Opening Statements - Bereaved Families and Justice Campaigns

14 October 2025 · Leslie Thomas KC, Rajiv Menon KC, Ifeanyi Odogwu, Dave Morris, Chairman · 2:59:16
▶ Watch on YouTube Open in interactive viewer

Afternoon session of opening statements from lawyers representing multiple core participants including Leslie Thomas KC for bereaved families, Rajiv Menon for Duwayne Brooks, Ifeanyi Odogwu for Dr. Neville Lawrence, and Dave Morris self-representing. Powerful testimony about how the SDS spied on grieving families, victims of police violence, and justice campaigns.

Key moments

Full transcript

00:33:22 Mr. Thomas, good afternoon. Uh, you can hear me? Okay, I can indeed. Very well, sir. The police are the public and the

00:33:37 sir. The police are the public and the public are the police. The police being the only members of the public who are paid to give full-time attention to duties which are incumbent on every citizen in the interest of community welfare and existence.

00:33:50 welfare and existence. Sir Robert Peele's seventh principle of policing.

00:33:54 policing. However, as the evidence in this inquiry shows, the SDS forgot they were citizens in uniform and instead treated fellow citizens as enemies.

00:34:05 enemies. This inquiry was convened because our democracy recoils at the notion that those who challenge the state can be spied upon. So John, the statements you will hear

00:34:18 So John, the statements you will hear today are not simply historical records. They are the lived experience of citizens who sought justice and found themselves under surveillance for doing so.

00:34:27 so. Behind each intelligence file is a mother berieved, a brother grieving, a son traumatized,

00:34:38 son traumatized, people whose lawful campaigns were treated as threats. These opening remarks gather those voices and lay before you the pattern of fabrication,

00:34:54 fabrication, intergenerational targeting, trauma, and mission creep. We say the evidence plainly shows You see, people were placed under covert scrutiny not for any threat they posed,

00:35:05 scrutiny not for any threat they posed, but for daring to hold the Metropolitan Police to account. So these are the opening statements of six clients represented by Bat Murphy solicitors, Ma Simpson, Bernard Renick,

00:35:20 solicitors, Ma Simpson, Bernard Renick, Lee Lawrence, Winston Silkot, SH Sir Dr. Graham Smith, and Mark Metaf. My name is Leslie Thomas of King's Council and I'm leading Sam Jacobs.

00:35:35 Council and I'm leading Sam Jacobs. Mer Simpson, the mother of Joy Gardner, Bernard Renwick, the brother of Roger Sylvester, Lee Lawrence, the son of Cherry Gross, were each the subject of reporting in connection with campaigns for justice

00:35:47 connection with campaigns for justice for the death of a family member killed in contact with the police. Winston Silk was the subject of reporting as the victim as of a miscarriage of justice after he was falsely convicted and subsequently

00:36:01 falsely convicted and subsequently acquitted of the murder of PC Blade lock.

00:36:03 lock. Dr. Graeme Smith founded the Hackne Community Defense Association, the HCDA. Mark Metaf was centrally involved in the Colin Roach Center.

00:36:16 Colin Roach Center. Each was the subject of wholly unjustified undercover reporting in the context of pursuing entirely lawful and peaceful means of seeking accountability.

00:36:27 accountability. Four of those whose state whose half statements are made and Stafford Scott who has provided a statement are black.

00:36:42 who has provided a statement are black. None have been accused of criminality or breaches of public order in the furtherance of their campaign. All were involved in legal proceedings involving the Metropolitan Police.

00:36:54 involving the Metropolitan Police. These are not features unique to our client group. They are shared by a number of non-state court participants across this inquiry.

00:37:11 We set out a number of introductory themes before turning to the individual statement open statements. From their stories, recurring patterns emerge. These p these themes are not academic

00:37:22 These p these themes are not academic abstractions. They are the fingerprints of a policing unit that has lost sight of its purpose. First, a feature rising across numerous

00:37:34 First, a feature rising across numerous reports in relation to justice campaigns is fabrication and falsehood. reports made on the quote friends of Roger Sylvester, a group that never existed, the HCDA was falsely described as an

00:37:48 the HCDA was falsely described as an anarchist from Trevor Morris claims to have dramatically intervened in a meeting regarding the death of Joy Gardner and quote stopped a riot. Yet the meetings were focused on peaceful campaigning.

00:37:59 campaigning. Ma Simpson's campaign was falsely reported to to be run by a member of the SWP.

00:38:08 SWP. Stafford Scott is falsely accused of threatening civil unrest. The Colin Roach Center was falsely reported to have been planned attack uh to planned to attack a union unanist politician.

00:38:23 to attack a union unanist politician. Dr. Graeme Smith was falsely reported to have received the gift of a motorbike from a client who had successfully sued the commissioner. HN15 Mark Jenn's falsehood including

00:38:37 HN15 Mark Jenn's falsehood including reporting on matters for which he he was the agitator and the isolated instance of violence which can be recalled by M Mark Metaf were those precipitated by Jenna himself.

00:38:53 himself. This reporting may have some element of bias and prejudice that anyone politically to the left and/or black people may be properly considered

00:39:09 people may be properly considered dangerous or at least hopelessly open to exploitation. Indeed, as HN43 Peter Francis describes, HN86 view of black justice campaigns were that

00:39:26 that they were unable to think for themselves and therefore they must all be led by some more radical leftwing groups to advance their own agendas. However, there's also deliberate exaggeration. It's difficult to align open an explanation for it other than

00:39:48 open an explanation for it other than deliberate exaggeration as a pretext for ongoing surveillance and justifying the ongoing work of the SD. It was described in the SDS closing report as I quote padding out an otherwise redundant operational deployment.

00:40:01 operational deployment. This was a unit whose activities had become wholly divorced from any possible legitimate purpose and its continued existence was served by fabricating

00:40:14 existence was served by fabricating prospects of subversion and disorder where there was none. Let me turn to the second theme intergenerational surveillance and legacy targeting. In earlier tranches of the inquiry,

00:40:27 In earlier tranches of the inquiry, it has seen the reporting on uh Celia Stubs over a period of decades. Decades after Blair Peach's death, she was still

00:40:41 after Blair Peach's death, she was still reported on in this tranch. The evidence before the inquiry includes the reporting following the shooting of Cherry Gross in 1985, witnessed by Lee Lawrence as a young boy.

00:40:58 Lawrence as a young boy. to Lee Lawrence's prosecution in 2000. Surveillance that spanned 15 years across two generations. Winston Silkcott's campaign was monitored and reported on long after his acquitt. We see children who have

00:41:09 acquitt. We see children who have suffered the terrible trauma at the hands of the Metropolitan Police have that trauma compounded by the targeting of covert intelligence gathering years

00:41:27 of covert intelligence gathering years later. Joy Gardner's son was 5 years of age when he witnessed her suffocation and Lee Lawrence was 11 when he witnessed his mother being shot. It reveals a pattern.

00:41:39 It reveals a pattern. Once targeted, always targeted. Families were treated as suspect categories across decades, embedding institutional mistrust and compounding trauma. Let me turn to the third theme,

00:41:52 Let me turn to the third theme, trauma and secondary victimization. The family justice campaigns not only have in common that they were each seeking justice, they also have in

00:42:06 seeking justice, they also have in common that they were spied on in their grief.

00:42:13 grief. The spying even extended to UCOs attending memorial services and reporting on funeral services. This pattern was familiar to the SDS with uh UCOs attending the funeral of Blair Peach.

00:42:30 Blair Peach. SCS intrusion towards families in grief and who were the victims of injustice risk retraumatizing families already suffering from state inflicted harm and in the event has done so. This theme is distinct from racism or

00:42:43 This theme is distinct from racism or other lack of public order justification

00:42:55 other lack of public order justification for it shows a disregard to the sanctity of mourning and private life. It raises the ethical question. Son,

00:42:59 Son, what kind of police force spies on grieving families? The fourth theme, the blurring of police functions and abandoning

00:43:13 abandoning even a pretense of policing public disorder.

00:43:15 disorder. The SCS repeatedly strayed into reporting that it could not even claim

00:43:28 reporting that it could not even claim to be related to public order. notably reporting on civil claims and defense strategies and the monitoring of uh members of parliament and elected officials. Even a pretense of policing public disorder was abandoned. This mission creeped reveals covert

00:43:40 This mission creeped reveals covert powers being deployed to protect the institution of the Metropolitan Police from accountability. It leaves those reported on considering just how corrupt the SDS re really

00:43:54 just how corrupt the SDS re really became. Many core participants describe a phenomenon of curious burglaries or entries into their homes which appear more consistent with the taken of information than the taken of property.

00:44:13 information than the taken of property. This concern features in the evidence of the HCDA, Bernard Renwick and Winston Silk. It's a concern raised by other core participants in their witness evidence. The question arises as to whether the SCS had any role to play in this behavior.

00:44:28 this behavior. Fifthly, complicity of managers and the lack of oversight. It's an obvious cause for concern that the problem was known to and sanctioned and approved by managers who sign reports and failed to filter and

00:44:41 reports and failed to filter and disapprove of racist language or privileged material. They acted in plain defiance of home office guidance and indeed any basic sense of a of a proper functioning of

00:44:57 sense of a of a proper functioning of the police. Barot ran up the chain of command.

00:45:02 command. Six. The constitutional significance of spying on justice campaigns. Some of the subjects of reporting were litigants in civil proceedings or supported those litigants. Indeed, they appeared to have been the target of

00:45:14 appeared to have been the target of reporting precisely because of their involvement in litigation involving the police. And it appears the interests of the Metropolitan Police Service in resisting it. In so doing, the SDS

00:45:31 resisting it. In so doing, the SDS surveillance interfered with access to justice, a constitutional right. Surveillance of legal processes themselves undermines the rule of law by tipping the scales in litigation.

