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Witness name: Simon Recaldin
Statement No.: WITN09891000
Dated: 26 March 2025
POST OFFICE HORIZON IT INQUIRY
TENTH WITNESS STATEMENT OF SIMON RECALDIN
1. 1, Simon Recaldin, of 100 Wood Street, London EC2V 7ER, will say as follows:
INTRODUCTION
2. The facts in this witness statement are true, complete and accurate to the best
of my knowledge and belief. Where my knowledge and belief, as set out in this
witness statement, has been informed by another person or by documents that
I have reviewed, I acknowledge that person or those documents. I have been
assisted in preparing this witness statement by Burges Salmon LLP and
Fieldfisher LLP (together "BSFf"), who act on behalf of Post Office in the Post
Office Horizon IT Inquiry (the “Inquiry").
3. I am employed by Post Office Limited (“Post Office”) as the Director of the
Remediation Unit and I have held this role since 10 January 2022. My line
manager is Post Office’s Interim Chief Operating Officer.
4. I make this witness statement in response to a request dated 13 February 2025
for information pursuant to Rule 9 of the Inquiry Rules 2006. Further to my sixth
(WITN09890600), seventh (WITN09890700) and eighth (WITN09890800)
witness statements, the Inquiry has requested supplemental data relating to the
Horizon Shortfall Scheme (“HSS”) and the Overturned Convictions Process
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(‘OC Process’). For completeness, I have adopted the same terminology and
definitions used in my previous witness statements.
5. Post Office has provided data in line with the headings supplied in the Rule 9
request which split the data by date of claims made. Accordingly, Post Office
has used the date of when the application was received as opposed to when
the offer was made by Post Office, or received, by the applicant.
6. As set out in my sixth (WITN09890600) and seventh (WITN09890700) witness
statements, in response to Rule 9(56) and (59) respectively, there are various
reasons why certain applications take different lengths of time to progress
through certain stages of the process. The progress of a number of these
stages is entirely in Post Office's hands. I have set out the steps Post Office
has taken to speed up these stages in my witness statements and oral evidence
(and latterly in the update shared with the Inquiry on 1 November 2024).
However, sometimes an application takes more time to progress through one
of the stages for reasons outside of Post Office’s control. A commentary on the
data and factors impacting timescales has not been requested in this Rule 9
however, Post Office is happy to provide further information if it would be of
assistance to the Inquiry.
7. Also, as requested by the Inquiry, I exhibit to this statement the five letters sent
to public interest Claimants on 25 January 2024", as referred to at paragraph
37 of my seventh witness statement (WITN09890700).
‘ POL00462741; POL00462742; POL00462743; POL00462744; POL00462745.
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REQUESTED DATA
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8. The Rule 9 request sought completion of the below table with data regarding
the HSS:
HSS Stage Number as of 30
January 2025
Total number of applications submitted 8,583
Total number of applications determined to be eligible 6,859
For claims made from the launch of the HSS up to and including 27 November 2020:
Applications submitted 2,479
Applications determined to be eligible 2,349
Applicants who have received an offer following assessment 2,340
Accepted offers 2,032
Fixed sum offers accepted? N/A
BAT Claims awaiting settlement 1
Standard Claims awaiting settlement 104
Complex Claims awaiting settlement 210
Applicants in the Dispute Resolution Procedure® 203
Applications currently at Meeting Stage* 198
Applications resolved following Meeting Stage 160
Applications unresolved following Meeting Stage 12
Applications at Mediation Stage® 3
Mediations resulting in a settlement agreement 7
Mediations not resulting in a settlement agreement 26
Applications withdrawn from the HSS 6
For Claims made from 28 November 2020 to 31 December 2023:
Applications submitted 508
Applications determined to be eligible 450
Applicants who have received an offer following assessment 397
2 Fixed sum offers commenced in September 2024.
This is defined as per Clause 7 of the HSS Terms of Reference (last updated October 2024) (“ToR’).
