WITN10990100
WITN10990100
Witness Name: Harry Bowyer
Statement No.: WITN10990100
Dated: 2" April 2024
POST OFFICE HORIZON IT INQUIRY
FIRST WITNESS STATEMENT OF HARRY BOWYER
I, Harry Bowyer, will say as follows:
INTRODUCTION
1. I am a former employee of Cartwright King Solicitors (CK) and held the
position of in-house barrister. I was made a director of the firm during the period
covered by this Inquiry (one of about 30 — I held no equity in the firm).
2. This witness statement is made to assist the Post Office Horizon IT Inquiry
(the “Inquiry”) with the matters set out in the Rule 9 Request dated 26"
February 2024 (the “Request’).
BACKGROUND
3. I joined CK in the summer of 2008 from the independent Bar where I had been
in practice since 1990 (called in 1989). My practice was entirely criminal and
Page 1 of 38
WITN10990100
WITN10990100
included both prosecution and defence.
4. When I joined CK I was the first employed barrister in the firm but over the
next few years the firm expanded their advocacy department by employing a
large number of barristers and solicitors with higher rights to cover almost the
entirety of their Crown Court work. CK would still brief out work that was a
long way from their offices.
5. When I joined CK they had 3 offices, Nottingham, Derby and Leicester. They
embarked on a period of rapid expansion by acquiring other firms of solicitors.
At their peak they had around 20 offices from London to Newcastle. This
involved a great deal of fairly ruthless reorganization as they cut away the
dead wood.
6. The Advocacy department at its peak was based in Nottingham and run as far
as possible like a set of chambers. The Nottingham Office had an area for the
advocates, the clerking team and any pupils. The Head of the Department
was initially one of the Equity Partners, Steve Gelsthorpe. This was then taken
on by Andy Cash and latterly by Mark Hopwell.
7. I handed in my 3 months’ notice at CK in December 2015 and left just before
that expired in February/March 2016.
Relationship between Cartwright King (“CK”) and Post Office Limited (“POL”)
8. I did have some involvement with POL prior to April 2012 which came about
as Andy Cash introduced the then Royal Mail Group (RMG) work to CK. He
was based in the Derby office but spent a great deal more time in Nottingham
when he became head of the Advocacy department. The RMG work was more
Page 2 of 38
10.
11.
12.
13.
WITN10990100
WITN10990100
provincial at that stage but in 2012 Andy Cash brought the POL work into the
firm which was nationwide in nature.
The bulk of the POL/RMG work was done by Martin Smith, based in Derby
and Andrew Bolc based in Leicester. They would prepare the cases and brief
them out to counsel. The RMG work involved some of the same type of cases
as the later POL work but also involved postmen stealing from the mail.
When he was in Nottingham Andy Cash would ask my opinion about the
POL/RMG cases both informally and, on occasion he would ask me to settle
an indictment or an advice on evidence. This would involve the file being
brought to Nottingham so that I could work on it. It would then be returned to
the lawyer working on it and I would be unlikely to see it again as it would
usually be briefed out to counsel.
During my time at CK I never prosecuted a trial for either RMG or POL. I
prosecuted a sentence at Nottingham Crown Court — I cannot remember the
name and I appeared more regularly, after we stopped the prosecutions, at
directions hearings to adjourn cases when we thought that a new expert was
to be instructed to replace Gareth Jenkins.
I prosecuted one case which involved the manager of a Crown Post Office
(i.e. a Post Office run by POL not a sub postmaster) after we stopped
prosecuting the Horizon cases as that case did not rely upon Horizon
evidence.
I have been asked to set out who I worked with at CK on POL cases. Initially,
as above, my main contact was with Andy Cash who asked me for early
advices, advices on evidence and to settle indictments on an ad hoc basis
when he was in Nottingham. I had a full criminal case load at this time and the
Page 3 of 38
14.
15.
16.
17.
18.
WITN10990100
WITN10990100
RMG/POL requests were sporadic. Martin Smith and Andrew Bolc had the
conduct of the files and I had little to do with either of them before 2012 except
when I visited the Derby and Leicester Offices when I had work at the Crown
Courts in those cities.
The situation changed in late June 2013 just before the Second Sight Interim
report was published. We became aware at CK through conversations that
Martin Smith had with senior POL executives that the Second Sight Interim
Report would reveal the existence of bugs in the Horizon system.
Simon Clarke, one of the in-house barristers at CK, had been briefed in an
Horizon case and discovered through a conversation with Gareth Jenkins that
Gareth Jenkins knew of the matters that were to be mentioned in the Second
Sight Interim Report of 8" July 2013 and had failed to disclose them.
Simon became the head of the Post Office Department shortly afterwards and
instituted the Sift program to make disclosure to the relevant convicted POL
defendants. During the Sift procedure I worked for long periods of time in the
Derby Office to be close to the files and conduct the reviews. This involved
working closely with Simon Clarke, Martin Smith and other junior employees
of CK who would be responsible for record keeping. We also had members of
the independent Bar to help with the reviewing process. Andrew Bolc would
occasionally attend the Derby Office during this process.
During this time we thought that POL would be instructing an independent
witness to replace Gareth Jenkins and POL were continuing to investigate
cases which began to pile up awaiting prosecution. These were known as the
“Stacked Cases.”
My direct contact with POL personnel was fairly limited. The point of contact
Page 4 of 38
19.
20.
21.
WITN10990100
WITN10990100
between POL and CK was Martin Smith who was the constant presence in
the Derby Office —- Simon Clarke and I were often out at court on non POL
criminal work. I had dealings on the telephone and by email with Jarnail Singh
who I understood to be head of crime at POL. I only met him face to face 2 or
3 times — once when Simon Clarke and I visited the POL offices in London at
Old Street to discuss possible expert witnesses and the other occasions were
when Jarnail Singh came to Derby. My visit to Old Street was the sole
occasion that I met Rodric Williams but I was in contact with him occasionally
by telephone or email.
As a result of the “stacked cases” I was in touch with some of the POL
investigators in those matters - the ones that stand out in my memory were
Helen Dickenson and Chris Knight.
I am asked for my view on how the working relationship between POL and CK
functioned during my time at CK and if there were areas for improvement.
Plainly the whole relationship between POL and CK was completely
compromised by the lack of honesty and transparency by certain people at
POL and Fujitsu who sat on the shortfalls of the Horizon system that they had
known about for some time. I do not know who knew what and when and
would be unable to identify those who sat on Horizon’s shortfalls. The reality
is that CK shut down prosecutions within days of the Second Sight Interim
Report being published when it became apparent that we had a dishonest
witness, Gareth Jenkins. Had these shortfalls been properly disclosed in a
timely manner then the prosecutions would have been stopped much sooner.
