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Witness Name: Kenneth William Donnelly
Statement No.: WITN10510100
Dated: 29 November 2023
POST OFFICE HORIZON IT INQUIRY
FIRST WITNESS STATEMENT OF KENNETH WILLIAM DONNELLY
1. I am the Deputy Crown Agent for Specialist Casework at the Crown Office and
Procurator Fiscal Service. This witness statement to the Post Office Horizon IT
Inquiry seeks to provide information in respect of both Scotland’s prosecutorial
framework during the period from 2000 to the present, and the operation and
practice of reporting agencies to the Crown Office and Procurator Fiscal Service
(‘COPFS’), in particular, those employed by Post Office Limited (“POL”). I make
this statement in response to a request from the Inquiry pursuant to Rule 9 of the
Inquiry Rules 2006 and dated 26 October 2023.
The prosecutorial framework in Scotland
2. In Scotland, the responsibility for all public prosecutions is vested in COPFS. The
head of the system of criminal prosecution is the Lord Advocate, who is a Scottish
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Minister in the Scottish Government and one of the Scottish Law Officers. The Lord
Advocate is responsible for all prosecutions in Scotland which are carried out by
COPFS on her behalf.
. COPFS operates independently and makes prosecution decisions based on the
evidence and the public interest rather than political considerations. It plays a
crucial role in the Scottish legal system by ensuring that criminal cases are
prosecuted fairly and in accordance with the law.
. When COPFS receives a report about a crime from the police or other reporting
agency, before deciding what action to take in the public interest, the prosecutor
will decide if there is enough evidence. There must be evidence from at least two
separate sources (corroboration) to establish that a crime known to the law of
Scotland was committed and that the accused was the perpetrator.
. Decisions on how to proceed in a case are for the prosecutor. In reaching that
decision, prosecutors will consider all the individual facts and circumstances of a
case.
. The criteria for decision making and the range of options available to prosecutors
are set out in the published COPFS Prosecution Code (WITN10510101)
The Crown's duty of disclosure
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7. Scottish criminal procedure proceeds on the basis, as required by Article 6 of the
European Convention on Human Rights and Part 6 of the Criminal Justice and
Licensing (Scotland) Act 2010, that the Crown (COPFS) has a duty, which exists
in perpetuity, to provide to the defence all material information, namely that
information which:
e would materially weaken or undermine the evidence that is likely to be led by
the prosecutor in the proceedings against the accused;
e would materially strengthen the accused's case; or
e is likely to form part of the evidence to be led by the prosecutor in the
proceedings against the accused.
8. This includes information, of which the Crown is aware, that is likely to be of real
importance to any undermining of the Crown case, any casting of reasonable doubt
upon it or which is of positive assistance to the accused. In essence, the Crown
must disclose any statement or other material of which it is aware of, and which
materially weakens the Crown case or materially strengthens the defence case.
9. The Crown is not obliged to disclose all material information against the accused,
only that information against the accused that forms part of the prosecution case.
Neutral information or information damaging to the defence and not part of the
prosecution case need not be disclosed and should not be brought to the attention
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of the court, neutral information being information with no evidential significance to
any party.
10. It is the Crown's duty to disclose information that is material to the defence. This
duty does not depend on the defence making an application or request to the
Crown for disclosure.
11.The Crown’s duty is a continuing one and it persists in perpetuity. It continues
throughout and to the conclusion of any trial, during any subsequent appeal
proceedings and even after the final disposal of a case.
12.Statute places a continuing duty of review on the Crown (section 123 Criminal
Justice and Licensing (Scotland) Act 2010). The Crown must, from time to time
during the lifecycle of the case review the information held and disclosed and make
further disclosure where appropriate. Where proceedings at first instance have
concluded, there is a continuing statutory duty on the Crown to review the
information held (section 134 Criminal Justice and Licensing (Scotland) Act 2010).
Specialist Reporting Agencies
13.Organisations other than the police who report cases to COPFS are called
specialist reporting agencies (“SRAs”). SRAs investigate alleged crimes in their
particular field and report them to COPFS.
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14.It is for COPFS to determine whether to prosecute and what form the prosecution
should take.