00:45:46 Seventh, chilling effect on the democratic participation. the the the penacious effect of surveillance of accountability groups and justice campaigns was and is a suppression of lawful democratic engagement

00:46:04 lawful democratic engagement that was recognized a decade earlier in the 1984 home office response to the special branch report on police accountability groups in which the MPS was directed that it should not be investigating groups or individuals quote because they are highly critical

00:46:19 quote because they are highly critical of the police. But we see in this tranch that it continued determinedly and prolifically a decade or more later.

00:46:31 prolifically a decade or more later. Citizens have learned that campaigning against the police misconduct risk illfiltration and monitoring. Eighth, smearing in the media. It's a

00:46:43 Eighth, smearing in the media. It's a common experience of families briefed by deaths following police conduct that in the aftermath they and or their loved ones are demonized in the press. Winston Silkot was branded a violent and demonized at the time of his trial.

00:46:55 demonized at the time of his trial. Roger Sylvester's descriptions of him being violent and strong and a drug addict. Joy Gardner was sim similly characterized as violent and dangerous. That well-known trope, the big black

00:47:10 That well-known trope, the big black dangerous person sharing the color of my skin makes me extra dangerous. You see, there's a suspicion that this common experience is fueled by MSP briefings. The obvious concern is that

00:47:23 briefings. The obvious concern is that this is this partly explains the SDS's avid interest. any information on these campaigns was good information because it might be you that it could be used by

00:47:35 it might be you that it could be used by the MPS in seeking to diminish campaigns for accountability. Sir, the inquiry must consider whether the SCS's intelligence directly or indirectly fueled media disinformation

00:47:50 indirectly fueled media disinformation campaigns amplifying stigma and harming families.

00:47:54 families. 9th missing reports and missing witnesses. Both Trevor Morris and Mark Jenner have stated that they cannot remember much of the detail of the events being considered and that they submit that

00:48:06 considered and that they submit that many they submitted many more reports that have been disclosed. UCOs and the SCS documents serve as substantially incomplete sources to understanding why groups are targeted, the extent of UCO reporting, and

00:48:19 the extent of UCO reporting, and crucially what was done with the intelligence gathered, the refusal of

00:48:30 intelligence gathered, the refusal of HN81 Dave Hagen to give oral evidence has left these witnesses deeply frustrated. The truthfulness of of his justification for reporting on family justice campaigns is strongly contested. His

00:48:46 campaigns is strongly contested. His refusal to give oral evidence contrasts with the open and forthright evidence enga uh engagement by those who were spied upon.

00:48:57 spied upon. I now turn to my opening statements. Opening statement of MNA Simpson. MNA Simpson is the mother of Joy Gardner. Joy traveled to the United Kingdom to join her mother and the rest of her family in 1987. She had a brief

00:49:09 of her family in 1987. She had a brief and unsuccessful marriage to a British citizen and the Home Office sought to deport her. Can we put our image MS uh two please?

00:49:29 Is the image up?

00:49:40 Yes, it is. Thank you. You can take it down now. Thank you. MNA describes Joy as a warm, caring

00:49:51 MNA describes Joy as a warm, caring person, a mother of two children. She was studying at university to try to fulfill her dream of becoming a journalist. She was an active member of her local church, which she regularly attended with her young son. So, on the morning of the 28th of July, 1993, Joy was at home in Crouchen with

00:50:08 1993, Joy was at home in Crouchen with her then 5-year-old son. Joyy's home was raided by Metropolitan Police Officers, the so-called aliens deportation group. They had orders to detain, deport Joy

00:50:19 They had orders to detain, deport Joy and her son. A police officer unplugged her phone to prevent her from calling her solicitor. Joy was then forced face down on the floor with her hands were then bound to her side with a leather belt to which she was handcuffed. Her

00:50:34 belt to which she was handcuffed. Her legs were strapped together. An officer then wound elastic adhesive bandage around her head several times. A second bandage was wound around her head in the opposite direction. She was then gagged

00:50:47 opposite direction. She was then gagged with a total of 13 ft of surgical tape. Her son saw this some of this restraint and heard all of it.

00:51:07 and heard all of it. Joy was then taken to hospital in a coma caused by a lack of oxygen. She died from exfixiation caused by that restraint. 1995, three officers of the alien deportation group stood trial on charges of manslaughter. They were acquitted.

00:51:20 They were acquitted. There has never been an an inquest or public inquiry into Joyy's death. MNA Simpson has always sought to honor her daughter by campaigning for the truth and for accountability.

00:51:35 and for accountability. Her struggle has not ended that. That is the context for the campaigning work carried out by MNA Simpson through the justice for joy campaign. Can we put up image MS1 please?

00:52:00 Thank you. Can take that down. Joyy's death was a key priority at the very highest levels of the Metropolitan Police. Baron Condom, the commissioner at the time, described Mark described to Mark Ellison his shock at the

00:52:12 Mark Ellison his shock at the involvement of the aliens deportation group. He described pressing the home

00:52:24 group. He described pressing the home office for an independent inquiry after the police officers were acquitted and his concern that the incident might precipitate riots. Reports were filed upon ma Simpson by at least four SDES officers. We can we see the theme of fabrication.

00:52:43 We can we see the theme of fabrication. HN7H of Morris claimed that the campaign was being run by a prominent member of the Socialist Workers Party. Mer Simpson refuted that entirely. The individual attended meetings but did not influence the campaign and

00:53:01 but did not influence the campaign and indeed MNA would not even have said that he was part of it. Trevor Morris also claims to have spoken at a campaign meeting in Tottenham Town Hall and in so doing that he stopped a riot. Ma Simpson has no memory whatsoever of that event

00:53:17 has no memory whatsoever of that event and she doubts it's true. She does not wish to give it the dignity of a response.

00:53:24 response. You you you may find it striking that at no point does Trevor Morris nor any of his managers who commended his work appear to have considered the ethics of a serving police officer using his covert identity to speak at a public meeting about the death of a person at

00:53:42 meeting about the death of a person at the hands of the police, the very same police force that this officer is a member of.

00:53:54 member of. We also see this the theme of smearing. The claim by HN43 uh Peter France SDS officers were specifically tasked to smear the Lawrence family and Joy Gardner resonates with MNA Simpson's experience in relation to the events following Joyy's death. Mners describes her shock and disbelief at hearing

00:54:08 her shock and disbelief at hearing officers claim that uh when they were on trial.

00:54:12 trial. uh she has provided to the inquiry an academic article outlining the derogatory and untrue reporting in the media on her daughter. She harbors a concern that at least part of the motivation for targeting the campaign

00:54:26 motivation for targeting the campaign was to seek an opportunity to undermine it if necessary by smearing Joyy's character. Ma Simpson explains that the campaign was a group of family and friends who came together to seek justice. MNA spoke about her daughter's

00:54:41 justice. MNA spoke about her daughter's uh to to educate the public. She sought support from local members of parliament. She publicized everything. She deplored violence despite the fanciful speculation of riots and

00:54:56 fanciful speculation of riots and disorder. Her campaign and campaigning was peaceful and sought to bring the local community together. Newspaper reports of the time report that MNA Simpson and Bernie Grant MP calling for calm. Her campaigning was never influenced or manipulated by political

00:55:11 influenced or manipulated by political organizations. And yet, every speech she made, every plan she made, and every event she attended to was reported on by SDS officers uh and filed by special branch. It had no justification.

00:55:24 branch. It had no justification. We'll leave the last word of this statement to Ma Simpson. Quote, our aim was not to make trouble. It was just to

00:55:37 was not to make trouble. It was just to get a voice as we needed justice for Joy for the way she was killed. We still need that justice. Bernard Renwick's opening statement. Bernard is the brother of Roger Sylvester. His participation in the

00:55:50 Sylvester. His participation in the inquiry has been been on behalf of his family and in particular his parents Sheila and Roert. Sheila Robert were born in Grenada and came to this country

00:56:02 born in Grenada and came to this country in the early 60s living in North London. Sheila worked in the maternity unit at the Wittington Hospital until she retired and Robert was a carpenter for Islington Council before becoming a back black cab driver. They had five

00:56:15 black cab driver. They had five children. Can we put up BR uh number one please? BR1.

00:56:24 That's a picture of Roger. Thank you. You can take that down. Roger was born at the Wittington Hospital in 1968. After finishing school, he commenced the course at North London College, but had to leave after

00:56:36 London College, but had to leave after he suffered a serious assault in 1986. Roger began to experience mental health difficulties after that assault. With the support of his family and friends, he continued to work and for a short

00:56:53 he continued to work and for a short while he was a computer operator for the Metropolitan Police. Tragically, Roger Sylvester was declared dead on the 18th of January, 1989. He died as a result of the prolonged

00:57:05 He died as a result of the prolonged restraint by eight police officers one week earlier at St. An's Hospital in Tottenham. At the inquest into his death in 2003, a jury returned the verdict of unlawful killing. The Inquisition

00:57:22 unlawful killing. The Inquisition describes the jury's findings, including that more force was applied than reasonably necessary. That verdict was later quashed by the High Court. Bernard Renwick's family issued a statement expressing their

00:57:34 issued a statement expressing their distress at the judgment. In June 2005, the CPS decided not to prosecute the officers, a decision that the family that the family felt had denied another jury the opportunity to consider the facts for themselves.