It is probably fair to say that the CK Post Office Department would have
benefitted from proper oversight from the earliest stages from people with
Page 5 of 38
WITN10990100
WITN10990100
actual experience of prosecuting cases rather than different individuals in
different offices doing their own thing.
22. When it was appreciated by Simon Clarke that POL had a big problem with
their expert (at that stage we did not realise that they had a big problem with
Horizon itself) steps were immediately taken to prevent further prosecutions
on tainted evidence, implement a review scheme and to revisit past
convictions with a view to disclosure and to obtain an independent expert. The
weekly hub meetings were established and the whole response was overseen
in due course by Senior Treasury Counsel, Brian Altman QC (as he was then).
Knowledge of Horizon
23. I am asked as to my understanding of the Horizon system during my time at
CK whilst acting for POL. This is a difficult question to answer accurately as
my knowledge has accrued over time and some elements I am not sure of
now owing to the passage of time. I was slowly drawn into the Post Office
work as described above and during the Sift process I reviewed dozens of
cases both Legacy and Online. I have kept an interest in the issue since
leaving CK and have read the Judgement of Holroyd LJ in Hamilton & others
as well as watching some of the evidence in the current Inquiry. To say what
I knew and when is quite difficult except for a couple of standout moments.
24. One of the more seminal moments was the publication of the Second Sight
Interim Report. This sticks out as we heard rumours immediately before
publication that the report was going to say that they had found bugs in
Horizon. Up until that stage we had been assured from all sides that the
Page 6 of 38
25.
26.
7-4
28.
29.
30.
WITN10990100
WITN10990100
system was robust and that there was nothing that could undermine the
integrity of the system. My information came from a number of sources both
from within POL and what I had picked up from within CK. I cannot, at this
point, remember specific conversations.
My understanding of the Horizon system was that it was an accounting system
used by Post Office in a couple of forms since the turn of the century. I was
told that it processed millions of transactions each day and was capable of
balancing the cash and the stock. I was aware of the difference between
Horizon Online and Legacy.
We were assured that there was no “back door’ into the system for Post Office
or Fujitsu to alter the figures unbeknownst to the Sub Postmasters (SPMs).
The fact that there was a “back door’ only came to light when we got hold of
the Deloitte report. Again I cannot remember who told us that there was no
“back door” but I can remember the shock when the Deloitte report said that
there was one.
I only heard of bugs in the Horizon system after the publication of the Second
Sight Interim Report in July 2013. I was not aware of the extent of the bugs
until Hamilton and others which was heard long after I left CK.
Whilst I was at CK we were assured that the system was robust. The Second
Sight Interim Report whilst reporting that they had come across two bugs did
not find anything “systemic” that would account for the losses allegedly
sustained by the SPMs.
I was told very little about the training offered to the SPMs.
My understanding of the difference between Horizon Legacy and Horizon
Online is relatively limited. The main difference between the two was that
Page 7 of 38
31.
32.
33.
34.
35.
36.
WITN10990100
WITN10990100
Horizon Online was a contemporaneous system whereas Horizon Legacy had
to be downloaded when the system was not in use.
I received no formal induction on the Horizon system from POL other than a
training day on the system with a number of external counsel who prosecuted
POL cases. I did not know these counsel and cannot remember their names.
I am afraid I cannot remember where this course was held except that it was
north of Nottingham. The course itself was not a great deal of use as it was
effectively the sort of training a new cashier would get. The training did not
cover reconciliation of balances. The instructor positively refused to answer
questions on how the system could be defrauded.
I am aware that my knowledge of the Horizon system has/had gaps in it. I
currently do not understand how the POL accountants managed to acquire
what must be hundreds of thousands of pounds in extra funds from SPMs
repayments without noticing it.
I was not aware of any bugs in the system until shortly before the Second
Sight Interim Report when Martin Smith was told that the Second Sight Interim
Report would disclose bugs in the system.
I was not aware that the system was not robust until after my time at CK had
ended.
To a large extent the gaps in my knowledge are as a result of non-disclosure
of the issues by POL.
I am asked what steps, if any, did I take throughout my time working at
Cartwright King to further your knowledge of the Horizon IT system, and any
bugs, errors or defects within it. I was, of course, interested as to whether
there might be any mileage in the claims that Horizon might be to blame for
Page 8 of 38
WITN10990100
WITN10990100
generating false figures. I was interested at the time in any possible attack
that might be mounted on the system. The following matters suggested to me
at the time that the system was robust:
i) POL’s assurances that they and Fujitsu found the system to be
robust with no faults that could produce shortfalls.
ii) The scale of transactions being conducted — millions of
transactions conducted daily in thousands of Post Offices
apparently trouble free.
iii) The fact that very few of these problems were being reported in
the Crown Post Offices.
iv) The full admissions to theft in a substantial minority of the cases
that I sift reviewed.
v) The different types of alleged offending encountered. Some were
alleged to be removing money to meet other expenses. Others
were allegedly asking pensioners to reenter their PIN when
making cash withdrawals, others were allegedly falsifying
postage. There was no obvious “one bug fits all.”
vi) We were told that there had never been any alleged surplus
figure generated by the system. (The Second Sight Interim
Report rebutted this!)
vii) The cavalier use of logins — for example post it notes with login
details left on the terminal. Login details shared with other staff
etc.
viii) False accounting by SPMs to cover shortfalls rather than using
the correct reporting procedures.
Page 9 of 38
WITN10990100
WITN10990100
ix) Independent corroborating evidence from the alleged victims of
these offences or other members of staff reporting use of POL
money being used inappropriately.
x) The lack of any successful attack on the system in the cases,
even where experts were instructed.
xi) The Second Sight Interim Report which stated that they could not
find any systemic fault with the system.
37. I appreciate that the above is all susceptible to confirmation bias but the reality
is that we had no firm evidence that there were bugs in the system until the
Second Sight Interim Report was published and very shortly after that we
stopped the prosecutions.
POL Prosecutions and Horizon Issues
38. I was aware from the beginning that the Horizon system was being challenged
by the Sub Postmasters for Justice group. As I have said above the first
confirmation that there were any bugs in the system came with the publication
of the Second Sight Interim Review.
39. I am asked to consider an advice that I wrote on 11" July 2012 in relation to
the prosecution of Kim Wylie [POL00180894]. I am particularly asked if I recall
the POL response to a previous advice in this case written in October 2010. I
have not been provided with that October 2010 advice and cannot recall its
contents nor its reception from POL.
