WBONO001140
WBON0001140
Claim No. HQ16X01238
IN THE HIGH COURT OF JUSTICE
QUEEN’S BENCH DIVISION.
IN GROUP LITIGATION BETWEEN:
A4
49,
ALAN BATES & OTHERS
Claimants
“ve
POST OFFICE LIMITED
Defendant
draft/ GENERIC DEFENCE
Helpline
Paragraph 29 is admitted. Calls to the Helpline are handled in accordance with the
following process
0)
2)
8)
@)
Helpline operators categorise the caller’s query using an online system (now called
“Dynamics”, previously called “Remedy”) and then provide advice by reference to
the Post Office “Knowledge Base”, an online resource which contains numerous
articles and other guidance documents on various matters (but is not scripted).
If the Knowledge Base does not contain sufficient information to allow the operator
to address the query, the next step is for the query to be escalated to a second tier of
more experienced staff.
If the second-tier adviser cannot respond in a satisfactory way to the query, he or she
will seck assistance from the relevant Post Office product team. For example, if an
issue relates to a lottery product, assistance would be sought from the team at Post
Office who manage the operational processes for that product. For issues relating to
the technical operation of Horizon (e.g. a broken printer), the matter could be
referred to Post Office's IT support partner, which was originally Fujitsu and is now
a company called Atos.
If, after these steps, a satisfactory response has not been given, Post Office will
consider whether to organise a visit to the branch and/or further training for the
Subpostmaster and/or Assistant(s) concerned.
WBD_001010.000001
WBONO001140
WBON0001140
(5) Post Office is willing and able to provide further assistance to Subpostmasters whose
problems are not addressed adequately through the Helpline. It is for any Claimant
who asserts that inadequate assistance was provided to identify, amongst other
things, the steps that he or she took to obtain further advice, assistance and/or
training.
Paragraph 30 makes allegations to which Post Office cannot meaningfully respond at the
pleaded level of generality. Post Office will respond to properly particularised claims if and
when they are made by particular Claimants, but the general thrust of the allegations is
denied. Further:
(1) The Helpline’s hours of operation have changed over time to meet demand and
there have been periods where the Helpline was more difficult to contact than in
other periods. It currently operates from 8am to 8pm on weekdays other than
Wednesdays (the usual day for branch balancing processes), 8am to 9pm on
Wednesdays, 8am to 6pm on Saturdays and 9am to 5pm on Sundays and most bank
holidays.
(2) Helpline operators do not give script-based responses.
(3) Helpline operators are not instructed to provide misleading information or advice
and they would have had no reason to do so.
(4) Whether it is appropriate to advise a Subpostmaster that a discrepancy should sort
itself out depends on the context. For example, the branch could be awaiting a
Transaction Correction that should correct an issue.
(5) Helpline operators are not instructed to encourage a Subpostmaster to produce and
confirm a Branch Trading Statement which the Subpostmaster did not believe to be
true and Post Office cannot conceive of a situation in which they would do so.
(6) Helpline operators are not instructed (and are not in a position) to review and advise
callers as to the experience of and the incidence of particular problems suffered by all
users of Horizon or of the Helpline or as to the incidence of such problems suffered
by all such users. Post Office cannot conceive of a situation in which Helpline
operators would do these things, or would have the knowledge to be able to make
such statements.
WBD_001010.000002
WBONO001140
WBON0001140
(7) _ Post Office notes that, in the GPoC, the Claimants have not indicated whether and,
if so, how each of the matters alleged in paragraphs 30.1 to 30.7 is alleged to have
caused any Claimants any loss.
WBD_001010.000003