17 42/20 42/22
97/1299/15 103/16 I 109/9 109/13 109/15 I 106/11 116/19 57/23 45/15 51/13 51/17
403/16 107/20 107/22I 109/22 117/14 119/3 Iglance [1] 92/1 Government [21] 3/2 I 51/20 51/21 52/1 52/3
408/7 110/11 112/13. I 124/6 124/25 127/15 I Glasgow [1] 4/11 11/11 11/17 12/8 52/5 53/19 53/22 54/9
442117 113/5 114/6 I 128/17 139/21 139/25 IGLO [50] 6/4 7/20 12/25 13/4 35/19 54/10 54/23 56/6
414/16 116/16 11711 I 140/15 140/19 12/9 12/10 12/12 67/21 89/16 89/21 I 60/17 60/21 63/3
418/8 120/11 122/20. [future [2] 108/4 12/13 12/24 13/1 13/6] 93/6 98/22 98/24 74/16 71/19 82/25
429/2 129/14 130/01 I 125/42 13/9 35/7 35/14 35/21] 103/6 105/17 109/14 I 83/3 115/7 121/13
431/25 132/1 13314 IG S*S*~*~S~*«*«(8N SGN BOIZA I MONON 141/44 19226) 121/14 120/22
44016 3 36/25 37/2 37/4 37/9 I 137/18 137/21 guided [2] 22/17 23/2
front [3] 14/9 74/24 Gallafent [20] 3/1 37/21 37/25 83/17 IGovernment's [2] q...
ooite 38/15 38/24 39/9 84/22 96/1196/13 I 94/24 105/15 a
39/10 47/3 57/10 97/23 98/7 98/12 grasp [1] 102/23 habit [1] 75/5
frustration [1] 116/19) 64/99 79/2 87/10 92/7 I 98/14 98/16 99/18 Igrass [1] 137/2 had [62] 2/14 3/12
Fujitsu [2] 27/2 11218 112/22 117/9 11915 I 400/15 100/19 100/19] grateful [10] 39/12 I 3/17 4/15 4/17 4/20
fulfil [2] 93/22 94/10 I soqr44 421/22 122/21II 100/23 105/9 107/17 I 41/20 52/18 75/7 I 8/2 8/5 9/7 9/10 918
full [6] 7/10 27/12 I 12816 139/22 142/3 I 08/4 108/23 425/1 I eart1 92/4 93/e 96/17 I 10/8 10/14 11/5 1317
woe Taps na 8 Gareth [1] 107/21 I 425/13 126/3 126/16 I 102/17 133/1 13/13 13/14 15/3
93/04 94/8 101/20 (Save [9] 5/11 26/22 I 132/19 137/22 137/23] gratitude [1] 106/5 I 19/19 26/18 26/20
65/25 66/11 69/11 I 13/2 138/3 13/2 I grave [2] 105/3 27/3 29/16 31/16
‘oa TOT 115/24 I 41772 135/10 135/23. Igo [19] 25/23 30/8 I 11718 32/12 32/23 32/24
fullest [1] 89/19 136/17 65/10 82/6 91/12 98/6 I great [3] 47/5 129/17 I 35/19 40/24 50/22
unest i] general [3] 81/11 I 107/22 114/9 115/15 I 129/20 52/16 52/17 56/21
fully [8] 30/15 45/22 \"+94720 13013 120/7 12716 12722 I greater (9] 24/9 54/10I 58/12 67/21 69/15
PO ert 2” Igenerally 11] 30/4 I +3379 139/16 135/15 I 54/22 58/3 56/5 60/19I 74/7 74/9 86126 9618
. 32/19 40/3 43/6 44/11 I 4136/8 136/9 137/5 78/8 95/22 129/6 96/9 103/10 104/1
function [1] 94/19 I aio s7it6 78/14 I 438/17 greatest [1] 105/21 I 104/16 107/6 108/5
functioning [1] 41/4 I 99/6 94/15 97/1 goes [7] 28/16 56/4 I ground [6] 2/13 17/10I 116/21 117/3 11713
faretions [2] 93/23 Igenerated [1] 6/9 I @5/24 79/16 8319 I S021 56/23 5815 I 117/12 120/5 1239
generic [2] 44/9 84/5 88/18 70/5 123/10 124/23 125/19
Re ence I 118/20 going [31] 1/71/11 grounds [3] 23/14 I 134/10 134/12 1386/1
lunded [2] Geoffrey [1] 107/8 I 4/14 2/13 9/2 12/2 I 7/12.83/20 135/5 138/4 138/10
aera) ogg (9etl"] 1198724 I 42122 14122 24/15 group [43] 0/2 6/3 I 140/1
junders [2] 63/9 64/14 66/20 73/1 I 39/7 48/17 50/4 58/4 I 6/24 8/2 8/6 8/10 hadn't [3] 41/16 51/23}
(48) from - hadn't
INQ00001057
INQ00001057
H
hadn't... [1] 136/7
half [7] 26/5 26/13
29/15 36/19 74/12
74/21 74/21
halfway [1] 128/25
Hamilton [4] 126/11
hand [4] 2/2 36/9 48/9)
115/15
handed [1] 6/12
handled [1] 118/3
handling [1] 123/9
hands [3] 38/18
105/15 114/4
happen [3] 37/17 64/6I
140/10
happened [7] 104/10
1241/6 121/11 127/13
129/11 1341/5 134/5
happening [4] 101/15
101/18 102/20 134/5
happens [1] 139/25
happy [4] 41/13 69/4
78/22 90/5
harassment [1] 17/2
hard [1] 102/23
hardly [4] 1/5
hardship [9] 30/18
30/19 76/4 76/5 76/18
77/12 112/19 112/20
112/23
harm [3] 104/6
106/12 115/21
has [120] 3/20 4/1
10/17 10/21 10/24
10/25 12/8 14/4 18/3
18/19 20/12 23/12
23/14 23/19 23/24
24/21 25/10 25/18
26/8 27/5 27/7 28/17
28/18 28/25 29/1
29/13 29/18 29/21
30/4 30/16 33/19 34/2
34/4 35/23 35/24 36/7
A1INT 44/8 44/16 45/5
45/18 49/10 49/16
49/24 54/6 55/13
55/19 56/25 59/17
59/18 60/5 61/15
63/20 63/22 69/8 71/4
7112 71/24 72/6
72/12 72/25 74/25
75/12 81/4 81/19
82/12 82/22 85/23
86/5 86/16 89/15
89/16 94/1 94/5 94/8
94/10 96/22 98/4 98/8
98/16 98/18 101/1
101/21 102/11 102/20
103/7 104/10 104/11
104/22 104/25 105/6
106/12 106/15 106/19
107/6 109/20 109/24
1411/2 115/13 116/10
116/20 117/9 120/4
121/6 121/11 123/18
123/24 124/23 127/5
127/13 127/17 129/8
130/10 130/16 130/18
131/22 132/24 137/41
137/21 139/13
hasn't [1] 55/22
have [266]
haven't [4] 41/9 41/15
55/14 90/10
having [24] 1/24 4/15
4/17 4/20 9/3 23/17
45/20 49/18 51/5
53/25 62/18 63/20
84/16 91/18 93/2
97/11 97/13 117/8
120/2 121/9 125/19
133/7 133/21 140/1
Hazzleton [1] 107/2
he [25] 12/7 12/24
13/4 26/18 26/18
26/20 26/20 26/21
26/22 69/10 69/11
83/19 83/23 87/11
87/13 87/15 106/19
106/22 106/25 106/25
116/20 129/13 130/2
136/15 136/16
head [5] 42/8 45/11
67/15 67/19 68/5
headed [2] 21/3
114/16
heading [4] 9/25
49/11 21/3 21/21
headings [1] 16/21
heads [24] 15/11
15/13 15/16 17/21
22/22 23/4 41/1 41/19
42/14 42/17 42/19
45/15 49/8 50/16
52/41 55/14 70/2 70/7
TTAT 115/18 115/19
121/17 122/24 131/8
health [5] 44/9 45/4
104/7 121/12 121/12
hear [11] 1/5 2/24 5/6
58/6 59/2 90/4 94/3
94/14 110/4 127/10
129/24
heard [20] 4/12 35/15
52/2 77/15 84/16
84/19 96/23 97/4
97/41 98/10 102/2
102/13 107/20 112/22
116/8 128/2 133/21
134/5 134/6 136/19
hearing [18] 1/16
1/24 1/25 2/20 39/22
40/4 90/5 104/16
108/20 109/23 110/11
113/15 127/18 129/24
139/13 139/20 140/6
14115
hearings [34] 1/8
1/21 2/4 4/9 5/10
26/18 39/19 52/20
64/9 64/9 69/2 93/9
94/1 94/2 94/6 94/12
94/12 95/3 95/12
95/16 96/23 97/13
102/3 104/23 105/6
106/7 106/10 112/13
127/1 129/6 133/2
133/6 134/7 140/12
heart [1] 132/8
heartrending [1]
110/20
height [1] 24/20
held [5] 61/2 61/7
62/20 116/23 133/7
help [4] 54/14 72/23
120/14 122/9
helped [1] 110/18
helpful [4] 64/16 69/3
106/9 133/19
helpfully [1] 69/20
helping [4] 11/18
hence [1] 46/6
her [17] 31/19 34/2
38/24 107/3 107/6
120/11 121/22 123/10
123/17 134/10 134/12
134/13 135/3 135/4
135/9 135/10 135/10
Herbert [10] 59/11
59/15 62/13 88/7 88/9
88/10 88/13 89/2
118/8 123/12
here [10] 1/21 30/24
39/1 68/14 80/1 85/16
120/21 134/16 135/25
136/4
high [7] 24/6 96/16
1041/3 103/15 104/5
105/6 105/21
higher [3] 30/7 55/1
60/6
highlight [3] 40/13
61/10 119/23
highlighted [1] 87/5
highly [1] 133/10
him [5] 34/2 106/20
136/15 136/16 136/17
his [17] 31/18 35/8
68/6 68/25 69/6 69/7
69/13 69/14 69/21
84/2 88/1 105/3 105/4
106/20 107/1 129/13
130/3
historic [4] 3/24 3/25
4/2 119/21
historical [24] 3/8
7/7 8/3 13/21 14/9
14/11 14/14 14/16
14/18 14/20 14/23
40/22 45/9 67/15
67/19 67/24 68/2 68/5
68/6 68/8 68/10 77/10
80/22 138/7
history [1] 105/22
HMRC [3] 85/24 86/1
86/4
Hodge [6] 83/7 83/15
83/23 85/2 85/5 88/5
hold [2] 30/6 55/17
holding [1] 112/12
holds [3] 22/4 86/18
86/21
hole [1] 132/5
Holmes' [1] 105/2
home [1] 134/23
homes [1] 104/19
Hooper [1] 114/22
hope [9] 33/7 75/8
83/2 119/17 120/11
4123/1 123/20 126/14
139/5
hoped [1] 82/16
hopeful [2] 2/9 2/10
hopes [1] 109/21
Horizon [26] 4/15 6/9
6/14 8/9 17/4 18/21
24/11 21/12 21/115
42/5 43/1 55/15 71/21
77/20 79/20 97/24
103/8 103/11 103/18
103/18 103/19 103/20
103/22 110/18 111/22
136/23
horse [1] 115/4
hounded [1] 96/20
hour [3] 134/17
134/18 134/19
hours [2] 92/13
123/24
house [6] 12/21 107/6)
107/9 128/25 134/24
135/1
how [10] 8/15 20/4
25/12 38/1 55/24
56/14 57/7 58/18
125/1 126/25
Howe [27] 3/4 12/17
17/46 20/12 29/24
34/7 31/12 31/20 37/5
37/7 42/14 45/12 49/7
60/9 61/5 68/24 71/11
73/22 75/15 85/19
86/8 96/4 105/13
111/4 123/8 124/22
125/3
however [10] 4/7 10/5
16/6 33/19 45/20
46/22 68/4 126/17
136/22 138/18
HSS [44] 7/17 8/7
10/8 14/12 15/12
15/18 16/7 17/8 17/12
17/14 17/20 18/17
22/13 25/19 26/25
27/7 29/20 29/22
29/25 30/4 30/13
47/7 57/16 91/10
113/18 113/25 114/25
(49) hadn't... -HSS
INQ00001057
INQ00001057
H 86/18 91/19 I make [6] 40/6 44/12 I1 would [9] 14/1 36/16] ignorant [1] 101/18
HSS... [17] 115/18 I can't [4] 2/6 64/7 88/22 110/7 39/11 49/24 55/16 _ illness [3] 30/19 31/4
415/19 146/16 1147/1 I! cannot [1] 106/18 I 110/8 73/15 83/11 95/21 76/4
4118/7 119/3 119/10 I! Carried [1] 135/18 II mean [5] 47/5 73/1 I 140/9 illnesses [1] 104/22
420/2 120/5 122/12 I! certainly [2] 64/11 I 88/15 96/12 129/2 [I'll [4] 57/23 96/11 imagine [1] 1/18
4123/6 123/21 126/1_ I 129/18 I meant [1] 34/9 134/18 140/10 immediate [4] 88/22
432/20 133/11 133/23 I! Confirm [1] 91/13 II mentioned [3] 34/10II'm [29] 2/2 2/13 12/2 I 111/16 112/17 132/4
439/10 I could [1] 135/22 T7917 135/23 12/22 24/15 38/1 39/7 immediately [3] 99/12
Hudgell [16] 12/17 {couldn't [2] 135/17 II might [2] 87/11 48/15 48/16 57/9 104/9 127/2
1747 2013 2900 I 136/9 128/3 64/14 65/3 65/7 65/22 Iimminent [1] 104/18
33/13 33/14 33/21 Ideal [1] 127/2 I move [6] 41/18 49/5 I 75/2 75/4 75/7 78/20 jimpact [12] 4/9 26/18
34/19 54/9 54/15 I didn't [1] 140/13 56/8 59/3 65/2 75/14 I 79/6 95/16 99/5 49/18 69/2 76/6 76/15
54/20 59/6 68/15 701g I 40 [7] 2/4 42/23 I need [1] 61/23 100/20 114/3 121/2 I 94/2 96/23 97/13
81/13 82/3 65/11 73/1 79/16 I never [2] 135/11 129/2 136/3 137/25 I 102/3 106/10 134/7
Hudgells [4] 51/10 80/11 136/6 136/18 140/14 140/18 impacted [2] 30/14
huge [2] 111/17 436/5I! don't [6] 61/11 66/13)I note [2] 78/22 84/2 II've [1] 77/5 76/1
human [10] 4/9 26/16 68/14 79/9 135/11 I pick [2] 59/3 59/4 i.e [11] 10/22 21/9 impede [1] 2/1
26/17 69/2 94/2 96/23 I 140/20 I published [1] 23/12 23/19 26/3 26/5 Iimplementation [1]
97/13 102/3 106/10 I! drove [1] 134/23 140/11 26/9 28/21 31/15 4/2
4134/7 lemphasise [4] 49/10/I put [4] 57/12 58/9 I 34/21 55/7 implications [2]
hundreds [1] 136/4 60/4 66/23 80/4 TAI9 128/23 identified [14] 14/2 I 69/23 70/2
hurdles [1] 115/3 I emphasised [1] I quote [1] 120/11 15/4 15/6 15/8 39/14 important [12] 21/24
husband [2] 105/2 47/16 I raise [1] 38/12 45/19 46/1 46/7 68/25 I 80/20 80/25 81/3 83/4
4135/5 lemptied [2] 134/24 I recognise [1] 49/1 I 72/2 84/6 88/16 93/11 I 93/12 97/10 106/7
I 134/25 Irefer [1] 96/13 100/5 108/17 114/20 119/23
I lended [1] 136/7 I require [1] 64/7 identifies [1] 8/11 128/12
laccept [1] 58/3 I feel [1] 107/15 I said [1] 38/8 identify [5] 14/1 18/18Iimpression [1] 73/1
ladded [1] 104/20 I finish [1] 139/8 I say [3] 37/18 95/16 I 53/2 53/6 54/21 imprisonment [1]
laddress [1] 40/23 I first [1] 93/1 140/21 if [73] 2/11 3/204/4 I 4/20
l addressed [1] I focused [1] 38/7 [I see [1] 9/4 7/24 8/20 8/24 9/9 improvements [1]
104/15 I get [1] 73/1 I set [2] 104/17 16/9 16/11 18/1 18/4 I 3/22
lagreed [1] 1/22 I! got] 136/8 113/10 19/6 20/2 20/13 21/19 Iinadequacy [1] 75/12
lalso [1] 112/6 I got [3] 134/23 I should [1] 128/4 I 22/17 25/18 25/23 __Iinadequate [2] 71/10
1am [14] 2/9 2/10 135/17 136/17 I start [1] 40/22 28/16 29/1 30/8 32/7 I 121/25