40. The “apocryphal evidence on the internet and elsewhere” would have come
to my attention through discussions with colleagues and by reading the media
Page 10 of 38
41.
42.
43.
44.
45.
46.
WITN10990100
WITN10990100
both online and print. The Sub Postmasters for Justice group were making
their case loudly at this time.
In July 2012 I had no reasons to doubt my instructions that the Horizon system
was robust and had seen no evidence to the contrary.
I was not involved in any contested trials for POL and, at this stage, I am not
sure that I had even been in court instructed in an Horizon case as I have
stated above. My involvement had been limited to early advices and settling
of indictments when I was asked to by Andy Cash. This was very sporadic
work.
I do not think that CK were involved in the instructing of Second Sight or the
work that they were instructed to do. I was told of their instruction by Andy
Cash very shortly before the Wylie advice of July 2012 which was prompted
by the Instruction of Second Sight. As Andy Cash was head of the Post Office
Department at CK at that time I feel sure that he would have told me if he/CK
had had any input into their investigation.
I had little understanding of what the Second Sight Review would entail over
and above what I put in my advice.
I state my concerns about the Second Sight Independent Review in my advice
of July 2012. These included whether cases would have to be adjourned
pending the Review, the inevitable challenge to the integrity of the system in
every contested case and, as I say in my advice, the argument being raised
that, “there is no smoke without fire and we would not have needed to audit a
bomb proof system.”
I am asked what alternative course of action I would have adopted. I make
clear from my advice that I was unhappy with the way that Fujitsu would not
Page 11 of 38
47.
48.
49,
50.
51.
WITN10990100
WITN10990100
cooperate without charging enormous fees to do so. On the basis that the
system was robust I would have required Fujitsu to demonstrate that the
system was robust, that there were no mechanisms through which the
shortfalls claimed by the SPMs could have been caused by the mechanics of
the system. It was my view that it was in the interests of Fujitsu to nip this in
the bud early and were I POL I would have demanded that this should happen
but there was no appetite from POL so to do.
When I stated, “until the 2"4 Sight investigation is concluded we will be in a
limbo” I meant that POL would be in a position where people would be able to
refer to the as yet unfinished review. This could be used as a reason to delay
cases until the Review had reported or should cases proceed before Second
Sight had reported POL would be vulnerable to the “no smoke without fire
arguments.”
I do not know what the response from POL was to my advice that this was a
“firefighting position” except that I was told by Andy Cash that they did not like
the advice. I was not asked to advise formally on the issue after that.
I was aware that there was an attempt to collate the previous challenges to
the Horizon system under Helen Rose. I don't think that I saw the product of
this collation.
lam asked to comment on an email exchange between Andy Cash and Jarnail
Singh [POL00143377]. I was copied into this email chain but wrote none of
the emails. I am asked, in particular, what I thought of Jarnail Singh's position
as regards my advice. I was of the view that he was somewhat over optimistic
as to the limited effect of commissioning the Second Sight Review.
I cannot recall any further consultation between me and POL — there was
Page 12 of 38
WITN10990100
WITN10990100
certainly no formal advice sought from me but there may have been email or
telephone correspondence on the subject. I was aware that Helen Rose was
collating material for the expert to be instructed. My feeling was that this
advice was something of a damp squib and did not give it much thought until
Second Sight produced their Interim Report the following year.
Helen Rose Report and Gareth Jenkins Expert Report
§2. I am asked to provide my reflections on an Email exchange between Mr
Jarnail Singh and me regarding ‘Horizon Integrity Project, dated 6 August
2012 [POL00141416]. This appears to be a response to my advice of 11"
July 2012 [POL00180894]. Helen Rose had been detailed to gather the
information requested in that advice so that we could have all of the attacks
made in court on the Horizon system in one place for an expert to deal within
a subsequent report.
53. I cannot recall the “chat” between me and Jarnail Singh mentioned in the
email.
54. I am asked about an email exchange between Mr Jarnail Singh and me
regarding Horizon and the Kim Elizabeth Wylie case, dated 12 September
2012 [POL00020489]. I am not sure that I saw the completed Helen Rose
report on this matter. At this stage POL work was something that I dipped in
and out of whilst conducting my defence work out of Nottingham. I would
respond to emails and give advice when asked but I did not have a general
oversight in 2012.
Page 13 of 38
55.
56.
57.
58.
WITN10990100
WITN10990100
In the email exchange [POL00020489] I express my preference for an
independent Expert Witness. The potential for allegations of bias or actual
conflicts of interest, as in the event were plainly relevant, were obvious. The
problem was that Gareth Jenkins had been fielded as an expert before and
had not been attacked in that manner and the point had not been taken by
previous prosecution counsel, defence counsel or Judges involved.
I was made firmly aware that finding an expert in the limited time available
who could realistically match the experience of Gareth Jenkins with the
system and in the teeth of resistance by Fujitsu over opening up their systems
because of concerns about commercial sensitivity was impracticable.
I cannot recall having any further input into the expert report but may well have
done. As I have said above I did not conduct any of the trials in Horizon cases
and was not involved in their day to day litigation.
lam asked to consider my email to Martin Smith regarding the Gareth Jenkins
report [POL00096997], dated 12 October 2012 and to explain what my views
were on the report. Specifically, with hindsight, did I think that the report was
sufficient and transparent. I cannot recall the report but at the time I seemed
to be happy with it. The idea was to have a report that would go to the
robustness of Horizon and deal with the attacks that had been made thus far
and why they were not valid and would provide the basis for dealing with any
fresh attack on the system. At this stage our instructions were that the system
was robust in its entirety and it is difficult to see what, with the knowledge we
had then, we could have done. The defence should have been put on notice
of what previous attacks had been made and why they were not valid and we
provided an expert for defence experts to have a crack at if they could.
Page 14 of 38
WITN10990100
WITN10990100
The Second Sight Interim Report, July 2013
59.
60.
61.
62.
63.
64.
I am asked if I was aware of any discussions between CK and POL in relation
to preparing a public response to the Second Sight interim report? I was not
aware of any such discussions and cannot say if any such discussions
occurred.
As far as CK’s concerns with the Second Sight Interim Report were concerned
we were very much alive to the fact that a system that we had been told was
robust did indeed have bugs in it. This was plainly going to cause POL
difficulties.
I remember being taken aback when we discovered what the Second Sight
Interim Report would contain as it flew in the teeth of what we had been told.
Again it was not of direct concern to me as I was not a member of the Post
Office Department.
I did become involved when I was approached by Simon Clarke who told me
about the conversation that he and Martin Smith had had with Gareth Jenkins
in late June over a case that Simon was prosecuting.
