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Witness Name: Jarnail Singh
Statement No: 1
Ref: WITN04750100
Dated: 6 October 2023
POST OFFICE HORIZON IT INQUIRY
FIRST WITNESS STATEMENT OF JARNAIL SINGH
I, Jarnail Singh, will say as follows:
1.
I am providing this statement following two requests for information dated 22
June 2023 and 18 August 2023, pursuant to Rule 9 of the Inquiry Rules
2006, regarding matters falling within Phase 4 of the Inquiry: action taken by
Post Office Ltd against Subpostmasters.
The requests contained a combined total of 224 questions, which I have
addressed below. Some of the questions are centred around cases or
subject matters to which I had limited involvement and the events of which
were over nearly 20 years ago. I have therefore found it difficult at times to
recall detailed information and have had to regularly rely on the information
contained in the documents given to me by the Post Office Horizon IT
Inquiry (“the Inquiry”) as part of the Rule 9 request. However, this statement
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is made to the best of my recollection and where I cannot remember
something or have had to rely on a document, I have made it clear.
3. I would also like to take this opportunity to express my sympathy to all
subpostmasters who were wrongly accused of offences due to the Horizon
IT system. As a criminal prosecutor, I always do my best with the knowledge
and evidence that I have in front of me and at the time of each sub-
postmaster case, I followed the relevant codes, policies and procedures and
genuinely thought that I was doing the right thing. I was therefore incredibly
shocked and saddened when I learnt that the subpostmasters who were
prosecuted were not at fault.
4. I can confirm that I am represented and have had legal assistance in writing
this statement. When seeking to obtain legal assistance, I was assisted by
the Post Office with the initial stage of confirming the availability of
insurance coverage, to cover the associated legal costs.
BACKGROUND
5. I have been asked to set out a summary of my career and qualifications. I
have attached a copy of my curriculum vitae, which provides these details
(WITN04750101).
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6.
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I was a senior lawyer in the Criminal Law Team (“CLT”) at the Royal Mail
Group Ltd (“RMG") and later at Post Office Ltd (“POL”). I joined the RMG as
a legal executive in December 1989 and then, upon qualification in around
1992, I became lawyer and was subsequently promoted to a senior lawyer
in the CLT. At RMG, I would deal with criminal prosecutions, the relevant
cases of which are given in this statement. On 1 April 2012, I was
transferred to POL.
When I transferred to POL, I was the only in-house criminal lawyer and POL
contracted all of their criminal prosecutions out to Cartwright King solicitors
(“CK”) who took over full responsibility for the lifetime of a case. At this
point, my role in relation to criminal prosecutions was limited. I would
provide input where requested and was copied into case correspondence
for information. However, in the main, I acted as a point of contact between
POL and CK and would request or forward information as and when
required. Although I would read the advice given by CK, I never made the
decision as or when to prosecute and under what charges.
I left POL around March 2015. I subsequently moved into commercial /
residential law.
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POLICIES / PRACTICES IN PLACE AND THE CRIMINAL LAW TEAM’S ROLE
RELATING TO RELEVANT PROSECUTIONS
9. The below gives an account of the policies and practices in place and the
CLT’s role relating to the prosecution of subpostmasters.
10. By way of overview as to the procedure when criminal prosecutions were
conducted at RMG, following an investigation, an Investigation Officer within
RMG would send a ‘green investigation file’ to the CLT. The investigation
file and its papers would then be reviewed by the head of the CLT and the
file would be allocated to a criminal lawyer within the team to provide advice
on prosecution. Each case would be considered in accordance with the two
stages of the Full Code Test within the Code for Crown Prosecutors (“the
Code”) and RMG’s own internal policies and procedures on prosecuting
cases. I cannot comment on the procedure for cases which were dealt with
by CK.
The rationale behind the practice of bringing private prosecutions
11.At the time of my employment at both RMG and POL, all potential cases
were investigated and prosecuted by POL / RMG, rather than being referred
to the Police or Crown Prosecution Service. I was not involved in the
rationale behind the reasoning for this as it was put in place long before I
started, but I was aware that this was the common practice with other public
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services, such as the Department for Work and Pensions or HM Revenue
and Customs.
Policies governing prosecution and charging decisions and the conduct of
prosecutions
12.In consideration of the policies governing prosecution and charging
decisions, and the conduct of prosecutions, I have reviewed the following
documents:
i. Post Office Internal Prosecution Policy (Dishonesty) (December 1997)
(POL00030659);
ii. Paragraph 3.3 of the Investigation and Prosecution Policy (March
2000) (POL00031012);
iii. $SO2 Royal Mail Group Ltd Criminal Investigation and Prosecution
Policy (1 December 2007) (POL00030578), which appears to be
substantially the same as the policy of the same date with a variation
on the title (POL00104812) (see, in particular, section 3);
iv. Royal Mail Group Prosecution Policy (version 2.1, October 2009)
(POL00031011);
ve Post Office Ltd - Security Policy — Fraud Investigation and Prosecution
Policy (version 2, 4 April 2010) (POL00030580);
vi. Post Office Ltd Financial Investigation Policy (4 May 2010)
(POL00030579);
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vii.
viii.
xi.
xii.
xiii.
xiv.
XV.
xvi.
xvii.
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Royal Mail Group Security - Procedures & Standards — The Proceeds
of Crime Act 2002 & Financial Investigations (version 1, September
2010) (POL00026573);
Royal Mail Group Ltd Criminal Investigation and Prosecution Policy
(version 1.1, November 2010) (POL00031008);
Royal Mail Security - Procedures and Standards - Prosecution
Decision Procedure (version 2,January 2011) (POL00030598);
Post Office Ltd Financial Investigation Policy (version 2, February
2011) (POL00104853);
Post Office Ltd Anti-Fraud Policy (February 2011) (POL00104855);
Royal Mail Group Prosecution Policy (version 3.0, April 2011)
(POL00030685);
Royal Mail Group Policy Prosecution (S3) (created September 2008,
version 3 effective from April 2011) (POL00030800);
Post Office Prosecution Policy (version 1.0) (effective from 1 April
2012) (POL00031034);
Post Office Limited: Internal Protocol for Criminal Investigation and
Enforcement, (undated but understood to have been produced in 2012)
(POL00104929);
Appendix 1 - POL Criminal Investigations and Enforcement Procedure
(flowchart), (undated but understood to have been produced in 2012)
(POL00105226);
Post Office Prosecution Policy England and Wales (effective from 1
November 2013) (POLO0030686);
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xviii. Post Office Limited Prosecution Policy for England and Wales (version
1, 22 January 2016) (POL00030811).
13.1 can confirm that during my time as in-house criminal lawyer, I was familiar
with the policies listed above save for the final document listed as this post-
dates my employment with POL. At the time, I was primarily concerned with
the Prosecution Policy, but less familiar with the other policies. I can recall
that when we drafted the initial advice, we did so from a template, which
prompted you to review, stage by stage, every evidential aspect of the
Prosecution Policy and Disclosure Policy.
14.1 was not involved in contributing or developing any of the policies listed
above. I believe that on the separation of RMG and POL, POL adopted all
of RMG policies.
15.I am described as the owner of the ‘Post Office Prosecution Policy’ (version
1.0) (effective from 1 April 2012) (POL00031034). By being ‘owner’ of a
prosecution policy, it means that I adopted the policy on behalf of POL on its
separation from RMG.
16.It was the policy of POL to prosecute those suspected of committing theft,
fraud and / or false accounting, as it had been the policy of RMG
beforehand. The aim and rationale behind this was both to hold the offender
to account and to deter potential offenders. POL would, however, only
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prosecute if they were satisfied that the Full Code Test in the Code had
been met.
17.In terms of the organisational structure of the CLT, I can recall that around
1995 the structure was: Head of the Criminal Law Team, 7/8 criminal
lawyers, 3 legal executives, 3 support staff and 5 secretaries. To be clear, I
was one of the criminal lawyers.
18.The structure subsequently changed gradually over time with people leaving
and was reduced to: Head of CLT, 3 lawyers, 2 legal executives, 2
secretaries and 1 admin staff. To confirm, when RMG and POL separated
on 1 April 2012 and I was transferred to POL, I was the sole in-house
criminal lawyer. It was at this point that POL contracted CK to prosecute on
behalf of POL.
19.At RMG, investigations were carried out by the RMG Investigations and
Security Team. I note that the Inquiry have referred to a ‘Fraud Team’. From
memory, the Investigation and Security Team and the Fraud Team are one
and the same and therefore, going forward I shall refer to them as the
Investigation and Security Team.
20.Once received, the investigation papers (green sleeve file) were passed to
CLT who would assess the evidence and provide advice in relation to
prosecution and charges. The decision to prosecute was taken by the
Investigation and Security Team, for those cases where there was a
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decision to prosecute. If the case was local (in or around London), CLT
would continue to deal with the case and occasionally I would do the
advocacy for the administrative hearings in the Magistrates Court. If the
case was further afield, CLT would contract one of the agents on their panel
to deal with the case for them.
2
=
. The people responsible for supervision and conduct of prosecutions were
the Head of Security and Head of the CLT. Counsel, who was instructed on
the case and the lawyer with conduct over the case, would also keep it
continuously under review in accordance with the Code.
22.1 do not know what qualifications or training the Head of Security or Head of
CLT had although I can recall that Counsel and agents for each case would
have had training on the workings of the Horizon IT system. I also attended
training on the Horizon IT system, first in the late 90s and later in 2012.
23.At RMG, the Head of CLT and the lawyer dealing with that particular case,
was responsible for supervising and reviewing the conduct of the
prosecution. At POL, the supervision and review of a case was done entirely
by CK although they would occasionally ask for my input.
24.1 cannot recall that the Post Office policy regarding prosecution of Crown
Office employees was any different from the policy and practice regarding
prosecution of sub-postmasters and their managers / assistants.
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25.1 can confirm that I have reviewed the Separation Project — Criminal
Investigations Policy for Post Office Ltd (POL00104900) and the
Prosecution Policy Paper dated January 2013 (POL00039969).
26. These would have been used by the Investigation and Security Team when
conducting investigations. There were no changes to the policies when POL
and RMG separated as I recall that POL adopted all of RMG’s prosecution
policies.
27.1 can confirm that I am the ‘one in house Criminal Lawyer’ referred to, at
paragraph 2.4 of the January 2013 Prosecution Policy Paper
(POL00039969).
28.1 worked closely with Martin Smith and Simon Clark (both of CK) and we
would discuss any cases as and when needed. However, I was more
involved from an administrative, rather than legal, perspective.
29.I have been asked to describe the ‘network of external legal agents and
Counsel’ used to manage the prosecution process. These were used by
RMG and I can recall that we had a panel of agents throughout England,
Wales and Scotland to deal with cases when we didn’t have the resources
to deal with them or if the case was located a long way away from London. I
cannot recall the exact number and full list, but I remember that the main
Counsel chambers were Bell Yard Chambers in London, John Dove in
Birmingham (Solicitor advocate) and Cardiff Chambers. From 2012
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onwards, POL used CK exclusively who had their own in-house Counsel
and lawyers.
30.1 was not involved in the analysis conducted by POL and referred in the
Prosecution Policy Paper dated January 2013 (POL00039969).
Involvement of the Criminal Law Team in advising on investigations
31.1 did not have any involvement into the input or formulation of any policies or
guidance. At POL, previous RMG policies and guidance were simply
adopted. Due to my lack of involvement, I cannot confirm or deny whether
CLT approved advice on the application of relevant codes of practice issued
under statute guidelines, case law and any relevant material.
32.1 do not know whether the CLT had any role in the provision of training to
members of the Investigation and Security Team involved in criminal
investigations, although I personally did not give any training to the
Investigation and Security Team when I was in RMG. However, on
separation of the businesses, I made arrangements with CK to provide
training for the Investigation and Security Team.
33.When I was at RMG, my advice memos to the Investigation Team would
give advice as to what additional witness statements/evidence were
needed, but beyond this I cannot recall providing any advice on particular
cases as to what investigations to make or lines of enquiry to pursue.
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However, other members of the team may have done so. I cannot recall
providing any advice on this when I was at POL, although CK may have
done so.
Guidance provided to the Security Team on the conduct of investigations
34.1 can confirm that the Inquiry have provided me with, and I have reviewed,
the following documents in answering their questions on this subject matter:
The Casework management document (POL00104747 and
POL00104777)
David Posnett’s email dated 23 May 2011 (POL00118096) and the
documents contained within the attached compliance zip file
(POL00118108, POL00118109, POL00118101, POL00118102,
POL00118103, POL00118104, POL001181105, POL00118106 and
POL00118107)
David Posnett’s email dated 29 May 2011 (POL00115665) and the
documents contained within the compliance zip file (POL00115666,
POL00115667, POL00115668, POL00115669, POL00115670,
POL00115671, POL00115672, POL00115673 and POLO00115674).
David Posnett’s email dated 27 April 2012 (POL00118110) and the
attachments (POL00118120, POL00118121, POL00118122,
POL00118123, POL00118124, POL00118125, POL00118126,
POL00118127, POL00118128).
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v. David Posnett’s email dated 18 December 2012 (POL00118289) and
the indices attached (POL00118290 and POL00118377)
vi. The email dated 28 July 2016 (POL00118129) and the documents
contained within the attached compliance zip file (POL00118130,
POL00118131, POL00118132, POL00118133, POL00118134,
POL00118135 and POLO0118136)
35.At the outset, I would like to flag that I was not involved in any guidance
provided to the Security Team on the conduct of investigations and had no
input into it at all. My comments below are based on a review of the
documents.
36.1! cannot recall either the 2000 or 2002 version of the Casework
Management Document. I did not have any input into these documents and
I was not involved in the development, management or amendment of them.
My knowledge is that it was the Information and Security Team who would
have been responsible for them and would have used them.
37.1 did not deal with these documents and the instructions / guidance given in
them was for the Security Team as part of their training as to how to put
investigation reports together. My understanding of them now is therefore
not based on any prior knowledge. I have reviewed them and understand
that they are giving instructions as to the content and presentation of
Investigation Reports.
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38.As to the relevance of these instructions, in relation to Post Offices’
disclosure obligations, my view is that the instructions clearly required
investigators to put the separate report on Form CSOO6D and possibly
CS6006E when reviewing the case. My role would have then been to review
those documents and decide whether they were disclosable or not. Had the
documents disclosed Horizon bug errors and defects, my duty was to
disclose these documents to the Defence as they were documents which
would undermine the prosecution case and assist the defence case.
39.At the time the suite of compliance documents contained within the
compliance zip file was circulated (listed at ‘i’ above), I considered their
status as guidance, in that I understood that their purpose was to be used
as guides, given to investigators by senior managers of the Security Team.
To my knowledge and recollection, the CLT had no input and I, personally,
certainly did not have any input into them.
40. There are two documents, both entitled ‘Guide to the Preparation and
Layout of Investigation Red Label Case Files. Offender report and Discipline
reports’ (POL000118101 and POL00115671). As to how these relate to the
Offender Report Template (POL00118102), my understanding of paragraph
2.15 (on p.10) in the first of these documents (POL00118101), is that a
comprehensive list of all failures in security, supervision, procedures and
product integrity must be highlighted bold in a Suspect Offender Report. I
understand that both documents give guidance as to the preparation of
Suspect Offender Reports. I therefore assume that these documents
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informed the content and creation of the Offender Report Template. I do not
feel able to comment on these documents beyond what is stated in them as
I do not recall them.
41.The Inquiry refers to the email of 23 May 2011 (POL00118096) and email of
29 March 2012 (POL00115665) as my emails. However, these were emails
sent by Dave Posnett and I was not a recipient of either.
42.1 had no involvement in drafting the documents entitled identification codes
(POL00118128) attached to David Posnetts’ email of 25" May 2011
(POL00118128) and 29" March 2012 and (POL00118131) attached to
email dated 28" July 2016.
43.1 cannot say why the Security Team investigators were instructed to assign
identification codes to suspected offenders as I was not part of any decision
or conversation in this matter. I cannot recall reviewing the document
entitled ‘Identification Codes’.
Process for prosecution and charging decisions
44. The below considers the process that was followed by POL/RMG in relation
to prosecution and charging decisions once an initial investigation had been
conducted by the Security Team. In answering the Inquiry’s questions
around this subject matter, I have reviewed the following documents:
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vi.
vii.
viii.
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Section 6 of “Post Office Internal Prosecution Policy (Dishonesty)”
(December 1997) (POL00030659);
Paragraph 3.3 of the “Investigation and Prosecution Policy” (March
2000) (POL00031012);
Paragraph 3.2.9 of the “Royal Mail Group Ltd Criminal Investigation
and Prosecution Policy” (1 December 2007) (POL00030578, which
appears to be substantially the same as the policy of the same date
with a variation on the title at POL00104812);
Section 4 of the “Post Office Ltd Fraud Investigation and Prosecution
Policy” (4 April 2010) (POLO0030580);
Section 5 of “Royal Mail Security - Procedures and Standards -
Prosecution Decision Procedure” (version 2, January 2011)
(POL00030598);
Section 5 of “Royal Mail Group Prosecution Policy” (version 3.0, April
2011) (POL00030685);
Section 4 of “Royal Mail Group Policy Prosecution (S3)” (created
September 2008, version 3 effective from April 2011) (POL00030800);
Section 4 of “Post Office Prosecution Policy” (version 1.0) (effective
from 1 April 2012) (POL00031034);
Appendix 1 to “Post Office Limited: Internal Protocol for Criminal
Investigation and Enforcement”, (undated but understood to have been
produced in 2012) (POL00104929);
“Appendix 1 - POL Criminal Investigations and Enforcement Procedure
(flowchart)”, (undated but understood to have been produced in 2012)
(POL00105226);
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xi. “Security Operations Casework Review” (4 February 2013)
(POL00105223);
xii. I Paragraphs 3.1 to 3.6 and 4.1 to 4.2 of “Post Office Prosecution Policy
England and Wales” (effective from 1 November 2013)
(POL00030686);
xiii. I Section 6 of “Post Office Limited Prosecution Policy for England and
Wales” (version 1, 22 January 2016) (POL00030811).
45. The ‘nominated decision maker’ within the Security Team was responsible
for making prosecution and charging decisions in respect of
subpostmasters, managers, assistants and Crown Office employees alleged
to be responsible for shortfalls shown by data from the Horizon IT system.
At POL, the person responsible for this was the Head of Security, John
Scott. This decision would be taken after seeking input from the CLT and
subsequently by CK when they took over conduct of criminal prosecutions.
46. The legal advice and draft charges would be drafted by CLT/CK and sent to
the Investigation and Security Team. The decision maker would then read
the advice and decide, at that stage, whether or not to accept the advice
and prosecute. If they decided to proceed, they would get the Investigation
Officer to issue the summons at the local Magistrates’ Court.
47.I cannot comment as to what training or qualifications all those providing
legal advice on prosecution, draft charges and charging decisions had, but
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certainly within the CLT everybody was a qualified lawyer as far as I can
recall.
48.1 cannot recall whether those involved in investigating a suspected offence
ever input into advice on whether the test for prosecution was met.
However, any case that I looked at, I would have considered in line with the
Code and Post Office policies.
The test applied
49. The below considers what test was applied by those making prosecution
and charging decisions. I can confirm that in answering the Inquiry’s
questions on this, I have reviewed the following documents:
i. Section 5 of “Post Office Internal Prosecution Policy (Dishonesty)”
(December 1997) (POL00030659);
ii, Paragraph 3.2.9 of “Royal Mail Group Ltd Criminal Investigation and
Prosecution Policy” (1 December 2007) (POL00030578);
iii. I Section 6 of “Royal Mail Group Prosecution Policy” (version 2.1,
October 2009) (POL00031011);
iv. Section 4 of “Post Office Ltd - Security Policy — Fraud Investigation
and Prosecution Policy” (version 2, 4 April 2010) (POL00030580);
v. Section 4 of “Royal Mail Security - Procedures and Standards -
Prosecution Decision Procedure” (version 2, January 2011)
(POL00030598);
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vi.
vii.
viii.
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Section 6 of “Royal Mail Group Prosecution Policy” (version 3.0, April
2011) (POL00030685);
Section 5 of “Royal Mail Group Policy Prosecution (S3)” (created
September 2008, version 3 effective from April 2011) (POL00030800);
Section 5 of “Post Office Prosecution Policy” (version 1.0) (effective
from 1 April 2012) (POL00031034);
Paragraphs 3.1, 3.2 and 4.1 to 4.7 of “Post Office Prosecution Policy
England and Wales” (effective from 1 November 2013)
(POL00030686);
Section 6 of “Post Office Limited Prosecution Policy for England and
Wales’ (version 1, 22 January 2016) (POL00030811).
50.1 cannot comment on others, but I can confirm that I would always consider
the evidential and public interest test in reviewing and drafting my initial
advice and throughout the subsequent lifetime of a case. In my view, the
test to be applied in making a prosecution/charging decision was adequate.
5
=
.At the outset, legal advice was all given internally by CLT / CK. When the
matter was committed to the Crown Court, once instructed, Counsel were
asked to draft the indictment and in doing so, look at the summons, and
also to provide advice on evidence. Essentially they would revisit and review
the whole case.
52.When I was asked to advise on a case, I would that the advice had regard
to both the Code and relevant POL policies. It was a matter of policy that all
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advice and decisions were made in line with the public interest and
evidential tests of the Code.
The conduct of prosecutions
53.When conducting a prosecution, during my time at both RMG and POL I
was alive to all of my responsibilities and duties under relevant legislations,
codes, policies and principles including, but not limited to:
i. The Code (and related CPS guidance)
ii. I Attorney General’s Guidelines on Disclosure
iii. I SRA Standards and Regulations
iv. Internal policies and procedures as listed at paragraph [15] above
v. Criminal Procedures and Investigations Act 1996
54. Initially, RMG had conduct of private prosecution and then, on separation of
the businesses, this was CK. The role of the agents was to attend Court on
behalf of the RMG and conduct the prosecution.
