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Witness Name: Elizabeth Jane Kennedy
Statement No.: WITN11830100
Dated: 10 December 2024
POST OFFICE HORIZON IT INQUIRY
FIRST WITNESS STATEMENT OF ELIZABETH JANE KENNEDY
I, Elizabeth Jane Kennedy, will say as follows
INTRODUCTION
1. lama Principal Public Prosecutor in the High Court & International Section
of the Public Prosecution Service for Northern Ireland (hereafter ‘PPSNI’).
This witness statement is made to assist the Post Office Horizon IT Inquiry
(the “Inquiry”) with the matters set out in the Rule 9 Request dated 28"
October 2024 (the “Request’).
BACKGROUND
2. I hold an LLB degree from Queens University, Belfast. I completed my
professional training and was admitted to the Roll as a solicitor by the Law
Society of Northern Ireland in 1999. I worked in private practice in criminal
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law before joining the PPSNI in 2012 as a Public Prosecutor. In 2024 I
became a Principal Public Prosecutor in the High Court and International
Section.
PPSNI INSTITUTIONAL AND INDIVIDUAL KNOWLEDGE OF HORIZON
ISSUES
3.
The PPSNI have been asked to set out when it first became institutionally
aware of any bugs, errors and defects in Post Office Limited's (hereinafter
‘POL’) computer system, Horizon, with the potential to affect transaction data
and/or create balancing problems in a Post Office branch and/or impact upon
the reliability of the Horizon data being used in support of prosecutions of
subpostmasters, their staff or POL employees. The PPSNI first became
institutionally aware of issues with the POL computer system, Horizon in
June of 2020.
(i) I This was communicated to the PPSNI by way of an email dated 18"
June 2020 from Peters & Peters to Ms Catherine McGalie, in her
capacity as a Principal Public Prosecutor in the Fraud and
Departmental Section of the PPSNI. Ms McGalie escalated this
through her line manager Mr Graham Cardwell to senior management
in the PPSNI. A decision was taken that as this related to Court of
Appeal cases and CCRC referrals this matter would be dealt with by Mr
James McLernon in the High Court and International Section of the
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(ii)
(iii)
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PPSNI under the supervision of the Assistant Director for the section,
Ms Eilis McGrath.
I exhibit a copy of the email dated 18'" June 2020 with the spreadsheet
of cases attached thereto (WITN11830102 and WITN11830101).
The PPSNI responded to this communication by identifying the cases
involved using the details provided to identify as many corresponding
PPSNI files as possible. The PPSNI asked the PSNI to conduct
searches for material they might hold. We used proactive searches to
try and identify any other N.I. cases affected by Horizon. The search
functionality on the PPSNI case management system is limited but the
PPSNI were able to identify additional cases not on the original POL
spreadsheet by searching for a specific witness, for example POL
investigators such as Ms Suzanne Winters. A preliminary review of
identified files was carried out by the relevant Assistant Directors in the
regional sections and the Fraud and Departmental section of the
PPSNI where these cases were dealt with previously. Thereafter the
files were passed to Mr McLernon for further action.
Peters & Peters, who act on behalf of POL, assisted in providing up-to-
date contact details for people potentially affected by Horizon and the
PPSNI worked closely with the Criminal Case Review Commission. The
PPSNI then sent pro forma disclosure letters to every person for whom
we had contact details. This letter gave a brief summary of the previous
prosecution brought against them, summarized the English High Court
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and Court of Appeal judgments on Horizon deficiencies and provided
web links to the full judgments. It advised on the process in Northern
Ireland of how to challenge a conviction by way of an appeal. The letter
also signposted them to the CCRC website and advised each person to
obtain their own independent legal advice.