38/4 38/4 48/25 48/25 I! had [4] 2/1452/16 [I started [1] 137/5 I 37/17 39/6 43/25 inappropriate [3]
58/4 63/17 78/22 52/17 135/4 I stress [1] 64/6 47/22 48/1 50/25 55/6 78/19 118/23
107/14 140/14 Ihave [14] 35/20 I take [3] 38/15 120/8 I 57/12 57/17 62/20 _Iincapable [1] 111/7
I anticipate [1] 88/2 I 46/24 72/2 75/5 78/23) 120/18 63/20 63/21 64/6 include [8] 16/22
I anticipated [1] 87/5 92/18 104/24 II then [2] 73/21 64/11 66/6 66/16 69/3 I 17/16 20/7 35/14 54/3
140/12 105/5 106/16 108/20 I 125/15 69/3 70/21 73/21 81/18 116/2 127/4
I appear [2] 2/23 96/3I 138/24 139/5 139/21 II thought [3] 34/11 I 78/24 79/2 79/3 79/13 Iincluded [6] 4/21 18/5
I appreciate [1] 38/25I! hear [1] 59/2 80/17 107/13 82/6 83/7 83/14 86/9 I 46/10 85/8 116/17
Lask [3] 38/24 92/9 I! hope [2] 120/11 I turn [2] 35/2 130/20 I 90/2 91/17 96/12 124/25
139/23 4139/5 I want [1] 99/5 98/25 101/9 101/9 _jincludes [4] 8/14
lasked [3] 105/23 I! indicated [1] 89/25 II wasn't [1] 39/5 102/8 109/5 110/9 15/25 52/22 76/3
1428/5 136/15 I just [5] 40/24 42/10 II went [1] 136/14 1412/4 114/11 114/24 jincluding [15] 3/8
lassure [1] 58/21 61/10 89/13 100/17 II were [1] 129/7 115/10 119/22 124/13 I 4/19 6/19 28/15 30/17
I brought [1] 135/21. I! know [2] 34/15 Iwill [42] 15/7 17/15 I 128/22 129/7 129/11 I 44/9 46/9 49/12 68/8
I butting [1] 128/7 130/2 22/9 50/5 64/3 64/9 I 129/19 133/14 139/5 I 68/19 72/8 94/16
lean [11] 2/15 41/12 leave [1] 63/24 66/7 79/25 92/13 139/23 139/24 141/2 I 95/20 127/22 139/20
56/25 57/11 57/18 lifted [1] 134/24 100/19 140/3 140/16 if! could [1] 16/9 inclusion [1] 85/6
65/17 79/6 81/13 85/9 II look [1] 141/2 I wonder [1] 113/19 Iignorance [1] 102/5 IIncome [1] 70/9
(60) HSS... - Income
INQ00001057
INQ00001057
I individuals [10] 96/13) 130/1 133/3 133/5 103/2 110/17 111/12 Iirremediably [1]
——______I 97 105/1 1103 I 135/14 411/20 112/9 118/18 I 75/25
income tl 4234 124/20 127/22 IInquiry's [4] 2/1 I 124/16 125/15 125/16 lirrespective [4] 30/25
cea 4132/6 132/10 139/15 I 39/24 84/12 116/15 I 125/19 126/9 126/19 isn't [2] 46/7 84/4
inconvenience [11] IiMdulge [1] 13923 insofar 1] 83/16 I 120/4 12018 129/18 isolated [1] 3/17
45/2 46/4 49/13 49/16 indulgences [1] insolvency [2] 16/25 I 129/19 130/24 131/7 Iissue [54] 3/12 3/19
sort S012 S88 sen I 11517 12424 4132/1 19216 139/3 I 11/1 1516 15/10 15/11
73/13 73/20 74/15 Industrial [2] 9/14 instances [1] 27/23 internally [1] 61/13 I 17/14 20/12 20/15
increased [2] 16/24 103/5 instantly [1] 112/19 Iinterpret [1] 113/13 I 24/10 24/16 25/17
171/20 ineligible [1] 138/6 instead [10] 30/1 30/6linterpreted [1] 41/16 I 27/1 27/5 29/18 34/7
incur [2] 7113 inevitably [3] 53/14 I 31/2 32/25 3965 30/14 intervene [1] 87/19 I 32/3 32/6 3217 3219
TBI 55/9 78/13 404/10 110/14 117/4 linto [34] 4/19 13/20 I 33/21 34/17 37/6
incurred (5) 21/13 infect [1] 10322 I 429/15 49/19 19/21 20123 I 41/14 41/16 46/3
ToS tae dono _ information [34] 6/9 institution [1] 1419/1 I 22/23 23/5 3913 43/17 I 49/12 57/24 59/6 61/3
pong 9/25 10/24 19/15 20/8 institutions [3] 97/15 I 45/22 45/24 46/2 I 68/15 68/19 70/18
indeed [7] 81/2 57111 I 2932/18 82/25 63/2, 108/6 113/16 49/17 49/21 5212 I 70/21 72/25 73/18
Torte tOy/tt 10429. I 53/9 84/2 61/2 61/6 instruct [7] 36/22 I 53/20 54/4 8612 56/4 I 81/20 82/1 82/3 84/5
113/13 11304 SING 61/8619 I 36/25 37/237/21 I 56/2072/6 94/18 _I 85/6 87/25 89122 90/2
indemnity [1] 70/20 62/23 63/9 64/22 37/25 124/13 124/20 I 111/4 115/25 116/6 I 90/17 97/9 106/7
independence [2] 66/19 69/10 69/16 instructed [2] 96/4 I 122/18 126/7 131/24 I 108/10 110/15 113/22
60/3 118/5 69/17 69/17 70/17 123/12 134/13 134/17 134/23 I 117/6 128/5 132/15
independent [26] 72/4 89/1 102/6 instructing [4] 102/15] 134/25 135/2 137/2 I 137/3
14/13 16/7 16/12 109/13 110/14 116/22 I 111/3 112/3 133/5 introduced [1] 51/17 Iissue 6 [1] 32/5
22/12 27/6 28/20 informed [1] 104/24 [instructive [1] 74/2 I introducing [1] 41/20 issued [1] 12/18
28/22 32/8 41/7 44/24 inherent [1] 89/7 insufficient [2] 44/16 Iintroduction [2] 1/17 Iissues [66] 1/9 1/13
inheritance [1] 7219 2/2 1/15 2/20 3/17 3/18
ecenr eee done 106/16 intend [1] 40/18 inverted [1] 64/5 3/24 5/8 5/18 6/13
70/22 78/12 86/7 initial [4] 46/17 56/18 Iintended [4] 8/8 investigated [1] 6/14 6/19 13/15 13/18
86/24 109/6 118/12 I 88/5 119/8 12/25 39/19 39/21 29/23 13/20 13/22 13/24
118/22 130/25 initially [1] 25/4 interest [1] 91/2 investigation [2] 14/2 14/7 14/8 15/3
indicate [1] 64/12 initiative [2] 23/16 interests [6] 20/17 I 19/21 62/13 15/7 15/13 17/6 17/15
indicated [11] 41/17 23/20 36/5 36/24 37/2 37/9 IInvestments [3] 3/2 I 21/12 21/12 28/7 31/5
59/16 75/22 76/25 injury [6] 17/4 44/15 I 37/24 93/6 103/7 32/14 34/6 35/3 35/4
77/5 T7I17 86/24 50/1 50/3 53/17 72/16 Iinterfere [2] 34/25 _ [invitation [6] 39/14 I 35/13 35/24 36/4
89/25 91/3 93/7 94/21 Inquiries [1] 97/7 128/14 39/18 40/19 84/6 37/11 38/9 39/13
inquiry [60] 3/13 3/19Iinterim [74] 4/3 9/16 I 88/19 140/24 39/16 39/22 40/9 44/9
indicates [1] 81/22 mae
indication [6] 40/11 4/7 10/24 11/25 17/18 I 10/5 10/10 10/20 invite [5] 13/19 16/9 I 44/10 45/5 45/20
63/24 64/17 65/8 23/10 29/10 32/18 10/25 12/25 29/19 20/24 112/24 138/25 I 48/17 60/7 69/9 82/17
75/12 104/14 35/23 36/7 36/19 37/5 I 29/21 29/25 30/4 invited [5] 13/17 85/17 90/14 93/3 93/9
indications [2] 137/7 41/13 64/22 67/21 30/11 30/17 30/20 18/17 81/10 108/23 I 93/11 93/12 93/15
437/12 68/1 68/12 69/3 69/5 I 30/22 30/25 32/15 129/83 94/9 94/16 94/23
indirect [1] 49/18 70/23 72/24 84/16 32/23 35/7 35/16 involve [1] 87/13 102/2 106/1 108/19
indirectly [1] 60/7 84/16 88/21 90/1 90/4 I 36/12 75/14 75/16 _Iinvolved [6] 28/9 109/15 137/2 140/5
individual [15] 33/17 93/2 93/8 93/12 93/13 I 75/20 75/23 76/9 81/24 89/15 96/7 it's [48] 16/16 18/16
36/21 37/21 53/4 94/5 95/11 96/7 97/11 I 76/13 76/15 76/18 100/16 125/4 24/6 28/11 29/8 31/11
67/16 72/20 7/47 97/21 102/17 103/25 I 76/24 77/11 77/13 involvement [3] 83/9 I 31/20 33/9 35/22
81/14 83/6 83/10 104/16 104/21 104/22 I 78/2 78/4 78/11 78/18 I 89/23 94/22 36/19 39/1 43/24 44/1
99/10 99/25 100/12 I 105/25 106/6 108/6 I 79/9 79/12 79/22 involving [2] 45/4 47/12 50/21 54/12
109/22 110/6 110/23 I 85/22 91/5 91/9 91/14 I 119/20 56/3 58/2 60/9 61/13
102/4 103/21 1
individually [2] 34/6 1141/4 112/14 113/14 I 95/10 97/6 97/9 97/17 Iirredeemably [1] 63/5 63/13 70/5 70/13
34/17 114/20 124/19 124/25 I 98/22 99/11 99/16 30/14 70/23 75/5 75/15
125/9 125/9 130/1 99/24 102/9 102/24 irrelevant [1] 53/14 I 75/47 77/17 7/22
(1) incomplete - it's
INQ00001057
INQ00001057
I jump [1] 115/4 knows [2] 36/8 46/17 47/10 47/12 63/25 64/16 80/9
it's... [18] 79/18 79/21 June [20] 8/22 9/7 9/9I 129/14 47/13 47/23 47/25 81/23 83/11 88/12
81/3 81/20 83/4 89/3 I 9/12 12/20 15/2 19/8 L 48/2 48/7 50/10 55/17 I 90/4 101/9 107/15
25/25 30/2140/12 I=__I 59/7 59/9 59/10 59/21 I 107/21 120/25 121/3
oe nN 65/9 65/25 66/2 97/3 Ilack [5] 60/23 75/2 I 2/13 70/22 70/25 (I 127/16
417/15 120/5 120/20 I 110/13 1143/7 119/14 I 103/23 11216 118/5 I 74/4 71/9 72/9 72/12 likelihood [2] 21/9
422/47 133/13 123/7 126/14 140/11 [lagged [1] 56/10 72/22 74/7 74/9 75/13 I 129/17
items [1] 106/23 /Yune 2020 [1] 15/2 laid [2] 7/15 129/9 I g6/24 89/9 91/19 98/1 Ilikely [15] 24/6 27/24
its [47] 2/8 3/22 8/5 Iune 20202 [1] 12/20 large [4] 38/25 54/16 I 100/3 100/11 101/20 I 28/41 34/1 46/2 55/2
45/13 15/17 22/15 June 2022 [1] 9/12 133/10 139/19 103/13 105/22 109/6 I 73/5 78/7 81/23 82/6
28/19 28/23 28/24 (\iust [34] 1/17 16/21 largely [4] 32/18 71/3I 446/12 117/20 117/24 I 92/16 117/21 133/14
31/24 40/2 41/7 54/13 I 26/20 37/20 40/24 I 81/5 82/22 119/12 119/15 119/21 I 137/8 137/43
42/10 46/11 48/18 largesse [1] 115/17 I 4120/6 121/19 122/3 likewise [1] 132/20
oom Ron Rone. 52/16 52/22 55/5 last [17] 11/9 18/46 I 422/15 122/15 122/17 Ilimit [2] 58/5 58/7
93/7 93/17 93/18 57/23 59/23 61/10 I 26/6 28/24 34/4 34/8 I 123/23 125/14 130/25 I limitation [4] 58/2
94/10 94/19 94/22 I 66/18 69/7 74/11 34/9 34/13 66/1 66/12) 1341/9 131/9 131/14 I 71/25 79/20 101/20
98/2 103/4 103/11. I 74/12 79/8 79/13 100/18 102/15 102/18 I 434/20 131/24 132/8 Ilimited [24] 72/9
403/12 103/20 103/22 I 89/13 90/15 92/1 92/9 I 104/15 105/12 118/20) 432/11 132/16 132/24] 1041/3 107/16 108/8
404/4 104/9 104/13 I 96/11 100/17 10716 I 130/12 legally [1] 120/2 113/21 114/23 114/25
406/1 109/12 110/15 I 117/3 120/42 1297 late [7] 34/15 56/11 length [1] 129/6 1145/2 115/6 115/23
110/24 115/24 122/16) 129/16 134/7 134/10 I 58/17 58/20 65/15 lengths [1] 56/16 I 146/10 117/6 118/7
136/19 85/24 102/14 less (10] 2/11.8/1 I 118/17 118/23 119/7
eetiwone® justice [4] 3/14 103/9 Ilater [6] 2/24 5/9 26/5 59/18 64/19 122/16 123/4 123/20
itself [19] 18/10 31/20I 103/16 105/21 39/21 90/8 113/8 70/11 76/14 82/10 I 124/2 130/16 130/23
37/13 42/20 42/29 Iiustifiable [2] 57/6 I 114/20 84/15 126/19 138/13 138/19
48/5 51/24 53/20 67/13 latter [1] 27/13 lesser [1] 55/3 Limited's [4] 117/16
53/24 54/9 57/16 justification [1] 88/23Ilaw [2] 28/18 81/22 test [4] 48/24 limits [2] 49/1 83/17
59/20 74/10 119/2 _ Iiustified [2] 46/12 lawyer [2] 51/6 123/2 ILet [2] 30/2 106/14 line [4] 18/16 40/7
42018 121/4 13316 I 49/22 lawyers [4] 1/15 1/19 Ilet's [4] 79/7 79/13 I 40/41 43/5
433/11 140/5 K 1/24 104/12 120/21 134/4 lines [2] 109/11 134/8
lay [5] 28/2 51/4 letter [10] 36/17 linked [2] 42/4 56/9
J Kay [1] 114/19 51/46 120/14 122/10 I 36/48 56/1 62/7 62/8 [Linnell [2] 114/19
Jacobs [1] 96/4 keen [2] 57/3 90/6 lead [1] 55/10 62/25 63/1 63/10 114/19
January [1] 68/3 keeping [1] 101/17 Ilearn [1] 120/41 70/16 124/8 list [5] 3/17 35/4 42/2
jewellery [1] 106/16. IKey [4] 21/3 2214 53/4 learned [1] 122/20 _tetters [6] 85/17 63/11 98/23
JFSA [4] 36/6 36/9 I 71/18 learnt [1] 130/11 65/20 67/1 70/10 77/6 Ilisten [3] 64/4 90/7
36/22 37/22 kicked [1] 137/2 least [8] 31/23 54/12 I 492/20 133/14
kicking [1] 111/3 66/25 77/6 11/5 _ level [6] 17/9 54/19 listened [2] 117/8
Jones [6] 83/7 83/15 I
83/23 el 85/5 88/5 kind [3] 9/5 57/24 A17/7 126/12 130/15 I 54/24 74/2 93/19 421/22
i 92/10 leave [5] 40/20 58/24 I 428/21 listening [3] 5/19
Madge [3] 6112393 knew [1] 36725 I 63/24 90/1 13679 ability [2} 716 84/12 I ga/ta oa/ta
judgment [4] 6/14 [Know [23] 5/16 27/8 leaving [1] 9/4 liable [1] 70/12 lists [1] 62/8
6/14 24/12 21/12 34/15 38/6 64/20 led [1] 20/12 liaise [4] 91/20 Litigant [1] 108/25
judgments [3] 6/13 I 79/1996/3 97/22 I Leeds [4] 4/11 life [1] 97/4 litigants [11] 96/41
6/13 103/9 97/25 98/2 98/21 left [3] 17/25 102/4 I lifetime [3] 75/6 97/20I 96/13 97/23 98/7
July [15] 119/13 I 102/49 10676 108/2 I 138/9 104/21 99/18 99/20 107/17