Disclosure
55.The Polices would incorporate the relevant legal legislations, codes, policies
and principles and give guidance on how to comply with them.
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56.1 was not involved in and therefore cannot comment on, what guidance was
given in the RMG / POL policies about disclosure from third parties, such as
Fujitsu. Any disclosure from a third party would have been requested from
the Investigation Officer who was assigned to that case.
57.As to my understanding of disclosure obligations, I am aware of the
obligations on a prosecutor to ensure that all relevant disclosure is given to
the defence, including that which may undermine the prosecution case. The
duty to review disclosure and subsequently disclose where necessary, is
ongoing.
58.1 have been asked whether the individual(s) who held the role of disclosure
officer also held the role of Investigation Officer and / or decision maker. I
am unable to answer this question as I have no personal knowledge.
59.In terms of disclosure when I was at CLT, an individual from the
Investigation and Security Team would prepare a disclosure schedule with a
list of the relevant and appropriate documents. This would be sent to CLT,
as part of the initial papers sent with the investigation report. The CLT
lawyer who received the papers, including me if I was allocated the file,
would review the disclosure and check that everything in it was relevant and
disclosable. If I felt that anything was missing, I would request it and, once
satisfied, serve the disclosure on the Defence as appropriate. My disclosure
duty was ongoing and therefore if I received or was made aware of a
relevant document at any point in the lifetime of a case, I would disclose it
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as appropriate. I would also deal with any disclosure requests received from
the Defence. To be clear, I was never the disclosure officer, as this was the
role of somebody within the Investigation and Security Team.
60.1 have been asked whether the individual(s) who held the role of
61.
Investigation Officer, officer in charge and / or disclosure officer, also made
decisions about the conduct of prosecutions. Due to lapse of time, I cannot
confirm or deny whether this was the case or not. However, if the
Investigation Officer had made the decision on conduct of prosecutions then
I would have had concerns about that.
I have been asked what advice I or the CLT more widely, gave to
investigators from the Investigation and Security Team about the disclosure
obligations in POL. I was the only in-house criminal lawyer at POL at the
time and I cannot recall specifically giving advice on disclosure obligations
to the Information and Security Team. However, had I been asked to give
such advice, I am confident that I would have emphasised the importance of
complying with the disclosure obligations and that it was a ongoing
obligation. I cannot confirm or deny whether CK provided such advice on
disclosure to the Investigation and Security Team.
62.1 never dealt with third parties and so my role never included giving any
advice in relation to disclosure to third parties. The only exception to this
was in the case of Mrs Misra, when the Security and Investigation Team
asked me to obtain answers raised by the Defence about the functioning of
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the Horizon system and I contacted the Head of Legal at Fujitsu to escalate
this request. Further information on this is given below and the contact did
not include giving any advice on disclosure, other than to request it.
63.Once a case was committed to the Crown Court, Counsel were briefed to
draft the indictment and provide advice on evidence.
64.When I was at RMG, I did not seek any external advice on the Horizon IT
system, with the exception of the case of Mrs Misra.
65. Once the Defence Case Statement or Defence Statement were received, I
would ensure that it was dealt with appropriately and that any further
disclosure that was raised, was also disclosed where relevant. I would
ensure that the statements and enclosures were sent to Counsel to advise
on and the Investigation Officers to deal with and provide. This was before
separation of the businesses. On separation, CK took over control of the
disclosure as well as all aspects of prosecution.
66.In addition and as noted in the cases below, for example the case of Mr
Wilson, where potential issues were raised about the Horizon IT system, I
would always request a witness statement to address the IT issues.
However, as happened in Mr Wilson’s case, the sub postmaster pleaded
guilty to the false accounting offence while the collation and service of such
further evidence was still pending.
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67.1 cannot provide any further comments where it was alleged in a Defence
Case Statement or Defence Statement that a discrepancy was attributed to
problems with the Horizon IT system as, other than the case of Mrs Misra, I
cannot recall dealing with any cases where this was alleged.
Experts
68.In the cases that I personally dealt with, no experts were instructed and I
was not made aware by any other members of CLT or external agents, of
any experts being instructed in respect of any other cases either.
69. In the case of Misra, the Defence expert Report raised questions and I
contacted the Investigation and Security Team to ask whether they could
answer these questions. I was told that the request needed to be made in
writing and it could take weeks for a response. I was worried that the normal
systems and procedures for obtaining information from Fujitsu would be too
slow and so I also contacted David Jones, Head of Legal at Fujitsu, to
escalate the request so that it would be dealt with as quickly as possible to
comply with the Court Order. Subsequently, Gareth Jenkins was put forward
to deal with the Defence’s requests as someone who was in a position to
deal with the issues raised by the Defence expert, but I understand that his
role was initially limited to that of a lay witness who knew the Horizon
system well. As far as I can recall the Post Office did not seek to rely on him
as an expert witness, or at least not initially. Subsequently, due to his
expertise and qualifications, the Court considered him an expert.
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70. Document UKGI00015008 references a meeting which I attended with
Gareth Jenkins, Warwick Tatford and John Longman in October 2010. I do
not recall this meeting or ever discussing Gareth Jenkins’ witness statement
with him. As far as I recall, I had very limited involvement with Mr Jenkins. I
cannot recall any discussions where he was informed of his duties to the
Court, although I would have assumed Counsel would have informed him of
the same.
71.1 am not aware of and I do not recall any policy or guidelines in place
regarding the provision of evidence by employees of Fujitsu.
72.Given that the Horizon IT system was a unique system, I felt that the
questions from the Defence should be answered by somebody who knew
the system well. Mr Jenkins was put forward as such a person and my
understanding was that he had the most experience and knowledge of the
system to provide full answers and analyse the data in full and I therefore
considered him to be an appropriate witness. I understood that it was made
clear that Mr Jenkins was an employee of Fujitsu. I knew that his Section 9
statement told him that he had to be truthful otherwise he would be liable for
prosecution. With the benefit of hindsight, I can see that it would have been
more appropriate for somebody from outside of the organisation to have
been utilised who could have been relied on as an expert witness. However,
I feel that it would have been difficult to find somebody who was an
independent expert, who had the experience and knowledge of the Horizon
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IT system, but did not work at Fujitsu. I did not feel that a person without
such knowledge or expertise of the Horizon IT system would be in as good
as position to assist the court as a lay witness with that specific knowledge.
Criminal enforcement proceedings
73.I have been asked in what circumstances steps were taken to restrain a
suspect's assets by criminal enforcement methods such as confiscation
proceedings. I am unable to answer this question as the decision to start
confiscation proceedings was made by the Confiscation Department.
74.1 have also been asked who decided whether criminal enforcement
proceedings should be pursued and what factors were considered when
making decisions around this. Again, decisions as to whether enforcement
proceedings should be pursued were made by a different department and
therefore I am unable to comment on this.
75.I have also been asked about the process that was followed by the
Financial Investigation Unit and what part the CLT played in this process in
criminal enforcement proceedings. In answering this question, I have
reviewed the Financial Investigation Unit process documentation
(POL00084988 and POL00084989).
76.My understanding is that when a sub postmaster was found guilty,
repayment directions were given by the Court. Counsel would forward these
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to CLT who would make sure that they were complied with by the Defence.
If enforcement proceedings were needed because the directions were not
complied with, the Investigation and Security Team would approach us and
we would make the appropriate application the Court. To clarify, this was
before the separation of the businesses. When the businesses separated,
enforcement proceedings were dealt with by CK.
INVOLVEMENT IN CRIMINALPROSECUTION CASE STUDIES
77.The below deals with the following cases in turn:
i. Rv David Blakey
ii. Rv Suzanne Palmer
iii. I Rv Susan Rudkin
iv. Rv Julian Wilson
v. Rv Seema Misra
vi. Action against Joan Bailey
vii. Rv Lynette Hutchings
viii. Rv Grant Allen
ix. Rv Angela Sefton and R v Anne Nield
x. Rv Khayyam Ishaq
78.Before I begin, I would like to express my deepest sympathies to each and
every sub postmaster whose case I dealt with and to confirm that I have
read all of their Impact Statements. I took my role as a criminal prosecutor
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seriously and always thought that I was following the correct course of
action based on the information and evidence I had in front of me. To learn
that the Horizon system was not reliable and that these sub postmasters
were wrongly convicted is deeply saddening. In particular, I would like to
express my deepest sympathies to Julian Wilson’s wife, upon learning that
Mr Wilson passed away before his conviction was overturned.
R -v- David Blakey
79.To assist me in answering the Inquiry’s questions in relation to this case, I
have considered the following documents:
i. The Record of Tape Recorded Interview with David Blakey dated 13
May 2004 (POL00044830 (part 1) and POL00044831 (part 2));
ii. IThe summary of key points from an interview with Gillian Blakey
(POL00044829);
iii. IThe Investigation Report dated 25 May 2004 (POL00044818);
iv. The Notification of Proceedings to Police forms relating to Mr Blakey
(POL00044821 and POL00044822);
v. My memo to S & A Casework dated 23 June 2004 (POL00044835).
80.1 can confirm that I was the solicitor who had conduct of this case for POL.
81.1 first become involved in the case of Mr Blakey when the file was allocated
to me by the Head of CLT. The Head of CLT would receive the file from the
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Investigation and Security Team, review the investigation papers and
evidence relating to the case, and allocate it to a member of the CLT which,
in this case, was me.
82.Normally, I would get involved in a case around 2 weeks before providing
the advice. From the documents, it appears that this would have been
around June 2004 as per my advice to S and A case work dated 23 June
2004 (POL00044835),.
83.Due to the passage of time, I cannot recall what papers were considered
and were before me when I wrote this advice. However, in principle, an ideal
file should contain the investigation report, tapes of recorded interviews,
audit report, disclosure schedule, contract of the sub-postmaster and
witness statements, including one giving an account of the operation of the
Horizon system.
84.My advice was written prior to the issue of any criminal proceedings against
Mr Blakey.
85.As with all cases, in giving my advice, I would apply the two-stages of the
Full Code Test of the Code; the evidential test and the public interest test.
My advice would be drafted from a template advice note which would give a
list of the factors that I needed to take into consideration when applying this
test. For example, when considering if prosecution was in the public
interest, I would look at the period of offending, any admission and the
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amount of loss that had incurred. I also recall that the Post Office Policy was
contained in the template advice so that I could easily run through and apply
it.
86.My advice (POL00044835) states that, in my opinion, there is sufficient
evidence to afford a realistic prospect of conviction. My assessment of the
evidence is that there was a low prospect of securing a conviction for theft
and a high prospect for false accounting. It notes that Mr Blakey has not
made any admissions of theft and I therefore identify that further evidence is
needed, in particular from staff members.
87.1 cannot recall the name, but an individual within the Investigation and
Security Team who was responsible for making the decision for
prosecutions, would have authorised the prosecution of Mr Blakey.
88.Due to the passage of time, I cannot recall who made the charging decision
in this case. However, it would not have been the CLT as our role did not
involve charging the individual. Although the charges were drafted by us, it
was for the Investigation and Security Team to make the decision as to
whether or not they accepted the drafted charges and, ultimately issue
summons.
89. There was no Horizon data or ARQ logs requested from Fujitsu in this case.
However, the statement from Jane Kay (POL00044825) sets out the
workings of the Horizon system.
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90.1 have considered the draft Schedule of Non-Sensitive Unused material
(POL00044817). I cannot recall this document but it is likely that I would
have reviewed it when I provided the advice. As detailed above, the
disclosure schedule would usually be sent with the initial investigation report
for the lawyer to review when they provided the advice.
91.Due to the passage of time, I cannot recall who the disclosure officer was in
this case.
92.My role in relation to disclosure was initially to review the disclosure
schedule and to confirm that all the material disclosed was relevant and that
there were no missing documents that I was aware should be disclosed.
The schedule would then have been sent to the Defence along with the
evidence. As disclosure is an continuous obligation, I had an ongoing
obligation to review disclosure throughout the case. However, I cannot recall
specifically whether any additional disclosure was disclosed in the lifetime of
this case.
93.In respect of what witness evidence was provided in this case, I can confirm
that I have reviewed the following:
i. The unsigned witness statement of Glen Morris dated 23 November
2004 (POL00044819);
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ii. IThe unsigned witness statement of Paul Whitaker dated 24 November
2004 (POL00044824);
ii. I The unsigned witness statement of Jayne Kaye dated 18 November
2004 (POL00044825);
iv. The unsigned witness statement of Natasha Beck dated 18 November
2004 (POL00044826);
v. The unsigned witness statement of Patricia Brown dated 15 November
2004 (POL00044827);
vi. The unsigned witness statement of Samantha Callaghan dated 15
November 2004 (POL00044828).
94. These witness statements were obtained to address issues including the
fact that it was Mr Blakey who was responsible for entering the data on the
Horizon system, the workings of the system and that no other staff had
actually stolen money from the Post Office or falsified the Post Office
accounts.
95. The purpose of obtaining each of these witnesses was as followed:
i. I Glen Morris (POL00044819) provided evidence in relation to the audit
he carried out which proved that there was a shortage of cash at Mrs
Blakey's Post Office.
ii. Paul Whittaker (POL00044824) was the Investigation Officer who
carried out an interview under caution of both Mr and Mrs Blakey and
provided evidence in relation to the same.
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iii. I Jane Kay (POL00044825) was a retail manager at a Post Office store
and gave evidence as to how the Horizon system worked.
iv. Natasha Beck (POL00044826) was a Post Office Clerk and gave
evidence as to her role at a sub Post Office.
v. Samantha Callaghan (POL00044828) was a member of staff at Riby
Square in Grimsby and gave evidence confirming that it was Mr Blakey
who would enter the information on the Horizon system.
96.In reflecting on the way that the investigation and prosecution was
conducted by the Post Office and the outcome of the case, I have reviewed
the following documents as provided by the Inquiry:
i. IThe memo from Phil Taylor to Paul Whitaker dated 24 March 2005
(POL00044357);
ii. I The judgment of the Court of Appeal in Josephine Hamilton & Others v
Post Office Limited [2021] EWCA Crim 577 (POL00113278) (in
particular, paragraphs 347 to 352).
97.It is apparent that the Court of Appeal have accepted that Mr Blakey was
wrongly convicted and for that, I can only apologise and express my
sympathies. Had I become aware of any information/evidence or had
knowledge, at any stage of the prosecution case, that the prosecution
should not continue, I would have flagged this and advised POL and the
Court to discontinue and offer no evidence in respect of the charges faced
by Mr Blakey.
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98. The judgment of Josephine Hamilton and Others v Post Office Limited
[2021] (POL000113278), paragraphs 347 — 352 note the case of Mr Blakey.
In particular, paragraph 351 notes:
“POL accepts that this was an unexplained shortfall case and that evidence
from Horizon was essential to Mr Blakey’s case. There is nothing to indicate
that any ARQ data was obtained at the time of the criminal proceedings.
There was no evidence to corroborate the Horizon evidence. There was no
investigation into Horizon reliability. There was no proof of an actual loss as
opposed to a Horizon-generated shortfall.”
99. From my recollection and from reviewing the documents, the workings of
the Horizon system were never raised as an issue and ARQ data was never
requested by the Defence. I cannot comment on any investigation as this
would have been carried out by the Investigation and Security Team, prior
to me receiving the file.
100. Mr Blakey was represented by solicitors and Counsel who were entitled to
request any evidence that they needed to support his defence. In addition,
the Defence are able to make a Section 8 application under the Criminal
Procedure and Investigations Act 1996 for disclosure should his legal
representatives have thought that evidence was being withheld from him. Mr
Blakey pleaded guilty and no such a request was made.
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101.As with all cases, I was shocked when I heard of the Court of Appeal
judgement and my full sympathy goes out to Mr Blakey for all the loss and
distress that he suffered.
R -v- Suzanne Palmer
102. The below deals with my recollection and involvement in the case of
Suzanne Palmer. To assist me in answering the Inquiry’s questions on this
case, I have reviewed the following documents:
vi.
vii.
viii.
The Record of Tape Recorded Interview of Suzanne Palmer on 6
February 2006 (POL00053009);
The Investigation Report by Lisa Allen dated 20 February 2006
(POL00053007);
The Notification of Proceedings to Police form in this case
(POL00053005 and POL00053006);
My memo to the Investigation Team dated 10 March 2006
(POL00052990);
The Schedule of Charges (POL00053011);
The memo from Lisa Allen to me dated 6 April 2006 (POL00052987);
My memo to the Investigation Team dated 15 May 2006
(POL00052994);
My memo to the Investigation Team dated 23 June 2006
(POL00053001);
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ix. IMy memo to the Investigation Team dated 11 July 2006
(POL00052991);
x. IMy memo to the Investigation Team dated 26 July 2006
(POL00053003) and the enclosed Advice from Counsel dated 25 July
2006 (POL00053008);
xi. The Indictment (POL00052986);
xii. I The memo from Jennifer Andrews to the Investigations Team dated 14
September 2006 (POL00052993);
xiii. I The memo from Jennifer Andrews to the Investigations Team dated 20
September 2006 (POL00052998).
103.1 first became involved in the case of Mrs Palmer when I received the file for
it. Again, I cannot recall exactly when this was but it is likely to have been a
couple of weeks before writing my memo of 10 March 2006 (POL00052990)
104.1 can also not remember what information I was provided with prior to writing
this advice but please see above in relation to Mr Blakey as to what an ideal
file should contain.
105. My advice states that I was of the opinion that there was sufficient evidence
to afford a realistic prospect of conviction of Mrs Palmer for the offences of
false accounting. I also advise on what additional evidence/statements may
be needed.
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106.As confirmed with the case of Mr Blakey, I would have considered both the
evidential and public interest test from the Full Code Test when drafting my
advice. Please see my answer above to Mr Blakey as to what this would
have involved.
107.1 cannot recall my reasoning at the time, but having reviewed my advice, it
appears that my reasoning for prosecution and recommendation for the
Crown Court was based on the seriousness of the offence and the high
deficiency in the account. In considering whether it was in the public interest
to prosecute, I would also have taken into account the fact that Mrs Palmer
was in a position of trust and the losses related to public money.
108. The Investigation Report by Lisa Allen dated 20 February 2006
(POL00053007) confirms that Tony Utting was the designated prosecution
authority in Mrs Palmer’s case. Therefore, I understand that it would have
been him who authorised her prosecution. In terms of the charges, we (the
legal team) would draft the charges and Tony Utting would approve them.
109. No Horizon data was requested in this case.
110.1 can confirm that I have considered the following documents:
i. The memo from Jennifer Andrews to the Investigations Team dated 11
October 2006 (POL00052992);
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The memo from Jennifer Andrews to the Investigations Team dated 8
November 2006 (POL00052988);
The memo from Jennifer Andrews to the Investigations Team dated 17
January 2007 (POL00052995);
My memo to the Investigation Team dated 19 January 2007
(POL00052997);
My memo to the Investigation Team dated 23 January 2007
(POL00053000).
111.1 cannot recall who the disclosure officer was in this case.
112. In terms of my role in relation to disclosure in these proceedings, they were
the same as above in relation to Mr Blakey.
113. In reflecting on the way that the investigation and prosecution of Mrs Palmer
was conducted and the subsequent outcome of this case, I have reviewed
the following:
The memo from Jennifer Andrews to the Investigation Team dated 31
January 2007 (POL00052982);
The Casework Management Initial Tick List for the Palmer case
(POL00052984).
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114.Mrs Palmer was found Not Guilty by the jury. However, I appreciate that she
still suffered loss and distress from the incorrect accusations from the Post
Office and my full sympathies are extended to her.
R -v- Susan Rudkin
115. The below deals with my recollection and involvement in the case of Susan
Rudkin. To assist me in answering the Inquiry’s questions on this case, I
have considered the following documents:
i. Letter from Mr Rudkin to Paul Hemley dated 14 January 2004
(POL00060416);
ii. Letter to Mr Rudkin dated 18 January 2005 (POL00061521);
iii. Incident report from 2004 (POL0006526).
116.1 have reviewed the Incident Report from 2004 (POL00065265) which
confirms that an error had been identified in Giro bank withdrawals of
£48.96 being erroneously entered twice. I have no specific recollection of
‘phantom’ banking transactions being reported by Miss Rudkin at the branch
in January 2005 and there is no mention of it in my memo to the Fraud
Team dated 3 October 2008 (POL00046488).
117.1 have considered the following documents:
i. The handwritten notes (POL00045243 and POL00045246);
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vi.
vii.
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The Record of Tape Recorded Interview of 20 August 2008
(POL00050026);
My memo to the Fraud Team dated 3 October 2008 (POL00046488);
The Schedule of Charges (POL00045220);
The memo from Mike Wilcox to me dated 29 January 2009
(POL00046505);
My memo to the Fraud Team dated 6 February 2009 (POL00046506);
The Summons dated 12 February 2009 (POL00046537).
118. I first became involved in the case of Susan Rudkin when I received the
‘green file’, after it was allocated by the Head of CLT. As with the other
cases, this would have been a couple of weeks before my report, so roughly
around mid-September.
119. Following my review of the file, I reported back to the Fraud Team by way of
a memo dated 3 October 2008 (POL00046488). I cannot recall, and the
documents do not assist me in recalling, what information/evidence I
considered prior to writing my advice memo on 3 October 2008. However,
please refer to my comments in respect of Mr Blakey as to what an ideal file
should contain.
120.As confirmed with the case of Mr Blakey and Mrs Palmer, I would have
considered both the evidential and public interest test as required by the
Code when drafting my advice.
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121.1 cannot recall my reasoning, but based on the memo, my advice states that
the evidence is sufficient to afford a realistic prospect of conviction. My
advice confirms that although I have recommended a charge for the offence
of theft, the case may also be considered for false accounting charges at a
later stage. I have also recommended what further evidence / witness
statements are required.
122.I cannot recall who authorised the prosecution of Mrs Rudkin, although it is
likely that it would have been somebody senior to Mike Wilcox, Investigation
Officer. I also cannot recall who made the charging decision in this case.