The PPSNI been asked whether, before 2013, any PPSNI employees, such
as Public Prosecutors or other staff members, became aware of any issues
(whether understood at the time to be caused by bugs, errors or defects or
not) within the Horizon system with the potential to affect transaction data
and/or create balancing problems in a Post Office branch and/or impact upon
the reliability of the Horizon data being used in support of prosecutions of
subpostmasters, their staff or Post Office employees. Based on the
documents available, before 2013, the PPSNI were not aware of any issues
with the Horizon system with the potential to affect the reliability of the
Horizon data. It appears, from the documents available, that in three cases
reviewed, the defendant, or their representatives, raised issues with the
Horizon data during the course of their prosecution. These are the cases of
Mr Alan McLaughlin, Ms Maureen McKelvey and Mrs Patricia Fegan. Mrs
Fegan’s case related to allegations from 2014. Mr McLaughlin and Mrs
McKelvey's cases are referred to in more detail in the following paragraphs.
In addressing the question of when the PPSNI became institutionally aware
of issues with the Horizon system and the question of whether any PPSNI
employees were ware of such issues before 2013, you have asked that
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consideration is given to specific documents. I will address each of these in
turn:
Letter from Charles McKay to Mr R McCarey dated 6 November 2004
at pages 4-5 (PNI00000001_036). This correspondence relates to the
prosecution of Ms McKelvey and the PPSNI would refer you to the
witness statement provided by Mr Kevin Shiels (WITN10580100), and
his subsequent testimony to the Inquiry in respect of this matter. Mr
Shiels has dealt with this matter in his testimony.
Letter from Madden & Finucane Lawyers to Director of Public
Prosecutions regarding Mr Alan McLaughlin dated 9 September 2022
at (AMCL0000001). This correspondence is specifically dealt with at
paragraph 6 below.
Post Office email chain from January 2020 at (POL00292987). The
PPSNI were not party to this correspondence and this email chain does
not refer to the PPSNI. We are therefore unable to confirm whether this
email was sent to PPSNI and do not have a record of this. We are
therefore unable to assist the Inquiry in this regard.
Letter from Amy Quirk (Senior Security Intelligence Manager, POL)
dated 11 December 2015 at (POL00333548). This letter appears to be
directed to the CPS, not PPSNI. On reviewing the documentation on
the identified files, the PPSNI have no record of receiving a copy of this
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vi.
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correspondence at any stage and are unable to assist the Inquiry in this
regard.
Post Office email chain from January 2020 at (POL00293011). The
PPSNI was not party to this correspondence. The email queries if
“Horizon update letters” were sent to Northern Ireland. On reviewing
the documentation on the identified files, the PPSNI have no record of
receiving any such correspondence and again are unable to assist the
Inquiry in this regard.
Email exchange between Mr Simon Hutchinson and PSNI dated July
2016 at (POL00333558). The PPSNI were not a party to this email
exchange. On reviewing the documentation in the identified files, it has
been established that this may relate to the prosecution of Ms Liza
Coleman, as Constable Gordon of the PSNI was the Investigating
Officer on that file and it related to a prosecution in 2016. This
prosecution related to the Defendant's fraudulent use of a pre-paid
credit card, the Sub-postmistress contacted police to state that the
defendant was using a credit card in the Post office branch, requesting
the card be “swiped” to withdraw money, she was handed the cash
“withdrawn” but due to an error the money was in fact being credited to
the credit card account. It is unclear from the evidence provided if this
was an error in the Horizon system or an error by the staff in not
recognizing this was a pre-paid credit card. Subsequently, the Directing
Officer raised enquiries with the Investigating Officer as to the amounts
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vii.
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taken as he could not reconcile the loss claimed by POL, of over
£10,000 and the amount the Defendant accepted she had gained,
approximately £4,000 to £5,000. The documents provided by the credit
card company did not match those figures provided by the POL. In
response to the Directing Officer’s enquiry, he was provided further
evidence from the credit card company but ultimately the Directing
Officer noted, “In view of the difficulty in reconciling the Post Office data
in respect of the use of the Mastercard with the Mastercard data, a
direction is being issued to prosecute Liza Coleman on Indictment for a
GENERAL DEFICIENCY FRAUD OFFENCE which will encompass all
her dishonesty” . There is no record on the file of the email exchange
referred to above.
Letter from Amy Quirk (Senior Security Intelligence Manager) titled
‘Disclosure for PPS’ dated 1 June 2016 at (POL00333553). The PPSNI
have no record of receiving said correspondence. The letter is not
addressed to any specific PPSNI office, department or member of staff
and therefore would be incredibly difficult to trace.