111/24 112/13 112/18 legal [78] 5/13 6/23 lifted [1] 134/24 108/24 125/1 126/16
9/22 10/8 66/4 66/22
66/23 67/20 81/4 91/8 127/3 130/2 132/12 I 13/10 16/25 17/13 Hight [5] 5/4 14/3 60/2I 132/19
133/2 135/4 135/11 I 24/1 27/6 27/10 28/4 I 93/23 95/8 litigation [46] 5/25
109/23 118/20 129/13 gation [46]
440/15 141/5 known [6] 6/2 7/16 I 28/13 28/25 29/9 like [22] 5/21 18/12 I 6/2 6/3 6/5 6/12 6/17
21/25 98/4 128/13 I 29/17 32/8 36/3 42/4 I 20/2 38/16 39/11 44/7 I 6/25 7/1 7/8 7/21 7/23
July 2021 [1] 10/8
July 5 [4] 66/4 139/4 42/24 43/2 43/14 50/24 57/18 58/9 8/2 8/6 8/10 13/25
(2) ifs... = litigation
INQ00001057
INQ00001057
L loss [90] 4/23 8/9 6/2 11/22 52/24 23/5 24/10 25/2 25/12
litigation... [31] 33/8 14/17 15/11 15/14 ILuncheon [4] 92/22 Imanaging[1] 6/12 I 26/16 27/4 27/14
35/3 35/12 35/17 15/16 16/17 16/22 Iluxuries [1] 131/9 —_Imanifest [1] 106/13 I 27/21 28/2 28/5 28/7
16/22 16/23 16/23 II manner [2] 76/20 I 28/10 29/12 30/3
see ren aos 4/19 I 16/23 17/5 17/24 Mo 4137/7 30/24 32/21 34/18
86/13 96/14 98/3 18/23 18/25 19/1 19/2 Imachine [1] 92/18 Imany [22] 1/19 4/24 I 35/13 37/6 38/6 38/9
105/16 105/19 107/22I 19/3 19/4 20/3 20/4 made [147] 27/23 53/14 73/2 94/3 I 39/14 39/17 39/19
408/11 108/17 110/2 I 20/4 20/5 20/6 20/14 main [3] 10/21 12/23 I 101/23 102/21 103/8 I 40/10 41/17 43/1
413/23 113/24 123/19 I 20/19-20/25 21/13 I 127/18 104/17 106/8 107/18 I 43/20 44/18 45/1 45/3
4oaie 125/13 1314 I 21/14.21/44 22/2 maintain [1] 11/22 I 444/47 112/11 114/3 I 46/8 47/18 50/6 52/19
4346 137/22 137/23. I 22/22 23/4 23/16 major [1] 141/1 114/3 114/11 116/5 I 63/9 56/13 57/12
438/14 138/20 23/48 23/18 23/22 —_Imajority [3] 17/17 I 417/22 1214/3 133/14 I 57/13 59/16 60/12
litigious [2] 12315 I 29/23 29/23 31/8 41/1 34/21 47/16 4141/2 60/14 60/19 61/16
437/14 41/19 41/22 41/22 I make [54] 2/5 3/22 IMarch [12] 4/8 4/10 I 61/18 64/6 64/6 65/4
little 9] 5/21 15/8 I 41/23.41/24 41/24 6/20 11/43 12/11 4/14 11/24 12/4 69/20 I 65/16 66/18 67/20
20/7 63/25 64/24 42/1 42/2 42/8 42/14 I 12/25 17/14 29/21 I 9/22 98/10 98/15 I 68/14 68/17 69/6
78123 107/21 13911 I 42/19.43/2 45/11 30/15 38/24 39/13 I 108/15 137/19 138/16 I 70/10 70/15 70/21
4140/1 45/16 46/20 49/5 49/8 I 40/2 40/6 40/24 41/8 IMarch 2022 [1] 11/24 I 71/14 72/18 72/19
live [1] 107/10 50/16 50/25 52/11 I 42/18 43/11.43/19 I Marian [1] 105/1 73/8 73/21 79/12
lives [5] 96/8 96/9 I 52/24 83/10 54/3 54/6 44/12 48/24 62/9 64/7 IMarion [1] 106/15 I 84/18 81/23 83/3
96/25 104/6 114/8 I 95/4 55/14 5/24 56/3 I 65/22 66/7 75/16 76/2Imarked [1] 52/16 I 86/25 88/2 90/17 93/1
loans [1] 4/23 60/17 70/2 73/14 86/17 88/22 90/19 I market [1] 107/7 95/11 95/14 99/20
locking [1] 134/18 I 79/19 74/14 77/17 93/5 97/5 97/15 98/7 IMarshall [4] 83/19 I 104/20 106/8 108/9
lodge [1] 135/10 77/19 82/23 83/24 I 98/15 99/6 99/20 85/2 85/5 86/16 108/12 108/14 108/22
lodged [1] 14/4 109/24 114/1 115/18 I 100/2 103/2 110/7 I match [4] 2/7 109/18 110/5 110/7
logical [1] 53/13 145/19 115/24 121/17 I 110/8 110/10 112/18 Imaterial [10] 14/4 I 110/40 114/41 112/6
London tH] 4/9 121/18 121/18 121/18 I 113/47 122/4 122/10 I 44/40 15/2 19/8 28/1 I 113/7 113/10 114/5
long [8] 5/16 128 I 121/19 124/19 122/22 127/15 130/24 I 28/1 28/22 31/19 4145/9 117/2 117/11
57125 111/13 11616 I!0sses [51] 6/6 7/20 133/8 137/2 138/1 31/21 63/22 117/19 120/7 127/12
433/9 137/2 137/21 I 8/1 16/8 16/13 16/14 I 139/24 140/3 140/19 Imaters [1] 62/1 127/23 129/13 129/23
longer [3] 42/10 68/5 I 16/14 16/15 16/18 makes [6] 27/8 27/15 I mathematics [1] 129/24 129/25 130/1
68/17 17/3 17/12 17/22 28/23 60/17 122/2 I 126/18 132/16 134/7 134/9
18/12 18/20 18/21 I 125/9 matter [18] 33/16 135/24 138/11 140/15
look [14] 25/24 36/16 ,
40/3 70/17 81/23 18/22 19/25 20/10 making [32] 5/11 34/1 46/17 47/22 me [36] 1/5 34/11
114)8 114/17 124/15. I 21/4 21/40 24/9 27/17 I 11/12 14/6 22116 2516 I 47/24 481 48/7 48/14 I 39/2 47/22 54/14
420/01 120/22 1414/2. I 27/19.27/23.27/25 I 29124 30/4 37/13 40/3 I 53/12 54/6 56/4 60/24 I 57/24 61/23 64/15
looked [3] 25/24 I 26/9 29/22.31/2.31/4 I 43/7 44/18 45/23 I 62/6 84/18 89/24 64/21 64/22 64/22
418/11 120/3 33/16 33/22 43/8 49/7 I 49/19 52/10 53/21 I 96/15 111/14 117/15 I 65/25 66/6 66/11 69/6
looking [6] 19/3 34/6 I 9022 51/2 54/7 51/7 I S411 54/17 62/4 71/9 matters [29] 12/3 I 74/24 77115 78/24
34/18 108/2 112/17 I 24/20 55/8 69/18 85/9] 77/13.99/11 99/15 I 21/24 22/23 23/6 I 83/4 87/11 92/2 92/2
19/2 85/11 111/18 113/20 I 101/4 107/23 112/17 I 39/15 52/13 54/3 ‘I 92/2 92/18 95/18 99/3
looks [2] 16/11 120/4 I 117/18 120/13 120/17 I 120/14 122/19 125/11) 67/16 67/19 67/24 I 106/4 106/14 107/16
Lord [14] 13/16 34/4 I 1218 122/1 122/11 131/14 132/17 133/23 I 68/2 68/5 68/6 68/7 I 128/6 129/3 135/10
82/11 82/24 12715 I 183/17 140/90 68/10 72/7 90/2 90/10 I 135/18 135/19 135/20
427/12 127104 128/23 I0St [2] 36/3 117/3 malicious [5] 7/12 I 98/19 112/2 116/8 I 140/24
429/12 129/17 129/24 I!0t [1] 98/5 81/47 83/17 138/15 I 446/21 117/14 121/17 Imean [12] 16/13 18/5
lousy [1] 135/20 138/24 123/9 124/10 130/10 I 19/1 47/5 73/1 88/15
on PIT ow [3] 73/1073/11 Imanage[1] 114/8 I 431/22 139/18 96/12 111/9 112/18
Lord Dyson's [1] 74/11 management [1] 4/23) may [120] 2/8 4/11 I 115/11 129/2 129/5
red lower [5] 55/1 60/6 Imanager[2] 53/5 I 4/12 5/95/19 12/17 _Imeaning [2] 17/23
TAIN7 74/20 75/1 96/6 44/25 17/7 18/1 19/7 I 51/6
lose [1] 10419 I ed [5] 3/1 3/7 3/20 [managers [2] 4/4 — I 19/8 20/9 21/18 22/16 Imeans [9] 4/4 9/9
(63) litigation... - means
INQ00001057
INQ00001057
means... [7] 21/13
29/1 96/13 111/10
111/14 112/18 124/14
meant [1] 34/9
meantime [1] 68/21
measure [1] 137/15
mechanism [10]
20/20 32/6 33/4 33/10
57/14 80/14 89/20
89/24 89/25 109/3
mechanisms [5] 37/8
85/14 87/8 109/3
126/6
Media [1] 110/23
mediation [10] 3/7
3/10 3/15 3/22 28/16
83/9 86/13 91/16
114/21 114/23
medical [4] 27/16
44/17 72/15 121/12
meet [2] 42/3 110/6
meeting [9] 28/16
62/20 63/23 123/7
123/11 123/14 123/15
123/18 124/23
meetings [3] 67/6
67/7 67/9
member [2] 98/16
126/3
member's [1] 49/12
members [11] 4/13
12/9 13/1 13/9 43/13
49/9 49/17 98/14
116/3 116/4 137/22
men [1] 32/22
mental [4] 44/9 45/4
104/7 121/12
mention [1] 123/5
mentioned [4] 31/10
32/16 79/17 135/23
mentioning [2] 20/10
20/14
merits [2] 33/15
33/17
Mertens [6] 3/2 92/9
92/24 92/25 95/14
142/4
methodology [1] 13/7
microphone [1] 75/3
mid [1] 5/17
mid-2022 [1] 5/17
midday [1] 120/12
midnight [3] 65/17
66/3 74/5
might [24] 44/7 54/13
55/9 58/6 64/16 64/18
70/17 78/2 79/3 79/10
80/2 80/5 80/17 87/11
102/19 121/14 127/22
128/3 129/14 129/17
133/20 137/10 139/6
140/10
mildly [2] 37/17 38/8
million [12] 6/22 6/22
6/25 7/18 7/18 13/3
35/8 99/15 110/17
111/20 117/3 126/15
mind [4] 37/19 38/5
65/9 140/14
Minister [13] 11/3
11/10 12/4 12/20
13/13 34/3 35/6 35/18
91/7 98/10 137/19
137/23 138/8
Minister's [4] 108/15
118/19 138/16 138/22
Ministerial [1] 119/18
Ministers [2] 111/19
126/15
minutes [3] 38/19
79/3 92/11
miscarriage [1]
105/21
misleading [3] 51/11
51/14 83/22
misled [1] 84/22
misreporting [1] 1/10
missed [3] 17/22 18/4)
48/19
misunderstand [1]
48/25
misunderstanding [1]
37/19
misunderstood [1]
63/22
mitigation [2] 24/2
28/5
Moderately [1] 9/4
moment [6] 8/21
17/15 22/9 38/17
114/18 121/15
money [21] 4/24
15/21 15/23 17/24
29/16 32/17 36/11
96/20 98/5 106/21
112/16 132/3 132/7
134/14 134/17 134/19
134/20 135/1 135/6
136/4 136/21
moneyboxes [1]
134/25
monies [1] 97/25
monitored [1] 100/16
monitors [1] 103/5
month [1] 82/14
months [4] 26/1
26/14 27/2 108/13
more [30] 2/11 12/3
16/16 16/20 17/9
31/25 50/18 57/16
59/8 64/16 64/18
70/11 73/5 74/19
79/10 79/11 82/9
87/14 90/6 91/15
92/14 95/20 106/18
110/13 113/15 133/25
134/14 140/2 140/2
140/5
Moreover [2] 52/7
59/20
morning [8] 1/3 38/16
44/17 101/2 102/16
120/4 130/11 130/13
mortality [1] 117/17
mortgages [1] 4/24
most [5] 7/24 46/2
58/4 94/10 114/11
mother [1] 106/20
move [10] 41/18 49/5
56/8 59/3 65/2 70/21
75/14 78/20 1114/5
113/10
moved [2] 12/3 67/22
moving [6] 58/25
85/14 102/12 124/9
125/2 128/18
MP [2] 11/3 12/5
Mr [69] 2/3 2/17 2/18
2/23 3/2 3/3 6/4 8/23
12/21 26/17 34/3 34/7
37/18 41/17 41/20
41/25 42/6 51/1 52/2
56/10 61/3 65/25
66/11 67/23 68/2 68/5
68/25 69/1 69/4 69/20 Imy [32] 11/20 37/19
72/10 75/22 80/19
81/19 84/2 85/2 85/5
86/16 87/10 88/1 92/9 I 65/23 75/2 79/1
92/12 92/12 92/24
92/25 95/14 96/1 96/2 I 106/17 111/3 111/24
96/4 99/3 100/17
103/9 103/16 105/12
105/13 116/15 116/19 I 134/24 134/25 135/9
4119/5 120/10 120/18
4123/8 123/13 124/22
128/2 128/2 140/8
142/2 142/4 142/5
Mr Alan [4] 6/1
Mr Beer [1] 72/10
Mr Jacobs [1] 96/4
Mr Justice [1] 103/9
Mr Mertens [2] 3/2
92/9
Mr Racaldin [1] 68/2
Mr Read [1] 67/23
Mr Recaldin [1] 68/5
Mr Sethi [4] 69/4
Mr Stein [5] 92/12
96/1 99/3 100/17
140/8
Mr Stein QC [1] 3/3
Ms [29] 3/1 38/15
38/24 39/9 39/10 47/3 I 28/11 30/15 54/12
57/10 64/20 79/2
87/10 92/7 112/22
114/19 117/2 117/9
117/24 119/5 120/11
121/22 122/21 123/6
123/7 123/15 126/11
126/11 128/6 133/22
136/13 142/3
Ms Elliott [2] 123/7
136/13
Ms Gallafent [8] 3/1
57/10 79/2 119/5
121/22 122/21 128/6
133/22
much [16] 1/6 2/19
9/4 15/20 16/4 38/14
42/8 73/5 95/25 97/25
416/22 122/1 134/17
134/19 135/6 140/23
mummy [1] 135/3
must [6] 8/12 28/9
42/4 55/7 81/14
125/12
38/5 48/8 49/2 50/4
57/23 58/24 62/22
102/15 106/16 106/16
112/3 112/7 121/3
129/18 133/4 134/24
135/17 136/14 139/21
140/14 140/24
myself [1] 87/13
N
nail [1] 103/15
name [2] 15/17 105/4
named [1] 91/21
namely [1] 18/21
National [1] 67/12
naturally [3] 37/4
46/18 128/9
nature [4] 20/3 27/22
129/5 130/3
nearly [1] 108/13
necessarily [5] 46/7
47/19 63/20 116/24
124/20
necessary [12] 24/8
59/13 62/20 68/11
70/19 76/1 86/20
1142/5 119/22
need [33] 21/23 42/23
61/23 64/15 66/13
71/13 76/12 79/13
87/18 92/13 95/7
107/10 108/1 110/1
110/9 110/10 112/2
113/9 113/9 113/14
116/12 125/10 127/19
127/19 127/19 1341/7
131/14 131/20 133/6
136/1 139/17 139/17
139/23
needed [4] 1/21 5/8
54/2 132/3
needs [7] 68/12 100/9
113/8 128/21 128/21
133/25 134/2
negligence [1] 103/23
negotiated [2] 83/13
84/24
(64) means... - negotiated
INQ00001057
INQ00001057
N 113/3 113/3 113/3 I 87/19 92/3 105/10 obliged [2] 70/6 80/10 117/14 117/4
aang tt) aoa I 115/4 115/5 115/24 I 111/23 124/12 offers [31] 22/8 26/2
rotate Bl 1221212216 125/4 notice [1] 140/11 obscure [4] 26/15 I 26/9 27/11 30/21
11/16 36/8 80/24 125/18 129/19 130/14 Inotified [1] 113/3 _ jobservation [1] 58/25I 45/23 46/10 46/23
81/21 82/20 87/2 133/12 136/8 140/5 [noting [1] 42/4 obtain [14] 4/5 27/6 I 59/10 60/6 65/21 66/8
89/10 131/19 non [22] 2/219/9 I novel [4] 30/1 32/8 42/16 44/8 44/22 I 73/3 74/1 74/6 74/8