00:57:46 facts for themselves. Bernard describes his in his statement that the fact that the the death came at the hands of the police made it even

00:57:58 the hands of the police made it even more traumatic and difficult to digest. His statement goes on to describe how the family's trauma was made worse by police officers seeking to cast Roger in a bad light. Press reports quoted members of the police federation and

00:58:12 members of the police federation and Metropolitan Police describing Roger as violent, strong, drugaddicted. This was the background to the family's decision to start the Roger Sylvester Justice Campaign initiated by two of his

00:58:25 Justice Campaign initiated by two of his cousins. The first meeting was a meeting for the family held at the home of a cousin. It was always a family campaign led by the family and not by political activists. While the campaign has never ended, its period of intense activity

00:58:44 ended, its period of intense activity was between 1999 and 2005 while various legal proceedings were taking place. Bernard Renwick describes regular meetings, usually at the home of a family member, sometimes as often as three times a week. Events such as memorials, vigils, and demonstrations

00:58:56 memorials, vigils, and demonstrations were held. The first event at the end of January 1999 was a march from Roger's home to Tottenham Police Station where a vigil was held. All of the events were

00:59:08 vigil was held. All of the events were publicized as widely as possible through websites, leaflets, emails, and word of mouth.

00:59:11 mouth. Sir, the first SDES report concerning Roger uh the Roger Sylvester campaign was made on the 25th of January 1999,

00:59:28 was made on the 25th of January 1999, the day after the vigil. It was prepared by HN81 Dave uh Hagen. Bernard Renick Renwick recalls the march. Well, he disputes Hagen's assessment that the march was predominantly made up of black youth. He describes 250 people being a

00:59:42 youth. He describes 250 people being a mix of all ages with the march being led by his parents and their pastor. He's been able to produce a picture of his parents at the march. Can we pull that up, please? That's BR2, please.

01:00:16 Thank you. You can take that down. A further report was filed the following week. In the report, uh Dave Hagen has started refer to the friends of Roger Sylvester. He describes complicated machinations between movement for justice, the monitoring group, the new monitoring project. He described MNA Simpson, the mother of Joy Gardner,

01:00:28 Simpson, the mother of Joy Gardner, having been having contacted the friends of Roger Sylvester. Bernard does not recognize the events described in that report. He has never heard of the friends of Roger Sylvester.

01:00:40 heard of the friends of Roger Sylvester. He is clear that the family never worked with MFJ. He refuts the idea that Ma Simpson acted as a conduit between his family and the MFJ.

01:00:51 family and the MFJ. She was another bereaveved mother with shared experiences. The reports give a fant uh fantastical and wholly inaccurate count of a supposed alliances and political infighting. It was a campaign for

01:01:06 infighting. It was a campaign for justice run by family members and devoid of any political interference. The inquiry has been addressed on the issue of racism both at an institutional level and on the part of individual officers.

01:01:20 officers. Sir, I urge you to listen to the voices of those affected to understand the pervasiveness of this culture and the impact on those affected by it.

01:01:34 impact on those affected by it. Bernard describes the racism inherent in the police response to his brother. As he puts it, and I quote, "Rather than recognizing he was a vulnerable young man showing signs of mental illness who needed their help, they saw him as a black man who posed a danger."

01:01:53 He recognizes that same response in the intelligent reports and policing of the campaign. This runs through the concoction by Dave Hagen of political

01:02:06 concoction by Dave Hagen of political maneuvering between bereieved families and through his misdescription of the nature of the campaign and those who supported it. It resulted in right police attending Roger Sylvester's inquest

01:02:14 inquest to be met by family holding hands in a prayer circle. So it was, you could just imagine just how dehumanizing and distressing that

01:02:27 how dehumanizing and distressing that was, that response by the police to a grieving family at his inquest.

01:02:35 I turn to the opening statement of Lee Lawrence.

01:02:40 Lawrence. Lee Lawrence is an award-winning author. His book, The Louder I Will Sing, a story of racism, rights, and redemption, was awarded the Costa Prize in 2020.

01:02:51 was awarded the Costa Prize in 2020. He's the chief executive of the Cherry Gross Foundation, which he founded to honor his mother. The foundation aims to tackle youth violence through a range of um disciplines from education and

01:03:04 um disciplines from education and training to improving institutional practices to adapting storytelling resources through a restorative justice. On the 12th of October 1999, Lee

01:03:15 On the 12th of October 1999, Lee witnessed the racist attack. As he was driving home, he saw a young Somali boy being chased and attacked by a gang of white youths.

01:03:29 white youths. He stopped his car, called the boy over. He was told that the the asalants were racist. Lee gave the asalants a warning to leave the young person alone.

01:03:41 to leave the young person alone. They were verbally abusive to Lee as he left.

01:03:46 left. Following that incident, Lee was asked to attend an interview at the police station where he was charged by the Metropolitan Police with assault. The asalants fabricated an allegation

01:04:02 asalants fabricated an allegation against Lee and the police chose to act on their account. This was the first consequence for Lee of the inter of intervening to prevent a racist attack. The second consequence was that an undercover police officer

01:04:16 police officer uh uh HN81 Dave Hagen began reporting on his case. The reports disclosed to Lee in the beginning of March 2000. Um, let me read that again. The reports

01:04:29 me read that again. The reports disclosed to Lee begin in March um 2000. The first SDS report on him wrongly asserts that Lee had approached the movement for justice for support and states that there was an attempt to turn his case into a race issue. The report

01:04:45 his case into a race issue. The report includes details of Lee's solicitors and the actions being taken to secure evidence relevant to the defense. A telling lie in the report is a reference to Lee as Lee Gross, the son of Cherry

01:04:56 to Lee as Lee Gross, the son of Cherry Gross. The Gross family were a target.

01:05:07 Gross. The Gross family were a target. More than a decade earlier, Cherry Gross had been shot in her own home by police officers, and the SDS had shown an interest in her case over many years. Can we put up image LL1, please?

01:05:28 There's a picture of Cherry. Thank you. We can take that down. Thank you very much.

01:05:34 much. On the 28th of September 1985, Lee, aged 11, along with his sister, was was asleep in his parents' bedroom. He was awoken by a loud noise. He saw his

01:05:46 awoken by a loud noise. He saw his mother get out of bed to investigate, at which point she was shot by a police officer.

01:05:48 officer. Lee was hysterical with fear, but told to shut up by the officer. Can we put up image LL3, please?

01:06:12 Thank you. You can take that down. The police permitted a press photographer to enter the house and photograph Lee and his sisters in their distress while traumatized by these

01:06:25 distress while traumatized by these events. Lee describes a childhood shaped by these events and he and his siblings became the main carers for his mother who having suffered paralysis below the waist as a result of the shooting was confined to a wheelchair.

01:06:40 confined to a wheelchair. Lee did not feel able to leave home until he was 27 due to his caring responsibilities. He continued to see his mother every day until her death in 2011. Can we put up image LL2 please?

01:07:05 Thank you. We can take that down. After his mother's death, Lee chneled his pain into setting up a charity in her memories, followed by a motility taxi firm. He fought for an inquest into her death, and this was eventually

01:07:16 her death, and this was eventually granted. The inquest took place in 2014. This was the first occasion that Lee and his sisters were able to see the full evidence of the events on that night in September 1985.

01:07:30 September 1985. The inquest criticized the inquest jury criticized numerous failures in the planning and conduct of the police raid. Sir Bernard Hogan how commissioner at

01:07:43 Sir Bernard Hogan how commissioner at the time issued an unreserved apology. While this was meaningful for Lee and his family, it was an apology that his mother never received. The first SDS um

01:07:55 mother never received. The first SDS um report that referred to Cherry Gross was filed less than 6 weeks after she had been shot. The SDS annual report in 1985 contains a list of groups that were effectively penetrated by the SDS

01:08:12 effectively penetrated by the SDS officers in the previous year. This list includes the gross family support campaign

01:08:16 campaign chair. You will recall the evidence of HN115

01:08:18 HN115 Tony weight that penetrated means an officer was in an organization and that one visit was not enough. There had to be repeat reporting or attendance.

01:08:33 be repeat reporting or attendance. All of this has come as a surprise to Lee Lawrence. He was a child at the time but does not remember a definable

01:08:44 but does not remember a definable campaign. He simply recalls that some close family members and friends organizing meetings in the local community for a short period of time. It is this history that provides the

01:08:56 It is this history that provides the context to a report by the SDS officer in two in 2000 some 15 years after Cherry Gross had been shot dealing with the prosecution of Lee. The inquiry has

01:09:10 the prosecution of Lee. The inquiry has disclosed a total of 10 further reports filed by Hagen on Lee's trial in a quiddle. Of note is firstly in two of the reports Lee Lawrence is portrayed as the perpetrator as alleged by the white youth. It's

01:09:24 as alleged by the white youth. It's unclear why Hagen has repeated these false allegations and from where he obtained them. Secondly, two of the reports accuse Lee and the uh MFJ of

01:09:38 reports accuse Lee and the uh MFJ of seeking to turn the case into racial incident. As Lee states, this is an absurd comment comment as it was a racial incident from the outset. He had intervened to stop a racist assault and had himself been charged with racially

01:09:53 had himself been charged with racially aggravated assault. Thirdly, a number of reports contain information concerning the legal process. The initial report gives details of solicitors who were act acted for him. Two reports um refer to details of the defense case following

01:10:08 details of the defense case following the acquitt. Two reports are concerned with the possibility of civil action against the Metropolitan Police. Lee Lawrence has dealt with the most unimaginable trauma and has put his experience to con constructive use both

01:10:19 experience to con constructive use both for himself and the wider community. The contrast between his commitment to using law to achieve accountability and the

01:10:30 law to achieve accountability and the nefarious actions of the SCS officers could not be starker. Lee's second book, The Color of Injustice, has just been published. In this book, Lee explores the impact of his mother's shooting on him and the

01:10:46 his mother's shooting on him and the family's campaign uh against a b broad broader backdrop of racism in the criminal justice system stretching back to the 18th century. On the 30th of September of this year,

01:10:58 On the 30th of September of this year, The Guardian published an interview with Lee. On being asked about Lee's work with the Metropolitan Police and the theme of how rare it is for the police to be held accountable, he is quoted as saying,

01:11:13 he is quoted as saying, "We speak about culture a lot within the Met and if the officers are doing wrong and not being penalized for it, and some are actually being promoted for it."