The relationship between COPFS and specialist reporting agencies
15.The constitutional relationship between COPFS and SRAs differs from the
relationship between COPFS and Police Scotland. In terms of section 12 of the
Criminal Procedure (Scotland) Act 1995 and section 17 of the Police and Fire
Reform (Scotland) Act 2012, the Lord Advocate has statutory powers to instruct
Police Scotland with regard to the investigation and reporting of criminal offending.
The Lord Advocate and her Procurators Fiscal do not have statutory authority to
instruct or direct SRAs in their investigations.
16.The authority of the Lord Advocate to designate an agency or body as an SRA
derives from the Lord Advocate’s status as a Minister of the Scottish Government
in terms of section 48(5) of the Scotland Act 1998. As the head of the systems of
criminal prosecution in Scotland, the Lord Advocate has the autonomy to appoint
a suitable agency as an SRA absent any official designation by statute. The
founding of some SRAs is historic and reports are accepted by COPFS as a matter
of continuing custom.
17.Organisations designed as an SRA by COPFS are authorised to report cases to
COPFS on the basis that legislative provision designates that organisation as an
appropriate enforcement, investigative or regulatory body, or where Ministers have
appointed the organisation to investigate or enforce legislation.
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18.It is for an SRA to investigate and then to decide whether to report the case
circumstances to COPFS for consideration of prosecutorial action. Some SRAs are
empowered by statute and have administrative penalties available to their
organisation which they may utilise as an alternative to reporting a case to COPFS
where such a sanction would be appropriate; others have no statutory authority.
19.In Scotland the ability of an SRA to investigate and report an offence directly to
COPFS is dictated by the relevant legislation governing their organisation's area
of responsibility. It may also be dictated by the nature of the crime committed and
the powers available to the reporting agency to investigate the offence.
20.An agency must be registered with COPFS before it can operate as a SRA. A list
of organisations registered with COPFS is publicly available on the COPFS
website. As of 2014, 172 organisations were registered with COPFS as SRAs. All
SRAs have a unique agency reference number for reporting cases to COPFS.
21.Generally, SRAs submit their report to COPFS in the form of a Standard
Prosecution Report (“SPR”) which is same format used by the police. The SPR
includes, inter alia, a narrative of the facts and evidence, draft charges, a list of
productions and a list of witnesses.
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Investigation and disclosure obligations of an SRA (2000 ~ 2010)
22. The basic parameters of the Crown’s common law duty of disclosure to the defence
were set down in 1998 by the High Court in McLeod v HM Advocate (No 2) 1998
JC 67. The law was then clarified in a series of decisions by the Judicial Committee
of the Privy Council and the Supreme Court (Holland v HM Advocate 2005 1 SC
(PC) 3, Sinclair v HM Advocate 2005 1 SC (PC) 28, McDonald v HM Advocate
[2008] UKPC 48 and HM Advocate v Murtagh [2009] UKPC 35). Following the
implementation of the Criminal Justice and Licensing (Scotland) Act 2010 (‘the
2010 Act”), the Crown’s duty of disclosure has been placed on a statutory footing.
The provisions of the 2010 Act replace any equivalent common law rules about
disclosure of information and the common law rules were abolished insofar as they
were replaced by or were inconsistent with the 2010 Act.
23.During the period 2000 to 2010, the common law duties that applied to the Crown
applied equally to the Police and SRAs. These common law duties required SRAs
to pursue all reasonable lines of enquiry, record all relevant information and provide
this information to the Crown.
24.In 2006, COPFS published the 7" edition of the guide, ‘Reports to the Procurator
Fiscal. A guide for specialist report agencies’ (WITN10510102). This guide
provides advice for SRAs to assist them in following best practice in the
investigation and reporting of criminal cases. The guide covers all aspects of
reporting to COPFS including general legal requirements, form of report,
preparation for trial, action following submission of statement, the role of COPFS,
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court procedure and jury trials. Earlier versions of this publication exist from 1996
to 2005.
25. The 1996 (First Edition) publication of the guide contains the wording:
“Finally, it is important that material which may be detrimental to the prospect
of a conviction is not omitted from the statement. In order to perform his or her
function properly the Procurator Fiscal must be aware of all the evidence which
has been gathered regardless of whether it contributes to the evidence against
an accused person or is in his or her favour.”