4 The ‘Meeting Stage’ being defined as those stages described in clauses 7(b) and (c) of the HSS ToR.
5 Cases either having been referred to Wandsworth Mediation Service (“WMS") or awaiting mediation with WMS
as set out in clause 7(d) of the ToR.
® As at 30 January 2025, settlement negotiations were ongoing.
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Accepted offers 288
Fixed sum offers accepted N/A
BAT Claims awaiting settlement 1
Standard Claims awaiting settlement 41
Complex Claims awaiting settlement 105
Applicants in the Dispute Resolution Procedure 88
Applications currently at Meeting Stage 88
Applications resolved following Meeting Stage 37
Applications unresolved following Meeting Stage 0
Applications at Mediation Stage 0
Mediations resulting in a settlement agreement 0
Mediations not resulting in a settlement agreement 0
Applications withdrawn from the HSS 2
For claims made from 1 January 2024 to 31 July 2024:
Applications submitted 1,553
Applications determined to be eligible 1,288
Applicants who have received an offer following assessment 158
Accepted offers 104
Fixed sum offers accepted N/A
BAT Claims awaiting settlement 0
Standard Claims awaiting settlement 276
Complex Claims awaiting settlement 465
Applicants in the Dispute Resolution Procedure 12
Applications currently at Meeting Stage 12
Applications resolved following Meeting Stage 0
Applications unresolved following Meeting Stage 0
Applications at Mediation Stage 0
Mediations resulting in a settlement agreement 0
Mediations not resulting in a settlement agreement 0
Applications withdrawn from the HSS 2
For claims made from 1 August 2024 to 30 January 2025:
Applications submitted 4,043
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Applications determined to be eligible 2,772
Applicants who have received an offer following assessment 8
Accepted offers 2
Fixed sum offers accepted 993’
BAT Claims awaiting settlement 0
Standard Claims awaiting settlement 166
Complex Claims awaiting settlement 125
Applicants in the Dispute Resolution Procedure 0
Applications currently at Meeting Stage 0
Applications resolved following Meeting Stage 0
Applications unresolved following Meeting Stage 0
Applications at Mediation Stage 0
Mediations resulting in a settlement agreement 0
Mediations not resulting in a settlement agreement 0
Applications withdrawn from the HSS 0
Fixed Sum Offers Overall
How many Applicants who previously received an offer for less than I 28
£75,000, but whose applications are not yet settled, have received a
fixed sum offer?
How many SPMs who previously had not applied to the HSS or who I 18,528
had withdrawn, have been written to regarding the availability of the
fixed sum offer?
In relation to HSS and all Applicants whose claims had been settled prior to FSOs becoming
available:
How many became eligible for top-up payments on the introduction of I 1,800
FSOs?
How many of those Applicants have received their top-up payments? I 1,677°
During what time period did those Applicants receive their payments? I 1,628 payments
made between 1
7 Between October to December 2024, Post Office sent 18,528 letters regarding the availability of the Fixed Sum
Offer (“FSO”) to Postmasters. As of 27 February 2025, Post Office had received 5,359 applications for the FSO,
with 2,283 FSOs being issued and 1,712 FSOs accepted.
® Neither of these Applicants had accepted the HSS offer at the time the FSO was introduced.
® The remaining 123 Applicants have been contacted by Post Office to encourage a response to the Top-Up offer.
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August 2024 and 31
January 2025
39 payments made
between 1 February
2025 and 11 March
2025
9. The Rule 9 request sought completion of the below table detailing the average
(mean) period of time an Applicant spent engaging in each stage of the DRP of
the HSS:
Stage of DRP*°
Average (mean)
time in weeks as of
30 January 2025
Time spent in DRP 69
Time awaiting and/or engaging in good faith meeting process 62
Time awaiting and/or engaging in escalation meeting process 44
Time awaiting and/or engaging in a mediation process 30
10.The Rule 9 request sought completion of the below table with data regarding
the OC Process:
Stage of Process
Total as of 30
January 2025
Submissions of full assessment
16
Acceptance of £600,000 offer 58
Acceptance of £600,000 offer without interim payment 4
Initial interim payment applications 107
Initial interim payments made 107
Subsequent applications for interim payments" 103
10 The data metrics used exclude ‘Paused’ cases as defined in paragraph 195 of my sixth (WITN09890600) witness
statement.