123.No Horizon data was requested in this case.
124.1 can confirm that I have considered the following documents:
i. IThe emails from March 2009 (POL00051044 and POL00059762);
ii. IThe letters from Mr Rudkin dated 25 February 2009 (POL00044916)
and 3 April 2009 (POL00060421).
125.I have been asked what, if any, impact Mr Rudkin’s letters had on decisions
relating to the prosecution of Mrs Rudkin. I do not recall having seen them
or having had any knowledge of them at the time of prosecution and I note
that they post-date the prosecution decision. Had I received them at the
time, I would have reviewed them in light of the public interest test. I cannot
say now whether I would have considered this correspondence alone, in the
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126.
127.
128.
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absence of medical evidence, to have caused me to reach a different view,
but I certainly would have raised this with Counsel and the Investigation and
Security Team for their consideration.
I have considered the letter from Richard Nelson solicitors to Mike Wilcox
dated 7 April 2009 (POL00046524). This confirms that Mrs Rudkin is
declining to attend Loughborough Police Station on a voluntary basis and
encloses a copy of a letter from Dr A T Peded dated 22 February 2009,
which confirms that she is not fit to be interviewed (POL00050993) due to
her poor mental health. I cannot remember being aware of the extent of Mrs
Rudkin’s poor mental health. From the documentation, the only information
relating to her health was contained in the memo from Mike Wilcox to me
(POL00046505) which states “/ have since been in contact with Richard
Nelson solicitors...who have notified me that Mrs Rudkin does not wish to
attend a further interview as they have concerns over her deteriorating
mental health.” \f I had had sight of Mrs Rudkin’s doctor's letter
(POL00050993), I would have certainly considered it and raised with the
Investigation and Security Team for their consideration.
I can confirm that I have considered the letter to Richard Nelson solicitors
dated 19 February 2009 (POL00050990). I cannot recall who the disclosure
officer was in this case.
My role in relation to disclosure in these proceedings was the same as
described above in relation to Mr Blakey.
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129. In terms of what criminal enforcement proceedings were taken against Mrs
Rudkin and what my involvement was in these proceedings, I have had to
refresh my memory with the documents that the Inquiry provided me with
(detailed in the following paragraphs). A summary of the events of the case
are detailed in the Financial Investigation Log (POL00057602).
130. Document POL00050242 is a Restraint Order to prevent the disposal of
assets. This would have been done at the outset of prosecution by the
Financial Investigation accredited officers, not the CLT.
131.Document POL00051380 is a memo from Rob Wilson to the Fraud Team
dated 6 May 2009, which confirms that Mrs Rudkin was charged with
stealing £43,894.15 belonging to Post Office Limited, contrary to Section
1(1) of the Theft Act 1968, for which she was sentenced to 12 months
imprisonment suspended for 2 years with a Community Order of 300 unpaid
work and electronically monitored curfew for 6 months requiring her to stay
indoors between the hours of 10pm and 5am.
132.On 8 July 2009 I sent a letter enclosing the Prosecution Statement under
Section 16 together with supporting documents to the Defence
(POL00052029).
133.On 24 July 2009, Counsel were briefed to attend the Confiscation Hearing
at Stratford Crown Court on 21 August 2009 (POL00052094).
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134.
135.
136.
137.
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On 12 August 2010 I received a letter (POL0055156). This lays out the
financial circumstances and difficulties of Mr and Mrs Rudkin and ultimately
asks me to consider whether a variation on the basis of inadequacy would
be a suitable way forward. Upon receipt of this letter, I passed it on to the
Financial Investigation Department to consider and for their further
instructions. It would not have been a matter for me to decide. I cannot
recall the response of the Financial Investigation Department. I would also
have forwarded it onto Counsel / the agents for their information.
Document POL00055203 is a letter written from me on 31 August 2010
which confirms that a further hearing for a Confiscation Order will be heard
at Birmingham Magistrates Court on 30 November 2010.
Document POL00057602 gives a summary of the case. This a document
created for internal administrative purposes and I had no input into it.
I can recall very little about this case, as I did not carry out the investigation
of Mrs Rudkin, or attend her Court hearing. I have therefore relied heavily
upon the documents provided to me by the Inquiry. From reviewing the
documents, it appears that the prosecution case itself was relatively
straightforward and concluded by way of an early guilty plea with the Court
imposing a sentence. However, as with the other subpostmasters who were
wrongly convicted, I extend my sympathies to Mrs Rudkin for her wrongful
conviction and in particular, the effect that this had on her mental health.
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R -v- Julian Wilson
138. The below deals with my recollection and involvement in the case against
the late Julian Wilson.
139.To assist me in answering the Inquiry’s questions on this case, I have
considered the following documents:
i. IThe Record of Tape Recorded Interview dated 15 September 2008
(POL00050140 (part 1) and POL00050128 (part 2));
ii. I My memo to the Fraud Team dated 6 January 2009 (POL00044806);
iii. IThe Schedule of charges (POL00047083);
iv. The email dated 23 January 2009 (POL00050763);
v. My letter to Mr Wilson's solicitors dated 2 April 2009 (POL00051265).
140.1 cannot recall exactly when I became involved in this case. My memo
(POL00044806) is dated 6 January 2009 and therefore, taking into account
Christmas and New Year, I would have likely become first involved around
mid-December.
141. Again, I cannot recall, and the documents do not assist me in recalling, what
information/evidence I considered prior to writing this advice memo.
However, as with the other cases, please see my comments in relation to
Mr Blakey as to what an ideal file would contain.
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142.1 advised the Investigation and Security Team that there was sufficient
evidence to afford a realistic prospect of conviction for the offences of theft
and false accounting. I advised that if the Defendant offered a guilty plea to
false accounting then it is advisable that the prosecution should accept this
plea and not proceed with the theft charge. The memo confirms that this
advice is in view of Mr Wilson’s admissions to false accounting in interview
under caution and denial of theft.
143.As with all cases, when drafting this advice, I would have considered the full
code tests as required by the Code, including whether it was in the public
interest to prosecute Mr Wilson.
144.1 cannot recall who authorised the prosecution of Mr Wilson. I assume that
the Team Leader within the Investigations Team or else a designated
decision maker within the Investigation and Security Team would have done
so. It would not have been the Investigation Officer.
145. Similarly, I cannot recall the name, but the decision maker would have
requested summons be issued in this case.
146.No Horizon data was requested from Fujitsu in this case. However, in my
advice note to Counsel dated 22 May 2009 (POL00044751) it notes that I
have requested further witness statements, including a statement
addressing the IT system.
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147.1 can confirm that I have considered the following documents:
vi.
vii.
viii.
The Schedule of Non-Sensitive Unused Material dated 18 March 2009
(POL00051194);
The memo from Rob Wilson to me dated 6 May 2009 (POL00051385);
The draft Brief to Counsel dated May 2009 (POL00044753);
The Summary of Facts (POL00044767);
The letter from Richard Nelson Solicitors dated 14 May 2009, with
handwritten comments (POL00051920);
My letter to Richard Nelson Solicitors dated 19 May 2009
(UKGI00012555);
Counsel's Advice dated 22 May 2009 (POL00044751) and the draft
Case Summary (POL00044809);
My memo to the Fraud Team dated 28 May 2009 (POL00051720);
My letter to Mr Wilson’s solicitors dated 28 May 2009 (POL00051715);
The Hearsay Notice (POL00047026) (page 2 onwards).
148. My role in relation to disclosure in these proceedings was the same as
detailed above in the case of Mr Blakey.
149. The information that was requested by Mr Wilson's solicitors is contained in
their letter of 14 May 2009 (POL00051920). This requests a draft indictment
and a schedule of unused material. It also notes that there are a number of
prosecutions being pursued by The Royal Mail Group Ltd which are similar
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to that of Mr Wilson’s and asks for the details of the number of prosecutions
that are currently ongoing and details as to the geographic location of such
prosecutions.
150.1 cannot recall whether I considered the request by the time I wrote to Mr
Wilson's solicitors on 19 May 2009 but it is likely that I did as it encloses one
of the requested items; the schedule of unused material. Furthermore, three
days after writing this letter, Counsel write an advice note (POL0004751)
referring to the request on 14 May 2009 at paragraph 7. It is likely that I
would have sent them this information a few days prior to writing the advice
note, which means I would have also considered it a few days prior to
receiving the advice note.
151. Following Counsel's advice, I forwarded the same to the Investigation and
Security Team and asked them to make further enquiries and deal with the
matters set out in it (POL00051720).
152.I have considered the following documents:
Counsel's Brief endorsed following the hearing on 15 June 2009
(POL00051459);
Counsel's endorsed copy of the Indictment (POL00044800);
John H. Dove's letter to me dated 17 June 2009 (POL00051936).
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153. Based on these documents, there does not appear to have been any further
disclosure provided to the Defence following receipt of Counsel's advice
before the Plea and Case Management Conference on 15 June 2009
although it is not clear and I cannot specifically recall.
154. John Dove's letter dated 17 June 2009 (POL00051936) summarises what
happened at the Plea and Case Management Hearing on 15 June 2009.
This notes that Mr Wilsons’ Counsel was anxious to reach some form of
acceptable compromise to avoid a trial. A deal was subsequently struck
whereby Mr Wilson would plead guilty on a basis of plea of an acceptance
of the false accounting in the years 2007 and 2008, but for the full amount
of the shortfall of £27,811.98. On arraignment, Mr Wilson pleaded Not Guilty
to Counts 1, 2 and 3 but Guilty to Counts 4 and 5. These pleas were
accepted and Counts 1, 2 and 3 were dismissed.
155. Document POL000119134 is a memo, confirming that in the Sentencing
Hearing, Mr Wilson was sentenced to 200 hours of community order on
account of both counts. He was also ordered to pay prosecution costs and a
Confiscation timetable was set.
156. In relation to what criminal enforcement proceedings were taken against
Julian Wilson and what my involvement was in these proceedings, I have
considered the following documents:
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vi.
vii.
viii.
xi.
xii.
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The letter from Richard Nelson Solicitors dated 14 January 2008
(POL00050695);
The Section 41 statement dated 16 December 2008
(POL00064718_001);
My memo dated 16 January 2009 (POL00050704);
The emails dated January 2009 (POL00050726);
The emails dated March 2009 (POL00044961);
My letter dated 24 June 2009 (POL00051969) and the Section 18 draft
order (POL00045621);
My memo dated 15 July 2009 (POL00052047);
The emails dated August 2009 (POL00052277);
The Financial Investigation Events Log (POL00044749);
The memo from Miss Andrews dated 5 August 2009 (POL00119134);
The memo from Miss Andrews dated 11 January 2010
(POL001 19126);
My memo dated 21 December 2010 (POL00119206).
157. These documents confirm that Mr Wilson was subject to a Restraint Order.
The same as with Mrs Rudkin, this was dealt with by the Financial
Investigation accredited officers, not the CLT.
158. Mr Wilson was also ordered to provide, and serve, financial information and
document POL00052047 confirms that I forwarded details of a registration
of a charge on Mr and Mrs Wilson's re-mortgage of their property to the
Fraud Team. I am unable to comment on Mr Wilson’s criminal proceedings
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beyond what is contained in these documents, but document POL00044749
provides a Financial Investigation Events Log which provides an overview of
the case, including what aspects I was involved in.
159. The memo of Jenny Andrew of 11 January 2010 (POL00119126) confirms
that Mr Wilson agreed to pay £28,434.95 within 6 months of the hearing i.e.
before 17 June 2010. A Compensation Order was also made for this
amount. My memo (POL00119206) confirms that the Order was postponed
by 6 months, giving a maximum statutory period of 12 months.
160. The Inquiry have directed me to the judgment of Josephine Hamilton and
Others v Post Office Limited [2021] EWCA Crim 577 (POL00113278),
paragraphs 175 — 178. In particular, I have noted that paragraph 177 states:
“POL accepts that this was an unexplained shortfall case and that evidence
from Horizon was essential to Mr Wilson’s case. Based on the papers
available from the criminal proceedings, there is nothing to suggest any
ARQ data was obtained. POL did not investigate any of the criticisms of
Horizon made by Mr Wilson historically and during his detailed interview.
There was no evidence to corroborate the Horizon evidence. There was no
proof of an actual loss as opposed to a Horizon-generated shortage.”
161. From the documents, it appears that the request for further disclosure was
taken seriously with the relevant information requested, but I acknowledge
that this was not available at the time of the Plea and Case Management
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Hearing. The case was not adjourned but instead, a basis of plea was
agreed meaning the case was concluded prior to any further disclosure
being obtained and disclosed which may have been relevant to the outcome
of this case. I cannot comment on the investigation process as this was
conducted by the Investigation and Security Team of which I was not
involved.
162.1 am saddened that Mr Wilson did not learn of his conviction being
overturned prior to him passing and extend my sympathies to his family for
the distress and loss that the conviction had upon them and Mr Wilson.
R -v- Seema Misra
163. The below deals with my recollection and involvement in the case of Seema
Misra. To assist me in answering the Inquiry’s questions on this case, I have
considered the following documents:
vi.
The Audit Report dated 16 January 2008 (POL00058550);
The Investigation Report (POL00044541);
My memo to the Investigation Team dated 1 April 2008
(POL00049658);
The emails from April 2008 (POL000497 16);
My email dated 21 April 2008 (POL00049717);
My memo to the Fraud Team dated 18 November 2008
(POL00044539);
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vii. I The Schedule of Charges against Seema Misra (POL00045010);
viii. I The Summary of Facts (POL00044613);
ix. The signed indictment (POL00051149).
164. The Inquiry have also provided me with the supplementary documents
listed below which I can confirm that I have reviewed:
i. IThe correspondence involving Fujitsu legal (FUJ00152928,
FUJ00152935, FUJ00152936, FUJ00152937, FUJ00152938,
FUJ00152943, FUK00152948, FUJ00152950, FUJ00152954,
FUJ00152964, FUJ00152966, FUJ00152993, FUJ00153005,
FUK00153014 and FUJ00157863);
ii. My email dated 15 July 2010 (FUJ00153141);
iii. IThe emails dated 5 February 2010 (FUJ00152940);
iv. The emails dated 8 February 2010 (POL0054051);
v. The emails dated 8 February 2010 (FUJ00153382);
vi. IThe email sent on my behalf dated 8 February 2010 (FUJ00152958);
vii. I The email from Gareth Jenkins to me and the email chain below
(FUJ00152962) and attachment (POL00053992);
viii. I My email dated 24 February 2010 (FUJ00152985);
ix. IMy emails dated 26 February 2010 (FUJ00152992);
x. IMy email dated 3 March 2010 (FUJ00153019);
xi. The Audit Record Query (FUJ00155189);
xii. I Gareth Jenkins’ email dated 11 October 2010 (FUJ00153390);
xiii. I My memo dated 29 March 2010 (POL00119318);
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xiv. My email dated 1 July 2013 (FUJ00154223).
165. As with the other cases, my involvement with the case of Mrs Misra started
on receipt of the file, which would have been roughly two weeks before my
advice memo dated 1 April 2008 (POL00049658). Therefore, it is likely that
my involvement would have started around mid-March.
166. As with the other cases, I cannot recall what information I received prior to
giving this advice but refer the Inquiry to my comments in relation to Mr
Blakey as to what an ideal file should contain. I cannot remember and am
therefore unable to confirm whether or not any of the documents at
POL00094011 formed part of the information that I received.
167. The advice that I gave to the Investigation and Security Team is laid out in
my memo of 1 April 2008 (POL00049658). This states that in my opinion,
there is sufficient evidence to afford a realistic prospect of conviction for the
charges. It notes that I have recommended a charge of theft of £74,609.84
in view of the fact the losses were accrued for a period of over a year. I also
suggested a charge of false accounting. I recommend that if Mrs Misra
pleaded Guilty to the false accounting than the prosecution in respect of the
theft is not proceeded with. I recommend that all relevant accounts and
documentation should be produced in full. My advice then lists further
statements which I think are needed.
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168.As with the other cases, my advice was based upon consideration and
application of the Code, including whether the prosecution of Mrs Misra was
in the public interest.
169. I believe that it was David Pardoe who authorised the prosecution of Ms
Misra. David Pardoe also made the charging decision in this case.
170. As to whether there was any disagreement between individuals within the
Investigation and Security Team or between me and the Investigation and
Security Team as to what the appropriate charges were, I can see from the
correspondence (POL00049716) that I have been asked whether I will be
changing my advice on the charges, to which I respond “No. Please
proceed as advised.” The final charges were always a subject of discussion
between teams and I cannot remember there being any specific
disagreement over the charges for Mrs Misra.
171.1 cannot recall being aware of any allegations made by Mrs Misra relating to
the reliability of the Horizon IT system when I advised the Investigation and
Security Team in April and November 2008. However, I have noted that
neither the Audit Report (POL00058550), nor the Investigation Report
(POL00044541) make reference to any issues with the Horizon IT system,
with the Investigation Report noting that Ms Misra attributes the losses to
staff theft. I believe that the issue was raised just before trial, causing an
adjournment of the trial.
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172.I have considered the letter dated 13 May 2009 (POL00051441) and the
emails dated 22 May 2009 (POL00051539). The letter of 13 May 2009
notes that Mrs Misra has indicated that she will plead Guilty to False
Accounting and Not Guilty to Theft. It requests Counsel's advice as to
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whether we should proceed on the account of theft as we have been unable
to locate the three employees who could speak to the count. Counsel's
subsequent email of 22 May 2009 advises that there is strong evidence to
proceed with the theft charge and we should not accept the plea. I recall
that it was felt that it would not be possible to pursue a Confiscation Order
without a theft conviction. Counsel also notes that the Defendant may have
given false details in relation to the whereabouts of the employees.
173.\In addition to the memo of 1 April 2008 (POL00049658), I have considered
the following documents:
The list of statements and evidence sent to me on 23 January 2009
(POL00050738);
The Schedule of Non-Sensitive Unused Material dated 23 January
2009 (POL00050750);
The Schedule of Sensitive Material dated 23 January 2009
(POL00050751);
My draft instructions to Counsel to settle indictment and advise on
evidence and brief for the Prosecution dated February 2009
(POL00044585) and the letter to Counsel's clerk dated 17 February
2009 (POL00050950);
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v. Counsel's email dated 10 March 2009 (POL00051092);
vi. My letter to the Castle Partnership dated 17 February 2009
(POL00050942);
vii. I The letter from the Castle Partnership dated 2 March 2009
(POL00051045).
174.1 cannot recall who the disclosure officer was in this case.
175. My role in relation to disclosure is the same as described in relation to Mr
Blakey.
176.1 would have reviewed everything handed to me, including the Schedule of
Non-Sensitive Unused Material dated 23 January 2009 and would have
considered my disclosure obligations at every stage of the proceedings as
part of my continuous duty.
177.Counsel would have advised on disclosure in response to my instructions in
February 2009. However, without the documents I cannot recall what this
would have said.
178.I have considered the attendance note dated 3 June 2009 (POL00051773).
The Inquiry have asked me to explain the circumstances in which the
challenge to the integrity of the Horizon IT system first arose in this case.
From my recollection, the challenge arose at trial and the defence material
only consisted of computer magazine articles describing issues with
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Horizon, although I do not recall being given a copy. The case was
therefore adjourned and directions were made for the Defence to take steps
to set out and instruct an expert. The case was then listed for a mention
hearing.
179.I have considered the email chain from August 2009 (POL00052202). It
appears that the email was sent to me on 4 August 2009 but then forwarded
to Phil Taylor on 11 August 2009 and so it is not clear what involvement I
had with this. The email within this chain from David Posnett on 4 August
2009 at 09:38 outlines the issues with obtaining the ARQ log showing
transaction data for the relevant period. It states that due to the size of the
ARQ request, he cannot authorise Fujitsu to proceed at this stage. The
email notes that the request from the Defence equates to approximately 31
ARQs and they have an annual allowance of 670 ARQs so the request
represents a large chunk of their quota. It also notes that they can only
request 60 ARQs a month, so the Defence request could be detrimental to
other Prosecution requests.
180.1 confirm that I have considered the following documents:
The letter from Coomber Rich dated 1 October 2009 (POL00052487)
and the enclosed application for disclosure (POL00052462) and further
request for disclosure (POL00058503);
The emails from December 2009 (POL00053723),
Counsel's Advice dated 5 January 2010 (POL00044557);
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vi.
vii.
viii.
xi.
xii.
xiii.
xiv.
XV.
xvi.
xvii.
xviii.
xix.
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The letter from me to Messrs Coomber Rich dated 11 January 2010
(POL00053746);
My letter to Messrs Coomber Rich dated 27 January 2010
(POL00044553);
The attendance note dated 27 January 2010 (POL00053849);
John Longman’s email dated 29 January 2010 (POL00053880) and the
audit report dated 14October 2005 (POL00093865);
The attendance note dated 1 February 2010 (UKGI00014903);
The emails dated January and February 2010 (POL00053938);
The letter from Juliet MacFarlane to Counsel’s clerk dated 2 February
2010 (POL00053954);
The email from Juliet MacFarlane dated 5 February 2010 at page 3 of
POL00114272;
The emails dated January and February 2010 (POL00053938);
The email dated 3 February 2010 (UKGI00014895);
The emails dated 5 February 2010 (POL00054010);
The email dated 24 February 2010 (POL00054185);
The emails from February and March 2010 (POL00054254);
The email dated 1 March 2010 (POL00054248);
The email dated 8 March 2010 and attachment to that email
(POL00054335 and POL00054346);
The attendance note relating to a hearing on 7 May 2010
(POL00045565);
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xx. I The Schedule of Non-Sensitive Unused Material dated 8 September
2010 (POL00055217) (the covering letter from Rob Wilson sending this
to the Defence is dated 15 September 2010 (POL00055236));
xxi. The emails dated 6 and 8 October 2010 (POL00055421).
181. The Inquiry have asked me to provide a full account of the disclosure
requests made by the Defence after the hearing on 2 June 2009 and the
Post Office’s response to those requests.