26.The 1996 (Second Edition), 1997 — 2001 (Third Edition), 2001 (Fourth Edition),
2001 — 2005 (Fifth Edition), 2005 (Sixth Edition), and 2006 (Seventh Edition)
editions all contain either the same or similar wording..
27.Between 2000 and 2013, COPFS would routinely meet with SRAs to provide
guidance and advice, both case specific and general. From 2003 onwards an
annual training conference was held for SRA’s where prosecutors from COPFS
would provide training and guidance regarding the reporting of cases to COPFS.
These conferences would deal with a range of matters such as the electronic
reporting of cases to COPFS via SRAWEB, but also dealt with matters such as
how to take witness statements, rules of evidence, and corroboration.
28.COPFS has continued to regularly engage with SRAs to provide training, guidance
and advice.
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29.The training and guidance issued to SRAs generally mirrored the content of the
guidance provided in the ‘Reports to the Procurator Fiscal— A Guide for Specialist
Reporting Agencies’. Prosecutors have and will routinely refer SRAs to this
guidance and the guide has been cited regularly as the practice to be adopted
when reporting cases. As case law has developed, training has been given to
SRAs on the changes to the law at these annual conferences. A copy of
PowerPoint presentation slides regarding the duties of disclosure that was
delivered to SRAs (including POL) in 2009 (WITN10510103) has been provided
with this statement.
Obligations and duties of an SRA (2010 — present)
30.On the commencement of both the Criminal Justice and Licensing (Scotland) Act
2010 and the Disclosure (Persons engaged in the Investigation and Reporting of
Crime or Sudden Deaths) (Scotland) Regulations 2011, statutory duties of
disclosure were introduced. Further guidance was issued to SRAs in December
2011 in a document ‘Disclosure of evidence: Guidance for specialist reporting
agencies’ (WITN10510104). It is set out within the guidance at para 1.2:
“To ensure that the Crown can comply with its disclosure obligations, all
agencies who report cases to the Crown must comply with obligations to
disclose relevant and material information to the Crown. This is known as the
principle of revelation.”
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31.The guidance indicates that the statutory framework is supported by the ‘Code of
Practice — Disclosure of Evidence in Criminal Proceedings’ (WITN10510105). The
duties and responsibilities are set out at para 18. The five core responsibilities and
duties are listed at para 18.2. These are, recording, retaining and reviewing
information, conducting reasonable lines of enquiry, identifying and investigating
exculpatory information, revealing and, where appropriate, providing information to
the Crown, the submissions of accurate Standard Prosecution Reports (SPRs) and
the taking and submission of witness statements.
32.“Investigative agencies” within the meaning of sections 117(4) and 164(3) of the
2010 Act are obliged by statute to adhere to these five core responsibilities and
duties.
Specific relationship between POL and COPFS
33.POL has been an SRA since 30 March 2012 but operated as an SRA before this
date when it was a part of Royal Mail Group (“RMG’).
34. POL investigate alleged crimes against the Post Office and report them to COPFS.
The relationship between POL and COPFS was not established, nor is it regulated,
by statute.
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35.Since 6 June 2011 RMG has been an “Investigating agency” in terms of section
117 of the 2010 Act and the Disclosure (Persons engaged in the Investigation and
Reporting of Crime or Sudden Deaths) (Scotland) Regulations 2011 (‘the 2011
regulations”). On the date of the enactment of the 2011 Regulations, POL was a
subsidiary division of RMG.
36.POL was a subsidiary division of RMG until 1 April 2012. Following the division of
POL from RMG on 1 April 2012, POL continued to report cases to COPFS using
the same agency reference number as it did when part of RMG, and it continued
to employ the same reporting practices.
37.POL report cases directly to COPFS in respect of a limited number of offences,
namely allegations of fraud, theft and embezzlement allegedly involving conduct
by POL employees or former employees. Police Scotland may also report such
cases directly to COPFS.
38.POL reports suspected criminal conduct to COPFS via a secure website created
for SRAs (referred to as “SRAWEB”). SRAWEB is an electronic system which
came into effect in around 2005/2006 and is accessible via a digital certificate.