neither [5] 91/7 91/7 I 12/10 12/13 13/15 [November [8] 8/19 I 44/23 62/24 63/14 I 74/12-74/16 74/20
91/9 108/15 116/13 I 16/14 19/1 33/24 9/11 25/3 25/20 56/12 I 72/3 77/23 80/9 86/24 I 74/22 76/25 77/11
neural [1] 87/6 33/25 34/1 41/24 42/2 I 56/20 104/15 105/23 I 109/6 77/13 80/5 86/19
neutral [6] 13/16 67/14 81/20 82/4 83/2 INovember 2020 [3] {obtained [5] 27/17 I 117/7 117/12 117/18
33/24 82/5 82/18 93/21 97/8 98/14 8/19 9/11 25/3 43/21 44/1 59/23 447/18 117/23 117/25
82/24 86/13 115/19 137/23 138/3 Inow [59] 2/137/16 I 61/19 office [219]
never [8] 18/5 98/6 I [RoN-binding [2] 33/25] 26/15 37/18 39/6 obtaining [1] 45/3 Office's [14] 43/21
404/3 105/22 132/04 I 341 41/12 44/2045/17 —_Jobvious [3] 84/14 I 45/17 59/23 76/10
435/11 136/5 136/18 [NOM-eligible [1] 9/9 I 51/17 53/11 56/25 I 89/8 132/23 76/19 100/11 116/2
nevertheless [10] /Mo"-executive [1] I 64/3 65/15 66/3 67/5 Jobviously [9] 19/2 I 121/24 132/22 136/28
44/18 44/23 45/5 93/24 73/4 78/20 78/25 88/8 I 54/15 66/11 70/23 I 139/16
49/16 56/23. 95/6 \Non-exhaustive [2] I 92/17 93/12 94/4 72/24 86/10 98/10 I officer [2] 67/23
4041/5 101/25 103/13. I 42/2 115/19 94/12 95/11 97/22 I 107/18 140/6 105/3
125/40 non-financial [3] 99/5 102/8 108/5 occasion [8] 39/5 offices [3] 102/4
new [3] 35/9 110/17 I 19/14 19/4 41/24 1140/7 111/7 1149 I 64/25 110/5 110/12 I 103/21 104/4
4126/4 non-GLO [5] 12/10 I 111/12 112/15 113/5 I 112/5 128/18 139/24 I official [4] 68/20
news [3] 111/19 12/13 98/14 137/23 I 113/8 113/9 114/14 I 140/10 93/19 114/22 136/11
414/22 119/13 138/3 115/23 119/12 120/7 Ioccasional [1] 8/23 often [2] 10/22 17/23
next [26] 4/11 1/25 non-payment [1] 2/21) 123/4 123/10 124/2 occasions [1] 77/16 I Okay [1] 100/25
4/8 5/5 9/21 12/4 19/7 non-pecuniary [5] 124/6 124/22 125/6 occur [1] 4/8 old [7] 30/19 31/1
38/15 39/25 64/05 I 13/1599/2181/20 I 127/17 128/17 130/9 Ioccurred [2] 10/17 I 39/3 76/5 108/20
34/19 90/3 90/5 go19 I 82/4 83/2 130/14 130/18 130/20I 116/21 407/4 107/14
92/9 94/13 106/8 non-renewal [1] 131/16 132/3 134/6 occurs [2] 140/17 once [5] 38/11 61/15
40/5 110/12 114/22. I 87/14 136/1 136/6 140/1 I 140/18 78/16 97/4 112/19
1412/5 127/17 128/18 I/Non-statutory [1] 140/15 October [1] 51/17 I one [37] 1/4 2/4 9/9
439/24 140/10 1414/3. I 97/8 number [30] 4/12 off [6] 59/3 112/15 I 16/11 16/19 16/21
night [14] 2676 28/24 [none [2] 7/4 8/5 8/11 13/14 20/23 24/6 I 134/10 134/21 136/17 I 18/9 23/1 36/9 39/5
34/4 34/8 34/10 34/14 [nonetheless [2] 25/22 26/9 33/20 37/4 I 138/9 42113 43/14 43/14
84/24 65/15 66/1 21/18 115/9 38/25 46/10 49/15 offence [1] 136/2 I 43/15 57/15 57/23
66/12 85/24 102/15 INOrIT] 23/1591/8 I 53/8 54/16 56/24 62/2 Ioffences [2] 4/19 9/18] 58/5 58/12 69/7 73/4
102/18 130/13 105/15 110/23 116/13 I 65/19 69/8 71/6 71/7 offer [48] 6/16 22/15 I 85/1 93/16 96/24 98/7
no [60] 2/4 10/15 19/7] 116/24 137/18 71/18 74/25 77/15 I 22/16 30/12 30/16 I 98/14 98/16 101/19
23/9 23/10 23/10 norm [1] 30/2 77/18 80/25 82/2 31/17 44/19 45/6 46/6 I 102/3 102/10 102/14
27/15 28/13 29/4 33/4 \Not [193] 146/17 117/11 121/2 I 54/1 54/4 54/6 55/18 I 103/16 103/18 109/16
33/13 34/9 34/13, (Mote [24] 42/21 43/23] 133/10 56/1 56/4 60/6 61/8 I 123/1 127/13 130/10
35/10 37/19 41/8 44/7 48/20 49/24 Inumbers [2] 26/15 I 62/17 62/19 65/20 I 130/22
4210 42/15 44/1 53/25 65/865/15 I 6/20 =I 67/1 68/22 70/20 74/4 jones [3] 17/7 69/8
45/14 59/17 60/4 63/4 I 85/22 66/7 66/18 69/7 I 7112 722 72/14 74/2 73/10
67/16 68/4 69/13 71/4 I 71/15 7210 75/4 I~___________I 75/1375/2075/20 Iongoing [3] 95/7
73/18 74/14 79/6 78/22 83/15 84/2 o'clock [1] 2/9 75/23 76/2 76/14 106/13 127/4
79/20 79/24 80/8 85/25 99/6 110/7 obfuscation [4] 98/18) 76/17 77/6 77/15 only [18] 16/3 16/4
80/24 83/5 87/18 124/12 130/16 134/8 I 105/5 130/6 137/1 I 77/46 7/24 77/24 I 21/25 27/2 29/16
88/23 89/5 91/24 noted [4] 30/10 32/21 object [1] 95/15 79/18 79/18 80/3 31/14 37/1 38/12
92/14 108/16 108/19 I S1/1 56/13 objective [1] 93/23 I 90/14 122/14 123/10 I 39/19 53/3 55/7 79/14
11018 114/14 111/22. [Motes [2] 70/13 95/4 [obligation [1] 48/21 I 423/24 136/11 81/4 99/7 122/12
nothing [6] 36/8 42/9 I obligations [1] 47/18 I offered [5] 5/3 59/17 I 123/24 133/4 140/5
(65) negotiating - only
INQ00001057
INQ00001057
fe) 27/15 28/1 29/9 29/23 I 31/11 34/24 38/5 126/23 59/14 59/18 59/20
onus [2] 101/21 31/4 36/3 36/10 39/23 I 39/15 42/9 42/17 48/6 Iowed [1] 88/12 60/3 60/5 62/9 62/14
101/22 40/9 40/14 42/12 48/9 48/15 51/13 owing [2] 15/24 18/20) 63/12 72/2 72/5 78/12
onwards [1] 134/8 I 46/16.49/20 50/15 I $2/1962/2565/4 own [10] 40/18 54/13 I 78/15 118/12
open [19] 2/3 24/1 I 90/18 5618 59/25 I 65/18.65/2068/13 I 59/9 110/24 1114/8 I Panel's [9] 22/20 2313
5/1 43/04 50/9 5825 I OV/16G1/17 61/18 I 71/44 72/10 73/7 —_I 421/41 132/24 134/25 I 43122 44/13 4615 55/6
59/22 84/12 82/9 g4/a I 01/18 63/9 67/11 70/7 I 83/25 87/14 88/19 I 135/6 135/10 59/24 60/23 118/14
B7/7 108/17 127/19 I 7222 73/14 7618 I 90/16. 91/22 94/23 jowned [4] 98/21 _I papers [2] 35/23
4128/1 129/16 133/23 I 77/12 78/24 81/1 I 97/18.98/239919 I 103/24 136/14 139/17] 101/23
433704 134/3 136/10 I 83/10 87/8 87/9 87/21 I 100/14 101/6 101/8 owns [1] 137/19 _I paperwork [2] 54/20
opening [4] 4012 I 87/24 87/24 90/ 102/24 104/17 106/20I 5 414/12
68/95 64/3 8/1 91/16 92/5 95/12 I 106/23 108/3 108/7 paragraph [30] 12/7
openly [1] 125/7 97/17 104/14 107/18 I 108/22 108/24 110/1 Ip.mf[1] 106/22 I 4914 tert5 1619
openness [1] 37/12. I 123/23 124/24 126/4 I 111/23 111/24 113/10 Ipace [2] 59/1 124/9 I 21/2 21/3 24/23 31/8
129/15 138/9 113/18 114/17 118/16 Ipackage [4] 110/18 I 36/49 42/22 43/21
cperated fe] tos [others [14] 4019 I 12011 120724 r21/6 I 111/20 11279126116 I Sar15 5arz4 61/18
48/2 88/7 103/24 49/17 76/8 93/10 121/14 122/23 127/10 I page [31] 9/69/24 I 61/44 63/7 71/14 91/2
operating [4] 20/19 I 94/17 95/15 112/4 I 12614 128/7 130/3 9/24 11/10 14/24 409/12 115/23 117/5
ald 2914 103/11 I 128/1 133/5 133/15 I 131/22 1324 133/20 I 16/10 18/16 19/9 117/16 118/6 120/18
; 14016 4135/6 138/24 138/25 I 19/11 19/11 21/2 I 420/19 420/19 120/20
oa io. [otherwise [8] 75/9 I 139/7 130/14 14016 I 2213 24/23 25/25 I 430r17 130120 131/17
20/22 23/8 31/8 95/8 I 985 102/19 116/7 I 140/20 25/25 30/9 31/9 31/10 I paragraph 6 [2] 61/44)
opportunity [11] I 124512277 125725 outcome [16] 14/7 I 361843723 8215 I 63/7
eee soto aong I 127122 2216 31/15 34/1 62/7 I 61/13.65124 65/24 I paragraphs [5] 11/9
ought [5] 5/5 23/23 I 62/7 62/25 63/1 63/10 I 66/18 67/2 120/9 16/20 108/24 109/17
aoe erie renner I 20225 30125 31/22 I Tovioe2iea2is I 120/19 120120 121114] 4oor17
440/21 ounce [1] 107/13 83/13 83/14 100/13 I 134/8 Parliament [5] 9/19
opposed [2] 26/12 [Our [53] 3/17 1216 I 118/13 page 290[1] 31/9 I 42/5 129/9 137/3
74/3 39/1 40/5 40/7 40/18 outcomes [1] 55/10 Ipage 302 [1] 65/24 I 437/20
option [1] 86/10 49/22 50/14 52/19 outline [1] 12/2 pages [3] 16/21 65/23I part [20] 7/6 8/10
or [166] 56/13 57/13 65/7 outset [4] 31/23 39/12) 121/15 12/6 13/10 21/49
68/14 71/14 72/10 I 90/4 132/2 paid [17] 6/25 9/17 I 36/10 52/8 57/14
oral [8] 1/14 1/16 2/24 ;
5/12 39/13 39/15 97/5I 77/8 85/16 85/24 outside [2] 23/17 39/6, 10/13 13/22 15/22 58/43 60/25 76/24
86/24 87/18 87/22 —_I outstanding [3] 3/24 I 27/12 27/14 29/16 —_I 87/1 96/14 98/4 99/1
ord [10] 25/4 36123 I 92/4 93/16 96/8 96/9 I 24/16 99/13 29/17 36/2 36/11 415/10 118/23 119/16
37/22 43/19 51/6 I 90/1096/2497/10 outweigh [4] 89/11 I 70/15 72/12.97/25 I 429/43 131/18
82/16 78/15 82/1 101/13 105/7 106/4 Oval [1] 2/7 98/6 105/20 131/10 _I participants [24] 2/20
133/8 139/8 106/9 106/13 107/9 over [16] 1/21 2/2 IPalmer[1] 126/11 I 3/3 5/14 11/24 12/16
orders [1] 85/10 108/7 110/4 111/2 I 6/25 31/4 31/7 65/24 Ipandemic [2] 24/20 I 13/17 14/5 15/7 24/15
ordinary [3] 79/25 I 1109 1195 118/18 I 74/12 77/1 79/14 25/7 34/20 37/7 42/12
80/1 81/15 113/19 115/5 115/14 I 86/1891/13. 92/1 —_Ipanel [52] 14/14 16/7 I 50/15 50/18 67/11
organisation [2] 119/8 122/3 1265 I 97/25 98/6 101/24 I 16/12 22/13 22/15 _I g1/1 87/22 90/8 94/15
37/12 104/8 4127/7 127/18 127121 I 11718 22/18 22/24 23/2 23/5I 95/9 96/7 107/17
organisations [1] 133/1 137/5 137/17 overall [5] 46/6 46/22 I 23/17 23/19 23/24 I 412/3 128/4
40/14 4130/4 56/4 77/15 80/8 28/21 28/22 41/7 participate [1] 93/9
organizing [1] 28/3 [Urs [1] 124/7 overlaps [1] 85/16 I 41/2143/14 43/18 _I participating [1]
originally [1] 3/12 {O¥"selves [3] 40/25 Joverly [2] 53/21 55/10 44/1 44/7 44/18 44/19 I 149/16
81/10 122/4 oversight [4] 11/22 I 44/24 45/5 46/3 46/22 I participation [1]
other [61] 3/6 3/14
6/1 6/7 7/1 7/1 7/23
17/15 18/20 19/20
19/25 26/7 26/24
out [77] 6/7 7/10 93/17 94/20 128/21 I 48/1049/10 49/16 I 43/44
12/23 13/18 15/8 overtaken [1] 35/5 I 49/24 52/8 52/9 52/13 I particular [44] 3/18
17/25 18/4 19/15 overturned [5] 10/14 I 52/22 54/25 55/16 — I 22/19 22/25 23/2 23/7
24/22 25/14 29/2 30/6 I 11/14 78/6 125/20 I 95/20 59/9 59/13 23/10 24/10 34/19
(56) onus - particular
INQ00001057
INQ00001057
P 35/9 35/11 76/9 76/13 I 26/8 26/10 26/11 90/9 103/20 93/18 94/16 114/15
particular... [36] 35/5 76/15 78/2 78/11 26/13 27/2 30/22 piecemeal [1] 76/24 I 119/18 122/15
38/3 38/8 40/1 40/23 I 80/22 85/22 86/25 54/21 55/8 55/8 65/21 I pieces [1] 62/11 POL's [1] 46/16
4/5 44/18 41/20 87/5 91/5 91/13 99/16 I 66/9 66/20 66/22 place [13] 22/10 36/9 I police [1] 105/3
45/23 47/23 48/1 99/24 118/18 124/16 I 66/25 67/4 77/2 77/6 I 37/8 39/25 67/6 89/10 I polite [1] 34/23
48/13 50/19 52/44 130/24 1341/7 132/16 I 117/7 120/1 120/5 93/18 98/9 104/12 Ipondered [1] 38/6
53/15 54/25 55/4 payments [65] 6/21 Iperceive [1] 48/17 I 114/14 132/13 134/9 I pondering [1] 57/9
61/12 67/10 70/48 9/16 10/6 10/10 11/13 I perceived [2] 53/21 I 139/22 posed [2] 65/3 68/19
72/8 80/3 81/24 g6/9 I 12/25 26/4 26/10 89/11 placed [3] 30/5 60/20 Iposition [36] 17/11
87/5 107/3 110/25 26/11 27/3 28/12 29/3 I percentage [2] 66/8 I 101/25 40/7 43/5 46/13 49/23
4113/2 113/10 113/14 29/6 29/19 29/22 30/4 I 73/23 places [2] 20/24 23/1 I 57/18 57/19 59/19
418/22 121/10 122/11 30/6 30/11 30/16 percentages [1] plan [1] 77/3 65/6 67/18 74/5 76/17
4127/6 127/16 128/5 30/20 30/22 30/25 73/25 planned [2] 3/12 77/8 78/3 79/21 79/21
particularly [10] 32/5 32/6 32/11 32/15 I perform [1] 123/1 116/7 86/4 87/18 87/22
24/23 33/22 45/3 32/19 32/23 32/24 —_I performance [1] plans [1] 4/23 87/24 88/21 90/20
60/11 69/8 69/18 33/1 35/6 35/7 35/16 I 103/6 play [2] 81/42 118/23 I 97/16 102/23 111/13
81/21 89/11 108/9 36/12 66/12 75/15 I performed [1] 105/19] played [3] 97/23 122/4 125/23 126/5
110/24 75/16 75/18 75/20 perhaps [9] 16/16 111/21 116/4 126/10 126/24 128/11