The thrust of the conversation was that it was Gareth Jenkins who had
provided the information about the two bugs mentioned in the Second Sight
Interim Report. This was clearly not consistent with statements that he had
given in the criminal cases that he had been involved with.
The implications of this were plainly enormous and it was our joint view that
POL could not continue to prosecute on his evidence and there would have to
Page 15 of 38
WITN10990100
WITN10990100
be a revisiting of previous cases with disclosure in mind. This was unlikely to
be popular with POL and our employers, CK.
65. The Management at CK turned out to be supportive of our position - the matter
was canvassed at the highest levels with the equity partners as POL was an
enormous client even for a firm of the size of CK. Simon wrote what was later
called “The Clarke Advice” on the 15 July 2013, which effectively stopped
the prosecution of POL cases by CK some 7 days after the formal publication
of the Second Sight Interim Report until an independent expert was engaged
which never happened.
66. POL were philosophical in regard to disclosure of the Second Sight Interim
Report to current and previous defendants. The attitude then was still that the
system was essentially robust and, once the new expert was instructed, they
could prosecute again. They were very concerned at the new cases being
investigated piling up.
The CK Case Reviews (Review Protocol [POL00129452])
67. The CK case reviews were designed to bring the attention of convicted
defendants to matters that should have been disclosed to them during their
prosecutions. This was initially limited to the Horizon Online cases. I was not
involved in settling the protocol but I have little doubt that had I asked for any
changes they would be implemented.
68. In broad terms the process operated by the relevant files being subjected to a
first Sift. This was carried out by various solicitors at Cartwright King (including
Martin Smith and Andrew Bolc) and those cases that passed the first sift
criteria were subjected to a second sift which was conducted by counsel.
Page 16 of 38
69.
70.
71.
72.
WITN10990100
WITN10990100
Initially the only counsel involved were Simon Clarke and myself but later
counsel from the independent bar were instructed. The operation was
conducted from the CK Derby offices to give easy access to the files. If
disclosure was required we were advising POL to disclose the Second Sight
Interim Report and the Helen Rose Report.
I have been asked to consider a number of case reviews and reflect upon the
same and I do so. The point of the reviews was to set out the reasoning
process for disclosure I am not sure that second guessing my decisions then
has much purpose bearing in mind that the whole process was fundamentally
undermined by POL’s lack of disclosure of all of the bugs then known about
and the presence of a “back door” into the system all of which we had no
inkling of at that stage and would, I am sure, have made a difference to the
review process.
Jamie Dixon [POL00297631] I advised disclosure of the relevant material in
this matter
Tahir Mahmood Sethi [POL00168922] this matter involved full admissions
to the auditors and in interview to effectively the amount missing. The
defendant pleaded guilty in the Magistrates’ Court. No disclosure was made
on review. In my view with the knowledge I had then this advice is
unexceptionable.
Nicholas Mackrill and Amanda Mackrill [POL00021272], In this matter
Nicholas Mackrill admitted and pleaded guilty on a limited basis to theft and
Amanda Mackrill stood her trial on the theft count and was acquitted. She was
sentenced to false accounting which she had admitted.
Page 17 of 38
73.
74,
75.
76.
77.
WITN10990100
WITN10990100
Nicholas Clark [POL00294610] The defendant admitted taking POL funds in
interview and in a note to the auditor. He pleaded guilty to false accounting. I
advised that no disclosure should be made and in my view on what I then
knew this advice was unexceptionable.
Vijay Parekh [POL00294429] this matter involved full admissions to taking
money for his own purposes to the auditors, in interview and the author of the
pre-sentence report. No disclosure was made on review. In my view with the
knowledge I had then this advice is unexceptionable.
Gillian Howard [POL00021207] in this matter the defendant admitted false
accounting to cover losses that accrued in her Post Office. Her solicitors
offered a plea to fraud on the basis that she covered the losses and had made
no financial gain. There was evidence that a son of one of their employees
had been committing thefts from the secure area which was not disclosed. I
was concerned about this case at the time and having reread the advice I think
that I should have advised disclosure not of the Second Sight Report but of
the subsequent thefts - despite the admissions to false accounting and the
basis of plea of no financial or material gain being honoured by the Judge and
the Crown.
William Giles [POL00294501] This Horizon Legacy case involved a
purported loss of over £186,000. The defendant admitted stealing money from
the Post Office but disputed quantum. The indictment was amended to a lower
figure of £164,152.95 and the defendant pleaded. No disclosure was made
on review. With what I knew then I think this decision, was not unreasonable.
Deborah D’Arcy [POL00091783] In this matter I advised disclosure of the
Second Sight Interim Report and the Helen Rose Report.
Page 18 of 38
78.
79.
80.
81.
82.
83.
84.
85.
86.
WITN10990100
WITN10990100
Jahira Begum [POL00021270] In this case I advised disclosure of the
relevant materials. I have been asked to comment on [POL00021285] which
is an email from me to Martin Smith telling him that we should disclose the
Second Sight Interim Report.
Kathleen Crane [POL00198128] Horizon Legacy case Defendant pleaded
guilty to Fraud and no disclosure advised. Again this case is on the line with
the protocol. She pleaded guilty at an early stage and with what I knew then
my advice was reasonable.
Robert Clay [POL00294422] The defendant pleaded guilty before primary
disclosure would have been made and was not dealt with on the basis of his
admissions. With what I knew then my advice was reasonable.
Daljit Singh Benning [POL00294514] I advised disclosure of the relevant
material.
Alison Henderson [POL00061747] I advised disclosure of the relevant
material.
Peter Huxham [POL00294518] I advised disclosure of the relevant material.
Ravinder Manku [POL00040024] This is an early advice on an unconvicted
defendant rather than a disclosure advice on a convicted defendant.
Anthony King [POL00168935] This was not really an Horizon case. The
defendant was generating rejected labels and using them as paid postage. He
pleaded at an early stage. On what I knew then I see nothing exceptionable
about this advice.
Siobahn Sayer [POL00294524] I advised disclosure of the relevant material
in this matter.
Page 19 of 38
87.
88.
89.
90.
91.
92.
93.
94,
95.
WITN10990100
WITN10990100
Angela Hodgson [POL00294516] I advised disclosure of the relevant
material in this matter.
Alison Henderson [POL00294503] I advised disclosure of the relevant
material in this matter.
Pauline Greenhalgh [POL00294502] In this case I did not advise disclosure.
With hindsight, even with what I knew then, I think that I should have advised
disclosure to comply with the protocol.
Mahesh Patel and Prakesh Patel [POL00142328] This is an early advice on
unconvicted defendants rather than a disclosure advice on a convicted
defendant.