SRAWEB requires SRAs to specify various information about the suspected
criminal conduct, including a ‘Charge Code’ albeit that this does not determine
ifwhat charges will ultimately be pursued by COPFS.
39.POL does not enjoy the statutory powers of the police concerning powers of arrest,
search and seizure. In conducting its investigations, POL relies on the co-operation
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of the subject being investigated to consent to interview, search and providing
access to and allowing the recovery of materials. Where such co-operation is not
forthcoming, POL may seek the assistance of the police to investigate and report
cases in certain circumstances.
40.During the period 2000 — present, it was not typical for POL to involve Police
Scotland in investigations being conducted in Scotland. Rather, POL would
prepare reports for COPFS. However, Police Scotland might be involved in cases
where a suspect refused to attend an interview.
41.COPFS has been unable to identify any specific direct guidance issued by COPFS
to POL prior to 5 September 2013. No specific internal guidance issued prior to
2013 has been identified regarding how prosecutors were to assess reports and
evidence submitted by POL, and it is understood that prosecutors would approach
POL reported cases as they would with cases from any other SRA.
42.COPFS is aware that a representative of POL was present at a COPFS SRA
training event at Tulliallan, Perthshire, Scotland, in 2009. This training included a
presentation where it was explained that reporting agencies must disclose all
relevant information to the Crown and that this was an ongoing duty. The
presentation referred to the then up to date case law in relation to disclosure and
made clear that consequences of non-disclosure were “unnecessary trials,
unnecessary delays and miscarriages of justice’ (WITN10510103 refers).
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Institutional knowledge of COPFS about Horizon
43. Between 2000 to 2013, COPFS was not institutionally aware of the bugs and errors
in the POL Horizon computer system (“Horizon”) that significantly impacted the
reliability of evidence submitted by POL.
44.On 14 May 2013, POL, via their Scottish agents, BTO Solicitors (“BTO”), contacted
COPFS to request a discussion about issues with the Horizon Online system (also
referred to as HNG-X or HNG-A). On 29 July 2013, solicitors for POL, explained
to COPFS that as a result of the ‘Second Sight’ and ‘Helen Rose’ reports, POL had
instructed their English solicitors, Cartwright King Solicitors (“CK”), to carry out a
review of all cases reported against sub-postmasters/mistresses (“SPMs”) dating
from the roll-out of Horizon Online in January 2010. In cases where an SPM had
raised an issue with either Horizon Online or their training of the system, both the
‘Second Sight’ and ‘Helen Rose’ reports were being disclosed to the defence by
POL. BTO then advised COPFS that it would be reviewing all the Scottish cases
that could be affected by the issues identified in these two reports. On 9 August
2013, COPFS Policy division made Senior COPFS officials aware of the
developments and asked that information regarding the issues with Horizon Online
be passed to prosecutors dealing with ongoing POL reported cases.
45.Following this initial contact, COPFS Policy division officials provisionally
concluded that all POL prosecutions in Scotland should be terminated. As a result,
POL instructed BTO and CK to meet with COPFS officials. This provisional position
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adopted by COPFS had been assessed by CK to raise a considerable public
relations storm for POL if it were followed.
46.On 5 September 2013 a meeting took place between POL, BTO, CK and Crown
Office Policy Division officials at Crown Office, Edinburgh. CK Senior Counsel,
Simon Clarke, was in attendance. At the meeting BTO explained that it had carried
out a review of all live Scottish cases and had determined that the Horizon system
defects identified in the ‘Second Sight’ and ‘Helen Rose’ reports did not play a part
in any live Scottish cases save for one. BTO’s review process assessed cases as
either ‘Type A’ or ‘Type B’; ‘Type A’ being cases in which Horizon had provided the
information as to wrongdoing but was not the provider of primary evidence. In
almost all of these cases the SPM had admitted to the taking of monies belonging
to POL for their own unauthorised purposes. ‘Type B’ cases were cases where
Horizon or the training of its use had been raised by the SPM. CK and BTO advised
that only ‘Type B’ cases were cases which, in their view, required disclosure of the
‘Second Sight’ and ‘Helen Rose’ reports. BTO’s review concluded that all but one
live Scottish case was a ‘Type A’ Case and that all concluded cases were ‘Type A’
cases which did not necessitate further review or disclosure.