parties [6] 61/17 63/8 75/20 75/22 76/2 26/15 42/9 48/18 pleading [1] 55/17 I 130/10 130/19 131/21
82/16 83/1 83/8 76/18 76/25 78/5 64/24 73/21 75/10 —_Iplease [13] 14/22 132/13 133/21
428/22 78/18 79/9 79/12 81/8 I 87/14 123/23 16/9 19/14 20/2 20/24 I positions [1] 113/11
partner [2] 105/12 84/8 85/15 86/3 99/12 I period [4] 25/20 25/23 39/7 61/23 positive [3] 14/6
123/8 99/19 109/2 109/4 56/18 67/16 68/4 61/25 99/1 120/9 65/13 66/24
partners [1] 96/25 109/10 109/21 112/19 Ipermission [1] 5/21 I 120/22 124/12 possesses [3] 31/14
parts [4] 11/9 112/23 122/17 125/16 I permit [1] 16/8 pleased [4] 11/11 31/20 31/21
party [6] 8/6 36/7 125/19 130/15 132/2 I permutations [1] 12/10 127/10 137/25 I possibility [3] 30/7
49/7 61/15 61/18 64/7 [Pecuniary [7] 13/15 I 55/12 pm [3] 92/21 92/23 I 79/11 127/10
passed [3] 28/20 57/2 33/21 70/2 81/20 82/4 I perpetrators [1] 141/4 possible [16] 11/17
102/16 82/23 83/2 115/15 point [45] 5/17 5/23 I 17/11 47/24 77/21
passing [1] 104/2 peers [4] 12/10 12/14 Iperson [5] 9/17 10/9 I 18/9 28/17 31/11 40/2 I 77/23 79/4 83/14
past [8] 5/2 516 37/11 I 197/23 1388 20/7 28/2 118/22 I 42118.43/11.44/12 I 89/19 90/12 91/17
37/21 38/1 44/8 penalties [2] 16/24 personal [8] 17/1 48/8 50/4 51/18 51/23 I 93/25 101/5 108/19
104/15 134/5 121/20 30/19 44/15 50/1 50/2 I 54/8 60/13 61/1 61/1 I 109/21 111/6 117/21
patience [1] 65/1 pending [1] 29/19 53/17 72/16 76/4 61/7 62/1 62/2 63/5 I possibly [1] 134/20
patients [1] 125/15 pennies [1] 135/21 [personally [1] 47/6 I 63/7 63/10 75/13 84/5 I post [236]
Paul [3] 11/3 1274. [Pension [1] 106/17 persons [8] 40/15 I 84/16 88/1 88/2 99/14 IPost Office [71]
83/19 pensioner [1] 107/15 I 51/4 51/16 78/7 80/23 I 99/22 100/2 100/7 99/23 101/14 101/16
pay [12] 27/11 7012 penury [1] 4/21 90/20 90/25 120/14 I 100/14 100/18 100/18 I 101/23 102/7 103/3
74/2 86/18 96/20 people [28] 1/4 10/6 Ipersuading [1] 47/5 I 100/20 101/21 101/22} 103/6 103/10 103/14
406/18 124/15 129/24 28/6 39/1 39/2 48/24 Ipertaining [1] 56/22 I 107/23 112/6 113/19 I 103/21 104/3 104/8
432/16 133/8 136/6 64/20 97/12 102/21 I Peter [2] 105/2 127/2 127/16 129/3 I 104/10 104/25 105/9
43714 103/24 104/19 107/19 I 106/19 135/4 106/1 106/12 106/21
payable [1] 91/12 111/15 112/13 112/15 I phase [7] 3/13 3/19 I points [24] 34/18 107/15 108/8 109/11
paying [2] 72/11 114/3 114/3 114/7 AIT 39/24 40/4 72/17 I 38/12 39/20 40/6 109/14 1114/6 112/7
132/25 417/12 122/10 122/19 I 95/19 42/41 42/18 50/14 112/10 114/4 114/11
payment [41] 2/21 127/12 131/8 133/12 I phase 2 [1] 40/4 50/15 56/8 59/4 67/10) 114/14 114/16 114/22
2/24 5/18 7/3 7/19 133/14 133/20 139/6 Iphase 5 [5] 3/13 3/19 I 70/16 78/24 87/19 115/21 115/23 116/10
140/16 AIT 39/24 95/19 90/7 90/18 98/7 98/25 I 116/23 117/6 117/16
me lope ated people's [2] 121/10 Iphases [1] 114/20 99/10 110/9 110/22 I 118/3 118/10 118/13
46/8 20/16 27/9 28/13 132/3 phoned [1] 135/5 113/11 113/17 144/41 I 1419/7 120/24 120/25
29/25 30/7 31/2 32/te PEF [26] 9/16 10/9 I phrase [1] 18/5 POL [10] 47/5 52/4 I 121/4 1214/5 121/9
5 "54/9 2614 26/5 26/8 [pick [4] 59135914 I 58/1 70/10 91/15 122/16 122/25 123/4
(67) particular... - Post Office
INQ00001057
INQ00001057
P 126/16 129/3 129/22 I 71/2073/1777/19 I probably [3] 123/21 I 66/19 66/20 76/6
Post Office... [23] practically [1] 49/21 I 79/24 128/2 129/5 82/19 82/22 97/8
4124/2 125/14 130/16 practice [4] 10/19 I presumptions [2] probe [1] 87/11 113/7 125/9 129/7
430/23 134/12 134/17 I 20/20 23/9 24/4 TT8 77/20 problem [6] 47/9 130/15
431/19 131/22 132/5 IPre [2] 33/6 75/20 [pretty [2] 42/8 59/1 I 47/12 102/2 102/22 _I progresses [1]
432/23 133/7 133/16 pre-action [1] 33/6 Iprevent [1] 10/6 130/7 131/13 103/25
4134/4 134/15 136/11. IPrecarious [2] 4/22 [previous [7] 26/12 I problematic [1] promise [2] 140/3
136/17 136/20 137/48 133/11 30/10 48/20 67/14 115/20 140/19
137/19 138/19 139/9 precedence [1] 137/9I 67/19 71/21 119/1 problems [4] 104/1 [prompted [1] 53/5
139/14 139/16 precedential [1] previously [4] 15/4 116/14 132/4 133/12 I promptly [5] 10/22
Post Office's [6] 86/15 15/8 59/16 116/22 procedural [4] 61/5 I 32/20 89/3 93/24
1400/11 1146/2 121/24 precedents [2] price [4] 105/21 61/9 69/9 119/10 137/4
132/22 136/23 139/16 100/10 127/11 prices [1] 106/23 procedure [4] 28/14 Ipronounce [1] 129/17,
post offices [2] 102/4 precisely [1] 64/15 I prima [1] 83/20 60/3 109/8 119/20 I proof [7] 21/4 21/6
104/1 precision [1] 74/13 I primarily [2] 40/8 procedures [5] 8/15 I 21/17 101/21 101/22
posting [1] 52/1 precluded [1] 50/8 I 48/21 29/19 32/10 87/3 101/25 115/8
postmaster [13] predate [1] 52/3 primary [4] 127/7 1409/8 proper [1] 100/5
10/10 21/6 21/25 predating [1] 90/22 (principal [1] 94/13 I proceed [3] 34/2 97/6I properly [7] 3/9 3/20
22/16 22/22 31/18 predicated [1] 81/2 I principle [22] 15/19 I 126/25 20/21 28/10 125/12
4313 44/19 45/21 (Predicted [1] 92/13 I 15/25 16/18 17/3 17/7 I proceeded [1] 6/3 I 132/11 136/25
52/12 77/23 85/22 IPrefer [2] 66/4 78/24 I 17/24 20/23 22/11 _Iproceeding [1] 35/1 Iproperty [2] 16/23
115/7 preferable [1] 79/3 I 23/13 41/4 41/11 proceedings [9] 2/3 I 121/18
postmaster's {2} [Preferably [1] 114/1 I 46/14.47/22.47/23 I 4/16 6/20 6/10.43/5 I proportion [2] 7/24
1104 87/1 prejudice [7] 63/18 I 47/25 48/2 48/7 58/11 50/10 84/23 91/18 I 29/3
80/24 82/9 82/19 58/14 77/23 80/3 80/6 I 103/14 proportionate [1]
ostmasters [31 we
oat 14/19 eA 88/21 123/16 123/17 Iprinciples [40] 8/12 Iprocess [35] 11/23 I 61/20
preliminary [2] 12/18 I 14/17 16/17 18/23 13/15 31/23 33/24 proportionately [1]
18/18 22/1 2216 86/16 40/6 19/5 20/11 20/25 21/3 I 43/17 48/15 52/24 74/241
aera vue 24 premature [1] 89/22 I 24/1 31/9 32/3 36/13 I 54/4 60/25 65/5 67/4 Iproposal [2] 10/11
79/23 80/14 80/18 premise [1] 79/18 42/1 47/10 47/13 69/19 77/4 78/14 82/8 I 76/9
81/9 81/24 82/2 84/9 preparation [1] 2/8 I 47/13 58/12 72/9 78/1 I 82/10 82/12 82/24 proposals [2] 110/5
88/24 91/6 111/21 prepare [2] 28/19 80/1 80/2 80/11 81/7 I 83/10 87/6 88/7 139/2
119/45 119/19 131/3. I 130/2 81/41 81/15 81/20 110/24 111/25 113/4 Ipropose [1] 14/1
4132/1 132/13 138/6 prepared [4] 59/11 I 84/6 84/8 85/17 99/17) 114/10 117/11 119/13 I proposed [1] 100/9
138/10 99/2 130/2 133/14 100/7 107/25 108/2 I 123/5 124/15 124/21 I proposing [1] 10/3
postmasters’ [1] preparing [1] 74/417 I 109/1 115/12 127/8 I 125/5 126/9 128/20 I prosecuted [4] 39/17
131/49 present [8] 1/235/2 I 127/19 127/25 128/12I 133/3 140/22 90/15 125/20 125/25
potential [11] 38/10 5/6 5/24 38/1 95/18 I 128/23 processes [1] 87/8 [prosecution [6] 7/12
45/2 48/17 50/9 52/6 123/14 133/25 prior [7] 30/11 62/3 I processing [2] 25/19 I 81/17 83/18 136/22
53/6 53/23 55/14 presented [2] 19/12 I 63/3 67/20 72/13 69/5 138/15 138/22
76/18 91/24 133/22 I 29/21 75/23 84/16 produce [7] 22/18 I prosecutions [3]
potentially [8] 44/22 presenting [1] 28/3 prioritising [1] 106/6 I 22/24 23/6 52/13 72/7 I 125/17 125/21 132/23
45/12 46/13 51/14 presently [1] 4/7 priority [1] 76/19 114/15 140/12 protection [1] 86/20
56/17 74/14 78/1 preserve [1] 104/4 privatised [1] 98/21 Iproducing [1] 115/2 Iproud [1] 105/2
86/14 press [8] 9/20 9/23 proactive [4] 52/20 [product [1] 103/23 I prove [5] 24/8 27/18
Pound [1] 107/8 51/21 58/4 78/22 §2/22 52/23 69/16 production [1] 105/24) 31/18 44/22 114/1
pounds [1] 136/4 99/14 110/15 137/3 I proactively [2] 72/3 I professional [6] proved [1] 81/21
power [1] 45/5 pressure [1] 30/5 86/19 16/25 29/9 36/4 42/25 I provide [32] 20/2
powers [2] 101/3 presumably [2] probabilities [4] 43/3 72/22 21/7 21/23 22/1 44/13
105/24 114/25 126/2 20/18 21/8 23/15 profit [1] 16/23 47/44 52/9 54/2 61/23
presumed [1] 37/14 I 27/19 profits [1] 121/18 61/25 64/17 66/25
practical [4] 17/9 resumption [4] __I probability [1] 129/15] progress [11] 65/12 I 69/4 73/23 77/5 82/25
(68) Post Office... - provide
INQ00001057
INQ00001057
Pp pursue [2] 17/14 I question 4 [2] 59/4 Ireach [4] 48/10 66/21 I 69/11 74/7 81/4 85/6
provide... [16] 9372 I ‘8/11 60/8 77/14 85/4 85/10 85/25 94/5
97/7 98/23 99/8 pursued [1] 33/6 questioned [1] 118/4 Ireached [8] 65/6 95/10 98/16 102/16
404/13 107/19 109/22 I Put [30] 5/7 17/11 questions [30] 14/19 I 66/22 67/5 69/15 107/21 116/16 117/1
441/20 120/22 124/6 I 37/8 37/15 47/3 51/11 I 26/17 32/25 33/1 33/3I 72/25 97/16 105/8 117/23 117/24 130/12
426/15 129/4 1097 I 82/1957/1257/18 I 40/9.40/20 40124 I 111/13 137/22
429/18 137/12 137/16 I 98/9 60/9 74/9 87/13 I 42/10 53/3 53/7 53/7 Ireaching [3] 76/22 Receiver [1] 68/20
provided [17] 4/3 7/4 I 93/18 10219 10417 I 53/11 57/17 65/2 I 83/1 115/14 receiving [3] 61/8
7/9 31/12 44/16 50/25 I 100/23 10716 112/11 I 80/1287/17 88/19 reaction [1] 1/3 724 144/41
53/4 58/10 61/19 62/5 114/6 117/13 122/3 I 107/3 108/8 108/12 read [6] 12/22 31/11 recent [2] 99/14
62/16 65/15 89/1 122/23 125/1 125/12 I 108/23 109/25 110/1 I 44/2 44/17 67/23 103/3
99/16 100/8 101/20 I 128/16 128/23 130/4 I 114/1 116/17 116/18 I 113/12 recently [1] 124/22
128/16 132/6 134/20 116/20 126/21 139/11 Ireads [3] 10/1 21/5 Irecognise [5] 49/1
provides [6] 61/14 putting [5] 37/16 38/8 quickly [1] 82/17 22/14 50/17 68/16 72/18
66/21 70/24 7518 101/4 104/11 136/4 Iquite [9] 38/1 57/25 Iready [3] 64/14 92/5 I 1041/1
86/19 122/13 puzzle [1] 38/5 75/9 75/11 117/21 93/13 recognised [1] 5/13
providing [9] 14/17 IQ ——~—~*:«*20016-128/4 13920 real [1] 102/25 recognises [2] 93/11
ATIBAMI3 617 ere pee I 40N4 realise [2] 121/16 I 95/6
64/22 72/15 93/18 QC [5] 2/3 3/1 3/3 I quote [1] 120/11 133/17 recommend [7] 22/16
402/10 130/22 96/2 142/5 Reality 13] 47/4 112/9 I 43/20 44/1 44/18 45/6
roving [3] 20/18 qualifications [1] RO 44378 55/18 59/22
oats 3/20 1223 Racaldin [1] 68/2 really [1] 122/20 _Irecommendation [10]
‘si quantification [1] __IRainey's [1] 134/6 Irearrangement [1] I 43/19 44/24 48/11
Oe yarns I 104 raise [6] 2/14 35/24 I gaya 52/10 60/5 62/9 62/15
29/18 32/7 42/16 quantified [6] 95/25 I 38/12 43/24 86/9 reason [8] 51/3 56/24I 76/10 88/23 118/14
44/14 44/20 45/15 56/3 81/5 82/21 82/22 I 89/22 60/1 89/5 99/4 101/12 Irecommendations
58/3 58/15 64/13 I O% raised [25] 20/13 31/7I 130/22 137/17 [11] 41/8 49/19 49/25
quantify [1] 42/17 I 32/25 40/10.42/19 I reasonable [11] 6/15 I 97/19 97/19 98/23
36/20 86/23 10012 Iqantum [4] 24/2 I SO/15 54/8 56/9 59/6 I 13/10 36/14 52/4 87/1 I 99/2 99/20 101/4
40915 123/21 28/5 81/12 13713 I 60/25 63/23 67/11 I 400/3 101/7 119/15 I 101/12 107/24
isional (7) 39/16 [Wasted [19] 9/18 I 67/11 8/24 69/8 129/21 131/20 132/16 I recommended [2]
Provisional [7] 10/18 10/19 11/2 11/6 I 69/24 76/5 76/7 76/8 Ireasonably [4] 61/19 I 22/15 59/18
90/14 90/18 91/3 .