Mohammed Luqman [POL00168939] This was case where there were
admissions to theft and a guilty plea at the first opportunity so disclosure would
not have arisen. On what I knew then I see nothing exceptionable about this
advice.
Neelam Shanez [POL00198136] I advised disclosure of the relevant material
in this matter.
Linda Wrigley [POL00294425] This was a case where there were
admissions to theft and a guilty plea at the earliest stage. The defendant
expressed surprise at the total sum alleged. I advised no disclosure. On what
I knew then I think that my advice was reasonable.
Katherine McQue [POL00294520] I advised disclosure of the relevant
material in this matter.
Sunil Patel [POL00294498] In this case the defendant pleaded guilty at the
first opportunity and admitted taking POL funds in interview. On what I knew
then my advice not to disclose was reasonable.
Page 20 of 38
WITN10990100
WITN10990100
96. Sennapathy Ponnampalam Narenthiran [POL00294522] I advised
disclosure of the relevant material in this matter.
97. Ali Hashmi [POL00168926] This was a guilty plea at the first opportunity in
the Magistrates’ Court. There were full admissions to theft and false
accounting. On what I knew then I see nothing exceptionable about this
advice.
98. Gregory Harding [POL00142279] This case pleaded on the first appearance
in the Crown Court on the basis that the defendant had not taken the money
which had been lost “in the normal course of business.” I advised no
disclosure. On what I knew then I think that my advice was reasonable.
99. Rabina Shaheen [POL00294526] I advised disclosure of the relevant
material in this matter.
100. Timothy Brentnall [POL00294428] In this case I did not advise disclosure.
With hindsight, even with what I knew then, I think that I should have advised
disclosure to comply with the protocol. I rather think that I was influenced by
the Judge sentencing on the basis of no loss and the defendant's admissions
in interview.
101. Jacqueline McDonald [POL00006579] I advised disclosure of the relevant
material in this matter.
102. Valery James [POL00294499] In this matter there were admissions to taking
over £90,000 from the Post Office and there was no real dispute as to the
alleged loss. On what I knew then I see nothing exceptionable about this
advice.
103. Scott Darlington [POL00168961] In this case I did not advise disclosure.
With hindsight, even with what I knew then, I think that I should have advised
Page 21 of 38
WITN10990100
WITN10990100
disclosure to comply with the protocol. I rather think that I was influenced by
the Judge sentencing on the basis of no loss and the defendant's admissions
in interview.
104. I am not totally sure why the 1t January 2010 was chosen as the start date
for the review process. I would have been involved in the decision-making
process. Brian Altman KC in his review of 15" October 2013 [POL00006581]
at paragraph 64 suggests that it was because all of the Post Offices were
balanced on the rollout of Horizon Online which would make sense.
105. I am asked to comment on [POL00147344] where it is stated that “CK
deliberately set a very low threshold’ for deciding whether to disclose the
Helen Rose report or Second Sight report to the Defence. The document
referred to is an email from Jarnail Singh who appears to be referring to the
CK Sift protocol [POL00129452] where the phrase is used. The idea was that
the initial sifters would pass the case on for a second sift using a very low
threshold and the second sifters would disclose the information where it might
have been disclosable had it been available at the time.
106. I am asked “In [POL00147344], it states that a new prosecution policy was
almost ready to be put into place. Please explain any role that CK played in
drafting this new prosecution policy.” I am not sure to which prosecution policy
this refers. I know that Simon Clarke was settling a prosecution policy but I
understood that there may have been other policies also being circulated. I
had little to do with this side of things.
107. 1am asked with the benefit of hindsight, how, if at all, should the review have
been conducted differently? Plainly the review was conducted on the false
premise that the only material that needed to be disclosed was the Second
Page 22 of 38
WITN10990100
WITN10990100
Sight Interim Report and the Helen Rose Report when it must have been
known at POL and Fujitsu that the problems with Horizon ran much deeper.
We were under the impression that whilst there were a couple of minor bugs
revealed by second sight and we had a problem with a dishonest witness the
Horizon system was fundamentally sound and once that had been
demonstrated by an independent expert witness that prosecutions would
proceed again. If we knew then what we know now then there should have
been a root and branch reappraisal of the past prosecutions and a complete
moratorium on prosecutions based on Horizon until it could be demonstrated
to be sound.
108. I am asked, “Were you (or others CK) involved in discussions about
termination of ongoing prosecutions following the Second Sight interim report
and/or the CK case review? If so, please explain.” At the time we had
suspended prosecutions until we had a new expert. The expectation was that
such an expert would be found and prosecutions could continue. Plainly some
cases were already in the system and decisions had to be taken as to whether
these could be adjourned or whether the prosecutions should be discontinued.
In the meantime POL was investigating new cases which were building up in
quantity. These were referred to as the “stacked cases.” As POL dragged its
feet on instructing a new expert these too became too stale to prosecute and
so we advised their discontinuance. I was involved in these discussions.
Mediation Scheme
109. I was not involved in the mediation scheme except on the outer edges.
Page 23 of 38
WITN10990100
WITN10990100
110. I am asked to comment on [POL00145821]. This is an email from Andy
Parsons of Bond Dickenson to Martin Smith, copied into Rodric Williams and
Jamail Singh. It required and urgent response and Martin asked me to
respond which I did in red below each point in Andy Parsons’ email. CK had
little input into setting up the mediation process but were asked to advise
where the process might affect defendants with POL convictions.
111. I am asked to comment on a number of documents entitled “Response To
Initial Complaint Review & Mediation Scheme Post Office Preliminary
Investigation Report.” These are reviews of documents prepared by, I think,
Bond Dickenson for the mediation scheme which they asked CK to respond
to. It is very difficult to comment on documents taken by themselves and
without sight of or reference to the documents to which they refer. It was my
strong view that SPMs who had been convicted or who were in the stacked
cases should not have been included in the mediation scheme. My view was
that their proper remedy was by way of appeal to the Court of Appeal.
112. The mediation scheme was run through Bond Dickenson and the email
correspondence shows that their grasp of criminal procedure was sketchy at
best.
113. [POL00140350] Josephine Hamilton. I make no suggestions to alter the
proposed text.
114. [POL00301427] This is an email where I am asked to comment on a number
of stacked cases when it appears that cases that were still potentially to be
prosecuted were to be included in the mediation scheme.
Page 24 of 38
WITN10990100
WITN10990100
115. [POL00108263] Kangasunduram Prince. This defendant stated that he had
left £48,010 in cash in the safe overnight and seemed to suggest that the
auditors had taken it.