01:11:24 are actually being promoted for it." What type of culture is that fostering? That it's okay to do the job with no integrity. What I've realized being on the opposite side is that there's a damage limitation perspective from the Met as an organization.

01:11:44 Met as an organization. Sir, we ask you to consider whether that damage limitation perspective was the driving factor, if not the only factor in such persistent interest in campaigns for justice and police accountability.

01:11:57 justice and police accountability. I now turn to the opening statement of Winston Silkot. In October 1985, PC Heath Blake was killed during disturbances on the Broadwater Farm estate in Tottenham.

01:12:08 Broadwater Farm estate in Tottenham. The disturbances occurred after local woman Cynthia Jarrett died from a heart attack after four police officers

01:12:19 attack after four police officers entered her home. In March 1987, Winston along with Mark Braithweight and Engin Ragit were convicted of the murder. He was sentenced to life imprisonment. In

01:12:38 was sentenced to life imprisonment. In fact, Winston and his codefendants were all innocent. Winston's conviction was based solely on fabricated confession recorded in Detective's Chief Superintendent Melvin. The convictions for all three men were eventually quashed by the court of appeal on the 5th of December 1991. He was represented by another core

01:12:49 was represented by another core participant in this inquiry, Michael Mansfield of King's Council. The Court of Appeals stated in its judgment that, and I quote, "The text of this interview represents the totality of the evidence

01:13:03 represents the totality of the evidence against Silkot on the charges of murder and riot. He did not appear in any of the thousands or so photographs taken at the scene on the night of the riot. Neither was there any scientific

01:13:18 Neither was there any scientific evidence relating to clothing, footwear, or blood staining. Nobody gave evidence against him. End of quote. Evidence presented to the court of appeal established that the unsigned uh statement contained the

01:13:30 unsigned uh statement contained the confession was falsified. Not only had it been taken in the absence of Winston's solicitor, deliberately concocted pages were inserted into it. In giving judgment, Lord Justice

01:13:45 In giving judgment, Lord Justice Ferguson stated, "What is the effect on of that evidence? It clearly destroys the basis of the crown's case." During the time they were wrongly convicted, the families and friends of the three men worked tirelessly to uncover this miscarriage of justice.

01:13:59 uncover this miscarriage of justice. They were frequently referred to as the Tottenham free. Their campaigning was supported by a very broad spectrum of society from members of the public to politicians and trade unions. The local community took a particular interest in

01:14:13 community took a particular interest in and work of the broadwater farm defense committee was addressed through the evidence of Stafford Scott in tranch 2 of this inquiry. Winston's brother George Silcot was Winston's main source of support. He lobbied on Winston's

01:14:26 of support. He lobbied on Winston's behalf, spoke at public meetings, and even ran for elected office in his efforts to fight this injustice. He was often aided by a friend of Winston called Delroy Lindo. Winston was not released until after uh sorry, Winston

01:14:42 released until after uh sorry, Winston was not released after his successful uh appeal. While awaiting trial, Winston had been convicted of a separate murder. Winston has always maintained that he acted in self-defense in that case. He

01:14:55 acted in self-defense in that case. He explains his concerns that the trial was adversely affected by the Metropolitan Police officers who put in place

01:15:05 Police officers who put in place exceptional security measures, attending all hearings, and even cheered in court on his conviction. The consequences of his second conviction meant that uh Winston remained in prison until October 2003.

01:15:13 2003. His brother George continued to campaign on his behalf and the campaign became known as the Winston Silkcott Defense Campaign. After his release, a BBC news quoted the vice chair of the National Assembly Against Racism, saying, quote,

01:15:28 Assembly Against Racism, saying, quote, "Just as he is being released, the media are showing a picture of Winston that makes him appear as someone who should be feared. This is an image that has been built up over the years, and I think there is a belief amongst uh

01:15:43 think there is a belief amongst uh police officers that he is guilty of the Blake Lock killing even though he was cleared in a course of law. There are three striking facts that emerge from the SCS reports. The first is none of the key people who played a role in the campaigns were involved in

01:15:57 role in the campaigns were involved in any left-wing politics and yet they were the subject of reporting by SDS. Reports filed upon George Silcot Delo and Stafford uh Scott with alarming regularity.

01:16:11 regularity. Second, there was never a single public order concern associated with their campaigning. Third, the reporting on the campaign continued long after um Winston's conviction for the murder of PC Blake lock was quashed.

01:16:27 PC Blake lock was quashed. The reports filed on Winston commenced shortly after his arrest and they continued until at least 2001, more than a decade after the crushing of his

01:16:38 a decade after the crushing of his conviction. Reports on him, his brother, and the campaign were filed by at least six different undercover officers. At one point H and five John um Dyn moved into Helen Steele's home. Her garden backed onto the Silkot family home.

01:16:49 backed onto the Silkot family home. There were num there followed a number of unexplained incidents at the family home where items were moved or disturbed. The reports go beyond detailed support

01:17:02 The reports go beyond detailed support offered to the campaigning by political groups. They touch upon the appeal hearings in Silkox's case and the trial of Detective Chief Superintendent Mvin, the officer who was prosecuted and acquitted for falsifying the evidence

01:17:13 acquitted for falsifying the evidence against him. They include personal inj

01:17:27 stood for election to his local council. This was the subject of an intelligence report. Details of Winston's contact with his friend Delroy Lindo are reported on by Dave Hagen, including the content of telephone conversations made by Winston from prison.

01:17:40 by Winston from prison. It is even stated by HN81 Dave Hagen in his hear that he provided information for the police to defend the Lindo civil proceedings against the commissioner, but his information could not be used. It is telling that a UCO reported

01:17:57 It is telling that a UCO reported intelligence apparently knowing that the purpose of the reporting it was in resisting civil proceedings. There is clearly and was clearly no justification for this reporting but

01:18:08 justification for this reporting but Winston Silkot would like to understand its purpose and its motivation. HN43 Peter Francis's evidence on the issue requires close scrutiny. On the

01:18:20 issue requires close scrutiny. On the one hand, he states that his reporting on the campaign came about because George Silkot appro approached the Y for help. He describes this as reporting on a group without illfiltrating it. However, he also claims that he was

01:18:35 However, he also claims that he was specifically tasked at various points to report on singleisssue campaigns, including the Winston Silcot defense campaign and the Broadwater Farm Defense Committee. Moreover, it should be noted that the reporting on George Silcot did

01:18:46 that the reporting on George Silcot did not start and uh when he was in contact with the Yre. This reporting had already

01:18:57 with the Yre. This reporting had already been going on for for a decade. The more compelling explanation may be that the SDS long-standing interest in in the ability to infiltrate justice campaigns, particularly black justice campaigns. When assessing the motivation for reporting upon Winston's,

01:19:10 reporting upon Winston's, sir, you may wish to have in mind a statement issued by the Metropolitan Police in December 1999 after the commissioner settled the civil claim

01:19:21 commissioner settled the civil claim arising from the overturn conviction. The statement indicated a continued antipathy towards Winston Silk as an and also an institutional reluctance to accept the clear and unambiguous findings of the court of appeal. It

01:19:33 findings of the court of appeal. It said, and I quote, "In settling this action for £50,000, we have not admitted liability. We recognize that this

01:19:44 liability. We recognize that this decision will cause disappointment and distress to many officers in the Metropolitan Police Service, especially those on duty on the night, most of all to Keith Blake's widow, Elizabeth." Close quote.

01:19:55 Close quote. In his witness statement, Winston describes how disturbed and vulnerable he feels as a direct consequence of the reporting on him and his family. His concern has always been that he will be vilified and targeted by the police for

01:20:13 vilified and targeted by the police for a crime he did not commit. He describes that feeling that the that the police have a target on his back and states that they sought to create their own false impression of his campaign so that any action they took against him would be justified. As he puts it, and I quote, "There was no justification for

01:20:27 quote, "There was no justification for them being there and writing reports at all. If you have someone under surveillance and they've not been doing the things that you're worried about, why not just leave them alone?" But they continued and continued and continued

01:20:38 continued and continued and continued even after my conviction was quashed. I now turn to the opening statement of Dr. Graeme Smith. Dr. Graeme Smith is a recently retired

01:20:49 Dr. Graeme Smith is a recently retired uh lecturer having taught for many years at the University of Manchester where he specialized in police counterterrorism and human rights law. He has particular expertise in the mechanism of police

01:21:01 expertise in the mechanism of police complaints and has been a consultant on combating impunity for human rights violations uh for the council of Europe.