91/22 118/15 138/18 11/6 13/13 13/23 32/2 I 85/4 85/6 85/18 87/18] g9/3 132/19 139/5 recommending [3]
72/19 75/16 78/17
2 32/13 32/23 78/21 I 87/21 94/17 reasons [12] 15/12 I 45/23 46/6 46/23
Provisions [4] 8/14 I 79/23 gort4 80/19 raises [3] 15/13 3513 I 15/14 ms ie reconsider [1] 131/21
4116 70/1 86/2 86/22 88/25 91/2 80/11 24/13 40/16 57/6 reconsidered [1]
PTSD [1] 114/6 126/22 raising [2] 42/10 54/5) 57/15 68/13 73/7 84/3I 101/9
Public [8] 9/7 01/2 — Iqueen's [2] 59/13 [rang [1] 135/8 138/24 record [3] 62/14
toate tog tena I 1195 range [4] 17/2 27/25 IRecaldin [1] 68/5 I 75/10 112/10
published [6] 2/25. [Wuestion 39] 19/47 10177 118121 recall [5] 26/16 30/21 Irecorded [1] 105/4
pusten U5] 22 I 19/17 19/18 19120 rapidly [1] 128/18 I 96/22 107/2 116/15 [records [6] 24/7
49/21 19/23 19/24 rate [3] 65/21 66/20 Ireceipt [2] 31/17 I 60/13 72/16 114/12
51/22 140/11 20/10 24/3 32/14 44/1 I 70/8 136/18 114/45 114/24
punitive [1] 119/2 I 4473 44/18 42/7 43/25 Irather [24] 5/8 23/25 Ireceive [10] 22/6 78/7 recourse [1] 33/7
pure [1] 123/13 45/13.47/1 47/18 I 34/6 34/17 39/21 40/9] 417/20 126/8 126/19 Irecover [1] 17/11
purpose [5] 35/8 I sorte Sorta 50/20 I 44/3. 45/25 50/18 54/5I 130/23 13216 136/12 recoverable [18]
ae 70125 89/20 I 54/11 55/3 56/9 59/4 I 55/8 59/9 64/3 64/10 I 437/8 137/11 45/11 15/14 15/16
60/8 60/8 64/1 69/23 I 69/14 76/23 77/16 —_Ireceived [34] 7/25 I 16/19 17/3 28/10 41/2
purposes [4] 5/24 I 704 70/22 7410 I 84/8 87/13 114/9 I 40/24 Ob tits 4412 41/19 42/7 43/41
95/18 103/12 113/15 I 76/44 95/4 85/16 121/23 128/18 132/7 I 25/10 26/19 26/21 45/12 48/8 48/12
purse [1] 134/25 I 86/23 8713 91/11 I 140/25 31/15 31/15 32/18 I 49/14 49/23 50/5
Pursuant [2] 8/3 97/6 I +944 ratings [1] 4/23 35/23 41/10 54/1 57/1 I 50/17
(68) provide... - recoverable
INQ00001057
INQ00001057
R reimbursement [1] [releases [1] 137/3 129/18 129/19 139/3 Irequires [7] 27/25
nave) Rina I 44/4 relevant [16] 6/19 repossessed [1] 43/18 113/25 114/25
rearoee (4 ita 45 reinstruct [1] 124/13 I 11/4 11/9 12/6 19/19 I 10719 43719 137/9 137/10
39/23 reinstructing [1] 22/3 24/8 31/21 43/9 Irepresent [13] 17/17 Irequiring [1] 54/22
reduce [1] 55/7 68/10 55/1 59/5 61/16 65/23 I 34/20 54/15 96/5 resolution [13] 8/15
reduced [2] 106/23 reject [3] 59/14 60/1 I 86/14 93/22 105/25 I 96/11 96/17 102/21 I 10/3 10/5 10/12 10/17
43415 62/19 reliable [1] 103/12 104/7 111/15 113/7 I 28/14 48/15 67/4 77/4
reduction [3] 54/19. ITelected [8] 48/4 48/9 [reliance [2] 6/8 114/3 124/14 126/24 I 83/1 88/4 89/12 91/17
54/24 55/4 60/5 74/8 74/16 74/19 I 138/22 representation [10] [resolve [14] 32/10
refer [8] 13/14 1613 I 74/24 123/10 relied [2] 22/5 43/10 I 47/21 69/9 74/7 74/9 I 68/48 68/18 72/20
16/4 51/1 93/6 96/13 relate [6] 32/25 33/2 [relief [2] 7/2 126/19 I 89/9 116/12 119/12 I 72/23 73/4 73/16
120/43 138/11 103/3 126/22 139/10 Irely [1] 115/6 119/21 120/6 125/14 I 76/19 77/21 83/8
reference [37] 3/5 3/9 139/10 remain [4] 15/5 57/19Irepresentations [3] I 86/12 87/3 87/9 109/9
3/10 14/1 14/42 14/13 I"elated [7] 20/1 50/23) 127/21 133/10 97/14 133/15 137/16 Iresolved [2] 33/7
15/9 16/2 16/6 16/12. I 91/8 59/5 60/7 100/18 Iremaining [1] 107/13 Irepresentatives [12] I 82/17
48/13 19/22 29112 I 104/22 remains [11] 11/1 I 5/13 37/6 58/14 75/9 I resolving [4] 8/15
AAIG 41/21 43/22 relates [3] 19/18 50/9 57/3 57/7 57/18 I 86/9 87/12 91/20 65/14 73/6 84/23
44iigasiia 47/14 I 2124 11618 59/18 66/24 83/12 I 91/21 112/2 124/24 I resource [1] 77/9
4912 50/8 58/10 59/5 relating [3] 13/24 I 87/7 91/15 115/13 I 127/21 132/25 resources [1] 70/17
61/10 63/8 83/25 84/2 39/16 90/14 remediation [4] 8/4 Irepresented [13] 3/4 Irespect [18] 3/24 7/7
84/12 84/13 89/20 —_IFelation [74] 10/18 I 10/16 80/21 91/10 12/16 33/20 35/15 19/13 20/4 27/7 27/10
98/3 106/1 120/17 12/18 12/24 13/8 remedy [1] 120/25 I 35/21 36/5 37/5 37/10 I 29/22 41/8 45/10 47/1
4122/1 122/2 127/4 13/12 14/10 17/8 remember [2] 114/10 I 73/24 74/4 82/3 89/2 I 50/13 50/24 53/24
44019 19/16 21/4 21/17 134/8 120/2 56/7 82/10 95/16
referred [8] 33/23 28/11 32/9 42/13 remiss [1] 140/9 representing [2] 81/9I 116/22 132/20
42/49 42/25 43/12 remoteness [2] 24/2 I 84/9 respected [1] 33/25
65/16 82/4 86/7 94/11
402/14 105/5 121/16 44/15 56/11 57/16 28/5 reputation [2] 17/1 I respectfully [2]
reflect [3] 49/8 59/7 59/25 61/20 65/3 I removal [1] 86/1 104/4 112/24 128/25
415/20 116/1 69/18 69/24 70/3 remove [2] 103/16 I reputational [1] respond [2] 11/25
70/22 71/25 72/15 126/10 111/18 140/22
reflected [4] 69/14
94/4 se ee 73/17 73/18 73/25 removed [1] 101/24 Irequest [22] 12/16 Iresponded [3] 69/20
reflecting [1] 46/11 78/5 79/17 80/13 removing [1] 137/14 I 13/17 33/11 33/13 109/11 109/16
reflects [5] 43/5 80/14 82/20 84/17 remuneration [1] 53/1 61/16 61/19 62/6 I responding [1] 3/15
54/22 54/24 71/6 93/3 93/15 97/16 86/21 62/10 62/12 69/10 response [7] 12/15
119/48 97/22 98/8 101/18 renewal [1] 67/14 I 69/13 69/15 69/16 —_I 42/18 45/17 85/16
refused [2] 29/21 104/11 107/3 107/23 Irepaid [1] 18/19 70/3 71/4 71/7 89/20 I 87/17 94/24 110/11
74/5 108/1 108/3 108/9 repay [3] 76/13 97/9 102/8 116/16 responses [5] 69/21
refute [1] 84/21 109/7 109/15 110/6 I 106/20 107/14 128/22 94/16 101/7 108/6
regard [7] 14/5 19/9 112/23 113/11 113/20 Irepayment [1] 15/21 Irequested [3] 11/24 I 108/7
36/16 49/18 86/4 115/8 116/21 117/14 [repeat [5] 38/10 63/21 122/18 responsibility [1]
4101/6 102/25 117/21 121/4 122/14 I 53/22 65/4 68/14 requesting [1] 52/25 I 70/14
regarded [3] 18/19 122/15 122/24 124/4 I 74/23 requests [4] 62/3 [responsible [2] 67/17
41/3 86/14 4124/7 126/25 127/9 Irepeated [1] 133/4 I 64/5 78/13 110/14 113/21
regarding [2] 121/10 127/21 128/5 130/15 Irepeatedly [1] 136/24Irequire [6] 3/551/5 Irest [1] 129/9
433/22 130/17 132/18 139/25 Ireplicated [1] 123/22 I 60/10 64/7 65/10 restrictions [1]
regardless [1] 39/4 relations [1] 110/22 /replicates [1] 101/14 I 105/24 117/10
regards [4] 99/14 relationships [1] 3/23Ireply [1] 26/22 required [12] 28/16 result [16] 18/3 19/22
401/19 108/23 130/9. IFelatively [2] 24/17 [report [18] 45/3 62/13) 43/25 56/6 60/18 88/6 I 20/5 22/19 22/24 23/6
region [1] 135/12 24/19 64/8 94/25 95/11 97/6 I 99/21 101/13 110/2 I 52/14 63/19 67/22
regularly [4] 41/12 release [4] 9/21 9/23 I 97/10 97/17 97/18 116/6 131/8 139/12 I 68/10 70/10 72/7
51/21 99/14 98/22 102/9 102/24 I 139/24 83/21 121/6 131/5
rehearse [1] 24/15 I creased [1] 109/13 I 103/2 120/4 120/8 requirement [1] 56/18] 132/22
(60) recovery - result
INQ00001057
INQ00001057
R 134/18 53/16 58/16 61/23 78/23 79/24 80/18 ISeptember [1] 40/4
resulted [3] 67/15 said [40] 2/19 10/11 I 99/6 113/16 117/17 I 97/7 series [2] 19/9 140/4
68/1 91/9 44/10 12/7 12/24 13/4 I 131/23 136/7 section 5[1] 42/2 I service [1] 105/19
18/25 25/19 30/10 I says [14] 29/7 54/1 Isections [1] 40/19 I services [2] 27/18
33/9 33/22 38/8 45/14 I 60/22 83/19 90/23 I secure [4] 130/25 127/24
46/16 46/19 46/24 106/15 106/19 107/4 Isecured [1] 83/21 I set [47] 7/10 7/18
66/1 92/5 106/15 107/8 111/19 119/14 Isee [17] 1/5 8/21 9/4 I 10/8 10/11 13/18
109/18 114/17 116/25 I 120/21 134/1 134/22 I 9/6 9/22 16/19 19/9 I 33/14 35/8 39/15
resulting [1] 4/20
retail [1] 43/15
retained [3] 24/7
88/11 88/14
retainer [1] 88/9
retire [1] 107/6 4117/3 117/9 120/4 scan [1] 16/21 20/22 22/10 23/1 42/17 51/13 52/18
retirement [1] 116/7 427/17 133/21 134/2 Iscandal [18] 3/16 24/23 57/9 67/2 62/25 65/4 67/25
return [1] 110/10 134/11 134/13 134/16 I 96/9 96/10 96/15 113/16 120/21 127/13 I 68/13 71/14 72/10
135/16 136/2 136/3 I 97/24 104/25 107/20 I 136/22 73/7 77/9 88/11 88/19
review [2] 3/15 97/20
reviewed [1] 118/10
reviewers [1] 118/9
revised [1] 67/23
136/6 136/8 136/13 I 110/19 110/20 111/22 Iseeing [1] 141/2 89/20 90/16 91/22
136/13 136/16 137/24 I 112/21 113/22 115/14 Iseek [12] 8/6 44/4 94/23 97/18 99/9
same [15] 1/19 1/19 I 115/16 115/22 118/2 I 55/17 65/3 70/15 100/14 101/6 104/11
right [18] 18/1 37/15 15/10 29/7 60/1 64/5 I 118/2 132/14 76/19 83/23 85/21 104/17 108/7 108/22
38/19 39/8 63/15 64/23 66/12 73/25 scenarios [1] 58/4 I 90/9 90/19 110/22 111/24 113/10 113/18
63/17 66/6 66/10 77/24 78/1 84/3 102/2 Iscenes [2] 102/20 110/23 118/16 120/24 121/14
66/15 80/16 87/23 125/13 135/8 139/19 seeking [5] 40/15 127/10 130/3 131/22
92/8 92/12 1141/5 sands [2] 102/12 schedule [2] 1/22 48/15 48/25 83/13 138/24 138/25 139/11
112/15 114/24 132/3 I 102/23 TAS 103/15 130/12 140/6
139/49 satisfactorily [1] 35/1I scheduled [3] 4/8 seeks [2] 93/22 Sethi [6] 26/17 69/4
rightly [4] 42/21 satisfactory [1] 29/13I 39/24 67/9 114/14 69/4 69/20 116/15
rigorously [1] 95/7 satisfy [2] 21/17 scheme [143] seem [3] 128/24 116/19
rise [1] 54/17 115/8 scheme's [1] 25/5 129/22 139/14 setting [11] 19/15
risk [3] 30/19 42/9 IS8Ve [1] 7/42 schemes [14] 3/16 Iseemed [1] 123/16 I 65/5 98/22 101/8
76/4 saw [2] 119/43 5/3 5/7 12/19 32/5 —_Iseems [12] 15/3 17/6 I 102/24 108/3 108/24
130/13 100/8 100/9 102/1 34/20 35/13 36/8 1140/4 111/23 121/5
risked [1] 107/19
riven [1] 133/14
rocket [1] 39/5
say [72] 18/4 18/15 I 104/12 123/23 137/6 I 53/12 117/8 120/15 I 122/23
24/25 34/7 35/22 137/11 137/15 139/1 I 125/2 130/18 131/20 I settled [3] 42/8
36/20 37/18 42/20 school [4] 134/11 I 133/3 400/10 113/3
ea uenoan 43/4 4719 47/12 47/13 I scope [2] 84/11 seen [13] 15/17 19/2 Isettlement [30] 3/7
95/17 95102 7/4 I 31/2.51/8 51/25 53/18 I 122/14 23/9 29/20 30/1 36/18 I 3/10 3/10 3/22 6/11
T1104 54/22 55/5 55/7 55/11 \score [1] 110/22 I 35/2460/16 71/5 I 6/17 6/18 6/20 7/3 7/5
roles [2] 4019 116/9 I 86/5 56/6 5912 595 scores [1] 136/20 I Titegoso7t3 I 7/07/14 719 7122
room [f] 4/19 61/8 61/24 63/18 64/3 Iscreaming [1] 111/3 I 122/12 41/16 13/8 26/2 30/21
rough [1] 92/10 65/13 68/13 71/6 73/2 ISoully [5] 11/3 12/5 Iseized [2] 114/11 I 58/13 74/6 74/8 83/16
roughly {t] 741 I 7622775 78 I 1221 34/3 105113 I 11613 83/21 84/24 98/1 98/2
round [2} 45/25 015 I 7828 79/5 79/15 80/4 second [14] 4/24 0/23] self [1] 2614 98/6 105/8 105/16
routinely [1] 17/22 I 80'680/11 80/20 I 12/7 19102015 senior [2} 82/11 13815
ruin 3) 104/48 80/25 81/25 84/4 I 2/10 25/24.43/11 I 444/21 settlements [3] 76/23
MOB MONS 84/25 88/10 88/13 I 45/11 55/13 58/1 60/7 Isense [1] 73/2 89/4 117/13
rule 2} 48118 140/20 I 88/25 89/21 90/24 62/2 65/2 sensitive [1] 45/4 Iseven [4] 12/20 35/6
ruled [1] 42/9 91/24 92/14 95/16 Isecondly [8] 8/11 sent [3] 65/18 65/20 I 35/19 67/7
rules [2] S5/11 oars I 96/18 101/12 1021 I 1944 13/12 27104 I t02 severe [2] 30/18 76/3
run ff} 106/12 404/24 108/9 109/12 I 40/11 71/20 86/6 —_Isentence [2] 37/20 Ishall [2] 61/17 64/24
running [f] 118s I (18/11 117/18 117/22) 90126 38/7 shared [3] 7/19 22/5
panning (i SS I 119/10 122/8 126/2 [Secretary [3] 9/13 _Isentient [1] 103/19 I 125/8
Ss 4128/8 128/20 133/16 I 11/19 40/21 separate [5] 15/13 Ishareholder [3] 11/20
sad [1] 104723 I 1389 138/17 140/21 Isection [14] 40/20 I 56/3 82/18 122/23 I 93/20 10314
sadly [1] 13373 saying [12] 210 I 40/22.42/2.44/14 I 132/15 shareholders [4] 50/3
safe [2] 134/18 34/23. 48/11 49/1 I 59/24 70/9 78/20 —Iseparately [1] 43/8 sharing [2] 61/2 61/6
(61) resulted - sharing
INQ00001057
INQ00001057
Ss 75/18 78/10 78/14 65/12 94/1 98/15 Smith [10] 59/11 19/4 19/17 26/10 29/5
Shazia [1] 107/12 81/10 82/4 83/18 104/22 105/6 59/15 62/13 88/7 32/5 34/7 62/22 74/23
she [21] 107/4 107/4 83/24 84/9 85/19 Sinead [7] 134/6 88/10 88/10 88/13 80/13 85/20 89/17
4107/4 107/5 107/6 85/20 86/6 86/17 134/11 134/13 134/17 I 89/2 118/9 123/12 4117/6 120/19
117/3 123/6 123/9 87/13 87/14 88/9 134/22 135/14 135/16 Iso [158] sort [1] 49/10
4128/6 128/6 134/9 88/11 91/4 91/5 92/19 /single [1] 20/9 so I will [4] 8/24 sorts [1] 39/23
434/10 135/3 135/4 I 98/19 99/23 99/24 sir [93] 2/19 3/5 5/16 Iso-called [1] 118/11 /sought [1] 100/8
4135/9 135/10 135/23. I 100/2 104/3 104/9 8/20 9/5 14/10 25/17 Isold [1] 106/16 sound [1] 129/20
4136/2 136/3 136/6 110/21 110/23 111/13 I 26/18 26/25 27/5 27/8Isole [2] 11/20 103/4 source [1] 132/1
436/11 1413/2 113/22 115/15 I 31/5 32/1 35/4 38/8 I solely [4] 22/21 23/4 Ispeak [1] 112/22
shifting [2] 102/23 116/1 118/17 118/19 I 38/12 38/18 39/11 52/10 100/18 speaking [2] 46/19
440/22 118/21 120/24 122/48 I 40/17 41/9 41/25 solicitor [1] 36/18 49/21
shop [3] 135/9 135/18 122/21 125/18 126/6 I 42/21 43/23 44/7 solicitors [20] 3/4 I specialist [3] 43/14
136/7 126/8 126/17 127/8 I 44/13 49/4 49/5 52/2 I 6/23 12/17 13/6 17/17 I 43/15 43/15
short [13] 1/25 10/22 127/25 127/25 128/4 I 52/15 57/44 57/12 20/13 35/20 36/17 I species [1] 29/23
23/14 24/17 24/19 129/16 131/10 131/25 I 58/9 58/21 59/2 60/16I 37/1 81/14 82/3 96/4 Ispecific [5] 22/21
37/14 38/22 71/16 132/21 137/12 137/12 I 61/12 63/25 64/11 102/15 105/13 111/4 I 40/9 52/11 100/23
92/11 106/23 132/21 [Shouldn't [1] 89/15 I 64/25 65/3 65/8 67/13 112/3 124/4 124/22 I 108/11
439/25 140/4 showed [1] 136/5 69/2 70/22 71/17 72/5I 125/4 133/5 specifically [1] 46/7
short-dated [1] showing [2] 31/1 73/16 73/21 73/23 _Isolution [1] 130/8 I specify [1] 19/14
106/23 4136/4 74/11 74/18 78/20 I solve [1] 132/3 spectrum [1] 17/2
shortfall [47] 3/8 3/25 shows [1] 26/2 84/4 87/17 88/19 some [55] 1/10 4/19 [speed [3] 5/2 76/6
4/2 TAT 8/3 13/24 shut [2] 58/20 129/16 I 91/24 92/15 96/3 96/3 I 5/7 5/22 9/10 26/6 89/12
44/9 14/14 14/14 Siddig [1] 107/12 97/11 99/7 99/16 29/4 30/10 31/2 35/23 Ispeedy [1] 66/16
414/16 14/18 14/21 side [1] 139/7 99/18 100/22 100/24 I 35/24 41/13 55/10 {spend [1] 5/21
14/24 16/14 16/15 sideways [1] 129/16 I 1014/1 102/8 102/24 I 55/14 60/6 72/18 split [1] 1/18
17/5 18/18 18/20 19/2 sign [3] 52/1 118/4 I 103/2 104/15 105/23 I 73/12 74/9 75/8 76/7 ISPMs [2] 112/20
19/13 19/16 19/21 1418/5 107/25 108/5 108/9 I 77/9 78/13 80/4 81/9 I 113/25