116. [POL00061199] Hughie Thomas This case was prepared on limited papers
— there was no defendant interview available and no way to tell how strong
the prosecution case was — it was already 9 years old in 2014 when this
document was prepared. It was my view that the proposed summary and
concessions proposed should not have been made on such limited
documentation.
117. [POL00108373] Terence Walters I make no suggestions to alter the
proposed text.
118. [POL00147935] This is an email from Andrew Bolc to Matthew Harris, Bond
Dickinson, where he has plainly quoted correspondence where I query the
serving of unredacted interim investigation reports complete with officers’
telephone numbers. I see nothing exceptionable in this concern.
119. [POL00142454] This is an email asking either Simon Clarke or myself how to
respond to an email from Messrs Howe + Co solicitors about the Helen Rose
Report. I do not know whether Simon or I responded to this email or what that
response was.
120. [POL00202683] This is the same document as [POL00142454] above.
121. [POL00141689] This is an email chain where I repeat my concerns raised
above in [POL00147935]. I see nothing wrong with the advice given.
122. [POL00046579] Mr Michael Rudd, Briefing Note This is a briefing note on
this applicant to the Mediation scheme. Without more I see nothing that should
concern me in this briefing note.
Page 25 of 38
WITN10990100
WITN10990100
123. [POL00206241] Wendy Buffrey This was a briefing note on this applicant's
mediation application. On what I knew then this note was unexceptionable.
124. [POL00206240] This is Jarnail Singh's email in response to the above briefing
note.
125. [POL00077936] This is not my document but refers to the case of Haji
Choudry which I had reviewed.
126. I am asked how the Mediation Scheme actually operated and I am not in a
position to answer this. Our involvement was limited to settling some case
summaries or editing others and limited advice as to disclosure. They were
not using the Criminal Procedure and Investigations Act 1996 (CPIA) rules so
we were limited to advising on the consequences of disclosure rather than
disclosure itself.
127. I had very little direct contact with Bond Dickinson. I don’t think that I ever met
any of their lawyers. Requests seemed to come via Rodric Williams but I was
occasionally emailed by Andrew Parsons and others, usually when there was
a deadline and Martin Smith was not available. During this period I was not
working exclusively on POL work and had my criminal case load based in
Nottingham as my mainstay work.
128. 1am asked to comment on [POL00209747] which is my advice on “Criminal
Applicants to the Mediation Scheme Convicted of False Accounting.” I cannot
recall who asked me to settle this advice.
129. I am asked for my views on the efficacy of the mediation scheme for applicants
with criminal convictions. I was not privy to the results of any such mediations
but my attitude at the time was that it was entirely unsuitable for those with
criminal convictions and those still under investigation for criminal offences. I
Page 26 of 38
WITN10990100
WITN10990100
was full of misgivings about the complete lack of criminal experience in Bond
Dickinson and the complete lack of understanding of disclosure in criminal
cases including basic GDPR.
130. In [POL00046590] (an email to Martin Smith) I refer to the opinion of a POL
investigator that an alleged robbery was an “inside job.” “The current version
refers to the officer's suspicions that the robbery was not genuine but this was
not part of the prosecution case nor was it aired with the defence at the time.
! do not think that it is safe to allow such conjecture in the Mediation Response
and have edited accordingly.” This allegation had never formed part of the
prosecution case and I had seen no evidence to support such an allegation
against the SPM. I did not see how an unfounded suspicion against the SPM
could be relevant to any issue in the mediation.
131. I had no contact with the JFSA or Second Sight and had no views on their
approaches. I was certainly interested in their product when it was produced.
132. I am asked what my view was of POL’s position during the mediation scheme
that the Horizon IT system was robust. This view did not surprise me as my
instructions were that it was robust. At the time POL were looking for an expert
in order to restart prosecutions based on the system.
133. We were not kept in the loop as to the progress of the mediation scheme so I
would have been in no position to have an opinion on the speed of progress
of the mediation scheme.
134. I had no insight into the abilities or resources of Second Sight to form any
belief as to their ability to carry out the work in the mediation scheme.
135. I was not ina position to assess the adequacy of POL’s disclosure to Second
Sight or the SPMs. We only had sight of a limited number of documents and
Page 27 of 38
WITN10990100
WITN10990100
those related to Criminal applicants only. We certainly did not see the totality
of disclosure to a single applicant let alone all of them.
136. I do not have sufficient information to have any views on the access to
adequate representation of the SPMs at the Mediation Scheme.
137. I do not know if the Mediation Scheme operated in such a way as to fulfil its
intended purposes as I had very little part in the process.
138. I am unable to comment on the adequacy of the Mediation Scheme as a
process to facilitate settlement discussions between SPMs and POL. I never
heard of any positively resolved mediations and certainly played no role in
them.
139. I am asked to set out what I consider the successes and failures of the
Working Group and the Mediation Scheme to be. I was not involved in any of
this and am unable to comment on any successes and failures.
140. I am asked if I am of the view that SPMs faced any challenges in seeking to
obtain redress from POL. To an extent I did not have a proper oversight of the
SPM's position as I was only involved in the criminal cases. Plainly the main
difficulty that the SPMs faced in getting redress was the failure of POL to face
up to what was happening and concealing the evidence that it was.
Brian Altman KC Interim Review of CK’s review process (13 August 2013 (sic)),
General Review of Post Office Prosecutions and Review of Post Office Ltd
Prosecution Role
Page 28 of 38
WITN10990100
WITN10990100
141. I amasked to consider Brian Altman KC's “Interim Review of Cartwright King’s
Current Processes.” [POL00006583] dated 2" August 2013 and my response
[POL00066807] dated 13" August 2013.
142. I had no issues with Brian Altman’s Interim Review but it has to be
remembered how fast things were moving in July and August 2013. Simon
Clarke spoke to Dr Jenkins on 28' June 2013, The Second Sight Interim
Review was published on 8" July 2013 and Simon Clarke wrote the “Clarke
Advice” on the 15" July 2013. Brian Altman wrote his Interim Review on the
2°4 August 2013 by which time the Review Process had been set up and the
first advices on disclosure had been written. The weekly POL Horizon call had
also been set up.
143. The purpose of my response, dated 13" August 2013 was not to criticise but
to update, address all of the concerns raised and deal with new ones that had
arisen with all of the new processes.
144. I am asked to address the meeting on 9" September 2013 between Brian
Altman KC, various POL employees, various CK employees and various
Womble Bond Dickinson employees [POL00006769].
145. I am asked what I made of Brian Altman's advice that “Fujitsu should be kept
at “arms length as a third party.” I cannot recall what I thought about this at
the time.
