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Department for Department for
Business & Trade Business, Energy
& Industrial Strategy
Guidance
Terms of reference for the GLO
independent reviewer
Updated 10 January 2025
Contents
Overriding objectives
Review application procedure
Assessment of claims
Reviewer assistance
Communications with DBT and Third Parties
Fees
Review and approval
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© Crown copyright 2025
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This publication is available at https://www.gov.uk/government/publications/compensation-
scheme-for-group-litigation-order-case-postmasters/terms-of-reference-for-the-glo-independent-
reviewer
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The Government announced the ex-gratia Group Litigation Order (GLO)
Compensation Scheme (the Scheme) on 22nd March 2022 with the
objective of ensuring postmasters who were part of the GLO and not eligible
to seek compensation from the Post Office have access to fair
compensation for their Horizon-related losses. The Scheme will be run and
delivered by the Department for Business and Trade (DBT). The terms of
the scheme are described in its Guidance and Principles
(https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attach
ment_data/file/1145098/glo-guidance-principles.pdf).
On 4th September 2023, DBT appointed Sir Ross Cranston to the position
of Independent Reviewer for the GLO Scheme.
In addition to considering Review Applications (defined below), the
Reviewer may also determine non-review related issues referred to him by
DBT via Dentons which arise throughout the course of the Scheme. This
may include, but is not limited to, eligibility for the Scheme.
Overriding objectives
1. The Independent Reviewer (the Reviewer) will apply his independent
judgement to individual cases, guided by considerations of fairness and in
line with the Guidance and Principles.
2. Where a claim is referred to the Reviewer, he will assess whether the
Independent Panel’s final assessment:
¢ was substantially inconsistent with the Guidance and Principles
¢ reflects a manifest error, procedural irregularity or a substantive error of
principle
(the Review Criteria, as defined further in the Guidance and Principles).
3. The Reviewer will only issue a written determination in respect of Review
Applications (defined in paragraph 5 below) which:
¢ were made within 15 working days of receipt of the Independent Panel’s
final assessment
e show a prima facie case that meets the Review Criteria
4. The Reviewer will carry out this process in a timely manner, while also
accounting for the need to ensure sufficient care and consideration is
given to each claim in order to provide a fair assessment.
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Review application procedure
5. If either party (the claimant or DBT) believes the Independent Panel’s
final assessment meets the Review Criteria, they can make an
application (Review Application) for review of the decision within 15 days
following the issue of the Independent Panel’s final assessment. A
Review Application should be completed in the form provided to the
parties by the Dentons claims facilitator assigned to the case (the Claims
Facilitator) when circulating a copy of the Independent Panel's final
assessment and should be no more than one page in length. Review
Applications are to be made via the Claims Facilitator who will then
provide a copy to the other party.
6. 1. Upon receipt of the Review Application, a senior lawyer at Dentons (the
Dentons Senior Lawyer) will provide their view to the Reviewer as to
whether there is a prima facie case that it meets the Review Criteria. The
Reviewer will decide whether such a case exists and will communicate
his decision to the Dentons Panel & Reviewer Liaison assigned to the
case (the P&R Liaison) within 10 working days of receiving the Dentons
Senior Lawyer’s view. If he concludes that it does not, the Claims
Facilitator will notify the parties accordingly and the Independent Panel's
final assessment will stand. If the Reviewer concludes that a case exists,
the Claims Facilitator will write to the parties to notify them accordingly
and to invite each party to prepare written submissions, which should not
exceed two pages in length (the Review Submissions).
Assessment of claims
7. In reviewing the Review Application, the Reviewer will follow the
Assessment of Claims process as set out at paragraphs 8 to 12 below.
8. When assessing whether the Review Application meets the Review
Criteria, the Reviewer will consider the following documentation which he
will receive from the Dentons P&R Liaison and which he should review
before making his final determination:
¢ aclaim-specific instruction letter
* areview summary document which sets out a summary of the Review
Application
e the Review Application
* acopy of Dentons’ letter confirming the Independent Panel’s initial view
following the first Independent Panel stage
¢ acopy of the Independent Panel's final assessment
¢ all documents which the Independent Panel received in relation to each
claim
10.
11
12.
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the parties’ Review Submissions produced pursuant to paragraph 7
above, setting out the respondent's position in relation to the alleged
substantial inconsistency with the Guidance and Principles and/or
manifest error and/or procedural irregularity and/or substantive error of
principle.
. The Reviewer will also consider the Review Application alongside any
comments on it which he may invite from the Independent Panel.
If in the exceptional circumstance, upon receipt of instructions in relation
to an eligible claim, the Reviewer considers that he is unable to form a
view without further evidence (including expert evidence), the Reviewer
should notify the P&R Liaison as soon as possible. The Claims Facilitator
will then seek this further evidence from the claimant or DBT (as
appropriate).
. The Reviewer will provide a written determination which will set out
whether the Independent Panel's final assessment should be upheld, the
reasoning for that decision and the total compensation award to be paid
to the claimant (in the event that the Independent Panel's final
assessment is not upheld) (Written Determination). The Reviewer should
provide the Written Determination within two weeks of receipt of the
claim-specific instruction letter.
The Claims Facilitator will then issue the Written Determination to the
parties.
Reviewer assistance
13.
14.
1. Astanding Secretariat to the Reviewer (the P&R Liaison Lead) will be
provided by Dentons.
The Reviewer may seek such further support from others as may be
agreed with Dentons.
Communications with DBT and Third
Parties
15.
The Reviewer may maintain direct contact with the Horizon
Compensation Advisory Board, DBT and the Justice for Subpostmasters
Alliance.
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Fees
16. DBT is liable for the Reviewer’s fees and disbursements.
Review and approval
17. This version of the Terms of Reference was approved by DBT on 11
November 2023.
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