19/23 20/6 24/11 signed [1] 138/4 108/11 110/13 112/13) 83/10 84/9 84/13 spoke [1] 134/9
21/15 27/20 40/23 [Significant [7] 4/21 I 112/25 113/12 113/18) 84/15 92/10 94/5 95/9 I spring [3] 5/5 39/25
41/22 41/24 42/5 43/1 I 4/24 17/23 43/16 114/22 116/7 118/4 I 98/4 104/14 104/13 84/19
45/9 45/20 54/19 55/8 I ©7/16 73/6 99/11 120/8 120/10 122/12 I 104/13 104/20 106/14 I staff [1] 111/8
70/5 71/20 73/42 significantly [4] 124/18 127/7 128/9 I 107/20 107/21 110/10 I stage [14] 31/14
73/17 77/10 77/19 16/16 16/20 78/4 129/22 133/1 139/4 I 111/12 112/13 113/7 I 31/14 51/19 64/16
79/19 80/4 80/22 95/21 139/23 113/8 114/5 115/17 I 69/18 72/12 73/5
435/25 138/7 signpost [1] 51/12 _Isister [2] 135/9 116/21 120/5 124/6 I 76/25 84/25 103/16
shortfall’ [1] 18/21 siloing [1] 101/17 135/18 127/3 128/21 131/16 I 113/9 124/14 133/3
shortfalls [13] 3/25 similar [5] 12/13 sit [2] 26/16 46/18 I 132/7 140/2 140/9 135/17
45/18 16/3 16/5 18/14 I 97/17 98/13 117/23 sitting [1] 92/2 somebody [2] 9/2 9/4Istages [4] 63/6 100/3
19/11 19/48 20/4 138/2 situation [5] 56/22 Isomeone [2] 58/6 100/6 119/8
50/23 51/8 55/16 simple [6] 15/20 77/22 120/25 128/19 I 129/12 stand [4] 34/25 92/5
74/13 106/21 71/12 109/25 110/1 I 131/3 something [6] 8/25 I 128/20 135/19
shortly [2] 69/11 116/11 116/13 situations [1] 133/11 I 37/17 45/2153/19 I standard [2] 24/9
90/13 simpler [1] 73/16 six [7] 6/12 19/14 54/22 104/19 26/19
should [76] 1/17 2/5 simply [13] 37/10 81/4 82/21 99/10 sometimes [1] 53/8 Istanding [1] 75/2
5/21 8/16 8/18 8/21 43/4 48/16 48/25 51/3 I 109/11 114/24. somewhat [1] 128/10 Istarkly [1] 136/24
9/3 9/24 14/5 23/23 54/24 79/1 79/25 size [1] 20/6 somewhere [2] 128/7 Istart [6] 38/20 40/22
31/3 33/23 39/20 80/12 84/4 85/1 slightly [3] 46/14 135/12 92/18 123/14 139/6
44/14 47/7 48/24 49/2 119/19 137/5 79/21 99/4 soon [4] 11/17 72/24 I 139/6
49/8 54/10 58/1 58/8 simultaneous [1] slow [1] 59/4 90/12 109/21 started [2] 104/23
61/20 73/23 75/16 99/5 slower [1] 99/4 sooner [2] 5/8 39/21 I 137/5
since [7] 12/3 25/9 [small [1] 134/11 _Isorry [45] 2/14 8/23. Istarting [3] 2/7 48/8
(62) Shazia - starting
INQ00001057
INQ00001057
Ss 109/20 131/18 138/12 139/4 I 18/18 21/9 21/11 28/4) 15/17
starting... [1] 62/1 strongest [1] 129/4 I 139/25 140/2 140/4 I 29/25 31/20 32/19 —_Isuits [1] 79/4
starts [1] 65/23 strongly [1] 97/9 140/7 140/20 32/23 33/13 36/11 I sum [10] 6/22 7/25
state [5] 9/13 14/5 structure [1] 67/24 Isubmit [1] 89/7 43/20 44/3 44/4 45/6 I 23/17 29/16 31/3
1718 39/11 40/21 [Structured [2] 36/5 I submitted [3] 88/6 I 46/1 46/7 46/11 46/24) 77/24 78/2 80/9 85/9
State's [1] 11/19 7713 119/8 125/17 49/15 50/10 50/25 132/7
stated [6] 28/25 97/4 sub [2] 77/10 116/17 Isubparagraphs [1] I 53/11 55/15 57/8 sums [12] 4/24 15/21
405/13 118/7 125/23 ISub-accounts [1] 19/15 59/23 64/13 68/19 15/23 17/23 32/16
434/2 116/17 subpostmaster [9] I 71/13 75/18 76/2 36/2 36/10 78/8 79/13
statement [12] 9/19 sub-scheme [1] 20/16 21/16 23/14 76/11 77/19 78/7 85/6 96/20 107/21
44/4 14/7 12/21 19/42 TTA0 23/19 23/20 96/5 78/12 78/13 78/15 supermarket [1]
25/14 40/3 40/12 66/1 subcategories [1] 122/5 125/24 126/2 I 79/24 80/21 80/23 106/22
97/3 110/15 119/18 12/2 subpostmasters [60] I 81/17 84/14 87/7 supplemented [1]
statements [3] 101/4 subcommittee [1] 2/22 3/23 4/4 4/13 88/23 89/8 91/10 99/1 I 54/10
115/6 137/3 93/22 5/19 8/8 9/17 11/5 101/10 101/12 105/1 I support [9] 21/7
states [4] 21/22 subject [11] 7/8 62/3 I 12/19 13/14 13/23 110/5 115/12 116/8 I 27/17 42/16 44/23
115/23 122/16 130/21 I 93/24 85/23 86/20 15/22 15/23 15/25 122/5 122/6 122/19 I 62/16 72/16 72/20
statistics [2] 73/22 90/18 90/24 91/23 17/10 17/48 17/20 127/9 127/13 130/1 I 89/21 139/17
74/10 108/19 127/3 128/17 I 17/24 18/11 20/21 1341/7 131/9 137/6 supporting [5] 22/5
status [2] 11/20 86/2 subjects [1] 92/6 24/6 28/17 30/5 31/12 I 139/12 61/2 61/6 94/19 95/2
statutory [3] 67/22 submission [13] 2/18} 32/2 32/12 32/17 suffered [8] 4/6 8/9 supportive [1] 87/7
97/8 104/17 39/10 60/9 92/25 96/2 I 33/12 33/20 39/17 20/19 21/10 24/9 suppose [1] 6/15
staving [1] 112/15 97/10 101/13 102/14 I 67/12 90/15 93/10 27/20 50/3 114/4 sure [7] 38/1 112/18
stay [1] 128/10 1277 142/2 142/3 96/21 99/13 101/17 I suffering [3] 49/8 114/3 121/3 122/22
Stein [9] 3/3 92/12 142/4 142/5 102/4 104/18 110/18 I 114/5 116/3 139/21 140/15
submissions [98] 112/12 113/25 114/12 I suffice [1] 69/6 surprise [1] 58/6
Sica coe 4/15 1/24 2/11 2/20 I 114/15 116/5 116/5 I sufficient [5] 5/24 surprises [1] 57/24
steps [2] 5/16 52/4 2/24 5/12 5/13 11/25 I 116/25 117/22 118/25) 20/20 21/7 22/1 95/18 I survive [1] 104/21
stigma [3] 17/1 53/16 12/15 13/18 14/7 15/5 I 124/1 124/4 124/11 I suggest [23] 9/2 Susan [1] 107/2
4121/9 15/9 17/19 18/15 124/24 126/5 126/18 I 29/21 42/23 84/9 suspect [2] 103/25
still [12] 18/20 25/15 24/14 24/24 26/7 126/22 126/23 127/20 I 101/15 115/5 116/13 I 114/19
26/13 106/19 107/5 28/24 29/7 30/9 30/10 I 134/12 131/44 133/10 I 116/24 117/15 118/1 I suspending [1]
411/44 116/23 119/24 I 32/21 33/9 33/12 subpostmasters' [1] I 118/15 119/24 121/23 I 114/13
126/19 131/11 13/9 I 39/14 34/4 34/8 34/9 I 131/24 123/2 126/18 128/3 _Isuspension [1] 60/14
433/25 34/13 38/25 39/13 subpostmistresses I 128/19 131/10 132/19 I suspicion [1] 101/10
stop [1] 64/23 39/15 40/5 40/8 40/14 I [1] 96/6 133/13 136/25 138/13 Iswallowed [2] 7/22
stories [1] 26/16 40/18 42/12 50/17 I subsequent [1] 90/22] 138/19 98/1
story [5] 39/3 110/17 52/19 56/13 57/13 I subsequently [4] suggested [22] 23/20Iswift [1] 10/4
411/49 114/22 119/13 I 99/18 65/4 65/6 65/7 I 6/16 25/3 58/11 29/24 31/20 42/6 —_Isympathetic [1] 57/5
straightforwardly [1] I 65/1268/14.68/25 I 109/17 42/14 49/6 49/7 53/13 Isystem [15] 4/15 6/9
75/11 71/14 73/8 79/2 81/1 Isubstantial [3] 7/21 I 54/16 61/5 67/13 103/8 103/11 103/48
Strategy [2] 9/14 I 85/2 86/26 88/5 90/3 I 61/8 19/9 7AM1 73/22 74/4 103/18 103/19 103/20
103/5 90/19 92/4 93/3 93/5 Isubstantially [2] 8/1 I 75/15 81/10 85/19 — I 103/23 113/3 114/6
stress [4] 45/19 50/2 I 99/7 99/16 94/5 94/11 I 126/19 86/6 86/16 87/11 1414/7 133/25 136/1
64/6 104/22 94/15 94/21 95/3 95/5 Isubstantive [2] 26/21] 89/14 129/12 136/23
stress-related [1] I 95/9 97/5 102/13 33/17 suggesting [1] 64/11 Isystems [1] 103/12
404/22 108/20 109/12 109/18 Isubstitute [1] 39/22 Isuggestion [13] '
strict [1] 55/17 110/11 113/13 113/17 /succeed [1] 44/17 I 51/1055/13.55/23. I —___________
strictly [1] 46/19 115/24 117/5 117/17 Isucceeding [1] 56/5 60/1 75/19 78/10 Itab [32] 8/20 9/21
118/6 119/9 119/25 I 104/17 79/10 83/7 83/15 14/7 12/6 12/22 13/18
strike [4] 51/15
14/11 14/12 14/15
strong [2] 11/22 122/16 125/24 127/15 Isuch [67] 10/21 16/18] 84/21 121/6 132/9
130/18 130/21 131/17) 17/10 17/11 18/3 Isuggests [2] 10/24 I 14/16 14/18 14/22
(63) starting... - tab
INQ00001057
INQ00001057
T tell [3] 39/2 64/15 42/22 43/9 43/21 135/5 135/20 135/21 I 89/5 90/2 95/6 95/19
tab... [20] 16/2 16/4 66/6 43/23 45/11 46/21 135/21 139/5 98/18 99/10 100/9
46/7 16/9 16/18 18/15 Itelling [1] 47/22 48/8 52/14 54/12 55/2 Itheme [1] 79/8 1041/9 101/49 102/22
19/7 20/24 22/11 tells [1] 114/21 60/21 60/24 61/8 62/1 Ithemselves [7] 17/21 I 103/9 105/10 107/18
24/23 25/23 30/8 31/9 Itempting [1] 39/2 66/5 70/2 71/10 71/14 I 33/12 38/10 44/3 411/23 112/14 115/24
31/40 32/1 36/18 ten [4] 74/16 75/4 75/1 79/4 79/16 80/2 I 50/16 83/8 125/15 117/11 117/22 118/4
42/23 52/15 61/14 75/3 92/11 80/10 81/5 81/21 83/6Ithen [66] 10/8 11/6 I 119/5 119/9 119/14
95/1 tense [1] 37/22 84/3 84/18 86/8 87/22I 11/6 12/3 13/12 14/22 I 1241/2 121/5 125/3
tab 17 [1] 42/23
tab 2 [1] 13/48
tab 3 [1] 36/48
tab 7 [4] 18/45
tailored [4] 116/1
take [23] 22/23 23/5
38/15 39/25 47/4
48/18 49/11 52/12
56/20 57/25 58/17
59/21 65/19 68/17
71/24 72/6 89/10
120/8 120/18 121/15
122/3 129/20 134/9
taken [26] 15/21
19/22 23/11 23/19
24/21 36/9 44/14
45/22 45/24 46/2
48/14 49/16 49/21
52/7 52/21 54/4 55/15
56/2 60/17 61/12 67/6
94/18 98/9 115/25
122/14 131/25
takes [3] 65/20 66/8
111/2
taking [6] 25/13 40/12
63/6 96/15 133/6
139/22
takings [2] 135/10
135/10
talking [1] 129/15
tallying [1] 134/12
target [2] 66/21 98/23
targeted [3] 110/2
137/16 140/4
tax [10] 28/10 69/23
70/1 70/6 70/7 70/9
70/11 70/14 70/15
86/2
team [6] 14/3 14/6
67/24 68/6 106/5
118/9
technically [3] 49/13
49/23 50/5
term [1] 67/18
terminal [3] 30/18
31/4 76/4
terminate [1] 88/9
terms [48] 2/5 2/8 3/5
5/15 6/16 6/18 7/4 7/9
8/5 14/12 14/13 16/2
16/6 16/11 17/8 18/13
22/12 23/8 25/22 41/6
41/21 43/2 43/22
44/13 47/14 49/2 52/8
58/9 59/24 61/10 63/7
69/9 81/6 84/12 84/13
84/23 88/20 89/9
89/11 94/20 98/3
105/25 124/47 121/20
4125/2 125/14 126/17
4129/4
terrible [1] 110/20
tests [1] 42/4
than [32] 5/9 8/1
15/20 21/9 24/1 26/5
34/6 34/17 39/21 40/9
45/25 50/19 51/5 55/8
59/10 59/18 64/4
64/10 70/11 76/18
76/24 77/42 77/16
78/8 84/8 92/14
126/20 129/7 133/25
138/9 140/5 140/25
thank [20] 1/6 9/4
38/14 39/11 49/4 49/4
52/18 63/18 64/25
75/7 92/7 92/15 92/20
93/1 95/12 95/14
95/24 95/25 140/8
140/23
Thanks [1] 2/19
that [870]
that I can [4] 1/4
that's [46] 1/24 15/2
18/4 23/11 24/9 26/10
32/15 32/15 33/1
34/12 34/23 38/7
87/24 124/8 127/2
429/19
their [79] 1/22 1/23
2/22 4/13 12/10 12/13
13/10 17/18 17/19
18/15 24/7 2417
248 22/2 2216 27/7
29/17 30/15 31/15
32/9 32/12 32/21
33/15 36/5 44/23 46/9
60/13 72/20 72/23
73/16 76/1 76/15 78/9
85/12 88/5 95/5 95/17
95/17 96/24 96/25
400/12 102/4 104/19
105/20 106/5 106/13
409/7 109/18 11/8
AMAT 112/12 112/16
413/17 11418 11418
114/12 1151/9 115/9
41715 117/24 124/11
421/12 121/12 122/23
124/18 125/19 125/24
126124 134/5 131/8
434/12 13317 13516
136/20 137/23 138/3
138/12 13917 140/6
them [58] 1/5 1/22
4/15 4/17 4/18 4/24
1213 15/8 22/7 22/8
247 24/16 26/16 27/4
29/16 32/24 34/21
45/14 45/15 53/8
53/14 65/10 68/14
7412 TANT 72114
7413 74/16 75/1
772 79/13 99/1
400/19 100/19 101/18
4102/6 104/20 105/8
406/11 108/24 111/10
41214 11214 112/11
414/13 114/16 117/13
421/11 124/20 1311
132/4 133/8 134/25
14/25 15/9 16/16
19/14 19/17 19/23
20/7 21/21 24/12 25/8
28/20 35/2 38/19
38/19 40/22 41/18
44/1 48/10 48/13
53/14 59/3 59/21 62/7
63/9 64/13 64/18 65/2
65/24 65/25 67/24
68/1 73/21 77/11
78/23 79/7 80/7 80/18
83/10 89/13 90/4
92/19 95/20 97/19
98/24 101/8 104/17
104/20 110/10 113/10
11419 114/24 118/9
118/10 125/15 129/14
429/19 130/20 136/14
136/21 140/41
theory [1] 17/7
there [119] 1/12 2/7
3/9 5/19 8/20 9/7 11/1
46/21 19/7 19/14
19/19 19/20 20/7 23/9
23/16 23/21 23/22
25/18 26/24 30/23
33/4 33/13 33/19
35/10 37/18 38/2
38/25 39/5 39/5 41/23
42/4 42/15 43/15 45/9
46/25 47/9 50/12 51/1
51/25 53/8 53/16
54/18 54/20 55/2
55/23 55/23 56/3 56/7
57/22 58/3 59/13
59/16 61/22 62/5
63/11 63/18 64/6 67/8
67/10 67/15 68/4
69/23 71/20 72/18
7315 73/18 74/19
74/24 75/12 77/3
78/13 80/7 80/13
80/20 81/22 83/20
87/18 87/19 88/22
125/18 127/3 130/6
130/14 131/10 131/16
133/9 133/20 133/22
134/19 134/20 135/19
136/21 137/1 140/15
there’ [1] 136/16
there's [6] 1/10 79/24
118/1 134/15 135/25
136/16
thereafter [5] 5/11
10/16 60/4 62/21
90/12
therefore [20] 5/20
7/22 12/10 43/16
45/16 46/25 50/11
78/1 88/2 94/11 98/8
98/22 102/22 118/21
1149/9 120/7 120/15
124/17 130/8 137/25
these [57] 1/21 5/8
5/10 8/21 17/21 18/11
25/25 26/1 26/7 32/12
32/14 34/20 35/4
39/19 39/25 45/8
52/20 64/8 70/18
77/20 82/16 88/4 92/6
93/5 93/9 93/15 94/6
94/9 94/12 94/12 95/3
95/12 95/16 98/19
99/18 102/1 106/7
107/17 107/19 108/19
1192/1 113/14 119/25
121/16 121/19 122/24
123/9 127/1 127/6
129/6 133/1 133/6
135/21 136/19 137/1
138/24 140/12
they [104] 2/12 4/6
6/21 7/20 8/1 9/3 13/7
13/18 13/20 17/3
20/17 20/19 22/6 22/7
24/9 31/14 31/15
31/16 33/7 34/16
34/22 34/23 34/24
(64) tab... - they
INQ00001057
4112/8 113/16 113/22
115/20 116/10 116/25
117/17 122/21 122/23
130/25 131/13 131/13
131/23 132/7 132/13
133/14 134/12 134/13
134/13 135/5 135/6
135/7 135/7 135/8
135/20 136/6 136/8
136/9 136/12 136/21
136/24 137/2 137/3
137/4 137/8 137/10
137/12 138/4 138/10
140/19
they'd [1] 66/17
they've [1] 122/7
things [7] 2/13 3/6
3/14 26/8 102/11
129/5 140/25
think [21] 2/14 38/15
47/4 53/16 58/24 64/3
65/25 79/1 79/9 80/16
92/9 92/18 95/19
102/15 120/18 129/12
129/14 130/13 130/17
140/2 140/8
thinking [3] 25/15
34/16 122/6
third [6] 13/9 36/10
49/6 61/1 70/21 70/21
thirdly [6] 8/14 28/3
40/17 43/18 71/24
86/16
thirds [4] 77/4
this [188]
thorough [2] 82/1
103/15
74/16 75/11 75/21
75/23 76/7 77/1 77/2
77/4 77/25 78/16 81/9
81/20 83/2 84/9 84/23
85/1 86/11 87/19 89/4
90/2 91/1 91/6 91/9
92/1 92/4 93/19 93/22
95/14 96/17 96/18
96/18 96/19 96/19
97/1 97/12 98/12 99/3
99/9 99/12 100/16
1402/1 103/14 104/7
104/24 112/20 117/18
117/25 119/7 120/5
125/11 125/12 125/16
125/18 125/20 126/5
126/114 126/13 126/20
127/24 127/22 130/15
131/25 132/5 132/9
132/21 133/12 133/20
138/2 139/4 139/18
140/5 140/13
though [11] 20/17
23/13 55/21 58/3
65/11 75/4 87/24
98/15 101/5 120/4
125/3
thought [8] 34/11
80/17 104/3 107/13
414/17 128/6 128/17
1441/1
thoughts [1] 57/23
threat [1] 136/21
threatened [2] 96/17
96/19
three [12] 12/1 13/20
14/2 40/6 43/13 50/14
25/14 25/24 30/15
39/4 43/1 54/8 55/15
56/15 56/22 56/25
57/6 58/5 58/7 64/5
65/6 67/16 73/24 76/1
78/22 86/18 92/8
92/10 98/4 105/6
105/11 111/13 111/44
122/7 12911 129/6
136/4 140/2
time-frame [1] 111/14
timeline [1] 69/5
times [2] 64/21
AM1N7
timetable [6] 2/25
5/12 100/14 101/8
101/10 113/9
timetabling [1] 110/8
timing [1] 69/12
timings [1] 92/16
tiny [1] 29/3
tired [1] 107/14
title [1] 113/19
to [1168]
today [27] 1/7 2/23
2/24 5/23 6/19 10/6
11/11 40/5 43/24
66/12 69/6 90/8 93/5
94/13 95/1 102/12
106/7 108/5 112/22
117/9 119/4 120/12
122/20 127/10 138/25
139/20 140/3
today's [3] 40/1 57/4
93/3
together [4] 9/10 38/2!