146. I am asked how POL responded to Brian Altman’s recommendations in his
interim review. I cannot say how they reacted. The main liaison between POL
and CK was Martin Smith so any information would have been trickled down
through him.
Page 29 of 38
WITN10990100
WITN10990100
147. The view at the meeting was that the bugs were of very limited effect and that
the system would be given a clean bill of health by an independent expert.
The systems to be put in place were to ensure that any further bugs would be
known about and properly acted upon.
148. I am asked to consider Brian Altman KC’s “General Review of Post Office
Prosecutions” dated 15" October 2013 [POL00006581]. I do not remember
seeing this document at the time and cannot say what reaction I had at the
time if any.
149. I am asked what my view is of Brian Altman KC’s analysis of POL’s strategy
and process of review and the nature and scope of CK’s review. My view is
that he was correct. On what we knew at the time what we were doing was
reasonable. We identified the problem that we thought that we had i.e. Gareth
Jenkins and his non-disclosure of the bugs revealed by The Second Sight
Interim Review. We suspended prosecutions, we set up the Wednesday Hub
and began a review of cases to inform the defence where we thought that
disclosure should have been made. That review was twice stated by Brian
Altman QC to be “fundamentally sound” both in his Interim Review (paragraph
15) and General Review (paragraph 170).
150. I do not know why Brian Altman KC was only provided with two case files at
this stage. Had he wanted more he could have asked for them and would have
been provided with them. I do not see how the provision of further original files
may have affected his conclusion on the identification of flaws in the review
process. He was given the final advices where the reasoning was set out. He
states that he might not have come to the same conclusions as reviewing
Counsel on some of them (paragraph 172). Unless it is suggested that he
Page 30 of 38
WITN10990100
WITN10990100
should have rereviewed each of the cases ab initio then, in my view, his
approach was reasonable.
151. I have been asked to consider the final version of Brian Altman KC’s report
“Review of Post Office Ltd Prosecution Role’, dated 19 December 2013
[POL00112937]. I do not know what input CK had into this report. I had no
input into it myself. I was not in direct contact with Brian Altman KC either by
email or telephone and even with my response to his interim report I asked
that he might be shown it rather than sending it directly to him. As far as I can
recall I have only met Brian Altman at the meeting of 9° September 2013 in
his chambers.
152. Again! am not sure that I have seen this report before. I note that Brian Altman
KC does not criticise the CK Review process having read 31 of our reviews.
153. I am asked for my general view on the content of this report and I think that
had Brian Altman KC known then what has come to light since he wrote the
report his views would have been rather different. This highlights the problems
with an Inquiry such as this one in that it is almost impossible to judge the
actions and opinions of those who did not know then what came to light later.
154. I am asked whether there is anything further relevant to the inquiry's terms of
reference of which I think the Chair should be aware? It is my view that were
it not for Simon Clarke's telephone call to Gareth Jenkins and the action that
he and CK took on that as a result the prosecutions would have continued for
many months afterwards as there was an enormous appetite in POL for them
to recommence.
155. The reality is that there may be grounds to criticize the way that CK conducted
the POL prosecutions however they did fulfil their role as external lawyers in
Page 31 of 38
WITN10990100
WITN10990100
calling a halt to the prosecutions and immediately implementing steps to
address the faults in the Post Office prosecutions as they perceived them at
the time.
Statement of Truth
I believe the content of this statement to be true.
som GRO
Dated:_2 Dyl 2024
Page 32 of 38
Index to First Witness Statement of Harry Bowyer
WITN10990100
WITN10990100
No.
URN
Document Description I
Control Number
POL00180894
Advice on Evidence re R v
Wylie - Harry Bowyer
POL-BSFF-0018957
POL00143377
Email from Andy Cash to
Jarnail Singh, cc Susan
‘Crichton, Hugh Flemington
and Harry Bowyer, re Case
No 21392 - Prosecution v K
ylie
POL-BSFF-0002542
POL00141416
Email from Jarnail A Singh
lo Andy Cash re Horizon
integrity project
POL-0142801
POL00020489
Email chain between Harry
Bowyer, Jarnail Singh,
(Andy Cash and Helen Rose
re Helen Rose disclosures
report (defence expert
reports & disclosure
requests)
POL-0013681
POL00096997
Email chain from Sharron
Jennings to Helen Rose,
Helen Dickinson and Andy
Hayward RE: FW:
HORIZON FUJITSU
REPORT VERY URGENT
POL-0096580
POL00129452
Initial SIFT Protocol/ SIFT
Reviews - Questions
regarding Horizon.
POL-0134936
POL00297631
(Case Review by Harry
Bowyer - Jamie Dixon case
POL-BSFF-0135681
POL00168922
\Case review of R v Tahir
Mahmood Sethi re
disclosure of the Second
Sight Interim Report,
undertaken by Cartwright
King Solicitors
POL-BSFF-0132513
POL00021272
RMG/POL Case Review for
R Nicholas John Mackrill
and Amanda Jane Mackrill
POL-0014464
10
POL00294610
Royal Mail - Case Review
R V Nicholas James Clark
POL-BSFF-0132687
1
POL00294429
ROYAL MAIL — CASE
REVIEW R. v Vijay Parekh
POL-BSFF-0132657
Page 33 of 38
12
POL00021207
Royal Mail Group - Case
Review - R v Gillian
Howard
POL-0014399
13
POL00294501
POST OFFICE —- CASE
REVIEW R -v- WILLIAM
GILES
POL-BSFF-0132666
14
POL00091783
Initial Sift Result Sheet -
Deborah D'Arcy, Post
Office Ltd - Case Review,
R. v. Deborah D'Arcy v
Plymouth Crown Court
POL-0091365
15
POL00021270
RMG Case Review for R v
Jahira Begum. Advice by
Harry Bowyer of Cartwright
King that the matters
identified in SS interim
report should be disclosed
ito the defence.
POL-0014462
16
POL00021285
Email from Harry Bowyer to
Martin Smith RE: Full
Review - Jahira Begum
POL-0014477
17
POL00198128
Case Review R. v Kathleen
Mary Crane Lewes Crown
ourt pre Horizon on line
case
POL-BSFF-0036191
18
POL00294422
ROYAL MAIL — CASE
REVIEW R. v Robert Clay
POL-BSFF-0132653
19
POL00294514
ROYAL MAIL — CASE
REVIEW R. v Daljit Singh
Benning
POL-BSFF-0132671
20
POL00061747
Post Office Ltd - case
Review, R. v Alison
Henderson written by Harry
Bowyer 2014
POL-0058226
21
POL00294518
POST OFFICE — CASE
REVIEW R -v- PETER
HUXHAM
POL-BSFF-0132675
POL00040024
R v Ravinder Manku, Post
Office Case Review
POL-0036506
[24
23
POL00168935
Case Review by Harry
Bowyer re: R v Anthony
John King - Liverpool
Crown Court.