01:21:15 violations uh for the council of Europe. Dr. Smith was the principal f founder of the uh HCDA and served as secretary for much of the seven years it was active between 1998 sorry 1988 and 1995 in investigating and publicizing allegations of police violence and misconduct. The HCDA was active at a

01:21:26 misconduct. The HCDA was active at a time when significant developments in international human rights law required state authorities to effectively investigate the alleged human rights

01:21:38 investigate the alleged human rights violations and remedy uh impunity. It is in the context of those developing obligations to investigate and remedy impunity that the SCS and special branch

01:21:50 impunity that the SCS and special branch were targeting and reporting on the HCDA and Dr. Smith, an organization and an individual known to be actively combating impunity for in human rights violations. Dr. Smith and the public at large have a right to know why. The

01:22:04 large have a right to know why. The earliest available SDS report on uh HCDA is dated the 23rd of August 1988, only one month after its launch. Attributed to HN10 Bob Lander, it falsely

01:22:17 to HN10 Bob Lander, it falsely characterizes the HCDA as a front organization for local anarchist activists. It was nothing of the sort. HCDA was formed at a conference organized by the Trevor Monavore campaign and the Hackne Anti-Fascist

01:22:33 campaign and the Hackne Anti-Fascist Action. From its inception, HCDA was a self-help group of victims of police injustice which given up on the police complaint system turned to the civil courts.

01:22:40 courts. SCS uh documented documents expressly stated that uh HN78 Trevor Morris and HN50 Mark Jenner targeted HCDA.

01:22:59 HN50 Mark Jenner targeted HCDA. In February 1995, Mark Jenner was tasked with targeting HCDA which was quote involved in the coordination and opposition to local police allegations of harassment, racism, wrongful arrest. Clearly opposition to harassment and

01:23:12 Clearly opposition to harassment and racism of the local police force was a basis for targeting. Special branch's interest in the HCDA was likely to increase by its growing reputation and profile in supporting

01:23:25 reputation and profile in supporting victims of police injustice in criminal and civil courts and campaigning for civil for police accountability. Much publicity surrounded arrest of a couple

01:23:39 publicity surrounded arrest of a couple an elderly couple in uh in January 1989 and assault of a multi motorcyclist in July of the same year. These cases attracted national and regional and local media interest. By 1992, broadcast and media coverage accompanied HCDA's

01:23:53 and media coverage accompanied HCDA's investigation conducted in parallel with the Metropolitan Police counter-corruption in investigation into Stoke Newton police officers code name Operation Jackpot. A Channel 4 TV

01:24:04 Operation Jackpot. A Channel 4 TV cuttingedge documentary was aired titled Coppers on Policing and Hackne. That Channel 4 program highlighted HCDA's civil action strategy and its effectiveness, reporting that quote, "Publicity,

01:24:15 "Publicity, senior officers dismiss HC uh sorry, forgive me, publicly senior officers dismiss HCDA as a politically motivated fringe route, but it is clear that

01:24:31 fringe route, but it is clear that HCDA's strategy of public accusation and civil litigation has put the police on the defense here. Many of the cases taken up by HCDA involve allegations of police brutality and racism. A common pattern was victims of police violence being falsely accused and charged with

01:24:43 being falsely accused and charged with offenses of assaulting police officers

01:24:51 offenses of assaulting police officers in the course of their duty. Following a quiddle and successful defendants would then turn to the civil courts to gain redress. Between January 1989 and September 1991, HCDA took up 130 cases, 57 involving allegations of assault by the police and 26 civil actions, 22

01:25:05 the police and 26 civil actions, 22 involving claims of assault. For the next 3 years or so, HCDA prioritized

01:25:20 next 3 years or so, HCDA prioritized drug cases as it struggled to cope with the number of people alleging planting by Stoke Newington drug squad. Within nine months of Operation Jackpot's announcement in January 1992, acknowledged by the MPS as the worst case of corruption in a decade, HCDA had examined 40 Stoke Newton drug cases, 36

01:25:34 examined 40 Stoke Newton drug cases, 36 involved black people, 20 Jamaican or of Jamaican descent, and civil proceedings had been commenced in nine of the cases. In total, 14 convictions in respect of drug drug offenses were eventually

01:25:50 drug drug offenses were eventually quashed. HCDA took up 90 Stoke Newington Operation Jackpot cases with 25 claims proceeding against the commissioner. This is the context for Trevor Morris's evidence to the inquiry that he obtained access to HCDA's files and submitted

01:26:05 access to HCDA's files and submitted several reports to the SDS as did Mark Jenner. The only credible explanation for this reporting is that it was perceived to serve an interest in having

01:26:19 perceived to serve an interest in having knowledge of or being able to res resist lawful campaigns for accountability, including civil proceedings. The reporting extended to Dr. Smith personally. Mark Jennins submitted 15 reports from Dr. Smith. Jennine's deployment in the field coincided with the disbanding of HCDA and the

01:26:35 the disbanding of HCDA and the withdrawal of Dr. Smith from community activities. Jenna acknowledges Dr. Smith's withdrawal from community activities in a report dated the 13th of June 1995. This report contains personal information about Dr. Smith, much of which is wrong. Despite noting this

01:26:51 which is wrong. Despite noting this withdrawal, Jenna continues to submit further 10 reports on Dr. Smith, the last one being in uh on the 19th of October 1998. as to why he would gather and report such information. Jenna claims that he would have been provided with information he gleaned about

01:27:04 with information he gleaned about Smith's personal circumstances because at the time he'd understood that that all such information would be wanted by the SDS to keep the special branch file on Smith up to date. There is an

01:27:16 on Smith up to date. There is an absurdity in the explanation given for the reporting. There are no reports available during the period when Dr. Smith had a registry file number and was active a prominent member of HCDA and yet at the point he withdraws and is no

01:27:31 yet at the point he withdraws and is no longer active he becomes the subject of multiple reports at one point four in one month Jenner will need to explain why he had the understanding that special branch wanted to keep the

01:27:44 special branch wanted to keep the registry file up to date another subject of the reporting in the defendants information service or this was Dr. Smith and others was in 1984. It was a database of police off of police officers found to have lack

01:27:55 police officers found to have lack credibility and whose evidence was either not relied on by prosecutors or the courts. The information was shared with criminal defense and police litigation solicitors and was the

01:28:09 litigation solicitors and was the subject of legal professional privilege. The MPS took exception to this. Dr. Smith was written to by the office of data protection registar and was visited by lawyer in 1995

01:28:22 by lawyer in 1995 and received objections from the MPS and the association of the chief police officers. As Jenna reported in October 1995 the disc is a database it's available for a fee to lawyers. It lists the details of police officers who've

01:28:36 the details of police officers who've been reported or convicted of criminal or disciplinary offenses or have been the subject of complaints. This is an important source of income for CRC.

01:28:50 This was just a reporting service, the sole aim of which was to provide information on the actions of the MPS. Jennifer filed these reports not withstanding the obvious breach of legal professional privilege. He did so against the background of the disc

01:29:02 against the background of the disc having a concern at the highest level of the Metropolitan Police leading to attempts them to by them to block the service. The reports filed on this cannot be simply be dismissed as uh

01:29:19 cannot be simply be dismissed as uh collateral reporting. Reporting on HCDA, Dr. Smith and the DISC were entirely it was entirely unjustified and improper. It was contrary to the Home Office directives that targeting of police accountability and anti-racist groups was strictly off limit. I now turn to the final uh uh core participant I

01:29:32 the final uh uh core participant I represent. That's Mark Meet. Mark has provided a witness statement on his own behalf and on behalf of the Colin Roach Center. Mark uh had been involved with a political uh trade unions and community

01:29:49 political uh trade unions and community actions for his entire life. It appears that the special branch had opened a registry file on him in 1987.

01:29:56 He had a number of SDS reports on him between 1986 and 1994. targeting the targeting strategy for Mark was prepared in February 1995 and

01:30:08 Mark was prepared in February 1995 and it states that he will be target he will target anarchist act activists in Hackne. It goes on to mention that Mark personally as being part of HCDA in his witness statement Jenner describes his long-standing strategy to was to get

01:30:22 long-standing strategy to was to get close to Mark Meetoff. He states that it would give him access to a wider range of groups. This explanation makes very little sense. Mark met has never been an anarchist. SDS wrongly reports to refer

01:30:39 anarchist. SDS wrongly reports to refer to CRC and HCD as being synonymous. This was simply not the case. CRC, the Colin Ro Center, was initially open to provide community hub for groups such as HCDA, the local gay and lesbian group, and the Hackne trade union support unit. In

01:30:54 Hackne trade union support unit. In 1995, it began to operate a membership and involve itself in local community campaigns ranging from housing, trade union work, supporting refugees and asylum seekers, and anti-fascist

01:31:06 asylum seekers, and anti-fascist activities. Mark Medaf describes CRC as first and foremost a place for advice. Jenner's witness statement asserts that the NPS were not interested in the activities of CRC because of its work on the police misconduct, but because of

01:31:18 the police misconduct, but because of its interest in planned demonstrations and public disorder. This we say is clearly speurious. Not only was there an absence of public disorder to be interested in in the contemporaneous

01:31:30 interested in in the contemporaneous records make the the contemporariness records make clear that the real interest uh reason for the interest was the SD and you'll see that in the SDS annual report where Jenna describes having a unique access to a range of

01:31:41 having a unique access to a range of anti police campaigns in London. It was precisely because of the work on police misconduct mischaracterized as anti- police that CRC was of interest.

01:31:53 police that CRC was of interest. Jenner describes the CRC as a stepping stone for getting access to a range of groups such as Red Action and the Irish Republican sympathi sympathi uh

01:32:04 Republican sympathi sympathi uh sympathizers. However, he notes that being associated with Mark Metaf hampered this strategy as Mark had a poor relationship with them. As early as January 1986, Jenner attended such meetings on his own due to his own poor

01:32:17 meetings on his own due to his own poor relationships and yet continued to file reports on every aspect of Mark's uh life from his job applications to bank accounts. Jenna expresses Jenna explains his reporting on the basis of all the

01:32:28 his reporting on the basis of all the information was to be hoovered up and that Mark remained one of his main targets albeit why this was difficult to fath fathom.