96/5 125/2
touched [2] 5/1 79/9
towards [9] 13/5
65/14 70/16 70/25
71/9 72/12 72/13
72/22 113/15
track [2] 112/10 117/6
trail [1] 138/10
trained [4] 123/2
trajectory [2] 65/14
66/24
transcript [4] 74/24
75/5 99/5 134/7
transferred [1] 126/7
transparency [1]
37/12
transparent [7] 36/6
88/6 100/9 127/19
128/13 128/22 137/12
transparently [1]
125/8
transpires [1] 129/20
trappings [1] 123/19
traumatised [1] 116/4)
treated [5] 15/24 40/4
43/8 58/23 120/23
treating [1] 113/22
treatment [3] 12/9
121/7 137/22
trial [1] 125/21
tried [1] 136/11
triggered [1] 28/15
troubling [3] 139/8
139/13 139/18
trust [2] 112/7 137/17
trustee [2] 28/8 68/21
truth [1] 104/9
try [4] 8/24 9/2 132/13
INQ00001057
T those [125] 1153/3 I 54/15 59/4 85/17 told [13] 2426/18 I 132/21
they. [1] 35/20 4219) 9/19 6/10 6/13 818 I 91/21 100/4 123123 I 63/11 63/13 63413 trying [4] 64/4 64/10
A214 4711349119 I 91101013 10/18 through [24] 10/7 I 87/20 104/9 105/8 I 65/22 12215
49/20 50122 50/24 I 10/1911/2 12/12 I 33/6 36/20 42/1 65/10) 114/22 120/15 122/20 Ituppences [1] 135/4
51/11 5219 53/3 54/1 I 13/12 13/22 14/1 14/7 I 76/24 77/4 BO/9 80124) 130/12 135/25 turn [13] 8/20 13/19
54/2 60/14 61/8 62/5, I 17/6 23/1 26/15 26/15 I 85/10 93/20 96/22 Itoo [2] 18/14 75/2 I 15/9 16/9 19/6 20124
83/13 66/16 70/15 I 30/12 31/5 33/3 36/25 I 96/23 102/3 103/6 I took [6] 41/25 52/4 I 31/25 36/2 42/23
7017 73/16 7a/t2 I 32/2.37/10 37/24 38/6 I 106/7 110/22 114/9 I 56/19 68/6 96/14 I S4/13 75/21 130/20
79/13 85/5 86/10 gale I 28/12 44/3 48/6 48/16 I 117/13 12611 127/23 I 114/16 139/7
88/10 88/13 91/23 I 48/20.50/14 52/23 throughout [3] 49/10 Itooth [1] 103/15 [Turning [2] 24/12
95/4 97123 ga/15 I 9317 54/5 55/19 55/20 I 68/7 103/14 tortuous [1] 5/16 I 62/7
105/20 108/22 109/18 I 99/15 57/5 58/20 throwing [1] 36/5 total [5] 57/1 81/4 _tutted [1] 135/20
409/18 109125 110/5 I 98/22 62/11 65/6 65/9 tied [1] 105/15 82/21 116/18 134/21 Itwice [1] 78/16
tive 11111 111/16 I 65/1267/4 73/10 time [37] 1/192/10 totalling [1] 13/2 [two [28] 1/4 1/7 1/11
73/15 74/6 74/8 74/10] 5/21 10/22 24/22 touch [1] 132/8 412 1/18 6/13 9/10
11/9 14/22 15/13 23/1
24/7 26/21 57/22
72/14 74/7 77/1 82/20
90/18 92/13 103/9
105/7 108/13 108/19
109/16 135/8 135/24
136/19
two-thirds [1] 77/1
type [4] 46/20 89/17
103/13 120/6
types [3] 42/2 74/17
122/11
typically [2] 46/21
76/22
Tyson [1] 128/23
c
UK [3] 3/2 93/5 103/6
UKGI [8] 93/6 93/7
94/1 94/8 94/10 95/6
95/16 95/21
UKG's [5] 93/15
94/19 94/21 95/2 95/4
ultimately [2] 91/11
118/12
unable [3] 21/16
109/14 115/8
unacceptable [3]
75/17 119/11 126/10
uncertain [1] 2/5
uncertainty [2] 55/3
106/18
unclear [1] 79/20
uncles [1] 135/8
uncover [1] 110/18
uncovered [2] 105/22
136/24
(65) they... - uncovered
INQ00001057
INQ00001057
U unlawfully [1] 132/22 I 64/19 65/1 65/10 102/13 105/20 107/19 I 48/2 48/7 50/21 50/21
nder 149] 6/3 8/5 8/7 Unless [1] 104/19 65/21 65/21 66/20 108/16 111/13 113/12 I 51/3 51/44 51/44
i bt bine unnecessary [2] 44/2I 90/4 90/8 102/10 114/15 121/23 129/5 I 51/14 51/17 53/22
45/12 1712 17/14 55/5 , 114/21 117/8 120/4 I 129/17 133/1 133/9 I 56/14 58/11 58/12
17/20 19/14 24/2 21/2 IUAParticularised [1] I 123/16 124/13 128/24 I 133/9 133/13 137/17 I 58/15 60/8 60/9 61/3
24/21 21/21 25/17 126/4 129/15 129/22 130/11 I 140/23 65/24 65/25 66/2
25/19 26/21 27/7 unreasonable [1] 139/23 via [4] 3/25 66/12 66/21 67/17
28/12 29/20 29/22 60/10 use [8] 1/13 41/5 victim [1] 114/5 67/25 68/4 68/11
29/25 30/4 31/5 31/13 unrepresented [1] 41/10 83/3 87/7 victimised [1] 111/8 I 68/25 69/4 69/13
36/13 41/5 41/6 42/15 74/3 105/23 132/8 140/13 I victims [6] 100/12 71/21 73/8 74/11
42/17 43/2 45/12 47/8 unspecified [1] 132/7Iused [11] 18/5 23/12 I 103/20 104/14 113/23 I 77/19 87/10 88/6 88/6
47/47 59/24 69/21 untenable [1] 123/25 I 28/2 39/3 41/12 51/16 I 131/13 136/25 98/6 102/4 102/16
74/25 74/1 7/14 78/3 until [411] 5/5 25/3 80/14 99/17 106/16 I view [23] 12/18 34/1 I 103/11 104/5 105/8
78/18 79/22 79/24 61/7 79/7 102/12 108/3 115/12 39/16 46/5 46/17 107/13 108/13 108/16
90/24 126/4 132/17 I 107/10 109/13 135/4 juseful [1] 120/7 48/18 50/14 55/2 79/1 I 116/22 120/16 123/9
436/21 136/10 139/19 141/5 Iuser [3] 71/13 116/11 I 82/6 83/20 84/15 85/1 I 123/11 123/13 123/13
underlying [1] 15/2. [UP [54] 7/22 8/20 9/16) 116/14 87/16 88/22 90/14 123/14 123/15 125/25
underpin [1] 47/10 9/20 10/8 10/9 10/11 user-friendly [2] 91/3 91/22 111/2 126/2 126/3 129/12
understand [41] 13/19 16/9 19/6 20/24 I 116/11 116/14 118/15 129/3 138/18 I 130/12 130/24 131/2
40/15 49/1 49/2 51/6 I 26/8 33/14 38/15 using [2] 19/7 124/3 I 138/25 135/9 135/12 136/8
96/12 109/24 124/2 I 42/2345/1148/16 usual [1] 69/22 __I views [3] 90/18 94/17) 136/10 138/9 140/13
425/23 127/5 130/9 I 92/4 53/23 56/10 59/3 Vv 123/5 440/14
139/15 59/4 60/11 61/3 65/5 village [1] 136/15 Iwasn't [2] 39/5 64/11
65/11 65/2066/3 _Ivaluation [3] 82/5 I virtue [3] 52/24 74/10 Iwatch [2] 135/19
understanaing 1 67/25 68/6 68/15 I 86/13 87/4 138/16 1307
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understood [4] 30/13I 77/9 78/8 88/1 89/20 I 33/4 73/10 73/11 Ivital [1] 105/19 water [1] 131/8
36/1 40/25 75/24 90/9 102/11 106/2 I 74/11 74/18 74/20 I voice [1] 35/14 way [45] 2/4 6/25
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undervalues [1] 30/6 I 137/4 137/6 139/12 Valuer [1] 33/24 136/10 60/8 69/13 69/22 82/1
undervalues [1] v6 I 439119 variation [1] 79/8 Iwaited [1] 2620 I g4/5 84/13 84/15
tt up-to-date [1] 106/2 various [5] 1/8 2/12 Iwalk [1] 39/3 84/22 85/7 86/12 92/5
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114/6
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us [314] 5/47 5/22 15/3] 80/12 82/10 82/11 I 25/1 25/2 25/21 26/22 I 41/19 45/1 66/3 82/10
35/13 36/22 36/25 85/23 89/10 90/4 90/6 I 32/3 33/11 33/22 90/4 90/6 102/17
37/3 37/24 37/25 90/13 92/4 92/11 93/8 I 34/15 35/10 37/17 403/25 107/23 120/15
53/13 63/25 64/17 93/12 95/25 98/4 39/4 47/23 47/24 48/1 I 130/12
unfairness [1] 123/3
unfamiliar [1] 28/6
unfolded [1] 38/9
unfortunate [2] 37/16
137/14
unhelpful [1] 77/8
unilaterally [2] 57/17
58/16
unique [1] 81/25
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51/24 110/15 109/25 119/25 120/2 I 95/19 106/21 106/22 I 54/15 57/5 65/19 38/20 40/8 40/12
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44415 126/13 126/13 126/20 I 115/16 119/25 134/11] 75/24 75/25 77/4 90/8 I 50/5 52/12 52/13 53/5
wee'uns [1] 134/24 127/19 129/7 1341/3 135/9 136/20 136/22 I 93/6 95/14 96/18 53/7 53/8 54/13 55/18
week [13] 1/25 1/25 131/12 138/6 140/25 Iwhenever [1] 79/4 I 96/18 96/20 99/13 58/16 62/5 64/3 64/9
25/20 56/18 90/3 90/5 I 141/1 where [50] 11/10 12/7I 103/24 105/3 107/2 I 64/13 66/7 67/2 68/22
90/9 94/13 102/11 what [93] 1/143/19 I 21/16 21/24 23/19 107/19 110/18 111/21 I 72/7 72/24 76/22
4106/8 107/5 136/5 4/1 7/16 18/1 20/13 I 23/24 24/5 27/22 111/24 112/10 112/12 I 79/19 79/25 80/16
44113 23/25 27/1 33/1 37/7 I 27/24 28/3 28/6 28/8 I 112/14 112/20 113/19 I 82/13 82/16 82/25
weeks [5] 10/23 25/3 37/15 42/7 45/14 28/10 28/15 29/13 114/4 114/7 116/16 I 82/25 83/5 83/11
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weight [1] 60/19 48/25 49/1 50/16 43/18 44/15 45/18 120/14 121/22 122/5 I 86/25 89/6 89/18 90/9
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80/20 88/18 92/12 104/2 104/5 104/10 I 136/3 137/5 115/10 114/19 116/14 117/22
409/16 113/17 114/5 I 106/15 108/2 10/2 Iwhereas [1] 126/13 Iwholly [6] 83/12 118/8 118/25 119/15
4146/9 116/13 117/11 I 110/13 111/9 111/25 Iwhereby [1] 1314/3 I 89/22 105/3 119/11 I 122/42 124/14 124/15
4173 147/19 149/47 412/18 112/24 113/16 Iwhether [42] 3/6 17/9I 121/25 139/16 124/20 124/25 125/41
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429/23 129/24 133/16 120/21 120/24 121/4 I 20/15 22/7 23/16 24/3 Iwhose [10] 9/17 126/19 126/25 128/19
134/23 136/2 136/15 I 121/6 121/10 122/8 I 25/14 25/17 27/7 10/13 10/18 10/19 129/8 129/49 129/24
wellbeing [1] 104/7 122/21 127/8 127/13 I 27/11 27/13 27/21 11/2 11/5 11/13 13/23 I 134/19 131/20 132/12
went [10] 37/15 42/1 127/17 127/23 128/4 I 29/8 29/12 30/3 30/24 I 32/22 78/5 133/15 134/8 134/20
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409/16 135/2 135/5 I 129/19 129/20 132/5 I 35/14 48/7 50/22 58/7 I 38/7 41/9 41/15 46/6 I 140/3 140/4 140/16
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were [79] 6/10 6/14 136/5 137/10 139/1 I 75/19 79/13 83/8 91/5I 101/12 102/24 107/22 Iwilling [1] 91/15
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73/10 73/10 73/15 134/20 135/22 49/12 109/20 115/18 I 2/12 2/24 8/21 8/24 I 34/24 37/6 45/1 86/9
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witnesses [1] 136/20
women [1] 32/22
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64/16 64/19 66/16
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73/15 76/12 76/15
77/8 77/20 77/23
78/13 78/24 80/8
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87/20 88/14 89/10
90/4 91/25 95/21
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98/15 98/23 99/1 99/2
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102/25 103/22 105/22
107/10 110/9 112/24
116/6 118/22 120/25
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128/24 128/25 129/5
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140/9 140/12
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40/13 40/18 42/11
60/9 64/8 93/3 93/7
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97/14 109/12 113/13
118/24 117/5 117/16
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130/18 130/20 131/18
138/12
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114/16 116/1 123/25
132/9
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114/16
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15/24 85/12 96/18
wrongs [1] 4/5
wrote [4] 51/18 86/3
Y
39/17 40/12 67/2 77/7
97/4 98/16 104/15
104/23 105/12 106/20
108/12 117/7 118/20
years [9] 26/21 29/14
60/11 101/24 103/8
107/4 107/10 114/24
116/21
yes [15] 18/7 20/2
34/17 38/3 63/2 63/16
66/2 66/14 73/7 92/24
95/23 100/22 100/24
129/10 129/22
yesterday [8] 65/16
65/17 65/18 74/5
85/25 85/25 86/3
124/10
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109/11 123/18 126/4
you [268]
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119/4 120/17 124/18
134/17 134/19 140/24
you,sir [1] 136/13
your [57] 3/5 3/13 4/9
5/20 8/20 9/21 12/15
12/22 13/17 13/19
14/3 14/6 15/4 22/14
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39/14 39/15 39/18
40/11 40/19 42/21
43/23 65/1 65/8 66/1
TAI15 79/2 84/6 88/19
90/14 90/16 90/17
91/3 91/22 97/3 97/18
105/7 105/13
year [16] 4/8 5/5 26/1
99/1 1014/3 105/15
105/17 105/17 105/24
106/5 108/13 109/25
110/14 113/6 124/15
128/20 134/7 138/11
138/18 138/25 141/1
yours [1] 96/1
(68) with - yours