182. With reference to POL00053723, my view in December 2009 was that the
disclosure request which had been made by the Defence was very wide, not
focused and their relevance was not clear as this was not properly set out in
a Defence Case Statement.
183.1 cannot recall the extent to which I advised directly on the merits of the
disclosure request. I can recall that I sought Counsel’s input at this stage
and John Longman and Phil Taylor were also heavily involved. I believe that
Counsel advised as to what the parameters of the request should be and
we progressed accordingly.
184. The Defence's expert report raised a number of issues/question and in
order to respond, as stated above, I spoke to the Head of Legal at Fujitsu.
Fujitsu put forward Gareth Jenkins as the best person to assist and I
understand that he met with the Defence expert and also responded to the
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Defence expert’s report and email requests. He also gave evidence in Court
and was cross-examined by the Defence.
185. Document POL00044557 is the advice given by Counsel in January 2010
on the disclosure requests made by the Defence. The advice notes that
although we have been put on notice that the Defence are challenging the
reliability of Horizon, this has been done in very general terms, with no
Defence Statement served mentioning this issue. The advice states that our
response to the disclosure requests should raise this failing and request a
detailed Defence Case Statement which fully particularises any problems
with Horizon which are alleged and upon which the Defence will seek to rely
upon at trial. The advice note then goes through each disclosure request in
turn.
186. Juliet MacFarlane's raises a concern about paragraph 23 of Counsel's
Advice in her letter dated 2 February 2010 (POL00053954). Paragraph 23
of Counsel's Advice (POL00044557) notes that there is a Brief in the case
of Hosi which should be disclosed. From recollection, the case of Hosi was
one of Juliet MacFarlane’s cases. Her concerns appear to arise from the
fact the case was ongoing and therefore there was no determination of the
evidence and the expert evidence was in draft format.
187. Document POL00053849 is an attendance note which discusses disclosure
and confirms that Counsel have advised we should disclose everything we
can disclose at this stage. I cannot remember whether the report in the case
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of Hosi was disclosed. However, it looks like it was not. I understand in
January 2010 that there was still an issue with how wide the Defence
Request was but there was a willingness to disclose and work was ongoing
by Investigation Officer, John Longman, to process the request.
188. Beyond what is detailed in the documents listed above, I am not ina
position to comment, as I cannot recall, whether Counsel advised on the
further requests for disclosure made by the Defence after January 2010 as I
cannot remember.
189. Similarly, I am not in a position to comment on the position taken by the
Post Office in relation to the Defence disclosure requests insofar as they
related to data from the Horizon IT system or information about the Horizon
IT system. From my perspective, I believed that the Post Office understood
that in its capacity, as a Prosecuting Authority, it had responsibilities relating
to disclosure. From the perspective of the legal team, all cases were kept
under review, including the ongoing disclosure obligations.
190.1 have considered the email from Issy Hogg dated 1 March 2010
(POL00054248), the notification of fixture dated 2 March 2010
(POL00054275), the email from Warwick Tatford dated 8 March 2010 and
the draft skeleton argument (POL00054335 and POL00054346) and the
emails dated 11 and 16 March 2010 (POL00054430).
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191.1 can recall reading the Defence argument but due to the passage of time, I
cannot recall what the arguments were in specific terms and do not feel that
I am able to add anything beyond what is contained in these documents.
192. In relation to the transcripts from 11 and 18 October 2010 (UKGI00014994
and UKGI00014845), there was a half-time submission and a pre-trial
submission. On both occasions, the Judge ruled that the case could be put
before the jury. The submissions are as per the two transcripts and again, I
do not feel that I am able to add anything beyond what is contained in these
documents.
193. In giving my account of Fujitsu’s involvement in these proceedings, I can
confirm that I have considered the following documents:
vi.
vii.
The report of Charles McLachlan dated 21 September 2009
(POL00093689);
The 2nd interim report of Charles McLachlan dated 19 November 2009
(POL00094101);
The emails dated 1 February 2010 (POL00053930);
The attendance note dated 1 February 2010 (UKGI00014903);
The witness statement of Gareth Jenkins dated 2 February 2010
(POL00053937);
The 3rd interim report of Charles McLachlan dated 3 February 2010
(POL00053992);
The emails dated 3 February 2010 (POL00054085);
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viii.
xi.
xii.
xiii.
xiv.
XV.
xvi.
xvii.
xviii.
xix.
XX.
xxi.
xxii.
xxiii.
xxiv.
XXV.
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The email dated 3 February 2010 (UKGI00014895);
The emails dated 5 February 2010 (POL00114272);
The emails dated January and February 2010 (FUJ00122804);
The email sent on my behalf dated 5 February 2010 (FUJ00122729);
The email dated 8 February 2010 and attached witness statement from
Gareth Jenkins at (FUJ00122808);
The emails dated 8 and 9 February 2010 (POL00054095);
The emails dated 22 and 23 February 2010 (POL00054183);
The emails dated 25 February 2010 (POL00054198);
The notice of additional evidence and attached witness statements
dated 26 February 2010 (POL00058450);
The emails dated 25 and 26 February 2010 (POL00054220);
The emails dated 26 February and 1 March 2010 (POL00054252);
My email dated 1 March 2010 (POL00054267) (and what appear to be
the attachments — the 4th and 5th Interim Technical Expert's reports
prepared by Charles McLachlan — (POL00054126 and
POL00054257));
My email to John Longman dated 1 March 2010 (POL00054250);
My email to Gareth Jenkins dated 1 March 2010 (POL00054267);
My email to Penny Thomas dated 3 March 2010 (POL00054282);
The emails dated 4 and 5 March 2010 (POL00054311);
Gareth Jenkins’ witness statement dated 9 March 2010
(POL00001643);
The notice of additional evidence and attached witness statements
dated 18 March 2010 (POL00058440);
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xxvi. Gareth Jenkins’ witness statement dated 8 July 2010 (FUJ00122906);
xxvii. The emails of 15 and 16 July 2010 (POL00055018);
xxviii. The email dated 22 July 2010 (POL00055059);
xxix. The emails dated 27 July 2010 (POL00055100);
xxx. The email dated 11 August 2010 (POL00055150);
xxxi. The memo from me to Post Office Security dated 11 August 2010
(POL00055146);
xxxii. The emails dated 1 and 4 October 2010 (POL00055356);
xxxiii. I The report of Charles McLachlan dated 4 October 2010
(FUJ00083736);
xxxiv. The email dated 6 October 2010 (UKGI00015008);
xxxv. The emails dated 7 October 2010 (FUJ00123031);
xxxvi. The emails dated 8 October 2010 (FUJ00123050);
xxxvii. The draft statement of Gareth Jenkins (POL00110275);
xxxviii. I The addendum report from Charles McLachlan dated 11 October 2010
(POL00030298);
xxxix. I The Joint Statement to the Court by Gareth Jenkins and Charles
McLachlan dated 11 October2010 (POL00001882);
xl. The transcripts of 11, 14, 15 and 18 October 2010 (UKGI00014994,
POL00029406, POL00001856 and UKG100014845);
xli. I The transcript of submissions, closing speeches and the Judge’s
directions on 19 October 2010 (POL00065708).
194.Penny Thomas worked for Fujitsu and, I understand, was the POL contact
for Fujitsu. She came to be involved in the proceedings when the
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195.
196.
197.
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Investigation Officer requested information from Fujitsu in order to respond
to the Defence expert report.
Penny Thomas said that we needed to follow the usual procedures for a
data request. I was conscious that this was a very slow procedure and so to
speed things up, I contacted Penny Thomas and she gave me the number
of David Jones, Head of Legal at Fujitsu. I explained the situation to him
and he identified Gareth Jenkins as an individual who had the appropriate
knowledge and experience to assist.
In normal circumstances, expert witnesses should be independent. I recall
that the input of an independent expert was considered but no suitable
expert was identified as nobody from outside of Fujitsu had suitable
knowledge of the Horizon system. As I have stated above, given that the
Horizon IT system was unique I felt that the questions from the Defence
should be answered by somebody who knew the system well. At all times,
the main consideration was which evidence would best assist the Court in
determining the issues in dispute. Mr Jenkins was originally brought in as a
witness of fact, who had in-depth knowledge of the system and was
therefore in a position to assist the Court in relation to the matters within his
knowledge. I recall that the Court effectively treated him as an expert
witness due to his qualifications, knowledge and experience of the system.
I never gave Mr Jenkins any formal instructions but I liaised with him on
certain issues to clarify points and to forward him information. It was John
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Longman, the Investigation Officer, who would ordinarily seek Mr Jenkins’
input in relation to issues raised by the Defence.
198. Initially, I did not consider Mr Jenkins to be acting as an expert but to be
brought in as a lay witness with technical knowledge who could respond to
matters raised by the Defence expert. I do not know what information was
given to Mr Jenkins as to his role as an expert or his duty to the Court. In
normal circumstances, when instructing an expert, I would provide this
information. However, this was an unusual case in that he was not regarded
by the prosecution as an expert witness but from recollection went on to be
treated as an expert by the court. I cannot recall who told him what his role
as an expert was but I believe that this may have been done by Counsel.
199.No explanation was given to me by anyone from Fujitsu or the Post Office
during the case of Mrs Misra of the position in relation to known bugs, errors
or defects in the Horizon IT system, past or current.
200.1 had limited contact with Mr Jenkins and am not in a position to comment
on any views that he expressed in relation to the disclosure being sought by
the Defence and the relevance of the material sought to the case. His main
point of contact was John Longman.
201. In respect of the email from David Jones to Roger Williams and David
Roberts dated 5 February 2010 (FUJ00122723), I was not aware at the time
that I was involved in Mrs Misra’s case that Fujitsu had concerns about the
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202.
203.
204.
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impact that “key issues about [Fujitsu’s] systems” might have on “relations
with POL if mishandled”. Had I known about this email or its content, I would
have wanted to know what the issues were. As a lawyer my main duty is to
the Court.
I do not think that any of the comments made by Mr Jenkins in his email
dated 1 March 2010 (POL00054250) were any different to the concerns
previously raised about the need for specific issues to be particularised by
the prosecution. Therefore, these comments did not have any influence on
me.
In relation to the requests for access made by the Defence on 22 July 2010
(UKGI00014898), I believe that this issue related to a separate incident
being reported and that the prosecution wished to adduce evidence in
relation to this. I recall that there was concern regarding the relevance of an
issue in a different branch being operated by different personnel to Mrs
Misra’s case. The request from the Defence was seen as too vague and, as
noted in my memo of 11 August 2010 (POL00055146), I state that we will
not provide this information and if the Defence wish to proceed with their
request, they can do so by means of a Section 8 application to the Court.
I have considered the document entitled “Correcting Accounts for “lost”
Discrepancies” starting at page 6 of POL00028838. I do not recall having
seen this document before the Inquiry provided it to me. If I had known
about this document, I would have passed it to the Investigation and
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Security Team to try and understand what it meant, the implications of it and
whether the problem was being resolved. Once it had been assessed, I
would have considered the disclosure test and disclosed it.
205.1 have considered the email from Mandy Talbot to me dated 8 October 2010
(POL000554 18). I do not recall any conversations with Mandy Talbot,
although there may have been a brief call immediately prior to her sending
this email. I was not involved in any wider briefings and, at the time, I did not
know who ‘Mike’ or ‘Rod’ were who are referred to in the email.
206.1 have considered my email dated 21 October 2010 (POL00055590) and my
memo to Post Office Security and others dated 16 November 2010
(POL00055759). At the time, I thought that the outcome of the case was a
success and I was relieved that the case was concluded.
207. There is a comment in my email that “it is hoped the case will set a marker
to dissuade other Defendants from jumping on the Horizon bashing
bandwagon”. I was asked to report back to the team and in doing so, I
commented on the outcome and the fact that the Defence’s criticisms of the
Horizon IT system were dealt with and that the prosecution case was made
out. I was aware that the case was of wider interest within the business and
my comment in relation to other cases was made with this in mind. The
wording of the email also had some input from Counsel.
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208.1 have considered the Draft Order (POL00045051) and the telephone note
dated 22 February 2012 (POL00094048). My role in relation to criminal
enforcement proceedings against Mrs Misra was limited. I provided the
Directions to the Accredited Financial Investigation Team for the
confiscation proceedings. I would have also briefed Counsel on the case if
required but cannot recall whether or not I did. As can be seen from my
memo (POL00119318), I attended the Confiscation Hearing and reported
back on it.
209. My understanding of the issues and outcome in the Lee Castleton case did
not have any impact upon my assessment of Mrs Misra’s case, on the basis
that the evidence from Mr Jenkins dealt with the issue and he had explained
to the Court why the outcome in the Lee Castleton case was irrelevant to
the issues in Mrs Misra’s case.
210.1 have read the judgment of Josephine Hamilton and Others v Post Office
Limited [2021] (POL000113278), paragraphs 75, 91 and 198 to 209 and I
hope that I have answered the criticisms highlighted in this judgment in the
above.
211.In terms of my reflections now on the way that the investigation and
prosecution of Mrs Misra was conducted, I wish that the wrongful conviction
had not occurred but, at the time, I felt that the case was conducted
professionally based on the knowledge and information before us. I would
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like to extend my sympathies to Mrs Misra for the loss and distress that she
suffered due to the wrongful conviction.
Action against Joan Bailey
212. The below deals with my recollection and involvement in the action taken
against Joan Bailey. To assist me in answering the Inquiry’s questions on
this case, I have considered the following documents:
vi.
vii.
viii.
The Audit Report dated 5 2011 (POL00055918);
The Record of Taped Interview dated 9 March 2011 (POL00056387
(part 1), (POL00056388 (part 2) and POL00056389 (part 3));
The record of forms / exhibits shown at interview (POL00056365);
The Investigation Report dated 11 April 2011 (POL00057198);
The memo from Maureen Moors to the Criminal Law Team dated 14
April 2011 (POL00056390);
My memo to Post Office Security dated 3 May 2011 (POL00056477);
My memo to Post Office Security dated 17 May 2011 (POL00056547);
The case closure report dated 1 December 2011 (POL00057282);
The Royal Mail Group Caution dated 23 November 2011
(POL00061539);
The case file event log (POL00057285).
213. To my knowledge, an audit, interview and investigation was done to
establish the cause of the ‘losses’ which had been occurring at the branch.
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My assessment of the case, based on the admissions made at interview,
was that the appropriate offences were fraud / false accounting. Taking into
account all of the factors in this case and applying the public interest test,
my assessment was that a caution was appropriate. Because no other
offences were being considered, it was not necessary as part of the legal
process, and therefore I did not, further investigate or consider whether the
losses in the branch might have been caused by the Horizon IT system.
214.1 do not recall whether any Horizon data (and in particular ARQ logs) were
requested from Fujitsu in relation to this case, but it is unlikely given the
decision to offer a caution on grounds of the admitted fraud. I do not know if
the Investigation and Security Team, as part of any wider consideration of
the matter, requested any information from Fujitsu.
215.I have no specific recollection of this case and therefore do not feel in a
position to provide any further reflections at this stage, other than to say that
I am, of course, sorry that action was incorrectly taken again Joan Bailey
and the loss and distress that this will have caused her.
R -v- Lynette Hutchings
216. The below deals with my recollection and involvement in the case of Lynette
Hutchings. To assist me in answering the Inquiry’s questions on this case, I
have considered the following documents:
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vi.
vii.
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The handwritten note (POL00046065);
The Audit Report dated 31 March 2011 (POL00056292);
The Record of Tape Recorded Interview dated 20 April 2011
(POL00056417 (part 1),POL00044505 (part 2), POLO0046625 (part
3));
The Investigation Report dated 5 May 2011 (POL00046706);
My memo dated 17 June 2011 (POL00046626);
The memo from Graham Brander to you dated 9 December 2011
(POL00046628);
The Advice and Proposed Charge drafted by Martin Smith of
Cartwright King (POL00057362).
217.1 first became involved in the case of Mrs Hutchings on receipt of the file
which, based on the date of my memo (POL00046626), would have been
around early June 2011.
218. My initial assessment of the case and advice I gave is as per the memo
(POL00046626). This notes that concerns were raised that the Horizon
system was not working properly and therefore this needed to be
investigated before final advice can be given.
219.1 subsequently handed over the case to Martin Smith of CK, to take over.
The advice given from CK on prosecution and charges is at document
POL00057362. This states that there is very strong evidence to support the
allegation that Mrs Hutchings had inflated the amount of cash held within
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the branch. It notes that she admitted to altering the cash declarations and
suggested that she had done so only since the migration to Horizon but
prior to this, all accounts balanced. CK comment that this is clearly untrue.
CK advise that Mrs Hutchings gave examples of problems which she
alleged to have experienced with the Horizon system but these do not
appear to be of any relevance and no explanation has been put forward as
to how the deficit has arisen.
220. Following the advice, the Summons dated 21 February 2012
(POL00057468) were issued. I assume that CK’s advice was accepted by
the Information and Security Team and that they authorised the prosecution
based on this advice and their charging decision to prosecute on the fraud
charge was also based on CK’s advice.
221.My involvement with the matter at POL00057362 is purely administrative, in
that I was sent a statement from Graham Brander which I subsequently
forwarded to CK to deal with.
222.I have considered the documents provided to me by the Inquiry but, beyond
the initial advice, I was not involved in the case and therefore I am unable to
provide any meaningful answers to the Inquiry’s questions beyond what is
contained in the documents.
223.\n reflecting on the way the investigation and prosecution of Mrs Hutchings
was conducted by the Post Office and the outcome of the case, I have
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considered the Judgment of the Court of Appeal in Josephine Hamilton and
Others v Post Office Limited [2012] EWCA Crim 577 (POL00113278) (and
in particular paragraphs 267 to 272).
224.1 understand entirely the points made in the Hamilton judgment in relation to
there being no evidence or investigation into the Horizon IT system. At the
time of dealing with the case I made my views clear in my advice note that
more evidence was required to support the prosecution case. However, the
case was subsequently taken over by CK who reviewed the evidence and
advised on the appropriate charges. The defendant was advised by their
Solicitor and Counsel and duly advised on their plea. I am sorry that no
further evidence or investigation into Mrs Hutching’s concerns were made
and that this resulted her being wrongfully convicted. I extend my
sympathies for the loss and distress that this must have caused her.
R -v- Grant Allen
225. The below deals with my recollection and involvement in the case of Grant
Allen. To assist me in answering the Inquiry’s questions on this case, I have
considered the following documents:
i. The Audit Report dated 2 February 2012 (POL00089081);
ii. IThe Record of Taped Interview re. interview of 19 April 2012
(POL00089670 (part 1), POL00089671 (part 2));
iii. The Investigation report dated 1 May 2012 (POL00089426);
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iv. The email from Andrew Bolc dated 4 July 2012 (POL00089294) and
the attachments (POL00089454, POL00089057 and POL00089455).
v. Gareth Jenkins’ email dated 31 January 2013 (FUJ00153958).
226. At the outset I would like to flag that I had very limited involvement in the
case as it was CK who provided and reviewed the investigation report and
provided the initial advice.
227.My email dated 21 and 22 May 2012 (POL00089273) refers to various
lawyers giving advice: Simon Clark, Paul Wright, Martin Smith and Chris
Knight. I can confirm that these are CK lawyers.
228. I cannot now recall whether I conducted my own review of the documents
provided by the Investigation and Security Team in this case. However, it is
unlikely as it was the role of CK to advise the Investigation and Security
Team and I was only copied into correspondence for information purposes.
229.CK’s advice is provided at POL00089057. This notes that, subject to a
satisfactory answer in relation to the possibility of lost data, they would
advise a charge of fraud by false representation. It notes that there is
insufficient evidence to prove to the criminal standard who, if anyone,
actually stole the money from the Post Office.
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230. In consideration of what action was taken by the Post Office following the
advice from CK and what charges appeared on the final indictment, I have
reviewed the following documents:
i. The Summary of Facts (POL00089562);
ii. IThe Summons dated 19 July 2012 at (POL00089072);
iii. I The unsigned witness statement of Stephen Bradshaw dated 1 May
2012 (POL00089560);
iv. The unsigned statements of Richard Cross and Andrew Wise dated 17
September 2012 and 1May 2012 respectively at (POL00089561);
v. The letter to me dated 8 August 2012 (POL00089477) and the email
dated 9 August 2012 (POL00089329);
vi. The letter from Stephen Bradshaw to Cartwright King dated 24
September 2012 (POL00089061);
vii. The list of witnesses (POL00089346) and the list of exhibits
(POL00089351);
vii. IThe emails of 16 October 2014 (POL00089050).
231.Having reviewed these documents, I can see that following the advice,
Summons were issued to Mr Allen for the offence of: between 1 April 2010
and 7 February 2012, dishonestly and intending thereby to make a gain for
himself or another, or to expose another to a risk of loss, made
representations to Post Office Ltd, which were and which he knew were
untrue or misleading, namely that Winsford Post Office had more cash on
the premises than was actually the case resulting in a shortage of £11,705,
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232.
233.
234.
235.
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in breach of Section 2 of the Fraud Act 2006. The email dated 16 October
2014 (POL00089050) confirms the Mr Allen subsequently pleaded guilty.
In relation to the Schedule of Non-Sensitive Unused Material dated 19
September 2012 (POL00089348), the disclosure officer in this case was
Stephen Bradshaw and CK were responsible for reviewing the disclosure
schedules provided by Stephen as disclosure officer. I did not have any
involvement in the disclosure process.
In relation to the letter from Andrew Bolc of CK to Martin Bloor of Maidments
Solicitors dated 22 November 2012 (POL00089376), I have no recollection
of having seen this document before the Inquiry provided it to me and I had
no involvement in CK’s response. I was not involved in, and therefore
cannot comment on, whether any consideration was given to a stay or
adjournment of the Plea and Case Management Hearing.
Similarly, I do not know whether any call logs relating to calls made from Mr
Allen’s branch to the Horizon Service Desk and / or the Network Business
Support Centre for the relevant period were ever requested.