47.POL advised COPFS that a full examination of the Horizon system would be
undertaken and would be completed within 6 to 8 months.
48. In light of these revelations, an instruction was thereafter circulated within COPFS
for prosecutors to consider POL reported cases on their facts and circumstances
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in determining whether they should be adjourned pending the outcome of POL’s
review. COPFS did not terminate all Scottish POL cases.
49.COPFS did not directly participate in the review of live Scottish cases and there
was no direct review of closed Scottish cases by COPFS.
50. Ultimately, it is understood that POL did not commission a second report as
discussed at the meeting of 5 September 2013. POL subsequently advised COPFS
that despite consulting with academics, a further interrogation of the Horizon Online
system was not possible.
51.On 6 October 2015, a further meeting was held at Crown Office, Edinburgh,
between prosecutors and both POL officials and their legal representatives. At the
meeting, POL informed COPFS that all POL reported English cases had been
reviewed including cases where there had been a conviction. The purpose of the
2015 meeting was to update COPFS on what had happened since and allow
COPFS to ‘take a view’ on POL reported cases if it so wished. POL advised it had
ceased prosecuting cases with any Horizon involvement on public interest grounds
as it considered there was an issue of the public perception about how POL was
conducting itself and it did not want the public to lose trust in the organisation. In
respect of all the Post Office cases sitting with COPFS, POL advised that were
these in England and Wales, POL would “close these down”. Further, POL advised
that in England and Wales, it was considered to be unfair to prosecute cases
without an expert being able to opine on the integrity of the Horizon system. As
such, COPFS was told that cases continued to be considered on a case by case
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basis but where reliance was required to be placed on the Horizon system the view
was generally being taken that the evidential test for prosecution was not met
because no expert would be available to speak to the accuracy of the system or
rebut any defence that shortfalls found were as a result of computer error rather
than as a result of a criminal act.
52.In 2015 COPFS decided that all live Scottish cases involving evidence from
Horizon should be carefully reviewed on a case-by-case basis. Where there was a
sufficiency of evidence without reliance on Horizon prosecutions could continue.
Where evidence from Horizon was essential to the proof of a charge cases were
reported to Crown Counsel with a recommendation of no action or no further action.
53.COPFS did not undertake its own retrospective review of closed cases where an
accused had either pled guilty or been found guilty after trial.
Current appeal proceedings in Scotland
54.Unlike in England and Wales or Northern Ireland, the Scottish Criminal justice
system is very much closer to the start of its journey in addressing potential
miscarriages of justice arising out of unreliable evidence obtained from the Horizon
system.
55.On 29 September 2023, two Scottish former POL SPMs had their convictions
overturned by the Court. At present, four SPMs are currently appealing their
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convictions to the High Court of Justiciary Appeal Court (“HCJAC”) with substantive
dates for the hearing of these appeals fixed for early 2024.
56. These appeals by six former POL SPMs (“the appellants”) mark the first tranche of
‘Horizon appeals’ in Scotland.
57. This first tranche of ‘Horizon appeals’ are all cases which have been referred to the
HCJAC by the Scottish Criminal Cases Review Commission (“SCCRC”). These
referrals were made following developments beginning in 2020, whereby a number
of different individuals applied to the SCCRC arguing that their convictions are
miscarriages of justice as a result of issues arising from the use that POL made of
its Horizon system.
58.Due to COPFS’ record retention policies, it is not always possible to examine full
case files to ascertain the extent that the Horizon system may have been relied
upon in convictions of POL SPMs dating back to 2000.
59.As a consequence, in respect of the first tranche of referrals by the SCCRC to the
HCJAC, material was ingathered by the SCCRC from COPFS, POL, the
appellants’ solicitors and from the appellants themselves so that a comprehensive
review of their cases could be undertaken
60.COPFS understands that these six referrals represent the cumulation of this
process of review by the SCCRC, in conjunction with an assessment of recent case
law in other parts of the United Kingdom, in particular, the findings of Mr Justice
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Fraser in the group litigation proceedings in the English High Court (Bates and Ors
v Post Office Limited (Common Issues) [2019] EWHC 606 and (Horizon Issues)
[2019] EWHC 3408).