Letter from Inspector J McCleary to Public Prosecution Service dated
16 August 2004 and accompanying documents at (PNI00000001_071).
This correspondence relates to the prosecution of Ms McKelvey and
the PPSNI would refer you to the witness statement provided by Mr
Kevin Shiels and his subsequent testimony to the Inquiry in which this
is dealt with fully.
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Email exchange between Mr Jarnail Singh, Ms Suzanne Winter and Mr
Ernie Waterworth and others dated September 2013 at
(POL00125050). The PPSNI were not a party to this correspondence
and there are no records to suggest that this was sent to PPSNI. We
are therefore unable to assist the Inquiry in this regard.
Email from Constable Alan Gordon to Mr Simon Hutchinson dated 20
June 2016 at (POL00333554). I would refer you to paragraph vi above.
PPSNI were not a party to this correspondence and neither this
correspondence, nor the reply, have been located in this file. It cannot
be confirmed whether this correspondence was received in PPSNI, and
we are unable to assist the Inquiry in this regard.
The PPSNI has been asked a number of questions in relation to a
suggestion that Mr Ernie Waterworth (a legal advisor instructed by Northern
Ireland POL Security Team in 2013) was going to meet with the “DPP to
establish if police can be taken out of the handing over process”. In respect
of this, I can confirm the following information:
Aletter was sent by email by Mr Ernie Waterworth on 10 April 2013 to
PPSNI requesting a meeting with the then PPSNI Deputy Director, Ms
Pamela Atchinson, who has since retired. I have exhibited this email
correspondence WITN11830103. On reviewing the remaining archives,
the PPSNI were able to locate a brief email, dated 4 June 2013, which
appears to confirm that the meeting took place with Mr Stephen Herron,
then Assistant Director of the Fraud and Departmental Section, not with
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the Deputy Director. I have exhibited a copy of this email
correspondence at WITN11830104.
This email confirms the outcome of the meeting was an agreement that
as McCartan Turkington and Breen were retained by POL they would
forward complaints and investigation files directly to the PPSNI and not
via the PSNI.
A further email exchange was located, dated 17 January 2014, from Mr
Stephon Herron, then Senior Assistant Director in the PPSNI, to PPSNI
colleagues, referring to the meeting with Mr Waterworth. This details
that the meeting with Mr Waterworth took place in May 2013 and
related to the manner of submission of POL files and the possibility of
drawing up an SLA (Service Level Agreement). This email
correspondence confirms that the SLA was not completed. I have
exhibited a copy of said email at WITN11830105.
On searching the archives, we have located a report from the Criminal
Justice Inspection Northern Ireland, dated July 2008. A copy of said
report is exhibited at WITN11830106.This report is an inspection of the
Royal Mail Group Crime Investigation Function and at point 4.6 there is
a recommendation that POL cases be “submitted by a more direct
method”. It seems likely that this was the basis for the discussions
between Mr Waterworth and Mr Herron at the meeting detailed above.
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Aletter dated 24 March 2009, from the PSNI to a Mr William Boyd,
Royal Mail Investigations, has also been located in the PPSNI archives.
I have exhibited a copy at WITN11830107. This letter indicates that the
PSNI wished to remove themselves from the process of passing files
from Royal Mail to the PPSNI (then PPS) and for files to be submitted
directly.
I can confirm that the suggested Service Level Agreement between
PPSNI and POL was not finalised and there is no record of this having
been agreed. PPSNI continued to receive POL files from PSNI after this
date.
PPSNI have no record of any communication with Mr Waterworth
specifically in relation to Mr Damian McCartan's case.
The PPSNI has been asked whether anyone from PPSNI attended a
meeting in November 2004 as suggested by Mr Michael Madden (of Madden
& Finucane Solicitors) and Mr Alan McLaughlin. The original file relating to
the prosecution of Mr Alan McLaughlin was destroyed in accordance with the
retention policy of the PPSNI in October 2008. There are therefore no
records or documentation relating to a meeting in November 2004. The
documents referred to do not identify the Prosecutor. The Directing Officer
who took the decision to prosecute has retired and is not available to assist
with this query. It is therefore not possible to confirm whether anyone from
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PPSNI attended such a meeting or to provide any details as to the
discussions if this did take place.