I have considered the emails dated 16 and 19 November 2012
(POL00089374). The Inquiry have asked me about the background to and
nature of the report which had been prepared by Gareth Jenkins, which was
proposed to be used in the cases identified by Rachael Panter. This report
dealt with the reliability of the Horizon system. I was not involved in any
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correspondence between CK and Gareth Jenkins in relation to the use of
this report. CK had care and conduct of the case and made the
determination that the report could be used across a number of cases. From
looking at the email chain, it appears that this was because it was a generic
report and not specific to one particular case. There was not, as far as I am
aware, any standard practice/process for using the same general
report/evidence across cases.
236.As to what my understanding was of the concerns which were being raised
by Fujitsu in this email chain (POL00089374), I can only comment on what
is contained in the email chain. Here, it appears that the concerns were
being raised largely in relation to the fact CK approached Mr Jenkins
directly, when asking him whether they could use his report for multiple
cases, as opposed to going through the usual process of contacting him
through a member of the Investigation Team.
237.1 can confirm that I have considered the following documents:
i. The emails dated 4 and 5 December 2012 (POL00089378) and 12
December 2012 (POL00089380);
ii. The letter to the court from CK dated 18 December 2012
(POL00089388), the Notice of Further Evidence dated 18 December
2012 (POL00089063), the statement from Gareth Jenkins dated 17
December 2012 (FUJ00124200), exhibit GlJ/1 (FUJ00080526) and
exhibit GlJ/2 (POL00031801);
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238,
239.
240.
241.
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iii. I The emails dated 5 and 19 December 2012 (POL00089390);
iv. The email from Gareth Jenkins dated 7 January 2013 (POL00089401);
v. The emails dated 31 January 2013 (POL00089427).
. I have been asked by the Inquiry to provide an account of Fujitsu’s
involvement in these proceedings.
I was not involved in, and therefore cannot comment on, how Mr Jenkins
came to be involved in these proceedings. However, it appears from the
documents that his involvement stemmed from CK finding in their
possession a report which comments on the reliability of the Horizon
system. Given that this report was generic in nature, CK determined that it
could be used in evidence in a number of cases where Horizon issues were
raised.
I was not involved in and therefore I did not have any say as to whether Mr
Jenkins acted as an expert or a witness to fact, but I assume that CK would
have wanted to have used him as an expert following the case against Mrs
Misra. I did not give Mr Jenkins any instructions and I do not know what
instructions he was given by CK.
I cannot recall whether Mr Jenkins ever conducted any analysis of the data
specific to the case of Mr Allen. Document POL00089380 notes that Mr
Jenkins said that he was able to retrieve the actual data from the time to see
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what actually occurred at this branch. However, I do not know whether this
was actually completed.
242. \t was for CK to decide whether Mr Jenkins should be instructed to examine
case specific data, both in this case and more generally. I have noted my
email of 1 February 2013 (POL00089427) where I ask whether we are in a
position to provide Horizon data to Mr Jenkins and seek his input. I cannot
recall the answer to this question and ultimately, it would have been a
decision for CK.
243.No information was given to me by anyone from Fujitsu (or the Post Office)
during the course of the criminal proceedings against Grant Allen as to any
bugs, errors, or defects in the Horizon IT system, past or present.
244. Document POL00089427 details Mr Jenkins’ concerns about the allegations
made in the Defence. I do not feel that I am able to comment further on this,
as I do not have any details of the allegation that he is referring to. As CK
had conduct of the case, I would not have had these details at the time
either and would have been copied in for information purposes only and
assumed that it would be dealt with by CK.
245.1 have seen that I advise on the acceptability of the basis of plea. I do not
know why and cannot recall why I would have got involved at this stage
when this would have been for CK, together with the Investigation Officer, to
consider as they would have had the background, knowledge and details of
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the case. I do not recall how it came for me to involved at this point. I can
only assume that I was asked because I was the POL criminal solicitor.
246. In reflecting now on the way the investigation and prosecution of Mr Allen
was conducted, I have reviewed the Judgment of the Court of Appeal in
Richard Hawkes & Others v Post Office Limited [2022] EWCA Crim 1197
(RLIT0000039) (and in particular at paragraphs 16 to 24). This highlights
the issues that sub postmasters were experiencing with Horizon. Had I
known any of this information at the time, I am confident that the
investigation and prosecution of Mr Allen, as with other sub postmasters
would have been conducted differently, or not at all. I am sorry that the
absence of this evidence resulted in the wrongful conviction of Mr Allen and
the loss and distress that this must have caused him.
R -v- Angela Sefton and R -v- Anne Nield
247. The below deals with my recollection and involvement in the cases of
Angela Sefton and Anne Nield.
248. My involvement in these cases was very limited as CK had complete
conduct of the prosecutions from initial advice through to conclusion. I
therefore cannot comment on the action taken, including the charges,
witness evidence or disclosure. I have read and reviewed the documents
provided to me by the Inquiry in relation to these cases but do not feel I can
add anything further than what is contained in these documents.
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249.1 have seen that I was sent an email from CK (POL000059313) asking me
for an update on Insight2 (Second Sight) Report. Second Sight were
brought in to review the prosecutions of the sub postmasters and were
drafting a report which reviewed the Horizon system. I understand that the
Defence solicitors were asking for this and CK’s email was simply asking
me for an update as to the report so that they could update the Defence.
Other than this, I do not recall being involved in this case.
250. However, as with all of the cases, I understand the extent of the loss and
distress that Ms Sefton and Ms Nield must have suffered and extend to
them my sympathies.
R v Khayyam Ishaq
251. The below deals with my recollection and involvement in the case of
Khayyam Ishaq. To assist me in answering the Inquiry’s questions on this
case, I have considered the following documents:
vi.
Martin Smith’s email dated 31 May 2012 (POL00119452);
The emails from February 2013 (POL00059808);
Rachael Panter’s email dated 4 February 2013 (FUJOO153967);
My email dated 6 February 2013 (POL00119434);
Martin Smith’s email dated 8 March 2013 (POL00119381);
My email dated 31 July 2013 (POL00119407).
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252. As can be seen in the above documents, as the only Criminal Lawyer at the
POL, I was copied into this case for information only. I had no involvement
in the actual prosecution of the case of Mr Ishaq and do not feel that I am
able to expand on anything other than that contained in the documents.
253. However, I would like to extend my sympathy to Mr Ishaq for the loss and
distress that he suffered due to the Horizon IT system.
Audit data from Horizon to support investigation, prosecution and/or other
legal proceedings
254. In considering the Inquiry’s questions in relation to the above subject matter,
I can confirm that I have reviewed the following documents:
The document entitled “Conducting Audit Data Extractions at CSR”
dated 4 May 2000 (POL00029176);
The document entitled “Conducting Audit Data Extractions at Live”
dated 27 November 2001 (FUJ0015276);
The versions of the document entitled “Management of the Litigation
Support Service” dated 27 October 2009 (FUJ00152212), 14 February
2012 (FUJ00152220) and 23 April 2012 (FUJ00152225) as well as the
version marked “withdrawn” (FUJ00152235);
The versions of the document entitled “Audit Data Extraction Process”
dated 13 September 2010 (FUJ00152216), 1 March 2011
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(FUJ00152218), 14 February 2012 (FUJ00152221), 3 September 2014
(FUJ00152225) and 4 September 2014 (FUJ00152229);
v. The document entitled “Security Management Service: Service
Description” (SVM/SDM/SD/0017) dated 24 August 2006
(FUJ00002033), 31 December 2008 (FUJ00080107), 15 October 2010
(FUJ00002264), 25 November 2013 (FUJ00088868), 4 December
2013 (FUJ00002555), 4 April 2014 (POL00002572) and 19 February
2016 (POL00002666) (in particular paragraph 2.4).
255. My role as a member of the CLT did not include dealing with any contractual
requirements between Fujitsu and POL. This was dealt with by a
contract/commercial team and was not part of my responsibilities.
256. The only role I had in obtaining audit data was to request it as and when it
was required through the Investigation and Security Team as happened in
the case of Mrs Misra. The Investigation Officer would deal with the request
internally and contact Fujitsu. In the case of Mrs Misra I contacted David
Jones, Head of Legal, direct to escalate the request but it was primarily for
the Investigation Officer to deal with requests. It was not usual for me to
contact David Jones at Fujitsu but I did so here, due to the urgency of the
request. I only obtained his name from Penny Thomas who provided it to
me so that I could try to bypass the usual slow procedure for obtaining ARQ
data.
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257.\n normal circumstances, I understand that David Jones in Fujitsu would be
negotiating and communicating about ARQ requests with our contract and
commercial team. I was not part of these negotiations and cannot comment
on who was also responsible for the provision of data or how any data was
obtained was presented by Fujitsu.
ARQ data issues
258. In answering the Inquiry’s questions on this subject matter, I can confirm
that I have reviewed the following documents:
i. I Mark Dinsdale’s email to Marilyn Benjamin and Juliet McFarlane dated
2 July 2010 (FUJ00122903);
ii. I The emails between Juliet McFarlane and Mark Dinsdale dated 13 and
16 September 2010 (FUJ00122980).
259. The first time that I had sight of these two emails was when the Inquiry
provided them to me. I did not see them or have any knowledge or them
during the time when I was involved in prosecutions of subpostmasters.
Given that this is my first time seeing these emails, I do not feel in a position
to answer the Inquiry’s questions on them as I do not feel that I could
expand on anything other than what is stated in the emails.
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The creation and development of standard Horizon Integrity reports
260. In addressing the Inquiry’s questions on the above subject matter, I can
confirm that I have reviewed the following documents:
i. The emails dated 13, 17 and 18 September 2012 (FUJ00156640);
ii. IMy email dated 20 September 2012 (FUJ00155085);
iii. I The email from me to Gareth Jenkins dated 1 October 2012
(FUJ00155090) and attachments (POL00107567 and FUJ00156648);
iv. Gareth Jenkins’ reply to me dated 1 October 2012 (POL00096983);
v. My email dated 1 October 2012 (FUJ00155093);
vi. Version 0.1 of “Horizon Integrity” (FUJ00123914);
vii. I Version 0.2 of “Horizon Integrity” (POL00107806);
viii. I My email dated 4 October 2012 (FUJ00153815);
ix. The emails dated 4 and 5 October 2012 at (POL0097007) and the
attachments (FUJ00153819, FUJ00153820 and FUJ00153821);
x. I Gareth Jenkins’ email to Martin Smith, me and others dated 5 October
2012 (FUJ00124012) and attachments (FUJ00124013, FUJ00124015,
FUJ00124016, FUJ00080526, FUJ00124020);
xi. The email from Sharron J Jennings dated 5 October 2012
(FUJ00123982) and the attachment (FUJ00123983);
xii. The emails dated 19 October 2012 (POL00097061);
xiii. I The emails dated 26 and 27 November 2012 (POL00097216);
xiv. I My email dated 27 November 2012 (POL00097218);
xv. Gareth Jenkins’ statement dated 27 November 2012 (FUJ00124072).
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261.Document POL00096983 refers to two ‘existing’ reports called ‘Horizon’ and
‘Horizon Online Integrity’. I cannot recall the specifics of these reports but
presume that they were generic reports, giving information both about how
the Horizon system operated and worked in practice and also about the
integrity of the Horizon system. I understand that CK requested them
because they wanted a report to be able to serve with all cases which
assisted the Court and the Defence in understanding the working of the
Horizon system in practical terms.
262.1 then requested another report. This was to assist Helen Rose, the
disclosure officer, who was, at that time, dealing with 20 cases. The report
was needed to deal with the issues in those cases. This email and the
questions in it, were drafted following consultation with and assistance from
CK.
263. By this point, I did think that Mr Jenkins was providing evidence as an
expert as he was seen as an expert by both POL and Fujitsu.
General
264.1 did consider that a challenge to the integrity of Horizon in one case was
relevant to other ongoing or future cases but I would also always deal with
the specific issues in each case in front of me on a case by case basis.
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265. Counsel were very experienced and had training on the Horizon system and
dealt with multiple POL cases. If they were aware that an issue raised in
one case was or could be relevant to another case, I was confident that they
would highlight this to me in their opinions and advice.
266.1 cannot think of any other matters that I consider are of relevant to Phase 4
of the Inquiry (Action against Sub-postmasters and others: policy making,
audits and investigations, civil and criminal proceedings, knowledge of and
responsibility for failures in investigation and disclosure).
267.1 have a lot of sympathy for these sub postmasters and the huge amount of
loss they suffered. I genuinely thought that I was doing the right thing at the
time. They are not criminals and I am sorry that the legal system failed them
and treated them as such.
Statement of Truth
I believe the content of this statement to be true.
Dated: 6 October 2023
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Index to First Witness Statement of Jarnail Singh
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No. I URN Document description Control number
1 WITN04750101 Curriculum Vitae of Mr Jarnail Singh WITNO4750101
2 POL00030659 Post Office Internal Prosecution Policy POL-0027141
(Dishonesty), Andrew Wilson December 1997
3 POL00031012 Investigation Policy Appendix 16 - Investigation I POL-0027494
and prosecution policy
4 POL00030578 $02 Royal Mail Group Criminal Investigation POL-0027060
and Prosecution Policy December 2007
5 POL00104812 “Royal Mail Group Ltd Criminal Investigation and I POL-0080444
Prosecution Policy"
6 POL00031011 RMG Prosecution Policy (undated) V2.1 POL-0027493
7 POL00030580 Post Office Ltd - Security Policy: Fraud POL-0027062
Investigation and Prosecution Policy v2
8 POL00030579 Post Office Ltd Financial Investigation Policy, POL-0027061
May 2010
9 POL00026573 RMG Proceedures & Standards - Proceeds of POL-0023214
Crime Act 2002 & Financial Investigations doc
9.1V1
10 I POL00031008 RMG Ltd Criminal Investigation and Prosecution I POL-0027490
Policy v1.1 November 2010
11 I POL00030598 Royal Mail Prosecution Decision Procedure POL-0027080
12 I POL00104853 Post Office's Financial Investigation Policy POL-0080485
13__I POL00104855 Post Office Ltd. Anti-Fraud Policy POL-0080487
14 I POL00030685 Royal mail Group Prosecution Policy, v3.0, April I POL-0027167
2011 - Rob Wilson (Head of Criminal Law
Team)
15 I POL00030800 RMG Policy - Prosecution (S3) Version 3.0 POL-0027282
16 I POL00031034 Post Office Prosecution Policy V1 POL-0027516
17 I POL00104929 “Post Office Limited: Internal Protocol for POL-0080561
Criminal Investigation and Enforcement (with
flowchart)"
18 I POLO0105226 Undated Appendix 1 - POL Criminal POL-0080851
Investigations and Enforcement Procedure
(flowchart)
19 I POL00030686 Post Office Prosecution Policy England and POL-0027168
Wales (effective from 1/11/13, review 1/11/14)
20 I POL00030811 Post Office Limited Prosecution Policy for POL-0027293
England and Wales v1
21 I POL00104900 Undated 'Separation Project - Criminal POL-0080532
Investigations Policy for Post Office Ltd’
22 I POLO0039969 Draft POL Board Prosecution Paper Policy May I POL-0036451
2002 Issue 7
23 I POL00104747 Investigation Policy: Casework Management POL-0080387
(England & Wales) v1.0
24
POL00104777
Investigation Policy: Casework Management
(England & Wales) v4.0
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POL-0080417
25
POL00118096
Email from Andrew Wise to Michael Stanway
forwarding an email re Casework Compliance
VIS00012685
26
POL00118108
Appendix 1 - Case Compliance checklist.
Undated (date taken from parent email)
VISO0012697
27
POL00118109
Appendix 2 - File construction and Appendixes
A, B and C: "Compliance Guide: Preparation
and Layout of Investigation Red Label Case
Files" Undated - date taken from parent email
VIS00012698
28
POL00118103
Appendix 5 - Discipline reports layout: "POL
template Offender Report (Personnel
Investigation)" - undated (date taken from parent
email)
VIS00012692
29
POL00118105
Appendix 7 - Tape Interviews. "POL Security
Operations Team guide: Summarising of Tape
Recorded Interviews." Undated - date taken
from parent email
VIS00012694
30
POL00118106
Appendix 8 - Notebooks: Guidance on using
notebooks in investigations. Undated (date
taken from parent email)
VIS00012695
31
POL00118107
Appendix 9 - Case Progression Toolkit. Undated
(date taken from parent email)
VIS00012696
32
POL00118101
Appendix 3 - Offender reports and Discipline
reports: "Compliance Guide to the Preparation
and Layout of Investigation Red Label Case
Files" - undated (date taken from parent email)
VIS00012690
33
POL00118102
Appendix 4 - Offender reports layout: "POL
template Offender Report (Legal Investigation)" -
undated (date taken from parent email)
VIS00012691
34
POL00118104
Appendix 6 - Identification codes (undated - date
taken from parent email)
VIS00012693
35
POLO00115665
Email from Dave Posnett to Dave Pardoe,
Allison Drake and others - Re: Case Compliance
POL-0115825
36
POL00115666
Security Operations Team. Summarising of
Tape Recorded Interviews.
POL-0115826
37
POL00115671
Post Office Ltd, Security Operations Team,
Compliance. Guide to the preparation and layout
of investigation red label case files. Offender
reports and discipline reports.
POL-0115831
38
POL00115667
Policy Guide: Notebooks
POL-0115827
39
POL00115668
Case Raise Facing Sheet and other Forms re
Investigations and Incident Reporting branch
losses
POL-0115828
40
POL00115669
Security Operations Team - Case Compliance
Checklist and Scoring
POL-0115829
WITNO04750100
WITNO04750100
41 I POLO0115670 Guide to the Preparation and Layout of POL-0115830
Investigation Red Label Case Files - Security
Operations Team Compliance
42 I POL00115672 Post Office Limited: Investigation, Legal - POL-0115832
Offence Report - Blank Form - Ref:
POLTD/1112/XXXX
43 I POLO0115673 Post Office Limited - Blank Personnel POL-0115833
Investigation Report Form - Ref:
POLTD/1112/XXXX
44 I POLO0115674 Post Office Limited Identification Codes- POL-0115834
Ethnicities
45 I POL00118110 Email from Andrew Wise to Darrell Kennedy, VIS00012699
Ben J Edwards and others re Case Compliance
46 I POL00118120 Security Operations Team Guide re VIS00012709
summarising of Tape Recorded Interviews
47 I POLO0118121 Guidance on using notebooks in investigations I VISO0012710
48 I POL00118122 Case Progression Toolkit VIS00012711
49 I POL00118123 Case Compliance checklist VIS00012712
50 I POL00118124 Compliance Guide: Preparation and Layout of VIS00012713
Investigation Red Label Case Files, File
Construction and Appendices A, B & C
51 I POLO0118125 Compliance Guide to the Preparation and VIS00012714
Layout of Investigation Red Label Case Files-
Offender and Discipline reports.
52 I POL00118126 POL Template Offender Report (Legal VIS00012715
Investigation) - Confidential
53 I POLO0118127 POL template Discipline Report (Personnel VIS00012716
Investigation) - Confidential
54 I POL00118128 Race Identification Codes, numbers 1-7. VIS00012717
55 I POL00118289 Email from Dave Posnett to Rob King, Andy POL-0119426
Hayward, Jarnail Singh cc Suzanne Winter
Robert Daily, Keith Gilchrist and Graham Ward
re Review POL investigation forms
56 I POL00118290 Index to GS Obsolete Investigation Forms - POL-0119427
undated (date taken from host email)
57 I POL00118377 Index to POL Investigation Forms POL-0119514
58 I POL00118129 Email from Andrew Wise to Helen Dickinson re I VIS00012718
Case Process and Compliance Documents
59 I POL00118130 Post Office Ltd Security Operations Team - VIS00012719
Compliance - Guide to the Preparation and
Layout of Investigation Red Label Case Files.
60 I POL00118131 Identification Codes, numbers 1-7 VIS00012720
61 I POL00118132 Available Intelligence Checks for Security Team I VISO0012721
Staff and Financial Investigators
62 I POL00118133 Security Operations Team - Asset Recoveries VIS00012722
63 I POLO0118134 Email to Post Office Security re: Security VIS00012723
Operations BO! Account Funding Notification
3
WITNO4750100
WITN04750100
64 I POLOO118135 Cash Seizure - CIT Collections Process VIS00012724
65 I POLO0118136 Security Operations Team - Triggers & VIS00012725
Timescales
66 I POL00105223 Security Operations Casework Review POL-0080848
67 I POL00084988 Security & Investigation Financial Investigation POL-0082046
Unit - Criminal Debt recovery for losses > £20K
Process flowchart
68 I POL00084989 POL Financial Investigation Unit Business POL-0082047
Process Documentation - Security &
Investigation Debt Process text
69 I POL00051382 Letter from Rob Wilson to John Dove re: R v POL-0047861
Susan Jane RUDKIN confiscation hearing
21/08/2009
70 I POL00084977 Post Office, Former SPM End to End Debt POL-0082035
Review v.0.5
71 I POL00044830 David Blakey - Record of Tape Recorded POL-0041309
Interview 13 May 2004
72 I POL00044831 Record of tape - recorded interview - David POL-0041310
Charles Blakey (Part 2)
73 I POL00044829 Interview with Gillian Blakey, Summary of points I POL-0041308
74 I POL00044818 Offence sheet - Theft and false accounting - POL-0041297
David Charles Blakey
75 I POL00044821 Notification of proceedings to police - David POL-0041300
Charles Blakey
76 I POL00044822 Form NPA 02 1/97 - Notification of proceedings I POL-0041301
to police - David Charles Blakey
77 I POL00044835 David Blakey: Memo from Jarnail A Singh to POL-0041314
S&A Casework, cc'd Paul Whitaker re: POST
OFFICE LIMITED v DAVID CHARLES BLAKEY
SUB POST OFFICE ASSISTANT, RIBY
SQUARE SPSO CASE NO: 0405/0172
78 I POL00044817 Schedule of non-sensitive unused material for POL-0041296
the case of R v David Charles Blakey
79 I POL00044819 David Blakey case study - Witness statement for I POL-0041298
Glen Morris
80 I POL00044824 Witness statement of Paul Graham Whitaker POL-0041303
81 I POL00044825 Witness statement - Jayne Anne Kaye POL-0041304
82 I POL00044826 Witness statement - Natasha Ann Beck POL-0041305
83 I POL00044827 Witness statement - Patricia Brown POL-0041306
84 I POL00044828 Witness statement - Samantha Alice Callaghan I POL-0041307
85 I POL00044357 David Blakey case study: Internal memo from POL-0040836
Phil Taylor to Paul Whittaker re: REGINA V
DAVID CHARLES BLAKEYCASE NO:
0405/0172
86 I POL00053009 Record of Tape/Recorded Interview with POL-0049488
Suzanne Palmer
87
POL00053007
Suzanne Palmer cases study: PO Investigation
report into Suzanne Palmer re: offence of false
accounting
WITNO04750100
WITNO04750100
POL-0049486
88
POL00053005
Notification of Proceedings to Police Form
POL-0049484
89
POL00053006
Notification of Proceedings to Police in relation
to Miss Suzanne Lesley Palmer - False
accounting
POL-0049485
90
POL00052990
Memo from Mr Jarnail A Singh to the Post Office
Limited (Investigation Team) re: Post Office
Limited v Suzanne Lesley Palmer.