POL-BSFF-0132526
POL00294524
ROYAL MAIL GROUP —
CASE REVIEW R. v
‘Siobhan Sayer
POL-BSFF-0132681
25
POL00294516
ROYAL MAIL — CASE
REVIEW R. v Angela Jane
Hodgson
POL-BSFF-0132673
Page 34 of 38
WITN10990100
WITN10990100
WITN10990100
WITN10990100
26
POL00294503
ROYAL MAIL — CASE
REVIEW R. v Alison
Henderson
POL-BSFF-0132668 I
27
POL00294502
POST OFFICE — CASE
REVIEW R —v- PAULINE
GREENHALGH
POL-BSFF-0132667
28
POL00142328
Post Office Ltd Case
Review - R v Mahesh Patel
& Prakesh Patel
Investigation Stage by
Harry Bowyer
POL-0143582
29
POL00168939
Royal Mail Group (POL)
Case Review - R. v
Mohammed Luqman -
Bradford Crown Court
POL-BSFF-0132530
30
POL00198136
(Case Review R. v Neelam
‘Shanez Hussain
lolverhampton/Derby
‘Crown Court
POL-BSFF-0036199
31
POL00294425
ROYAL MAIL CASE
REVIEW R. v Linda
(Christine Wrigley
POL-BSFF-0132654
32
POL00294520
ROYAL MAIL — CASE
REVIEW R. v Katherine
Jane McQue_
POL-BSFF-0132677
POL00294498
Post Office Case Review -
R v Sunil Patel -
Canterbury Crown Court
POL-BSFF-0132663
POL00294522
POST OFFICE LTD —
CASE REVIEW R -v-
SENAPATHY
PONNAMPALAM
NARENTHIRAN
POL-BSFF-0132679
35
POL00168926
Case Review of R v Ali
Hashimi, by Cartwright King
Solicitors re Disclosure of
‘Second Sight Interim
Report
POL-BSFF-0132517
POL00142279
(Case Study: R v Gregory
Charles Harding - RMG -
case review - Bradford
Crown Court - Pre Horizon
(Online Case - Harry
Bowyer - Cartwright King
Solicitors
POL-0143537
37
POL00294526
ROYAL MAIL GROUP —
CASE REVIEW R. v
Rabina Shaheen
POL-BSFF-0132683
Page 35 of 38
WITN10990100
WITN10990100
POL00294428
ROYAL MAIL CASE ]
REVIEW R. v Timothy St
John Brentnall
POL-BSFF-0132656 I
39
POL00006579
(Case Review of Rv
McDonald
POL-0017664
POL00294499
POST OFFICE — CASE
REVIEW R -v- VALERY
ROSE JAMES
POL-BSFF-0132664
41
POL00168961
POL Case Review of Rv
[Scott Richard Darlington -
Pre-Horizon on-line case by,
Harry Bowyer
POL-BSFF-0132552
42
POL00006581
Review of PO prosecutions
by Brian Altman QC
POL-0017666
POL00147344
Email chain regarding
briefing on Cartwright King
Review work
POL-BSFF-0006467
POL00145821
Emails between Rodric
illiams and others
POL-BSFF-0004948
45
POL00140350
ito Initial Complaint Review
'& Mediation Scheme Post
Office Preliminary
Investigation Report RE:
South Warnborough -
Josephine Hamilton
Cartwright King - Response —
~ POL-0141753
POL00301427
Email chain regarding
briefing on Cartwright King
Review work
POL-BSFF-0139477
47
POL00108263
Initial Complaint Review
jand Mediation Scheme
Report for Tovil Branch, Mr
Prince
POL-0106386
POL00061199
Response To Initial
Complaint Review &
Mediation Scheme Post
Office Preliminary
Investigation Report re:
SPMR Hughie Noel
Thomas
POL-0057678
49
POL00108373
(Cartwright King - Briefing
Note RE Mr Terence
Walters (M006) - Mediation
Scheme document
POL-0106481
50
POL00147935
lo Rodric Williams and
pis from Matthew Harris
jonny Gribben, cc Kathryn
POL-BSFF-0007058
Page 36 of 38
WITN10990100
WITN10990100
lexander and others re
M046 - POL for GC
approval (Incorporating
‘CK's comments) (criminal)
51
POL00142454
Email from Andrew
Parsons to Harry Bowyer,
Martin Smith, CC Jarnail A
‘Singh and others re: Fw:
Post Office Mediation
(Claims - concerning Della
Robinson
POL-BSFF-0001772
52
POL00202683
Bond Dickinson email -
forwarded emails between
PO and Howe & Co re
disclosure in Post Office
mediation claims.
POL-BSFF-0040746
53
POL00141689
Email from Jarnail Singh to
(Andrew Parsons, Rodric
Williams, Jonny Gribben
RE: K Mediation
Responses - Disclosure
Issue [BD-
4A.FID20472253] 41188
POL-0143066
54
POL00046579
Briefing note by Cartwright
King re Prosecution against
Michael Rudkin (Ibstock
SPO)
POL-0043058
55
POL00206241
BRIEFING
NOTEMEDIATION OF
WENDY BUFFREY
POL-BSFF-0044304
56
POL00206240
Email from Jarnail Singh
To: Rodric Williams,
(Andrew Parsons, Belinda
(Crowe and others re Post
Office Ltd Mediation - M041
- Password protected.
POL-BSFF-0044303
57
POL00077936
Mediation Application
Form, Haji Abbas Choudry,
M102
POL-0074499
POL00209747
POL Advice - Criminal
lapplicants to the mediation
scheme convicted of false
jaccounting.
POL-BSFF-0047810
59
POL00046590
Email from Harry Bowyer to
Martin Smith Re Post Office
Ltd - 41712
POL-0043069
60
POL00006583
Brian Altman KC's Interim
Review of Cartwright King’s
POL-0017668
Page 37 of 38
WITN10990100
WITN10990100
Current Processes”, dated
2 August 2013,
61
POL00066807
RESPONSE TO THE
INTERIM REVIEW OF
CARTWRIGHT KING'S
CURRENT PROCESS BY
BRIAN ALTMAN QC
POL-0063286
62
POL00006769
Note of conference with
Brian Altman QC.
POL-0017616
63
POL00112937
Post Office Ltd Review of
Post Office Ltd Prosecution
Role - Altman QC
POL-0110333
Page 38 of 38