The e-mail from Constable Gordon to Simon Hutchinson dated 1 July 2016
(POL00333558), does not contain any PPSNI file reference numbers, the
name of any possible defendant, nor does it refer to any prosecutor by name
to enable the relevant case file to be identified. As per paragraph 4(vi) above
it is considered likely that this relates to the prosecution of Ms Liza Coleman.
On reviewing the documents in our possession in respect of the prosecution
of Ms Coleman, we have not discovered any documentation which would
confirm that the discussions with the PSNI referred to in the email took place
or what was discussed. There is no evidence to suggest that the email was
shared with PPSNI, and we are therefore unable to assist the Inquiry in this
regard. We are unable to clarify this with the case Directing Officer as they
have retired. As set out in paragraph 4(vi) above, this case did not relate to
the prosecution of a sub-postmaster or sub-postmistress, but rather to the
fraudulent use of a pre-paid credit card by a member of the public.
The PPSNI has been asked whether it was ever made aware of the Second
Sight and Helen Rose reports. Based on the documents held by PPSNI there
is nothing to suggest that PPSNI was at any stage made aware of the
Second Sight and Helen Rose reports. No copies have been located.
The PPSNI has been asked questions in respect of the prosecution of POL
cases between 2000 and 2013. I can confirm as follows:
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10.
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The Horizon evidence presented to the PPSNI was normally in the form
of transaction logs or print outs exhibited to statements provided by the
POL investigators. The investigators normally included some
paragraphs in their statements as to how the Horizon system operated,
these were technical in nature, and then detailed the evidence obtained
from the system and exhibited the relevant printouts.
The extent to which the prosecution relied on this evidence varied
depending on the facts and evidence in each individual case.
The PPSNI had no reason to specifically interrogate the Horizon
evidence and data.
In each case the decision to prosecute was taken based on all
available evidence and by applying the test for prosecution as detailed
in the Code for Prosecutors. The test for prosecution is set out in full
along with the relevant provisions of the Code for Prosecutors in the
witness statement of Mr James McLernon, witness statement
[WITN10280100]. A suspect is not put on their plea nor is a guilty plea
accepted in any case before a decision is taken as to whether the test
for prosecution is met.
The PPSNI has been asked whether it was ever made aware of the advices
of Simon Clarke (POL00113694 and POL00006799). On the documents
reviewed, to the best of my knowledge, it does not appear that PPSNI have
ever been made aware of the advices of Mr Simon Clarke. They do not
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11.
12.
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appear on any of the identified files and Mr Jennings is not listed as a
witness on any of the identified files.
The PPSNI has been asked whether, in relation to prosecutions of POL
cases relying upon Horizon evidence, PPSNI instructed any experts and/or
asked POL to provide evidence/testimony relating to the Horizon IT system
or the reliability of information extracted from it. As stated in paragraph 9
above, the POL files typically contained a statement from the investigator,
giving a brief description of how Horizon operated, before detailing the
specific evidence relied on. On the identified files, there is no evidence that
the PPSNI ever instructed any experts or asked POL to provide
evidence/testimony relating to the Horizon IT system or the reliability of
information extracted from it. The witnesses, namely the investigators, may
have been asked such questions in the course of giving their testimony, but
PPSNI have no records of same.
The PPSNI has been asked a number of questions relating to paragraph 41
of Ms Suzanne Winter’s statement (WITN10400100). Ms Winters does not
detail any specific meetings or name any PPSNI representatives who
attended said meetings. PPSNI would have raised typical queries with the
PSNI investigating officer, who submitted the file, and possibly the POL
investigators, where required. PPSNI may have held meetings where
necessary in individual cases to clarify evidential queries but at all times
retained independence as the prosecuting authority. It is not possible to
identify whether any meeting as described by Ms Winters took place or
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13.
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indeed which case this would have related to. An examination of the case
files held has no record of any such meeting having taken place.