POL-0049469
91
POL00053011
Schedule of charges re: Post Office Limited v
Suzanne Lesley Palmer
POL-0049490
92
POL00052987
Memo from Miss Lisa Allen to Mr Jarnail Singh
re: Suzanne Lesley Palmer
POL-0049466
93
POL00052994
Memo from Jarnail Singh to Investigation team
re: POL v Suzanne Lesley Palmer - Southend
Magistrates Court - Committal 3rd July 2006 -
Case No: POLTD/0506/0619 - outcome of
Magistrates hearing (declined jurisdiction)
POL-0049473
94
POL00053001
Suzanne Palmer Case Study: Memo from
Jarnail Singh to POL Investigation Team cc Lisa
Allen re: POL v Suzanne Palmer committal
hearing 03/07/2006 - update re hearing and
witnesses etc
POL-0049480
95
POL00052991
Memo from Jarnail A Singh to Investigation
Team Post Office Limited c.c. Lisa Allen, Press
Office, POST OFFICE LIMITED v SUZANNE
LESLEY PALMER
POL-0049470
96
POL00053003
Memo from Miss J S Andrews to Post Office
Limited (Investigation Team) re: R v Suzanne
Lesley Palmer (Basildon Crown Court - Plea &
Case Management Hearing)
POL-0049482
97
POL00053008
Counsel Advice on Evidence - R v. Suzanne
Palmer
POL-0049487
98
POL00052986
Indictment Sheet re: R v Suzanne Lesley
Palmer
POL-0049465
99
POL00052993
Memo from Miss J S Andrews to the Post Office
Ltd (Investigation Team) re: R v Suzanne Lesley
Palmer
POL-0049472
100
POL00052998
Memo from JS Andrews to Investigation team
re: Regina v Suzanne Lesley Palmer - warned
for trial w/c 22 Jan 2007 - Notice of Additional
Evidence
POL-0049477
101
POL00052992
Suzanne Palmer Case Study: Memo from
Jennifer Andrews to POL Investigation team cc
Lisa Allen re: POL v Suzanne Palmer trial w/e
22/01/2007 - enclosing draft admissions
POL-0049471
102
POL00052988
Memo from Miss J S Andrews to the Post Office
Limited (Investigation Team) re: Post Office
Limited v Suzanne Lesley Palmer (Trial during
w/c 22nd January 2007)
WITNO04750100
WITNO04750100
POL-0049467
103
POL00052989
Letter from Miss J S Andrews to Investigation
Team Post Office Limited c.c. Lisa Allen, POST
OFFICE LIMITED v SUZANNE LESLEY
PALMER
POL-0049468
104
POL00052995
Suzanne Palmer Case Study: Memo from
Jennifer Andrews to POL Investigation team cc
Lisa Allen RE: POL v Suzanne Palmer trial w/c
22/01/2007 - enclosing notice of additional
evidence for Defence
POL-0049474
105
POL00052997
Memo from Mr Jarnail Singh to the Post Office
Limited (Investigation Team) re: Post Office
Limited v Suzanne Lesley Palmer (Trial on w/c
22nd January 2007)
POL-0049476
106
POL00053000
Letter from Mr Jarnail A Singh to Lisa Allen re:
Post Office Limited v Suzanne Lesley Palmer
(Basildon Crown Court w/c 22nd January 2007)
POL-0049479
107
POL00052982
Memo from Miss J Andrews to Investigation
Team Post Office Ltd, RE, PO v Suzanne Lesley
Palmer, Southend Crown Court, Trial 24th-26th
Jan 2007
POL-0049461
108
POL00052984
Suzanne Palmer Case Study: Casework
Management Initial Tick List
POL-0049463
109
POL00060416
Susan Rudkin case study: Letter from Mr EM
Rudkin to Paul Hemley Re: Suspense account
POL-0056895
110
POL00061521
Letter from Paul Hemley to E M Rudkin re:
Suspense account query
POL-0058000
111
POL00065265
Susan Rudkin case study: Incident Report for
Ibstock Post Office Branch
POL-0061744
112
POL00045243
Handwritten statement in re to subpostmaster
debt recovery (undated - date estimated from
audit date) Susan Rudkin
POL-0041722
113
POL00045246
Handwritten note re: Interview at Ibstock Post
Office
POL-0041725
114
POL00050026
Record of tape recorded interview of Susan
Jane Rudkin dated 20/8/08.
POL-0046505
115
POL00046488
Susan Rudkin case study: Memo in re to Jarnail
Singh to Fraud team post office limited and Mole
Willcox in re to ' Post office limited v Susan Jane
Rudkin dated 3/10/2008.
POL-0042967
116
POL00045220
Schedule of charges - Post Office Limited v
Susan Jane Rudkin
POL-0041699
117
POL00046505
Letter from Mike Wilcox to Jarnail Singh in re to
Susan Jane Rudkin
POL-0042984
118
POL00046506
Memo from Jarnail Singh to Fraud team post
office in re to Susan Jane Rudkin
WITNO04750100
WITNO04750100
POL-0042985
119
POL00046537
Susan Rudkin case study: Summons, Hinckley
magistrates court in re to Susan Jane Rudkin.
POL-0043016
120
POL00051044
Email from Jarnail A Singh to Tahira Rasool in
re to Michael and Susan Rudkin (Ibstock)
Leicester post office.
POL-0047523
121
POL00059762
Email from Glenn Chester to Sarah Howards,
Re: Urgent Advice needed-Flag Case FCT728
POL-0056241
122
POL00044916
Letter from Mr Michael Rudkin to POL re:
Requesting withdrawal of suspension &
prosecution
POL-0041395
123
POL00060421
Letter from E M Rudkin to Mr Goerge Thomson
re: Private, In the Strictest Confidence and
without Prejudice.
POL-0056900
124
POL00046524
Letter from Marie Dancer to Mike Wilcox in re to
Susan Rudkin
POL-0043003
125
POLO0050993
Letter from Dr A T Peden Richard Nelson
Solicitors in re to Susan Rudkin's mental health.
POL-0047472
126
POLO0050990
Letter from Jarnail Singh to Richard Nelson
solicitors, RE: PO v Susan Jane Rudkin,
Coalville Magistrates Court- 13 March 2009 at
10am
POL-0047469
127
POL00050242
Restraint Order Prohibiting Disposal of Assets -
Susan Jane Rudkin
POL-0046721
128
POL00051380
Susan Rudkin case study: Memo from Rob
Wilson to Fraud Team cc Mike Wilcox, Ged
Harbinson and Press Office re: R v Susan Jane
RUDKIN - report on final result
POL-0047859
129
POL00052029
Letter from Jarnail Singh to Messrs Richard
Nelson Solicitors re: Regina v Susan Jane
Rudin Stafford Crown Court Confiscation
Hearing - 21st August 2009
POL-0048508
130
POL00052020
STATEMENT OF INFORMATION RELEVANT
IN ACCORDANCE WITH SECTION 16 (3) OF
THE PROCEEDS OF CRIME ACT 2002,
REGINA V SUSAN JANE RUDKIN
POL-0048499
131
POL00052094
STAFFORD CROWN COURT -
CONFISCATION HEARING - 21st AUGUST
2009, THE QUEEN v SUSAN JANE RUDKIN,
BRIEF TO COUNSEL FOR THE
PROSECUTION
POL-0048573
132
POL00055156
Letter from Charlotte Knight to Mr Singh, Re: R
v Susan Jane Rudkin- Outstanding Confiscation
Order-29.894.15 Deadline for payment
Wednesday 18 August 2010
POL-0051635
133
POL00055203
Letter from Jarnail Singh to Charlotte Knight, re:
Regina v Susan Jane Rudkin Outstanding
Confiscation Order
WITNO04750100
WITNO04750100
POL-0051682
134
POL00057602
Financial Investigation Events Log,
POLTD/0809/0101 Susan Rudkin
POL-0054081
135
POL00051231
Susan Rudkin case study: Letter from John
Dove to Jarnail Singh re mags hearing - guilty
plea
POL-0047710
136
POL00050140
Transcript: Record of tape interview in re to
Julian Wilson dated 15/09/2008
POL-0046619
137
POL00050128
Transcript: Record of tape recorded interview in
re to Julian Wilson.
POL-0046607
138
POL00044806
Julian Wilson case study: Memo from Jarnail
Singh to the Fraud Team Post Office Ltd re:
POL v Julian Wilson (Astwood Bank)
POL-0041285
139
POL00047083
Julian Wilson Case Study: Post Office Limited V
Julian Wilson - Schedule of Charges
POL-0043562
140
POL00050763
Email from Gary R Thomas to Fraud Team Post
Office, Jarnail A Singh, RE: T.1.C's Julian Wilson
POLTD
POL-0047242
144
POL00051265
Letter from Jarnail Singh to Jolyon Canlin; Re
POL v Julian Wilson
POL-0047744
142
POL00051194
Royal Mail Group, Schedule of Non-Sensitive
Unused Material re: Julian WILSON
POL-0047673
143
POL00051385
Letter from Rob G Wilson to Jarnail Singh re:
REGINA v JULIAN WILSON
POL-0047864
144
POL00044753
The Queen v Julian Wilson - Instructions to
counsel to settle indictment and advise on
evidence and brief for the prosecution
POL-0041232
145
POL00044767
Summary of facts re: Royal Mail Group Ltd v
Julian Wilson
POL-0041246
146
POL00051920
Julian Wilson case study: Letter from J. Canlin
to Mr J Singh RE: Julian Wilson - Worcester
Crown Court. 15th June 2009 - PCIVIH
POL-0048399
147
UKGI00012555
Letter pertaining to Plea and Case Management
hearing R v Julian Wilson from Jarnail Singh to
Jolyon Canlin
UKGI023351-001
148
POL00044751
In The Crown Court at Worcester, Advice
statement re: R v Julian Wilson
POL-0041230
149
POL00044809
Indictment, Draft Case Summary from Anthony
Vines, Civitas Law - R v Julian Wilson
POL-0041288
150
POL00051720
Letter from Jarnail Singh to Fraud Team Post
Office Limited c.c. Gary Thomas and others re:
REGINA v JULIAN WILSON
POL-0048199
151
POL00051715
Letter from Jarnail Singh to Messrs Richard
Nelson. Re: Regina v Julian Wilson - Worcester
Crown Court - Plea and case management
hearing - 15th June 2009
POL-0048194
152
POL00047026
Draft Case Summary at the Crown Court at
Worcester in The Queen v Julian Wilson
WITNO04750100
WITNO04750100
POL-0043505
153
POL00051459
INSTRUCTIONS TO COUNSEL (Mr Anthony
Vines of Civitas Law) DRAFTED BY ROB G
WILSON TO SETTLE INDICTMENT AND
ADVISE ON EVIDENCE AND BRIEF FOR THE
PROSECUTION IN THE MATTER OF THE
QUEEN V JULIAN WILSON (Backsheet
endorsed by Counsel (Richard Cole) with
various dates)
POL-0047938
154
POL00044800
Indictment, Statements of Offences - R v Julian
Wilson
POL-0041279
155
POL00051936
Letter from John H. Dove. to Mr. J. Singh re:
Regina - v - Julian Wilson - Worcester Crown
Court
POL-0048415
156
POL00050695
Letter from Richard Nelson solicitors to Jarnail
Singh (POL) seeking variation of restraint order
against Julian Wilson dated 14/01/09.
POL-0047174
157
POL00064718 001
Graham Ward's witness statement in support of
an application for a restraint order (Section 41
Proceeds of Crime Act 2002) against Julian
Wilson.
POL-0061197_001
158
POL00050704
Memo from Jarnail Singh to Fraud team (Ged
Harbinson & Phil Southern) re to Julian Wilson
Astwood Bank.
POL-0047183
159
POL00050726
Julian Wilson case study: Email from Graham C
Ward to Jarnail A Singh, RE: FW: Post Office
Ltd v Julian Wilson
POL-0047205
160
POL00044961
Email from Glenn Chester to Zoe Topham re:
Fw: Astwood Bank 346246 B96 6AD
POL-0041440
161
POL00051969
Letter from Miss J S Andrews to Jolyon Canlin
of Messrs Richard Nelson re: REGINA -v-
JULIAN WILSON
POL-0048448
162
POL00045621
Court order (Worcester) in re to R V Julian
Wilson
POL-0042100
163
POL00052047
Letter from Jarnail Singh to Fraud Team Post
Office Limited c.c. Graham Ward and others re:
REGINA v JULIAN WILSON
POL-0048526
164
POL00052277
Email from Graham C Ward to Jarnail A Singh
re: Julian Wilson - Restaint Order
POL-0048756
165
POL00044749
Financial investigation events log - Case
number: 0809/126 Gary Thomas - Astwood
Bank/ Julian Wilson
POL-0041228
166
POL00113278
Approved Judgment between Josephine
Hamilton & Others and Post Office Limited
POL-0110657
167
POLO0058550
Seema Misra Case Study: Email from Mr Keith
Noverre to Mrs S Misra re: Audit of West Byfleet
Post Office Branch
POL-0055029
168
POL00044541
POL Investigation Report for Seema Misra
(POLTD/0708/ 0249)
WITNO04750100
WITNO04750100
POL-0041020
169
POL00049658
Memo from Jarnail Singh to Investigation Team
Post Office Limited and Adrian Morris re Post
Office Limited v Seema Misra.
POLTD/0708/0249. Opinion that there is
sufficient evidence to prosecute, and in the
Crown Court.
POL-0046137
170
POL00049716
Email from Jason G Collins to Jarnall A Singh
re: DAM Authority Seema Misra West Byfleet
POL-0046195
171
POL00049717
Email from Jarnail A Singh to Investigation
Team Post Office Ltd
POL-0046196
172
POL00044539
Memo from Jarnail Singh to the Post Office
fraud team re Post Office Limited Seema Misra
POL-0041018
173
POL00045010
POL v Seema Misra - Schedule of Charges
POL-0041489
174
POL00044613
Summary of facts (POL v Seema Misra)
POL-0041092
175
POL00051149
Indictment - R v Seema Misra
POL-0047628
176
POL00094011
West Byfleet, Seema Misra Reports re
transactions, remittance out slip, and final
branch trading statement.
POL-0094133
177
POL00051441
Letter from Phil Taylor to Mr Wawick Tatford.
Re: Counsel's advice on criminal prosecution of
Seema Misra for theft
POL-0047920
178
POL00051539
Seema Misra Case Study - Email from Warwick
Tatford to Phil Taylor re Seema misrta Guildford
Crown Court Trail - W/L 1st -12th June 2009.
POL-0048018
179
POL00050738
letter from Jon Longman to Jarnail Singh
regarding statements and evidence for the
committal of Seema Misra
POL-0047217
180
POL00050750
Schedule of Non-sensitive unused material, R v
Seema Misra
POL-0047229
181
POL00050751
Schedule of sensitive material, R v Seema Misra
POL-0047230
182
POL00044585
Seema Misra case study - Instructions to
counsel to settle indictment and advise on
evidence and brief for the prosecution in The
Queen v Seema Misra
POL-0041064
183
POLO0050950
Letter from Jarnail Singh to Clerk to Warwick
Tatford in re to Regina v Misra
POL-0047429
184
POL00051092
Email from Warwick Tatford to Jarnail A Singh
Re Indictment for Misra
POL-0047571
185
POL00050942
Letter from Jarnail Singh to Castle partnership
Solicitors in re to Regina v Seema Mirsa dated
17/02/09.
POL-0047421
186
POL00051045
Letter from Castle partnership to Royal mail
services in re to PO v Seema Misra dated
02/03/09.
POL-0047524
10
187
POL00051773
Seema Misra Case Study: Attendance Note by
Jarnail Singh re: Seema Misra at Guildford
Crown Court(CRM/258932/JSX)
WITNO04750100
WITNO04750100
POL-0048252
188
POL00052202
Email from John Longman to Phil Taylor Fw:
Trial of Seema Misra - West Byfleet SPSO -
Branch Code 126023 - Guildford Crown Court
30th November 2009 (Four day trial)
POL-0048681
189
POL00052487
Letter from Coomber Rich to Royal Mail Legal
Services, RE: R v Seema Misra, Guildford
Crown Court- 30 November 2009
POL-0048966
190
POL00052462
Seema Misra Case Study - Regina v Seema
Misra - Application by the defence pursuant to
s8of the criminal procedure and investigations
act for disclosure of relevant material
POL-0048941
191
POL00058503
Email from Warwick Tatford to John Longman,
Re: Misra further disclosure request from the
defence.
POL-0054982
192
POL00053723
Email from Jarnail Singh to Warwick Tatford incl
em chain from Mark Dinsdale to Rob Wilson re:
advice requested on disclosure request in
MISRA case
POL-0050202
193
POL00044557
Advice on requests for disclosure in Seema
Misra case
POL-0041036
194
POL00053746
Seema Misra case study - Letter from Jarnail
Singh to Coomber Rich Solicitors, RE: R v
Seema Misra, Guildford Crown Court, Trial 15
March 2010
POL-0050225
195
POL00044553
Letter Jarnail to Singh to Seema Misra's lawyers
regarding Regina v Seema Misra Guilford crown
court
POL-0041032
196
POL00053849
Attendance note from Jarnail Singh for Seema
Misra dated 27/01/10.
POL-0050328
197
POL00053880
Seema Misra case study: Email from John
Longman to Phil Taylor, Jarnail A Singh, RE:
West Byfleet- Latest Defence Request for
Disclosure dated 29/01/10.
POL-0050359
198
POLO0093865
Draft Audit Report for West Byfleet Post Office
(FAD 126023) by Alan Stuart (Seema Misra
case study) and an email from John Longman to
Warwick Tatford and Jarnail Singh re training
POL-0093987
199
UKGI00014903
Seema Misra case study: Court Attendance
Note from Jarnail Singh re Seema Misra for
Mention dated 01/02/10, updated 03/02/2010
UKGI025696-001
200
POL00053938
Email chain from Warwick Tatford to Jarnail
Singh; John Longman; Mandy Talbot; Craig
Thompson and others, re: Mrs. Nixon.
POL-0050417
201
POL00053954
Letter from J McFarlane to the Clerk of Warwick
Tatford Re Regina v Seema Misra
POL-0050433
11
202
POL00114272
Email from Jarnail A Singh to David Jones re:
Regina v Seema Misra trial- 15th March 2010
WITNO4750100
WITNO04750100
POL-0113199
203
UKGI00014895
Seema Misra case study: Email from Issy Hogg
Coombe Rich Solicitors to Jarnail Singh re:
Seema Misra Guildford Crown Court mention
1st February 2010
UKGI025688-001
204
POL00054010
Email from Issy Hogg to Jarnail Singh RE: FW:
R v Seema Misra Guildford Crown Court Trial
15th March 2010 - disclosure
POL-0050489
205
POL00054185
Memorandum from Jarnail Singh to Issy Hogg,
re: Regina v Seema Misra, Guildford Crown
Court, Trial - 15th March 2010.
POL-0050664
206
POL00054254
Email from John Longman to Thomas Penny,
Mark Dinsdale and Jarnail Singh re: West
Byfleet
POL-0050733
207
POL00054248
Memo from Issy Hogg to Jarnail A Singh re.
Regina v Seema Misra Guildford Crown Court
Trial - 15th March 2010 regarding disclosure
and application to stay count 1
POL-0050727
208
POL00054335
Email from Warwick Tatford to Jarnail Singh,
RE: R v. Misra - skeleton argument on abuse of
process
POL-0050814
209
POL00045565
Regina Misra attendance note for the case listed
on 7/5/2010
POL-0042044
210
POL00055217
Seema Misra case study: Schedule of Non-
Sensitive Unused Material - R v Seema MISRA
POL-0051696
211
POL00055236
Seema Misra case study - Letter from Rob G
Wilson to Miss Issy Hogg, Re: Regina v Seema
Misra, enclosing updated schedule of non-
sensitive unused material
POL-0051715
212
POL00055421
Email from Warwick Tatford to Jarnail A Singh
re: Seema Misra - Disclosure
POL-0051900
213
POL00054275
Notification of Fixture of Hearing re abuse of
process application at Guildford Crown Court on
10th March 2010 - Seema Misra
POL-0050754
214
POL00054346
Seema Misra Case Study: Response to Defence
Abuse Skeleton by Warwick Tatford - (R v
Seema Misra)
POL-0050825
215
POL00054430
Memo from Jarnail A Singh to Mandy Talbot re.