61.The first tranche of cases was referred by the SCCRC to the HCJAC in October
2022.
62.It should be noted that Scottish criminal law is separate and distinct from that of
England and Wales. Although the decisions of the Courts in England and Wales
and Northern Ireland offer insight as to how a ‘Horizon case’ might be identified,
different legal principles exist.
63.Scots law cannot therefore simply adopt the legal precedent set in other UK
jurisdictions.
64.In that respect, at present, there is no legal precedent in Scotland relating to what
is a ‘Horizon case’ and so in this first tranche of cases, both COPFS and solicitors
for the appellants have been carefully examining case material so that assessment
criteria for a ‘Horizon case’ can be applied within the Scottish legal framework.
65.In assessing and responding to the first tranche of appeals, COPFS has become
aware that both POL and POL’s former legal representatives are in possession of
additional material relating to the investigation of the appellants that neither
COPFS nor the appellants have previously been privy to.
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66.A document recovery exercise is currently underway to enable COPFS to recover,
review and thereafter disclose this additional material to the appellants. This has
involved the recovery of over 5,000 additional documents from POL to date, with
further material anticipated. POL’s interrogation of its own systems to produce all
relevant material to COPFS has extended this process of disclosure and review.
67.Given the volume of potentially relevant material held by POL and the fact that
these appeals mark the first interaction between the ‘Horizon issues’ and Scots
criminal law, this process requires, and continues to require, careful and
responsible consideration.
68. The remaining four appeals in this first tranche of referred cases are expected to
be fully considered and disposed of by the HCJAC by February 2024.
Review of Scottish cases
69.COPFS believes the total number of former POL SPMs who were convicted on the
basis of unreliable Horizon evidence to be higher than this first tranche of appeals.
70. It is understood that further cases are presently under consideration by the SCCRC.
and are following a similar process of review to the first tranche.
71.Whilst this review by the SCCRC is underway, COPFS is undertaking a review of
all potential ‘Horizon cases’ reported to it during the period of interest. COPFS is
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carrying out this review with the assistance of both POL and the SCCRC to ensure
that all available case material is recovered as efficiently as possible so that all
potential future appellants can be identified, and their cases reviewed.
72.Due to COPFS policy decisions taken within the period of interest and the fact that
all ‘Horizon cases’ in Scotland were prosecuted by COPFS under the application
of Scots criminal law, the total number of Scottish cases is anticipated to be
significant less than in England and Wales. As an estimate, it is certainly not
anticipated that the number of Horizon cases in Scotland will amount to in excess
of 100 cases.
73.Following the conclusion of the first tranche of appeals it is anticipated that a
streamlined and expedient process of review, appeal and disposal will be available
for application to any future cases. It is anticipated that the rate of review and
appeal will thereafter increase exponentially. It is not possible at this stage to
provide a timescale for this process to be completed.
Concluding remarks
74.COPFS recognises that the expedient review of past prosecutions and the efficient
disposal of appeals is paramount to ensuring that justice is delivered to those who
have been affected by the Horizon IT ‘scandal’. To that end, tireless work continues
to be carried out by prosecutors to identify and bring before the Court all cases in
Scotland which were impacted.
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75.1 believe the content of this statement to be true.
SIGNED
KENNETH WILLIAM DONNELLY
DEPUTY CROWN AGENT, SPECIALIST CASEWORK
CROWN OFFICE AND PROCURATOR FISCAL SERVICE
29 NOVEMBER 2023
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Index to First Witness Statement of Kenneth William Donnelly
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No. I URN Document Description Control Number
1 WITN10510101 I COPFS Prosecution Code WITN10510101
2 WITN10510102 I Reports to the Procurator Fiscal. A I WITN10510102
Guide for Specialist reporting Agencies,
7th Edition (2006)
3 WITN10510103 I Disclosure Presentation to SRAs (2009) I WITN10510103
4 WITN10510104 I ‘Disclosure of evidence - Guidance for I WITN10510104
specialist reporting agencies’, (2011)
5 WITN10510105 I'Code of Practice Disclosure of I WITN10510105
Evidence in Criminal Proceedings’,
(2011)
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