01:32:39 fath fathom. At the end of Jenner's deployment, he suddenly disappeared after he'd mistakenly disclosed his name to Allison. Mark remembers Allison's fears for Jenner's well-being after this sudden disappearment. Mark reached out

01:32:53 sudden disappearment. Mark reached out to make sure that he was well to offer support. This contrast with the the contrast between this empathy and concerns and the actions of Jenna and the SDS couldn't be more stark. Finally, let me come to some concluding marks. And I know I'm right at the end of my time, but um so if you can just bear

01:33:07 time, but um so if you can just bear with me um 3 minutes, that's all I ask. Of course. So John, in each of these stories, the same question arises. What kind of

01:33:20 same question arises. What kind of police force spies on grieving families and those seeking justice before the courts? The evidence that Weaver outlined shows fabrication, racism, intrusion into legal privilege, and a

01:33:31 intrusion into legal privilege, and a chilling disregard for the rule of law. Our clients simply ask recognition of the wrong done to them and for reassurance that no other family will suffer the same v uh fate to borrow from MNA Simpson who speaks for so many. Our aim was not to make trouble. It was to

01:33:50 aim was not to make trouble. It was to get a voice because we needed justice. That is why we're here now. We acknowledge uh the commissioner's apology and his acceptance that the deployments of uh N HN15 and HN81 against them were not justified. But let us be clear, we

01:34:10 not justified. But let us be clear, we should never have been here in the first place. Any decent observer knows that grieving families are not legitimate targets of covert policing. There was no disorder to quell. There was no hidden

01:34:22 disorder to quell. There was no hidden criminality to expose. the only people exercising their right to demand justice. This has to be said, and the fact that we have to say this at all is a stark reminder of how far the Metropolitan Police has lost sight of

01:34:38 Metropolitan Police has lost sight of its obligations of those it was meant to serve. And yet, there remains a painful omission. And I'm sure, sir, that you've spotted this. At the end of Celia Stub's closing

01:34:50 At the end of Celia Stub's closing statement in Tranch One, her council called upon the commissioner to apologize to her directly. You, sir, you replied, and I quote, I hope that your last remarks are reflected upon and responded to. However, sir, Celia Stub

01:35:10 responded to. However, sir, Celia Stub has still not received any response from the commissioner. Despite these calls, there's been no personal apologies to the families of Cherry Gross, Joy Gardner, Roger Sylvester, or any of the other brief relatives who were spied upon. A general apology

01:35:25 upon. A general apology that does not even name those directly affected can never be enough. Until those families receive a personal apology, the stain on the reputation of the Metropolitan Police will endure. Thank you.

01:35:39 Thank you very much. Um, the point you made at the end of your submission is a forceful and valid one. I was delighted that you began by

01:35:50 I was delighted that you began by quoting Sir Robert Peele, who should be in our hearts. Thank you, sir.

01:36:11 I hope I do not uh mispronounce the name of the uh next advocate. If I ask for Ethan Odogu to be put on the screen, please

01:36:28 good afternoon, sir. Good afternoon, Mr. I do hope I pronounced your name correctly. If I didn't, I apologize. Pronounced it correctly, so I'm grateful.

01:36:32 grateful. Thank you. Um, I'm happy to address you now. I believe I was going to be after Mr. Rajie Menon on the running order, but I'm happy to address you now.

01:36:43 I'm happy to address you now. Oh, I'm I do apologize. I misread the running order that I have been given. And you are absolutely right. It is Mr. Menon who comes next. Thank you for correcting me. And at least I've got one

01:36:54 correcting me. And at least I've got one thing right. Pronunciation of your name. Mr. Menon. apologies. Do you?

01:37:07 Mr. Menon. apologies. Do you? No problem. Good afternoon, sir. In 1993, Dwayne Brooks was 18 years old. He lived in Charlton, Southeast London. He was at college training to be an electrical engineer. Steven Lawrence was his close friend. On the morning of

01:37:18 his close friend. On the morning of Thursday, the 22nd of April, 1993, Mr. Brooks could not have imagined that within 24 hours his life would be turned upside down and changed forever. That

01:37:31 upside down and changed forever. That evening, whilst he and Steven Lawrence were waiting for a bus in Elam, they were the victims of a vicious and unprovoked racist attack. Steven Lawrence was murdered. Mr. Brooks was fortunate to survive the attack, but suffered post-traumatic stress disorder

01:37:46 suffered post-traumatic stress disorder for the following decade. He is now aged 51. The trauma shapes his life even today.

01:37:48 today. From the very outset, when officers arrived at the scene of the attack, Mr. Brooks was treated appallingly by the police. At the police station, the police were so hostile to Mr. Brook's

01:38:01 police were so hostile to Mr. Brook's account of the racist abuse shouted by the attackers that he felt the police were playing Jedi mind tricks on him. Scared, alone, and vulnerable, Mr. Brooks had the courage to stick to the truth. It is it is his courage that

01:38:17 truth. It is it is his courage that enabled the racist nature of the attack to be exposed. It is chilling how Mr. Brook's experience and his treatment by the police mirror the earlier experience of Natham Adams and his treatment by the

01:38:32 Natham Adams and his treatment by the police. Both were black teenagers from Southeast London. Both were the surviving victors victims of murderous racist attacks. Both were eyewitnesses.

01:38:47 racist attacks. Both were eyewitnesses. Both were harassed and failed by police officers who sought to undermine their accounts. Both suffered severe trauma that was ignored by the police. Both were racially stereotyped by the police. Both were treated like criminal suspects, not victims of crime with no

01:38:59 suspects, not victims of crime with no charges ever brought in relation to the racist attacks on them. Both were victims of institutional racism that permeated the police. And for present purposes, both were wrongly targeted by undercover officers.

01:39:14 undercover officers. In 1999, Sir William McFersonen, the chair of the Ste Steven Lawrence inquiry, made critical findings in respect of Brooks, Mr. Brooks, excuse me, including the following. One, the

01:39:26 me, including the following. One, the greatest trauma suffered by Mr. Brooks was that he saw his friend murdered, dying on the pavement, and dead as he was carried into the hospital. and he has had to endear that night and the whole course of the failed

01:39:41 whole course of the failed investigation. He was a primary victim of the racist attack. He is also a victim of all that has followed, including the conduct of the case and the treatment of himself as a witness and not as a victim. Two, to say that

01:39:52 and not as a victim. Two, to say that there were real lessons for the police to learn about how Mr. Brooks was handled at the scene and that the police did not deal with Mr. Brooks very well at all were understatements. No officer

01:40:06 at all were understatements. No officer treated Mr. Brooks properly at the scene or later at the hospital. No officer at any time treated him properly as a victim. There is no evidence that any officer understood that Mr. Brooks needed close, careful, and sensitive

01:40:25 needed close, careful, and sensitive treatment. Mr. Brooks was simply treated as a potential witness in inadequately at that. Three, we are driven to the conclusion that Mr. Brooks was stereotyped as a young black man exhibiting unpleasant hostility and agitation who could not be expected to help and whose condition and status

01:40:39 help and whose condition and status simply did not need further examination or understanding. We believe that Mr. Brook's color and such stereotyping played their part in the collective failure of those involved to treat him properly and according to his needs.

01:40:51 properly and according to his needs. And four, we are satisfied that the lack of respect and sensitivity to in handling him must reflect unwitting and

01:41:03 handling him must reflect unwitting and collective racism, particularly in those who dealt with him both at the scene of the murder and at the hospital. Mr. Brooks was a victim of racist stereotyping. We do not believe that a young white man in a similar position would have been dealt with in the same way. He simply was not treated

01:41:15 way. He simply was not treated professionally and appropriately and according to his needs. In 1999, Mr. Brooks sought legal accountability for the way he had been treated by the police. He issued county court proceedings against the

01:41:28 court proceedings against the Metropolitan Police Commissioner for false imprisonment, misfeasants in public office, and negligence, and against 13 named officers for breaches of the Race Relations Act 1976.

01:41:41 of the Race Relations Act 1976. The Court of Appeal held in 2002 that Mr. Brooks claims against individual officers for racial discrimination in the provision of services were permissible and should not have been struck out at first instance. Even

01:41:53 struck out at first instance. Even though Mr. Brooks did not make his needs as a victim of crime known to each officer who was providing him with services, this significant principle remains good law today and was untouched

01:42:11 remains good law today and was untouched by the House of Lords who in 2005 struck out Mr. Brooks's claim for negligence against the commissioner, ruling the police,

01:42:30 settled the rest of Mr. Brooks's claim, apologizing to him for the way the police had treated him and paying him damages.

01:42:38 damages. Despite his mistreatment by the police, Mr. Brooks has done everything that was asked of him from day one. He assisted three separate police investigations. He made at least nine witness statements

01:42:55 made at least nine witness statements during the first investigation alone and attended three identification parades and various drivearounds. During the private prosecution in 1996, he gave evidence as requested despite being medically unfit to do so. Whilst taken into a form of witness protection, he

01:43:12 into a form of witness protection, he was guarded at one point astonishingly by a police officer who was a known associate of Clifford Norris, a notorious criminal and father of David Norris, one of those suspected at the time of having murdered Steven Lawrence. During the subsequent murder trial of

01:43:26 During the subsequent murder trial of David Norris and Gary Doppson in 2011, Mr. Brooks gave evidence despite the death of his father the night before. The two men were convicted nearly 19 years after Steven Lawrence's murder and sentenced to life imprisonment. Mr.