Fw: West Byfleet Trial - 15th March 2010 -
Guildford Crown Court
POL-0050909
216
UKGI00014994
Seema Misra case study: Record of
proceedings in the matter between Regina and
Seema Misra in the Guilford Crown Court
(120090070) on 11/10/2020 (Day 1)
UKGI025787-001
217
UKG100014845
Regina v Seema Misra, before his Honour
Judge N.A.Stewart proceedings on Monday 18th
October 2010 day 6
UKGI025638-001
12
218
POL00093689
Exhibit SM3 for R v Seema Misra Case at
Guildford Crown Court. Expert report on
Horizon.
WITNO04750100
WITNO04750100
POL-0093811
219
POL00094101
Final version of the 2nd Interim Technical
Expert's Report
POL-0094223
220
POL00053930
Email from Jon Longman to Warwick Tatford
and Jarnail Singh, RE: Fw West Byfleet dated
01/02/10.
POL-0050409
221
POL00053937
Witness Statement of Gareth Idris Jenkins
(signed) - comments on 2nd Interim Technical
expert's report (Seema Misra case study)
POL-0050416
222
POL00053992
Third Interim Technical Expert's Report to the
Court prepared by Charles McLachlan regarding
Seema Misra
POL-0050471
223
POL00054085
Email from Mark Dinsdale to Post Office
Security, FW: West Byfleet Issues - email chain
with POL and Fujitsu regarding info for expert
witness report
POL-0050564
224
FUJ00122804
Email from David Jones to Jarnail Singh, Jane
Owen and cc Penny Thomas re: FW: Requests
for access re: Jerry Kwami Hosi - Legally
privileged
POINQ0129018F
225
FUJ00122729
Email from Marilyn Benjamin (signed off as
Jarnail Singh) to David M Jones re West Byfleet
Issues- Seema Misra
POINQ0128943F
226
FUJ00122808
Email from Gareth Jenkins to Jarnail Singh; re:
R v Seema Misra Guildford Crown Court Trial-
15th March 2010
POINQ0129022F
227
POL00054095
Email from Jarnail Singh to Issy Hogg RE: Rv
Seema Misra Guildford Crown Court Trial- 15th
March 2010
POL-0050574
228
POL00054183
Memo from Jarnail A Singh to Gareth Jenkins
re. Regina v Seema Misra Guildford Crown
Court Trial - 15th March 2010
POL-0050662
229
POL00054198
Memo from Marilyn Benjamin to John Longman
and Warwick Tatford re. Fw: Regina v Seems
Misra Guildford Crown Court Trial - 15th March
2010.
POL-0050677
230
POL00058450
Notice on The Queen v Seema Misra with List of
Witness.
POL-0054929
231
POL00054220
Email from Marilyn Benjamin to Jarnail Singh re:
REGINA v SEEMA MISRA GUILDFORD
CROWN COURT TRIAL - 15TH MARCH 2010
POL-0050699
232
POL00054252
Seema Misra case study: Email from Gareth
Jenkins to Jarnail A Singh re. Regina v Seema
Misra Guildford Crown Court Trial - 15th March
2010
POL-0050731
13
233
POL00054267
Memo from Jarnail A Singh to Gareth Jenkins
re. Regina v Seema Misra Guildford Crown
Court Trial - 15th March 2010
WITNO04750100
WITNO04750100
POL-0050746
234
POL00054126
4th Interim Technical expert’s report to the Court
re Seema Misra prepared by Charles Alastair
McLachlan, a Director of Amsphere Consulting
Ltd.
POL-0050605
235
POL00054257
5th Interim Technical expert’s report to the Court
prepared by Charles Alastair McLachlan, a
Director of Amsphere Consulting Ltd re Seema
Misra.
POL-0050736
236
POL00054250
Email from Jarnail A Singh to Post Office
Security, copied to John Longman and Warwick
Tatford re. Regina v Seema Misra enclosing
expert reports
POL-0050729
237
POL00054282
Memorandum from Jarnail Singh to Thomas
Penny re Seema Misra Guildford Crown Court
trial 15th March 2010 - West Byfleet.
POL-0050761
238
POL00054311
Email from Penny Thomas to Jarnail Singh and
Jon Longman re: REGINA v SEEMA MISRA
GUILDFORD CROWN COURT TRIAL 15TH
MARCH 2010
POL-0050790
239
POL00001643
Witness statement of Gareth Jenkins
VIS00002657
240
POL00058440
Notice of Further Evidence bundle of documents
re: R v Seema Misra
POL-0054919
241
FUJ00122906
Witness statement of Gareth Idris Jenkins; Re:
Seema Misra
POINQ0129120F
242
POL00055018
Email from Issy Hogg Coombe Rich Solicitors to
Marilyn Benjamin re Seema Misra Guildford
Crown Court.
POL-0051497
243
POLO0055059
Email from Issy Hogg to Jarnail Singh re Seema
Misra - request for information on reproducible
errors, reconciliation and transaction
corrections, known error logs etc.
POL-0051538
244
POL00055100
Emails between John Longman, Jarnail A Singh
and others, re. Regina V Seema Misra - Guilford
Crown Court - Trial
POL-0051579
245
POL00055150
Email from John Longman to Jarnail A Singh,
Re: West Byfleet-Misra
POL-0051629
246
POL00055146
Letter from Jamail Singh to Jon Longman, Re:
Regina v Seema Misra Guildford Crown Court
Trial Case No: POLTD/07/08/0249
POL-0051625
247
POL00055356
Email from Marilyn Benjamin to John Longman,
Re: Draft of Final Report re:Misra
POL-0051835
248
FUJ00083736
Technical expert's report to the Court prepared
by Charles Alastair McLachlan, a Director of
Amsphere Consulting Ltd
POINQ0089907F
14
249
UKGI00015008
Email from Gareth Jenkins to Warwick Talford,
Jarnail A Singh and John Longman re: Draft
Witness Statement
WITNO04750100
WITNO04750100
UKGI025801-001
250
FUJ00123031
Email thread between Gareth Jenkins and
Warwick Tatford (Jarnail Singh cc'ed) re draft
witness statement
POINQ0129245F
251
FUJ00123050
Email from Gareth Idris Jenkins to Jarnail A
Singh, Warwick Tatford, John Longman and
others re. Witness statement V0.3
POINQ0129264F
252
POL00110275
Witness Statement of Gareth Idris Jenkins
Version 3.0 11/02
POL-0108082
253
POL00030298
Addendum to Technical expert's report to the
Court prepared by Charles Alastair McLachlan,
Director of Amsphere Consulting Ltd.
POL-0026780
254
POL00001882
Joint statement to the Court prepared by Gareth
Jenkins of Fujitsu Ltd and Charles McLachlan, a
Director of Amsphere Consulting Ltd.
VIS00002896
255
POL00029406
Tape transcript of R v Seema Misra Trial in
Guildford Crown Court, 14 October 2010 -
Evidence of Gareth Jenkins
POL-0025888
256
POL00001856
Transcript of Proceedings Day 5 In the Crown
Court at Guilford Before His Honour Judge N. A.
Stewart for Regina v Seema Misra.
VIS00002870
257
POL00065708
Judgment re: HIS HONOUR JUDGE N.A
STEWARD REGINA -v- SEEMA MISRA
19/10/2010.
POL-0062187
258
FUJ00122723
Email from David M Jones to Roger Williams
and David Roberts re West Byfleet Issues-
Seema Misra
POINQ0128937F
259
UKGI00014898
Seema Misra case study: Email from Jarnail A
Singh, Andrew Winn, Marilyn Benjamin and
others re:
UKGI025691-001
260
POL00028838
Responsive Notes (Receipts/Payments
Mismatch issue)
POL-0025320
261
POL00055418
Email exchange between Mandy Talbot, Jarnail
Singh, Rod Ismay and Mike Granville
POL-0051897
262
POL00055590
Email from Marilyn Benjamin on behalf of Jarnail
A Singh to Mandy Talbot, Hugh Flemington,
Jacqueline Whitham, Re: Regina v Seema
Misra-Guildford Crown Court-Trial-Attack on
Horizon
POL-0052069
263
POL00055759
Memo from Jamail Singh to John Longman Paul
Southin, Graham Ward, Re: Regina v Seema
Misra Case No: POLTD/0708/0249
POL-0052238
264
POL00045051
R v Seema Misra - Provision of Financial
Information (s18 Proceeds of Crime Act 2002)
POL-0041530
15
265
POL00094048
Telephone note for Jarnail Singh and Phil Taylor
re Seema Misra. Written by Marilyn Benjamin.
WITNO04750100
WITNO04750100
POL-0094170
266
POL00031352
Email from Jarnail A Singh to Hugh Flemington,
Alwen Lyons, Simon Baker, Re: Discuss of
defect in horizon in court Seema Misra and Lee
Castleton
POL-0028254
267
POLO0060974
Email from Jarnail Singh to Chris Aujard re 2nd
sight and QC - lessons to be learned from Misra
case - POL criminal lawyer offers insight after
Misra trial and expresses doubt about Second
Sight inquiry due to the ease of SPM in making
accusations against Horizon.
POL-0057453
268
POL00055918
Audit of Howey PO from Judy Balderson to Mr C
Burston
POL-0052397
269
POL00056387
Joan Bailey - Record of Taped Interview, Date
of Interview: 9.3.11, Time commenced: 12.32,
Time concluded: 13.12
POL-0052866
270
POL00056388
Joan Bailey - Record of Taped Interview, Time
commenced: 13.14, Time concluded: 13.57
POL-0052867
271
POLO0056389
Joan Bailey - Record of Taped Interview, Time
commenced: 14.00, Time concluded: 14.23
POL-0052868
272
POLO0056365
Post Office - Record of Forms / exhibits shown
at Interview - Joan Bailey
POL-0052844
273
POL00057198
Post Office Ltd investigation report for Joan
Bailey, POLTD/1011/0164 - Offence(s)
POL-0053677
274
POL00056390
Memo from Maureen Moors to Royal Mail Group
Criminal Law Team re: Fraud - Joan Bailey -
Recommending prosecution be pursued
POL-0052869
275
POL00056477
Memo from Jarnail Singh to Post Office Security
re: Post Office Limited v Joan Francis Bailey
POL-0052956
276
POLO0056547
Memo from Jarnail Singh, Senior Lawyer to Post
Office Security re: ROYAL MAIL GROUP
LIMITED v JOAN FRANCIS BAILEY
POL-0053026
277
POL00057282
Letter from Steve Bradshaw to Colin Burston,
RE: Case closure- Suspects Name- Joan
Francis Bailey- Branch- Howey- Branch Code-
158 644
POL-0053761
278
POL00061539
Joan Bailey case study - Royal Mail Group
Caution form - Joan Francis Bailey
POL-0058018
279
POL00057285
Joan Bailey case study: case file event log,
Howey Post Office
POL-0053764
280
POL00046065
Statement for Rowlands Castle - Lynette
Hutchings
POL-0042544
281
POL00056292
Audit Report of Rowlands Castle Post Office
2011
POL-0052771
16
WITNO04750100
WITNO04750100
282 I POLO0056417 Lynette Hutchings Case Study : Record of POL-0052896
Taped Interview of Lynette Hutchings dated
20/04/2011
283 I POL00044505 Record of Taped Interview with Lynette POL-0040984
Hutchings
284 I POL00046625 Transcript: Record of taped interview re Lynette I POL-0043104
Hutchings dated 20/04/2011.
285 I POLO0046706 Investigation report by Graham Brander - POL-0043185
Subpostmaster Lynette Jane Hutchings.
286 I POL00046626 Memo from Jarnail Singh to Maureen Moors and I POL-0043105
Graham Brander in re to Post office LTD v
Lynette Jane Hutchings
287 I POL00046628 Memo from Graham Brander to Jarnail Singh in I POL-0043107
re to Ms Hutchings.
288 I POL00057362 Lynette Hutchings Case Study: POL v Lynette POL-0053841
Jane Hutchings - Advice
289 I POLO0057468 Lynette Hutchings case study: Summons to POL-0053947
Portsmouth Magistrates Court - Lynette Jane
Hutchings
290 I POL00057796 Letter from Cartwright King to Messrs. Coomber I POL-0054275
Rich re: Post Office Ltd v Lynette Jane
Hutchings (Portsmouth Magistrates Court on
06/06/2012)
291 I POLO0057751 Investigation Schedule non-sensitive - Lynette POL-0054230
Jane Hutchings
292 I POLO0046099 List of witnesses in re to queen v Lynette POL-0042578
Hutchings - version April 2012
293 I POL00057026 Witness Statement of Nigel ALLEN in case of POL-0053505
Lynette Hutchings
294 I POL00044533 Witness Statement - Nigel Allen V.8 POL-0041012
295 I POLO0056955 Lynette Hutchings case study: Witness POL-0053434
statement of Adam Shaw
296 I POL00046120 Witness Statement of Adam Shaw POL-0042599
297 I POLO0056987 Witness statement of Sarah Juliff re: Lynette POL-0053466
Hutchings.
298 I POLO0057245 Lynette Hutchings case study: Witness POL-0053724
Statement of Louise Sheridan
299 I POL00044534 Witness Statement - Louise Sheridan POL-0041013
300 I POL00054806 Incident Log Table in re to Lynette Hutchings POL-0051285
from 01/06/2010 to 05/04/2011
301 I POLOO056659 Witness statement of Andrew Dunks of Fujistu POL-0053138
Services (signed) re Horizon helpdesk calls from
Rowlands Castle Post Office (Lynette Hutchings
case study)
302 I POL00046047 APD01 - Report in to Post master help desk POL-0042526
2010 - 2011
303 I POL00057001 Royal Mail Group witness statement for David POL-0053480
Dixon
17
WITNO04750100
WITNO04750100
304 I POL00056742 Witness Statement for Gary Thomas, Post POL-0053221
Office Ltd
305 I POL00057267 Witness Statement of Graham Brander (Lynette I POL-0053746
Hutchings case study)
306 I POL00044535 Witness Statement - Graham Brander POL-0041014
307 I POL00046100 List of exhibits in re to Lynette Jane Hutchings - I POL-0042579
version 09/07
308 I POL00046095 Handwritten note on Regina v Lynette Jane POL-0042574
Hutchings
309 I POLO0046096 Handwritten notes on Regina v Lynette Jane POL-0042575
Hutchings: basis of plea
310 I POL00058132 Lynette Hutchings case study: Court attendance I POL-0054611
note of William Martin Counsel for Claimant
311 I POL00058252 Email from Rachael Panter to Steve Bradshaw I POL-0054731
re: Counsel's note of outcome in Lynette
Hutchings case
312 I POL00058153 Lynette Hutchings case study: Email from Martin I POL-0054632
Smith to Stephen Bradshaw re attendance note
for Lynette Hutchings case and costs
313 I POL00089273 Email from Rachel Panter to Jarnail A Singh re POL-0086248
Various
314 I POL00089081 Branch Audit Report of Winsford Post Office POL-0086056
(217401) - Identifying Mark: RC2
315 I POLO0089670 POST OFFICE LTD Record of Taped Interview I POL-0086645
of Mr Grant lan Allen
316 I POLO0089671 POST OFFICE LTD- CONFIDENTIAL Record POL-0086646
of Taped Interview of Mr Grant lan Allen
317 I POL00089426 Post Office Ltd: Legal Investigation - Offences POL-0086401
report
318 I POL00089294 Email from Andrew Bolc to Post Office Security, I POL-0086269
Jamail Singh, Steve Bradshaw and others re
Grant lan ALLEN - Winsford PO POL 1112/0228
319 I POLO0089454 Letter from Andrew Bloc to Post Office Limited POL-0086429
Security Team re: POL v Grant lan Allen Case
POLTD/1112/0228
320 I POL00089057 Post Office Limited Regina v Grant lan Allen - POL-0086032
Charging Advice
321 I POLO0089455 Proposed Charge - (Post Office Ltd v Grant lan I POL-0086430
Allen)
322 I POLO0089562 Summary of facts - Post office Limited v Grant POL-0086537
lan Allen
323 I POL00089072 Magistrates Court (Code 1188) - Court POL-0086047
correspondence
324 I POLO0089560 Post Office Limited - Witness Statement of POL-0086535
Stephen Bradshaw
18
325
POL00089561
Post Office Limited - Witness Statement of
Richard Cross and Andrew Wise
WITNO04750100
WITNO04750100
POL-0086536
326
POL00089477
Letter from Stephen Bradshaw to Legal Services
(For the attention of Jarnail Singh) Re Mr Grant
Allen.
POL-0086452
327
POL00089329
Email from Steve Bradshaw to Post Office
Security, cc'd Jarnail A Singh RE: Serving of
Summons - POLTD/1112/0228 - Defendants
Name - Grant lan Allen
POL-0086304
328
POL00089061
Letter from Stephen Bradshaw to Andrew Bolc
re R v Grant lan Allen
POL-0086036
329
POL00089346
Post Office Ltd - List of Witnesses in R v Grant
lan Allen
POL-0086321
330
POL00089351
Post Office Ltd, List of Exhibits in R v Grant lan
Allen
POL-0086326
331
POL00089050
Email from Victoria Brooks to Martin Smith,
Alexandra Ward and others re: M109 - draft
POIR CK amended Contains wording of criminal
charge against Grant Allen.
POL-0086025
332
POL00089348
Post Office Ltd, Schedule of Non-Sensitive
Unused Material in R v Grant lan Allen
POL-0086323
333
POL00089376
Letter from Andrew Bolc to Martin Bloor, RE: R v
Grant Allen
POL-0086351
334
POL00089374
Email chain from Jarnail A Singh to Rachael
Panter, Andy Cash, Martin Smith RE: POL
cases raising Horizon
POL-0086349
335
POL00058016
Email from Andy Cash to All Prosecution;
Rachael Panter; Andrew Bolc; Martin Smith, re:
Horizon Integrity Report.
POL-0054495
336
POL00089378
Email from Andrew Bolc to Gareth Jenkins, RE:
Post Office Ltd v Grant Allen
POL-0086353
337
POL00089380
Email chain from Gareth Jenkins to Steve
Bradshaw, RE: FW: Post Office Limited v Grant
Allen.
POL-0086355
338
POL00089388
Letter from Andrew Bolc (Cartwright King) to the
Chief Clerk Chester Crown Court re: Regina v
Grant lan Allen
POL-0086363
339
POL00089063
Crown Court Chester - Court correspondence
(Grant lan Allen)
POL-0086038
340
FUJ00124200
Witness statement of Gareth Jenkins.
POINQ0130414F
341
FUJ00080526
Fujitsu Report: Horizon Data Integrity v1.0
POINQ0086697F
342
POL00031801
Fujitsu Horizon Online Data Integrity Ver 4.1
POL-0028703
343
POL00089390
Email from Mark Dinsdale to Thomas Penny and
Jayne Bradbury re: POL cases raising Horizon -
Time Booking PO number
POL-0086365
344
POL00089401
Email from Gareth Jenkins to Rachael Panter,
Jarnail Singh, Martin Smith and others re:
Various POL cases related to Horizon
POL-0086376
19
345
POL00089427
Email chain from Jarnail Singh to Gareth
Jenkins, Rachael Panter, Andy Cash, and
others re: Horizon cases.
WITNO04750100
WITNO04750100
POL-0086402
346
POL00089416
Email from Fernando Rodrigues to John Gibson
re: Grant Allen - 24/01/2013 Chester Crown
Court. Guilty plea offered on a basis.
POL-0086391
347
POL00089422
Email from Andrew Bolc to Jarnail Singh and
Steve Bradshaw re: Grant lan Allen POLTD /
1112 / 0228
POL-0086397
348
POL00089423
Grant lan Allen Final Result/Sentencing Sheet
POL-0086398
349
POL00089065
Post office - A letter from S Bradshaw, re Gran
lan Allen
POL-0086040
350
RLIT0000039
Richard Hawkes & Ors v Post Office Limited
[2022] EWCA Crim 1197
RLITO000039
351
POL00044159
Email from Paul X Williams to Tim Gordon-
Pounder re audit of Fazakerley Branch (Code
214420).
POL-0040638
352
POL00044010
Interview record - Angela Sefton interviewed by
Stephen Bradshaw
POL-0040489
353
POL00057435
Angela Sefton case study: Record of Taped
Interview — Angela Sefton
POL-0053914
354
POL00057389
Royal Mail Group, Record of Taped Interview
Anne Nield
POL-0053868
355
POL00043958
Angela Sefton and Anne Nield case study -
statement signed by Angela Sefton and Anne
Nield SB145
POL-0040437
356
POL00044198
Angela Sefton and Anne Nield case study: List
of Offences Report by Stephen Bradshaw re:
Fazakerley Branch
POL-0040677
357
POL00044013
Internal Memo from Maureen Moors (POL Fraud
Team) to RMG Criminal Law Team re
Fazakerley Branch - Prosecution recommended
(Sefton and Nield case study)
POL-0040492
358
POL00057495
Angela Sefton and Ann Nield Case Study: Letter
from Andrew Bolc to Post Office Ltd, RE: POL v
Angela Marty Sefton and Anne Nield
POL-0053974
359
POL00044030
Magistrates Court Summons for Angela Mary
Sefton
POL-0040509
360
POL00044033
Summons letter (Magistrates Court 2267)
addressed to Ms Anne Nield.
POL-0040512
361
POL00058146
Criminal Form List for week commencing
06/08/2012
POL-0054625
362
POL00059525
List of Witnesses - Post Office The Queen v
Anne Nield POLO09 Version April
POL-0056004
363
POL00059663
Post Office, List of Exhibits, The Queen v
Angela Mary Sefton
POL-0056142
364
POL00058291
Post Office Ltd, List of Witnesses CROWN v
ANNE NIELD
POL-0054770
365
POL00059664
CROWN v ANNE NIELD, POL List of Exhibits
POL-0056143
20
WITNO04750100
WITNO04750100
366 I POL00044028 Witness Statement of Kevin Ryan - Fazakerley POL-0040507
Branch.