" This figure excludes requests for subsequent interim payments from two Claimants who have (1) not yet
submitted fully particularised claims and (2) have received interim payments (of £500k+).
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Subsequent interim payments made 99
Pecuniary claims assessed by POL 16
Non-pecuniary claims assessed by POL 74
Initial offers made for pecuniary claims 10
Initial offers made for non-pecuniary claims 74
Initial offers accepted for pecuniary claims 2
Initial offers accepted for non-pecuniary claims 39
Ongoing without prejudice discussions 13
Settlements following without prejudice discussions for pecuniary I 8
claims
Settlements following without prejudice discussions for non-pecuniary I 10
claims
Pecuniary claims referred to Independent Assessment Panel 1
Non-pecuniary claims referred to Lord Dyson 10
Pecuniary claims referred to Independent Assessment Panel resulting I 0
in settlement
Non-pecuniary claims referred to Lord Dyson resulting in settlement 9
Claims referred to a court for determination 0
The total number of eligible Claimants in the OC process 113
The number of eligible Claimants in the OC process whose convictions I 111
have been overturned
The number of eligible Claimants in the OC Process who are PNCs 2
The number of Claimants who have not reached full and final 22
settlement and have not submitted a fully particularised claim (either
pecuniary or non-pecuniary), excluding PNCs. 12
The number of PNC Claimants who have not reached full and final I 1
settlement and have not submitted a fully particularised claim (either
pecuniary or non-pecuniary), but have received an initial interim
payment.
The number of convicted Claimants who have not reached full and final I 22
settlement and have not submitted a fully particularised claim (either
’2 Including those who are minded to accept the fixed sum offer but could still submit an assessed claim.
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pecuniary or non-pecuniary), but have received an initial interim
payment.
11.The Rule 9 request sought completion of the below table detailing the average
(mean) period of time Claimants have spent engaging in each stage of the OC
Process:
Stage of OC Process Average (mean)
time in weeks as of
30 January 2025
Time from submission of full assessment to initial offer for pecuniary I 6.9
claims
Time from submission of full assessment to initial offer for non- 4.3
pecuniary claims
Time from acceptance of £600,000 offer to receipt of £600,000 0.9
Time from acceptance of initial offer to payment (pecuniary claims) 0.7
Time from acceptance of initial offer to payment (non-pecuniary 1.3
claims)
Time spent in without prejudice discussions following rejection of 12.1
initial offer
Time from referral to Independent Assessment Panel to a N/ATS
determination being made
Time from referral to Lord Dyson to a determination being made 4.4
STATEMENT OF TRUTH
I believe the content of this statement to be true.
Dated: 26 March 2025
‘3 One referral was made to the panel on 8 November 2024 and a full judgmentis awaited.
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Index of Exhibits to the Tenth Witness Statement of Simon Recaldin
Number I URN Document Description Control Number
1. WITNO9890600 I Sixth witness statement of Simon I WITNO9890600
Recaldin
2. WITNO09890700 I Seventh witness statement of WITNO9890700
Simon Recaldin
3. WITNO9890800 I Eighth witness statement of Simon I WITN09890800
Recaldin
4. POL00462741 Letter from HSF to Hudgell POL-BSFF-FLP019-
Solicitors re Compensation for 0000001
Postmaster 1
5. POL00462742 Letter from HSF to Hudgell POL-BSFF-FLP019-
Solicitors re Compensation for 0000002
Postmaster 2
6. POL00462743 Letter from HSF to Hudgell POL-BSFF-FLP019-
Solicitors re Compensation for 0000003
Postmaster 3
7. POL00462744 Letter from HSF to Paul Marshall POL-BSFF-FLP019-
(Cornerstone Barristers) re 0000004
Compensation for Postmaster 4
8. POL00462745 Letter from HSF to Paul Marshall POL-BSFF-FLP019-
(Cornerstone Barristers) re 0000005
Compensation for Postmaster 5
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