01:43:38 sentenced to life imprisonment. Mr. Brooks has been equally committed to exposing racism and corruption in the police. He assisted the Steven Lawrence Inquiry, the Police Complaints Authority, the Independent Police

01:43:54 Authority, the Independent Police Complaints Commission, the Independent Office for Police Conduct, Operation Hearn, and the Steven Lawrence Independent Review. Largely hidden from the limelight and always self- aacing in demeanor, Mr. Brooks continues to be

01:44:06 demeanor, Mr. Brooks continues to be dedicated to the pursuit of truth. For more than 25 years, Mr. Brooks has sought to make a positive contribution to society, notably by doing all he can to improve policing and race relations. He has supported many individuals,

01:44:18 He has supported many individuals, families, and campaigns fighting for justice and against police brutality. He has also strived to improve this the support given to victims of crime. He has worked with policy makers and

01:44:29 has worked with policy makers and strategists to improve engagement and communication between the Metropolitan Police Service and diverse communities in London. He joined the meth's

01:44:41 in London. He joined the meth's operation blunt 2 initiative to combat knife crime in London. He was an independent member of the meth firearm and taser reference group which scrutinized the police use of firearms and tasers in London. He led an engagement team on the territorial

01:44:55 engagement team on the territorial support group and the river team. He was a member of the mayor's office for policing and crime stop and search group. He has contributed to the college of policing strategic command course and delivered equality and diversity training at the college of policing. He

01:45:09 training at the college of policing. He was a liberal democrat counselor in the London bur of Lewisham from 2009 to 2014. He led on stop and search scrutiny attending met gold group meetings

01:45:20 attending met gold group meetings following critical incidents in the burrow and was instrumental in establishing a system for the online reporting of crime against the LGBT community. He spent four years as a lead member on the safer communities board of

01:45:37 member on the safer communities board of the local government association. He was awarded an OBBE in 2015 for public and political service. He presented an award-winning BBC documentary in 2019 entitled Stabbed Britain's knife crime crisis. He is the chair of trustees atu

01:45:52 crisis. He is the chair of trustees atu Juvenus, a black le charity dedicated to empowering young people who are vulnerable to crime exclusion from school and exploitation. He was a member of the wind rush crossgovernment working group from 2020

01:46:04 crossgovernment working group from 2020 to 2023 which supported the delivery of practical solutions to address the challenges affecting the wind rush generation and their families and revamped the compensation scheme. He led on the implementation of the

01:46:15 on the implementation of the recommendations in Wendy Williams windrush lessons learned review. And finally, he was appointed to the youth justice board in 2023 for a tenure of

01:46:35 justice board in 2023 for a tenure of three years. But despite all that public service, despite all that activism, or maybe because of it, Mr. Brooks was subjected for many years to inappropriate police harassment and covert surveillance. He is keen to acknowledge at the outset that he is acutely aware that the impact of the

01:46:49 acutely aware that the impact of the spying on him was nothing compared to the impact of the spying on, for example, the women who were deceived into relationships. Nevertheless, it is

01:47:01 into relationships. Nevertheless, it is essential that the inquiry examines the police spying on Mr. Brooks in full as required by its terms of reference. It is important to note that by no means all the spying on Mr. Brooks was by undercover officers in the special

01:47:14 undercover officers in the special demonstration squad. Plumstead police station had a racial incidents unit. Police constable Alan Fiser, the racial incidents officer, got to know black victims of racist crime. He was there to assist in what can only be described as

01:47:29 assist in what can only be described as a breach of trust. He was deployed as a plain clothed spotter at the May 1993 anti-racist demonstration against the British National Party in Welling, presum presumably to identify black

01:47:42 presum presumably to identify black people he recognized in attendance. Learning this has left Mr. Brooks speechless as it may leave many others speechless, too. Mr. Brooks finds it profoundly disturbing that the police

01:47:55 profoundly disturbing that the police were spying on him and other victims of racist violence, but not, as far as he is aware, on well-known racist criminal groups who were committing serious violent crimes. Pausing there, it appears that this fundamental failing

01:48:14 appears that this fundamental failing has finally been acknowledged by the Met uh in its tranch 3 phase 1 opening. It is significant that the Metropolitan Police Service now accepts firstly that undercover officers indefensibly

01:48:25 undercover officers indefensibly reported on individuals, family justice campaigns, and police accountability groups, including Mr. Brooks, who presented no risk of criminality or public disorder. And secondly, that instead of such reporting, the prevention investigation of racist

01:48:36 prevention investigation of racist violence should have been properly resourced, which it clearly was not. We trust that the inquiry will give credit where credit is due. It is undoubtedly

01:48:48 where credit is due. It is undoubtedly because of the perseverance of so many individuals, campaigns, and groups, including Mr. Brooks and the family of Roland Adams, that this concession has at last been made. In light of this concession, we trust that the inquiry

01:49:00 concession, we trust that the inquiry will properly investigate the extent to which the undercover policing of racist individuals and racist criminal groups was underresourced.

01:49:14 was underresourced. Another incident of concern to Mr. Brooks involved deputy assistant commissioner John Griev of the Metropolitan Police Service. One of his initiatives after taking charge of the

01:49:25 initiatives after taking charge of the Steven Lawrence murder investigation was to set up a series of meetings with Mr. Brooks and his solicitors. This was during the post McFersonson era when the police were supposed to have learned lessons from the past. Before one of

01:49:37 lessons from the past. Before one of those meetings in May 2000, whilst he sat in the offices of Dyon Gadala solicitors, he gave himself authority to covertly record the meeting and proceeded to do so. We understand that this is unlikely to have been the only

01:49:53 this is unlikely to have been the only such meeting that was covertly recorded. As far as SDS spying on Mr. Brooks is concerned. Some of it was highlighted by Mark Ellison Queen's Council in the Steven Lawrence Independent Review published in 2014.

01:50:09 published in 2014. Whilst the primary focus of the Ellison Review was police corruption in the original investigation into Steven Lawrence's murder, the Ellison Review also examined the role of undercover policing in the investigation and explored the extent, purpose, and

01:50:23 explored the extent, purpose, and authorization for any police spying on Mr. Brooks. In respect of undercover policing, Mr. Ellison concluded that although there were no surviving SDS records supporting the contention of Peter Francis, the former SDS officer

01:50:43 Peter Francis, the former SDS officer who was deployed undercover in September 1993 and turned whistleblower in 2013, that he was tasked to gather intelligence that could be used to smear or undermine the Lawrence family campaign. It is clear the majority of SDS records from that era had been destroyed. In any event, if there had

01:50:58 destroyed. In any event, if there had been such tasking, it would most likely have been oral rather than recorded in writing. Second, no definitive findings can be made concerning Mr. Francis's

01:51:09 can be made concerning Mr. Francis's various claims, including his claim that Branch asked the Steven Lawrence murder investigation team to ascertain and report back the names of individuals and groups present in the Lawrence family home in the weeks following the murder. Three. In August 1998, an SDS officer

01:51:22 Three. In August 1998, an SDS officer who we now know was David Hagen whilst spying on the Lawrence family met with an ex special branch officer, Detective Inspector Richard Walton, who was secundered to the Met team that was

01:51:34 secundered to the Met team that was drafting the final written submissions to be made on behalf of the commissioner to the Steven Lawrence inquiry. This was wrongheaded, inappropriate, and highly questionable. Mr. Ellison concluded

01:51:46 questionable. Mr. Ellison concluded there was no conceivable public order justification for this meeting. Four, the Met should have provided Sir William McFersonson with the information regarding undercover policing that

01:51:57 regarding undercover policing that touched on the Steven Lawrence murder investigation, but failed to do so. If the withheld information had been provided, it is likely that the meth's case at the inquiry and its reputation

01:52:11 case at the inquiry and its reputation as a whole would have been further and severely damaged. In respect of Mr. Brooks. Mr. Ellison concluded that one, Mr. Francis's claims that he was tasked in September 1993, soon after being

01:52:22 in September 1993, soon after being deployed undercover as an SDS officer,

01:52:32 deployed undercover as an SDS officer, to identify Mr. Brooks in footage of the May 1993 demonstration against the BNP in Welling. As it happens, Mr. Brooks had already been identified in the footage by another police officer. It is possible, Mr. Ellison concluded, that Mr. Brooks was identified independently

01:52:44 Mr. Brooks was identified independently by both officers. two, the circumstances surrounding the prosecution of Mr. Brooks for offenses arising from the May 19 May 1993 demonstration in Welling and the Met's handling of this prosecution remain somewhat unsatisfactory.

01:52:57 remain somewhat unsatisfactory. No clear explanation has been pro provided as to why it was considered appropriate to charge Mr. Brooks in October 1993 when their case against

01:53:11 October 1993 when their case against others for similar alleged offending had already been dropped. Three, there was further SDS reporting on Mr. Brooks after the publication of the McFersonen report, namely between 1999 and 2001. This was largely about gathering

01:53:26 This was largely about gathering personal information about Mr. Brooks and tactical information about the progress of Mr. Brooks's civil claim against the commissioner. Such reporting should not have taken place and in any event should have been terminated by SDS

01:53:40 event should have been terminated by SDS managers once they learned of it. It had little value in terms of legitimate public order concerns. It should never have been disseminated as it was to other parts of the Met such as the unit

01:53:51 other parts of the Met such as the unit dealing with Mr. Brooks as a victim and a one a vulnerable witness. Three detective assistant commissioners sorry deputy assistant commissioner Greavves's covert recording of a meeting in May 2000 m with Mr. Brooks and his

01:54:07 2000 m with Mr. Brooks and his solicitors was unnecessary, unjustified, and no doubt compounded Mr. Brooks's concerns about the activities of the Met as a whole. Ultimately, the Ellison review raised many questions about the

01:54:18 review raised many questions about the police treatment of Mr. Brooks generally and the SDS spying on Mr. Brooks specifically. For example, why was the SDS interested in Mr. Brooks in the

01:54:29 SDS interested in Mr. Brooks in the months following the racist murder of Steven Lawrence in the first place? Surely the focus of any undercover policing in 1993 should have been on those suspected of having murdered Steven Lawrence, not on the surviving victim of the attack. Why was Mr.