367 I POL00044027 Witness Statement of Stephen Bradshaw - POL-0040506
Fazakerley Branch
368 I POL00058307 Witness Statement of Stephen Bradshaw POL-0054786
(signed) - Ann Nield / Angela Sefton case
369 I POL00057824 Witness statement of Ali Askar re Angela Sefton I POL-0054303
and Ann Nield
370 I POL00043965 Court Order allowing further evidence in case of I POL-0040444
R v Angela Mary Sefton & Anne Nield
720120934 - sent to Defendant's solicitors
371 I POL00044047 Unsigned Witness statement of Stephen POL-0040526
Bradshaw - Fazakerley Branch.
372 I POLO0044160 Extract of NBSC Call Log from Fazakerley POL-0040639
branch
373 I POL00044037 Witness Statement of Frances Ann Ellis POL-0040516
374 I POL00044038 Witness Statement of Christopher William Dixon I POL-0040517
375 I POL00059459 Witness Statement of Tim Gordon-Pounder Post I POL-0055938
Office Ltd re Angela Sefton and Ann Nield case
studies
376 I POL00060275 Witness Statement of Stephen Bradshaw - POL-0056754
Fazakerley Post Office — Nield & Sefton
377 I POL00044206 Letter from Hogan Brown Solicitors to Mr S POL-0040685
Bradshaw, Re Post office v Mrs Angela Sefton.
378 I POL00057809 Anne Nield case study: Disclosure Officer's POL-0054288
report
379 I POL00057812 Investigation Schedule, Schedule of non POL-0054291
sensitive Unused material - Anne Nield
380 I POLO0057810 Schedule of sensitive material - Anne Nield POL-0054289
381 I POL00057876 Angela Sefton case study: Schedule of non POL-0054355
sensitive unused material- investigation
commencement date form - R v Angela Mary
Sefton
382 I POL00057936 Schedule of Sensitive Material re: Angela Mary I POL-0054415
Sefton
383 I POLO0057350 Schedule of Non Sensitive Unused Material, R v I POL-0053829
Anne Nield
384 I POL00057944 Schedule of non-sensitive unused material- Rv I POL-0054423
Angela Mary Sefton
385 I POL00057949 Schedule of non sensitive unused material, R v POL-0054428
Angela Mary Sefton
386 I POL00044036 Defence Statement re Angela Mary Sefton -Rv I POL-0040515
Angela Mary Sefton
387 I POL00044042 Regina v Anne Nield Defence Statement POL-0040521
388 I POLO0058155 Email from Jarnail A Singh to Hugh Flemington, I POL-0054634
Susan Crichton and Alwen Lyon re: 2nd Sight
Review draft
21
389
POL00058115
Email from Jarnail A Singh to Simon Baker;
Hugh Flemington, re: Horizon Challenge.
WITNO04750100
WITNO04750100
POL-0054594
390
POL00058303
Email chain from Jarnail A Singh to Hugh
Flemington re: FW: R v Sefton & Nield Liverpool
Crown Court 17th October 2012
POL-0054782
391
POL00058306
Letter from Andrew Bale to Laurence Lee & Co
re: R v Anne Nield & another, Liverpool Grown
Court regarding appointment of second sight.
POL-0054785
392
POL00058311
Letter from Jarnail A Singh to Andrew Bloc re:
Angela Sefton and Anne Nield - 24040 - Theft /
Fraud
POL-0054790
393
POL00059314
Letter from Hogan Brown Solicitors to Cartwright
King solicitors re: R v Angela Sefton - Disclosure
of reports
POL-0055793
394
POL00059313
Email from Rachael Paner to Jarnail A Singh re:
Insight 2
POL-0055792
395
POL00044023
Letter to Cartwright King Solicitors from Ms
Brigitte Waters (Laurence Lee & Co Solicitors)
regarding 'R v Anne Nield’, and asking for
documentation relating to an audit conducted in
2005.
POL-0040502
396
POL00059726
Angela Sefton and Ann Nield case studies:
Letter from Andrew Bole on behalf of Cartwright
King Solicitors to the representatives of Angela
Sefton and Anne Nield Re Material to disclose -
ongoing disclosure.
POL-0056205
397
POL00044020
Letter from Mr Andrew Bolc to Mr Steve
Bradshaw regarding 'R v Sefton & Nield' and
preparation for court documents.
POL-0040499
398
POL00059750
Schedule of Non-Sensitive Unused Material -
Anne Nield
POL-0056229
399
POL00059752
Schedule of non-sensitive unused material -
Angela Sefton investigation Version April 2012.
POL-0056231
400
POL00044022
Cover letter from Mr Andrew Bolc to Mr Stephen
Bradshaw in 'R v Sefton & Nield' regarding an
audit conducted in 2005.
POL-0040501
401
POL00044219
Letter from Hogan Brown Solicitors to Cartwright
King Solicitors Re Future hearing of Mrs Angela
Sefton, request for evidence.
POL-0040698
402
POL00044218
Letter from Laurence Lee & Co Solicitors to
Catwright King ISolicitors Re Regina v Anne
Neild
POL-0040697
403
POL00044221
Prosecution Certificate of readiness from Judge
Watson QC for R v Anne Nield& Angela Sefton.
POL-0040700
22
404
POL00044217
Letter from Mr Andrew Bolc (Cartwright King
Solicitors) to John Gibson regarding 'R v Angela
Sefton & Anne Nield’, enclosing letters from the
defence.
WITNO04750100
WITNO04750100
POL-0040696
405
POL00060277
Letter to Hogan Brown Solicitors from Andrew
Bolc re. Letter to Defence where there is
material to disclose - ongoing disclosure
(defence case statement) R v Angela Sefton &
another
POL-0056756
406
POL00060279
Ann Nield case study: Letter to Laurence Lee &
Co to Andrew Bolc re. Letter to defence where
there is material to disclose - ongoing disclosure
(defence case statement) R v Anne Nield &
another Court and Next Hearing Date: Liverpool
Crown Court - w/e 15/04.2013
POL-0056758
407
POL00066798
Angela Sefton Case study. Letter from Simon
Clarke to Hogan Brown Solicitors re: Angela
Sefton outcome and potential grounds to appeal
POL-0063277
408
POL00066799
Ann Nield Case Study: Letter from Simon Clarke
to Laurence Lee& Co Solicitors Re Anne Nield
Liverpool Crown Court
POL-0063278
409
POL00058294
Letter from Laurence Lee & Co Solicitors to Miss
Waters re: Regina v Anne Neild
POL-0054773
410
POL00059421
Email from Andrew Bolc to Jarnail A Singh re:
Sefton and Niled poltd/1112/0203, Alen
poltd/1112/0228
POL-0055900
411
POL00089394
Email from Gareth Jenkins to Andrew Bolc, re:
Sefton & Nield
POL-0086369
412
POL00044019
Notice of further evidence - R v Anne Nield &
Angela Sefton
POL-0040498
413
POL00059424
Witness Statement of Gareth Idris Jenkins
POL-0055903
414
POL00044163
Horizon Data Integrity - This document
describes the measures that are built into
Horizon to ensure data integrity
POL-0040642
415
POL00044164
Horizon Data Integrity for POL - This document
describes the measures that are built into
Horizon to ensure data integrity
POL-0040643
416
POL00044050
Case Report - Opening for Regina v Angela
Sefton and Anne Neild - In the Crown Court at
Liverpool
POL-0040529
417
POL00043964
Angela Sefton and Anne Neild case studies:
Agreed Facts for R v Angela Sefton and Anne
Neild (120120934)
POL-0040443
418
POL00044024
Report outlining Anne Nield and Angela Sefton's
prosecutions - Fazakerley Branch - Enquiry
Reference POLTD/1112/0208
POL-0040503
23
WITNO04750100
WITNO04750100
419 I POL00113343 Roger Allen & ors v. Post Office Limited and POL-0110721
Crown Prosecution Service [2021] EWCA Crim
1874 - Approved Judgment.
420 I POL00029169 ICL Pathway Conducting Audit Data Extractions I POL-0025651
at CSR Process (v1)
421 I FUJ00152176 Conducting Audit Data Extractions at Live - ICL I POINQ0158370F
Pathway Ltd - v2.0
422 I FUJ00152212 Management of the Litigation Support Service - I POINQ0158406F
Fujitsu v1.0
423 I FUJ00152220 Management of the Litigation Support Service, POINQ0158414F
Fujitsu v1.1
424 I FUJ00152225 Management of the Litigation Support Service - I POINQ0158419F
v2.0
425 I FUJ00152235 Management of the Litigation Support Service POINQ0158429F
v2.0
426 I FUJ00152216 Audit Data Extraction Process - Fujitsu v0.2 POINQ0158410F
Draft
427 I FUJ00152218 Audit Data Extraction Process, Fujitsu v1.0 POINQ0158412F
428 I FUJ00152221 Audit Data Extraction Process - v1.1 POINQ0158415F
429 I FUJ00152226 Audit Data Extraction Process - v2.1 POINQ0158420F
430 I FUJ00152228 Audit Data Extraction Process - v3.0 POINQ0158422F
431 I FUJ00002033 Fujitsu Services Security Management Service: I POINQ0008204F
Service Description. Version 1.0
432 I FUJ00080107 Fujitsu's Guidance on Security management POINQ0086278F
service: Service Description (v.2)
433 I FUJ00002264 Fujitsu and Post Office Document re: Security POINQ0008435F
Management Service: Service Description v3
434 I FUJO0088868 Fujitsu/Post Office Security Management POINQ0095039F
Service: Service Description (v3.5)
435 I FUJ00002555 Fujitsu Security Management Service: Service POINQ0008726F
Description, HNG-X and HNG-X Application Roll
Out Transitional Period, Version 4.0.
436 I POL00002572 Fujitsu Security Management Service: Service VIS00003586
Description v 5.0
437 I POLO0002666 Fujitsu/Post Office Fujitsu Services Security VIS00003680
management service: service description
438 I FUJ00122903 Email from Penny Thomas to Tom Lillywhite, POINQ0129117F
Gareth Jenkins and Guy Wilkerson re: FW:
Duplication of Transaction Records in ARQ
Returns.
439 I FUJ00122980 Email from Penny Thomas to Gareth Jenkins, POINQ0129194F
Juliet Mcfarlane, Mark Dinsdale and others re:
Duplication of Transaction Records in ARQ
Returns
24
440
POL00119134
Memo from J S Andrews (Royal Mail) to Post
Office Security cc Gary Thomas, Graham Ward
Re: REGINA v JULIAN WILSON WORCESTER
CROWN COURT CONFISCATION HEARING —
W/L W/C 16TH NOVEMBER 2009 CASE NO:
POLTD/0809/0126
WITNO04750100
WITNO04750100
POL-0119053
441
POL00119126
Criminal case study of Julian Wilson: Memo
from Miss Jennifer Andrews (Royal mail) to Post
office Security Cc: Gary Thomas, Press Office
Re: REGINA v JULIAN WILSON CASE NO:
POLTD/0809/0126
POL-0119045
442
POL00119206
Memo from Jarnail Singh to Post Office Security
re: R v Julian Wilson - Final Confiscation Order
POL-0119125
443
FUJ00152922
Crim Case Study of Seema Misra-Email chain
from Hugh Flemington to David Jones, Penny
Thomas, Guy Wilkerson and others Re: West
Byfleet Issues
POINQ0159117F
444
FUJ00152928
Crim Case Study of Seema Misra: Email chain
from Penny Thomas to David Jones, CC Tom
Lillywhite and David Keeling Re: West Byfleet
Issues
POINQ0159123F
445
FUJ00152935
Email from Jarnail Singh to David Jones re:
West Byfleet Issues - Seema Misra
POINQ0159130F
446
FUJ00152936
Email from Benjamin Marilyn to David Jones re:
West Byfleet Issues - Seema Misra
POINQ0159131F
447
FUJ00152937
Email from Benjamin Marilyn to David Jones re:
West Byfleet Issues - Seema Misra
POINQ0159132F
448
FUJ00152938
Email from Jarnail Singh to David Jones re:
West Byfleet Issues - Seema Misra - Legally
Privileged
POINQ0159133F
449
FUJ00152943
Email from Marilyn Benjamin (on behalf of
Jarnail Singh) to David Jones re: Regina v
Seema Misra Guildford Crown Court Trial - 15th
March 2010
POINQ0159138F
450
FUJ00152948
Email from Gareth Jenkins to David Jones re:
Regina v Seema Misra Guildford Crown Court
Trial - 15th MArch 2010
POINQ0159143F
451
FUJ00152950
Email from David Jones to Jarnail Singh re:
Regina v Seema Misra Guildford Crown Court
Trial 15th March 2010
POINQ0159145F
452
FUJ00152954
Email from David Jones to Jarnail Singh, Gareth
Jenkins, Thomas Penny and others re: West
Byfleet Issues - Seema Misra - Legally
Privileged
POINQ0159149F
453
FUJ00152964
Email from David Jones to Jarnail Singh re :FW:
Regina v Seema Misra Guildford Crown Court
Trial - 15th March 2010
POINQ0159159F
25
454
FUJ00152966
Email from Roger Williams to David Jones and
David Roberts re West Byfleet issues, Seema
Misra.
WITNO04750100
WITNO04750100
POINQ0159161F
455
FUJ00152993
Email chain from Penny Thomas to Jarnail
Singh, cc Suzie Kirkham, Tom Lilywhite, David
Gray and others Re: FW: Regina v Seema Misra
- Guildford Crown Court Trial - 15th March 2010
POINQ0159188F
456
FUJ00153005
Criminal Case Study: Seema Misra - Email from
John Longman to Penny Thomas, Mark
Dinsdale and Jarnail A Singh re West Byfleet -
126023
POINQ0159200F
457
FUJ00153014
Email from David Jones to Jarnail Singh cc
Penney Thomas and Gareth Jenkins re: FW:
Regina v Seema Misra Guildford Crown Court
Trial - 15th March 2010
POINQ0159209F
458
FUJ00157863
Seema Misra Case Study - Email from David
Jones to Marilyn Benjamin re: Regina v Seema
Misra - Guildford Crown Court - Trial - Thank
you email for Fujitsu’ contributions
POINQ0173630F
459
FUJ00153141
Email chain between Guy Wilkinson, Ken
Westfield, Penny Thomas and Gareth GI
Jenkins re: re: CT0875: Regina v Seema Misra -
Guildford Crown Court - Trial
POINQ0159336F
460
FUJ00152940
Email from Gareth Jenkins to David Jones and
Penny Thomas RE: WEST BYFLEET ISSUES -
SEEMA MISRA - Legally Privileged
POINQ0159135F
461
POL00054061
Seema Misra case study: Email from David M
Jones to David M Jones, RE: R v Seema Misra,
Guildford Crown Court Trial 15 March 2010
POL-0050540
462
FUJ00153382
Email from Warwick Tatford to Gareth Jenkins,
Jarnail Singh and others Re: Witness statement
V0.3
POINQ0159577F
463
FUJ00152958
Seema Misra case study: Email from Jarnail
Singh to David M Jones, Gareth Jenkins and
Penny Thomas RE: R v Seema Misra trial 15
March 2010 - urgent email requesting input from
Gareth Jenkins
POINQ0159153F
464
FUJ00152962
Email from Gareth Jenkins to Jarnail Singh re
REGINA v SEEMA MISRA GUILDFORD
CROWN COURT TRIAL - 15TH MARCH 2010
POINQ0159157F
465
FUJ00152985
Email from Jarnail Singh to Gareth Jenkins re
REGINA v SEEMA MISRA GUILDFORD
CROWN COURT TRIAL - 15TH MARCH 2010
POINQ0159180F
466
FUJ00152992
Seema Misra Case Study - Email chain from
Gareth Jenkins to Jarnail Singh re: REGINA v
SEEMA MISRA GUILDFORD CROWN COURT
TRIAL - 15TH MARCH 2010
POINQ0159187F
26
467
FUJ00153019
Email from Monica Thompson (on behalf of
Jarnail Singh) to Thomas Penny re R -v- Seema
Misra Guildford Crown Court - Trial - 15 March
2010 - West Byfleet Our Ref: CRM/258932/JSX
WITNO04750100
WITNO04750100
POINQ0159214F
468
FUJ00155189
Audit Record Query of West Byfleet (126033),
requesting a report of all transactions and
events for the office
POINQ0161384F
469
FUJ00153390
Seema Misra Case Study: Email from Gareth
Jenkins to Charles McLachlan re: Further info re
Calendar Square and PEAK Incident
Management System , Call Ref PC0126376
POINQ0159585F
470
POL00119318
Seema Misra Case study: Memo from Jarnail
Singh to Post Office Security (Jason Collins,
Paul Southin) re: Regina v Seema Misra,
Guildford Crown Court, Confiscation
Proceedings - 23 April 2012
POL-0119237
471
FUJ00154223
Email from Jarnail Singh to Gareth Jenkins re.
My Witness Statement for the MISRA case.
POINQ0160418F
472
FUJ00156640
Email from Simon Baker to Jarnail A Singh,
Gareth Jenkins and Pete Newsome Re:
URGENT EXPERT REPORT ON HORIZON
SYSTEM
POINQ0162834F
473
FUJ00155085
Email from Jarnail Singh to Gareth Jenkins and
Simon Baker Re: Horizon System
POINQ0161280F
474
FUJ00155090
Email from Penny Thomas to Peter Thompson,
Howard Pritchard, cc Pete Newsome and others
re: Horizon Fujitsu Report Very Urgent
POINQ0161285F
475
FUJ00155089
Tracker of Horizon Integrity Offices- re: progress
of litigation cases which challenge Horizon's
integrity
POINQ0161284F
476
FUJ00156648
Seema Misra Case Study: Horizon Integrity -
summary report prepared by Helen Rose, Post
Office Security Team
POINQ0162842F
477
POLO0096983
Email from Gareth Jenkins to Penny Thomas,
Hugh Flemington, Martin Smith and others, re
Horizon Fujitsu Report Very Urgent.
POL-0096566
478
FUJ00155093
Email chain from Jarnail Singh to Gareth
Jenkins re: Horizon Fujitsu Report - Very Urgent
- Horizon Online Integrity
POINQ0161288F
479
FUJ00123914
Fujitsu/Post Office Horizon Integrity report about
investigations into the integrity of the Horizon
system; V0.1a
POINQ0130128F
480
POL00107806
Gareth Jenkins Report on Horizon Integrity V0.2
POL-0106053
481
FUJ00153815
Email from Jarnail A Singh to Gareth Jenkins
RE: HORIZON FUJITSU REPORT VERY
URGENT
POINQ0160010F
27
482
POL00097007
Email from Martin Smith to Jarnail Singh and
Gareth Jenkins, CCing Sharron Jenkins and
others, re Horizon Fujitsu Report Very Urgent.
WITNO04750100
WITNO04750100
POL-0096590
483
FUJ00153819
Fujitsu /Post Office, Gareth Idris Jenkins
Horizon Integrity report V.0.2
POINQ0160014F
484
FUJ00153820
Systems Diagram
POINQ0160015F
485
FUJ00153821
Diagram of Horizon systems
POINQ0160016F
486
FUJ00124012
Email from Gareth Jenkins to Martin Smith,
Jarnail Singh and others re: Horizon Fujitsu
Report Very Urgent
POINQ0130226F
487
FUJ00124013
Signed Witness Statement of Gareth Jenkins
POINQ0130227F
488
FUJ00124014
Fujitsu Report: Horizon Data Integrity v1.0
POINQ0130228F
489
FUJ00124015
Horizon Online Data Integrity for Post Office Ltd
POINQ0130229F
490
FUJ00124016
(unsigned) Witness statement of Gareth
Jenkins, for Post Office Ltd.
POINQ0130230F
491
FUJ00124020
Fujitsu Horizon Online Data Integrity for Post
Office Ltd Draft Report for 2012, Version 0.1b
POINQ0130234F
492
FUJ00123982
Email from Sharron L Jennings to Martin Smith,
Gareth Jenkins and Jarnail Singh re Horizon
Fujitsu Report Very Urgent
POINQ0130196F
493
FUJ00123983
(unsigned) Witness statement of Gareth
Jenkins, for Post Office Ltd.
POINQ0130197F
494
POL00097061
Email from Sharron Jennings to Post Office
Security, Thomas Penny, Gareth Jenkins and
others re Patel - POLTD/1112/0107. Includes
discussion of Gareth Jenkins' witness evidence
in court cases.
POL-0096644
495
POL00097216
Email from Rachael Panter to Jenkins Gareth
Gl, Andy Cash, Jarnail A Singh and others RE:
Fujitsu expert report - URGENT
POL-0096799
496
POL00097218
Email from Jarnail A Singh to Jenkins Gareth Gl
RE: Fujitsu expert report - URGENT
POL-0096801
497
FUJ00124072
Witness Statement of Gareth Idris Jenkins - Kim
Wylie case
POINQ0130286F
498
POL00119452
Email from Martin Smith to Steve Bradshaw
cc'ing Jarnail Singh, Post Office Security and
others re: CASE NO 24676 - Prosecution of
Ishaq - Judgement
POL-0119371
499
POL00059808
Email chain between Rachael Potter and Barry
James Robson Re: Wylie - further requests for
disclosure
POL-0056287
500
FUJ00153967
Email chain from Rachael Panter to Gareth
Jenkins, Martin Smith and Jarnail Singh, re
Horizon cases - Ishaq Defence Case Statement
POINQ0160162F
501
POL00119434
Email thread from Jarnail A Singh to Martin
Smith, Steve Bradshaw and Post Office Security
RE: Post Office Ltd -24676 - Prosecution of
Ishaq
POL-0119353
28
WITNO04750100
WITNO04750100
502 I POLO0119381 Email from Martin Smith to Jarnail Singh cc POL-0119300
Steve Bradshaw, Helen Dickinson and others re:
Post Office Ltd - 24676 - Prosecution of Ishaq
503 I POLO0119407 Khayyam Ishaq Criminal Case Study: Email POL-0119326
from Jarnail A Singh to Helen Dickinson, CCing
Rob King, Andy Hayward and others re: POCA
Hearings
29