PPSNI Conduct of Prosecutions and Disclosure Oligations
The PPSNI has been asked to consider paragraph 39 of Ms Suzanne
Winter’s statement (WITN10400100) and advise whether it did/does have an
agreed process or Memorandum of Understanding in relation to how Post
Office cases were/are prosecuted. To the best of our knowledge, there has
never been a Memorandum of Understanding or an SLA (Service Level
Agreement) in relation to how Post Office cases were processed. The
process is described in the earlier statement to the enquiry of Mr James
McLernon, witness statement (WITN10280100), at paragraphs 24 to 30
therein. There was only one exception to this process in the identified files,
this related to the prosecution of Mr Robert Dillon.
On a detailed review of the papers, it appears that this file was submitted to
the PPSNI by McCartan, Turkington and Breen Solicitors on 24th May 2013.
The investigation on this file was carried out entirely by POL and there was
no PSNI involvement. This case is not a “Horizon” file, in that the prosecution
did not rely on Horizon data. An unscheduled audit was carried out at the
Post Office branch, this detected a discrepancy of approximately £12,000.00.
The Sub-postmaster Mr Robert Dillon was contacted, and he confirmed on
the phone that he had taken £12,000.00 in cash to pay for a car for his wife,
as they had been in an accident the previous day. He confirmed he was still
in possession of the cash and returned to the branch with £12,000.00 in cash
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that day. Mr Dillon confirmed this account in interview and subsequently
entered a guilty plea to the directed charges.
The PPSNI has been asked why it was not until 2020 that Horizon related
cases were identified. As per paragraph 3 above, PPSNI did not become
institutionally aware of issues with the computer system, Horizon until June
of 2020. Prior to this, issues had only been raised in relation to the Horizon
data in a small number of cases, namely the prosecutions of Mr Alan
McLaughlin and Ms Maureen McKelvey, which are looked at in detail below,
and in the case of Ms Patricia Fegan.
In the case of Ms Fegan, she specifically stated in interview that the
computer system was to blame for the discrepancies in the accounts. The
decision to prosecute was based on admissions made by Ms Fegan in
relation to false accounting only, rather than relying on the Horizon data and
this was not used in the prosecution. Prior to taking her decision as to
prosecution, the Directing Officer on this file did raise a query with the
Assistant Director of the Fraud and Departmental Section, Mr Ciaran
McQuillan, and with other Senior Public Prosecutors as to whether there
were any other prosecutions in Northern Ireland where the failures of the
Horizon system were at issue, she was advised that they were not aware of
any such files.
It appears that the PPSNI received relatively few prosecution files relating to
POL. The cases were dealt with by individual prosecutors, working out of
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various offices throughout Northern Ireland and the challenges to Horizon
evidence were case specific and did not give rise to a requirement to a
review of all files received.
The PPSNI has been asked whether, once it became aware of relevant
Horizon issues, POL made any suggestions as to the approach that PPSNI
should take in relation to its Horizon cases (both open and closed). When the
systemic issues in respect of Horizon evidence were brought to PPSNI
attention, the approach followed is that described in Mr McLernon’s witness
statement to the Inquiry (WITN10280100), at paragraphs 31 to 33 as set out
below for ease of reference:
“31. Going forward, PPS understands that the Post Office will
continue to conduct their own internal investigations but where it
becomes apparent that a criminal offence may have been committed
the matter will be referred to Police at that early stage.
32. PPS understands that all statements provided by the Post Office
in respect of ‘legacy Horizon’ or providing ‘legacy Horizon’ data now
comes with a clear warning of the judicial findings that have been
made about bugs, defects and errors. As at the date of signature of
this statement, following inquiries with the Regional and Fraud
sections of the PPSNI, we are not aware of any ‘live’ cases involving
investigations which postdate the ‘Horizon’ issues coming to light.
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16.
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33. There was a more recent case arising from a branch audit in
2019, initial audits were conducted by POL who then turned material
over to PSNI who led the investigation and conducted a PACE
interview. During the course of the investigation POL brought to the
attention of the PSNI investigators that there were significant issues
coming to light with the reliability of the ‘Horizon’ IT platform. In this
case the PPSNI directing officer reviewed the file and directed ‘no
prosecution.’ The file has therefore been closed.”
The PPSNI has been asked whether, once it became aware of the Horizon
issues, PPSNI’s prosecution process changed in any way in relation to Post
Office cases where Horizon was concerned. PPSNI prosecution process
remains as previously described in Mr McLernon’s witness statement to the
Inquiry (WITN10280100), at paragraphs 4 to 23 therein.
At all times the test for prosecution is applied to each individual case in
accordance with the Code for Prosecutors, and each individual case is
assessed based on the evidence available and the individual factual matrix
of each case.
The PPSNI has been asked to set out what the disclosure duties are for a
prosecutor in Northern Ireland, if any, once a case has been finalised and
how that duty is discharged in circumstances where the prosecutor may
come to be aware of information that supported the convicted individual's
case. As specifically referred to in Mr McLernon’s witness statement
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(WITN10280100), at paragraphs 16 to 23, the disclosure duties for a
prosecutor in Northern Ireland are found in the Criminal Procedure and
Investigations Act 1996 (as amended) (hereafter ‘CPIA’), the accompanying
CPIA Code of Practice for NI (July 2005), the PPS Code for Prosecutors, the
Attorney General’s Guidelines on Disclosure of Unused Material in Criminal
Proceedings (2013) and the PPS/PSNI Disclosure Manual (revised Jan
2015).
In particular, in relation to post conviction disclosure paragraph 72 of the
Attorney General’s Guidelines on disclosure states as follows:
“Where, after the conclusion of proceedings, material comes to light
that might cast doubt upon the safety of the conviction, the
prosecutor must consider disclosure of such material.”
Further, the common law remains applicable, particularly outside of the
scope of the CPIA, in relation to post-conviction disclosure (R (on the
application of Nunn) (Appellant) v Chief Constable of Suffolk Constabulary
and another [2014] UKSC 37). There are no specific guidelines on how that
duty should be discharged as this would be tailored to the specific case.
The PPSNI has been asked whether it complied with its duty of disclosure in
relation to Post Office cases affected by the Horizon system. Paragraph 3 (iii)
above details how the PPSNI complied with the disclosure in relation to Post
Office cases affected by the Horizon system.
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19.
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The PPSNI has been asked whether it is aware of any circumstances in
which PPSNI has continued to prosecute, or defend appeals by convicted
subpostmasters, in Horizon cases after 2013. The appeals of Ms Fegan, Mr
McLaughlin and Ms McKelvey were conceded at the outset. Mr Lee
Williamson also lodged an appeal. This appeal was initially contested as it
was not accepted that the case was a “Horizon” case on the evidence
available. Following the enactment of the primary legislation five of the nine
counts the Appellant was convicted of were automatically quashed. The
remaining four (forgery) counts were not quashed by the legislation. After
carefully reflecting on the new evidence in this case, in particular the
Appellant's affidavit and the report from the IT expert instructed by the
defence, PPSNI were satisfied there was a sufficient evidential basis on
which to conclude this was a case in which the reliability of the Horizon
system was an essential component of the original underlying prosecution
case and PPSNI did not oppose the appeal on the remaining counts on the
indictment.
Prosecution of Mr Alan McLaughlin
20.
The PPSNI has been asked whether anyone from PPSNI saw the McClure
Watters report in relation to Mr McLaughlin’s case at the time of his
prosecution. The original PPSNI file in relation to Mr McLaughlin was
destroyed in 2008, in accordance with the PPSNI retention policy.
Accordingly, there are no records to confirm whether anyone from the PPSNI
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21.
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was provided with the report of McClure Watters (Chartered Accountants)
(AMCL0000006) during the course of the initial prosecution.
As part of Mr McLaughlin's appeal, PPSNI were provided with an almost
complete set of the prosecution papers in the appeal bundle lodged by
representatives for Mr McLaughlin, and this included the aforementioned
report. Instructed prosecution counsel noted in his skeleton argument to the
Court of Appeal that:
“It is reasonable to assume, given the guilty pleas, that the defence report
was served on the prosecution prior to trial, rather than held back. The
report placed the reliability of the Horizon evidence in issue. That being the
case, disclosure of relevant problems with that system was required. No
such disclosure was provided.”
On this basis the Appeal was conceded at the outset.
The Directing Officer for the PPSNI has retired and as the PPSNI file was
destroyed, we are unable to confirm who saw the report, or any actions
taken as a result.
PPSNI received a copy of the report as part of Mr McLaughlin's Appeal
bundle.
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Prosecution of Ms Maureen McKelvey
23. The PPSNI has been asked a number of questions in relation to the
Prosecution of Ms Maureen McKelvey. I refer the Inquiry to the detailed
witness statement of Mr Kevin Shiels and to his testimony to the Inquiry in
respect of this prosecution.
Other matters
24. There are no other matters that the PPSNI consider the Chair of the Inquiry
should be aware of.
Statement of Truth
I believe the content of this statement to be true.
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Index to First Witness Statement of Elizabeth Jane Kennedy
UR
Document
Description
Control Number
WITN11830102
Email
correspondence
between William
Green to Cathy
McGalie, Nick
Vamos and Rodric
Williams re: Post
Office Limited
WITN11830102
WITN11830101
List of Individuals
that were
prosecuted for false
accounting / audit
cash loss / theft
WITN11830101
PNI00000001_036
Letter from Charles
McKay to Mr R
McCarey dated 6
November 2004 at
pages 4-5
VIS00013112_036
WITN10580100
Witness statement
of Mr Kevin Shiels
WITN10580100
AMCLO0000001
Letter from Madden
& Finucane
Lawyers to Director
of Public
Prosecutions
regarding Mr Alan
McLaughlin dated 9
September 2022
AMCLO000001
POL00292987
Post Office e-mail
chain from January
2020
POL-BSFF-
0131050
POL00333548
Letter from Amy
Quirk (Senior
Security
Intelligence
Manager, POL)
dated 11 December
2015
POL-0180987
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POL00293011
Post Office e-mail
chain from January
2020
POL-BSFF-
0131074
POL00333558
Email exchange
between Mr Simon
Hutchinson and
PSNI dated July
2016
POL-0180998
10
POL00333553
Letter from Amy
Quirk (Senior
Security
Intelligence
Manager) titled
‘Disclosure for PPS’
dated 1 June 2016
POL-0180993
1
PNI00000001_071
Letter from J
McCleery to PPS
Belfast chambers
regarding further
documentation
disclosure on R V
Maureen McKelvey
VIS00013112_071
12
POL00125050
Email exchange
between Mr Jarnail
Singh, Ms Suzanne
Winter and Mr Ernie
Waterworth and
others dated
September 2013
POL-0131063
13
POL00333554
Email from
Constable Alan
Gordon to Mr
Simon Hutchinson
dated 20 June 2016
POL-0180994
14
WITN11830103
Letter sent from
McCartan
Turkington Breen
on behalf of Post
Office Limited to
Deputy Director of
Public Prosecutions
of Department of
the Director of
Public
WITN11830103
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Prosecutions,
Belfast.
15
WITN11830104
Email
correspondence
between Marion
Kemp and Stephen
Herron regarding:
meeting re Royal
Mail files
WITN11830104
16
WITN11830105
Email
correspondence re:
Margaret Ruth
Johnston
WITN11830105
17
WITN11830106
Criminal Justice
Inspection - Royal
Group, An
Inspection of the
Royal Mail Group
Crime
Investigations
Functions
WITN11830106
18
WITN11830107
Letter from Chief
Inspector, lan
Campbell on behalf
of Northern Ireland
Police to Mr William
Boyd (Royal Mail
Investigations).
WITN11830107
19
WITN10280100
Witness statement
of Mr James.
McLernon
WITN10280100
20
POL00113694
Advice from Mr
Simon Clarke
(Barrister/Cartwright
King) on the use of
expert evidence
relating to the
integrity of the
Fujitsu services Ltd
Horizon System
POL-0112802
21
POL00006799
Advice on
Disclosure and the
Duty to Record and
Retain Material
POL-0017591
Page 24 of 25
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22 I WITN10400100 First Witness WITN10400100
Statement of
Suzanne Winter -
WITN10400100
23 I AMCLO000006 Letter to John J AMCLO0000006
Rice & Co from
McClure Watters,
RE Your client: Alan
McLaughlin
Page 25 of 25
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