01:54:42 victim of the attack. Why was Mr. Francis asked to identify Mr. Brooks in footage of the May 1993 demonstration against the BNP in Welling? Why was Mr. Brooks charged with offenses arising

01:54:53 Brooks charged with offenses arising from that demonstration when the charges against others for similar offenses had already been dropped? What possible justification could there have been for the SDS spying on Mr. Brooks between 1999 and 2001?

01:55:05 1999 and 2001? What possible justification could there have been for Deputy Assistant Commissioner Grieve covertly recording a meeting with Mr. Brooks and his solicitors? All questions that clearly arise, we suggest from the Ellison

01:55:16 arise, we suggest from the Ellison review. Turning then to the undercover policing inquiry, the SDS intelligence reports and other material recently disclosed to Mr. Brooks provide yet

01:55:28 disclosed to Mr. Brooks provide yet further evidence of police intrusion into his life and breaches of trust. Peter Francis, HN43, and David Hagen, HN81,

01:55:40 and David Hagen, HN81, were two SD officers who we know reported on Mr. Brooks. According to Peter Francis, one, there was racist banter amongst SDS officers as a group

01:55:52 banter amongst SDS officers as a group and much more overt racism from certain members of management. A detective chief inspector in the SDS, HN86,

01:56:03 inspector in the SDS, HN86, referred to black justice campaigners as monkeys, and detective chiefs who pretended Robert Potter, whose police career was later ended when he was arrested for racist behavior in a public place, indulge in casual racism using

01:56:18 place, indulge in casual racism using the n-word regularly. Two, the special branch attitude towards the Lawrence family was 100% racist. They were viewed as being unable to think for themselves or run their campaign themselves and

01:56:29 or run their campaign themselves and must therefore have been led by others. Three, HN86 and other police officers often spoke nastily and disparagingly about Mr. Brooks with a racist spin on a lot of it. People deliberately

01:56:41 lot of it. People deliberately mispronounced his name with the intention of making him sound like he was thick. HN86 once said that if only

01:56:53 was thick. HN86 once said that if only it was Mr. Brooks who had been stabbed. Nobody would have been interested in a kid who was living in a hostel as opposed to a kid from a good family like the Lawren's. Pausing there. Sir, HNS86

01:57:04 the Lawren's. Pausing there. Sir, HNS86 was not the only police officer to make such a disgusting comment about Mr. Brooks. The inquiry has disclosed a document to Mr. Brooks, which reveals that a detective constable, David Dooall, told two Operation Hearn

01:57:16 Dooall, told two Operation Hearn investigating officers on the 19th of February, 2014 that quote, "The wrong person got stabbed." end quote.

01:57:28 person got stabbed." end quote. Returning to Peter Francis, he had private meetings with HN86, which included discussions about identifying people on a list provided by the Lawrence family liaison officers and

01:57:39 Lawrence family liaison officers and viewing footage to identify Mr. Brooks at the May 1993 demonstration. Five, he was tasked by HN86 to report

01:57:50 Five, he was tasked by HN86 to report anything that he could find about the Lawrence family that campaign, Mr. Brooks, and others that had the potential to smear and discredit or could be used by the police to alter public perception. Six, he was also tasked at various

01:58:02 Six, he was also tasked at various points during his deployment to report on black justice campaigns, including the Roland Adams family campaign. Seven. In 1997, HN86 and Roger Pierce told him

01:58:17 In 1997, HN86 and Roger Pierce told him there would be battles in the street if his spying on the Lawrence family campaign and other black justice campaigns were disclosed to the Steven Lawrence inquiry and the public found out what he'd been doing.

01:58:29 out what he'd been doing. As far as David Hagen is concerned, the chair has recently ruled that he is excused from attending the Tranch 3 hearings on the basis that giving oral evidence would apparently risk causing a

01:58:44 evidence would apparently risk causing a severe impairment of his health. This um is a major setback and a slap in the face for all those non-state core participants on whom Mr. Hagen spied and reported. They have been waiting for years patiently to hear how Mr. Hagen

01:58:57 years patiently to hear how Mr. Hagen seeks to justify what he did. Mr. Brooks is furious. There's no other way to put it. Mr. Hagen will no longer be required to explain any of the following. Why did he spy and report on Mr. Brooks between 1998 and 2001? Was he ever tasked by a

01:59:13 1998 and 2001? Was he ever tasked by a senior officer to spy and report on Mr. Brooks? And if so, by who? Why did he report on personal matters concerning Mr. Brooks that had nothing to do with public order? Why did he report on Mr. Brooks's civil claim against the commissioner. Why did he patronizingly

01:59:26 commissioner. Why did he patronizingly and wrongly suggest in an intelligence report that Mr. Brooks was incapable of making his own decisions and was being

01:59:41 making his own decisions and was being manipulated by Alexad from the movement for justice? To to what extent was his reporting based on fabrication and/or exaggeration andor gossip? Was there any racist banter amongst SDS officers? Was there more overt racism from senior SDS

02:00:01 there more overt racism from senior SDS managers? Did he ever witness HN86 do or say anything that was racist? None of that now uh is capable of further exploration, unfortunately. Turning then to the issue of Mr. Brooks giving evidence to the inquiry. Mr. Brooks argued for and welcomed this

02:00:12 Mr. Brooks argued for and welcomed this inquiry. He willingly took part in early discussions with the then Home Secretary and the inquiry team in the buildup to

02:00:23 and the inquiry team in the buildup to the first hearings in 2020. Since then, he has become increasingly despondent. The process has dashed his expectation and dampened his belief that the inquiry

02:00:37 and dampened his belief that the inquiry will ever meaningfully meet its terms of reference and treat those who have been wrongly spied on with the respect and humanity they deserve rather than as inconvenient witnesses. There appears to be little understanding of the painful experiences that so many non-state core participants have suffered and how the

02:00:48 participants have suffered and how the spying and intrusion have affected their daily lives. In stark contrast, there is far too much difference to the police

02:00:59 far too much difference to the police and SDS officers. Mr. Brooks also wishes to reiterate what other non-state corp participants have already highlighted, namely that it is outrageous that some SDF officers who apparently spied on the far right are giving evidence in close

02:01:12 far right are giving evidence in close hearings from which the non-state core participants, their lawyers, and the general public are excluded. This is particularly gling given the fact that some information about their

02:01:23 some information about their infiltration of far-right groups is already in the public domain. What possible national security or privacy concerns could justify not hearing evidence in open hearings about events that took place over 25 years ago?

02:01:36 that took place over 25 years ago? Additionally, when is the inquiry going to explore the nature and extent, if any, of undercover policing of racist criminal groups? Mr. Brooks understands that a key purpose of the non-state core participants um sorry, let me rephrase

02:01:52 participants um sorry, let me rephrase that. Mr. Brooks understood that a key purpose of the non-state core participants participating in the inquiry was that they would at long last be provided with answers to questions that have been unanswered for years. However, this is simply not happening

02:02:04 However, this is simply not happening for the vast majority of non-state core participants. On the contrary, for some, the inquiry is merely adding to the trauma they have already suffered. Additionally, Mr. Brooks is still

02:02:15 Additionally, Mr. Brooks is still awaiting substantial disclosure from the inquiry about various important matters, some of which he has been told will not be available until early 2026.

02:02:27 be available until early 2026. This additional delay in disclosing all relevant material is understandably a matter of considerable concern for Mr. Brooks. He is insensed that the inquiry has asked him and other non-state corps participants to provide witness

02:02:41 participants to provide witness statements and give oral evidence before seeing all the undercover reporting about them and before hearing the oral evidence of the police officers who who spied on them. He believed this is

02:02:54 spied on them. He believed this is fundamentally unjust and disrespectful. It stacks the scales against the non-state core participants and undermines their ability to give their best evidence, thereby thwarting the

02:03:06 best evidence, thereby thwarting the inquiry's ability to meaning fulfill its terms of reference. In what other legal forum would the victims of abuse of power by the state be expected to give evidence before they've had full disclosure of the precise nature and extent of that abuse? In the opening

02:03:18 extent of that abuse? In the opening statement made on his behalf in November 2020, prior to the Tranchan hearings, Mr. Brooks's position was made crystal clear, and I quote, "As far as the inquiry itself is concerned, I can be brief about Mr. Brooks's position. It is

02:03:33 brief about Mr. Brooks's position. It is simple. When Mr. Brooks is provided with full disclosure about the undercover policing against him, he will address it. But not until then. He is the first to accept that he has, as a result of a long struggle, received some information about the spying on him from the

02:03:47 about the spying on him from the Metropolitan Police and others. He has more than most, but he's received nothing from the inquiry, and there's a lot more to come. What Mr. Brooks is not prepared to do is be treated like a suspect all over again, giving yet

02:04:01 suspect all over again, giving yet another account, answering the inquiry's questions in advance, as if the burden is on him to establish that there was no good reason for the police spying on him. End quote. That remains Mr. Brook's position today. Having said that, he has provided the

02:04:13 Having said that, he has provided the inquiry with a first witness statement. He remains willing to give oral evidence and assist the inquiry. However, he is

02:04:24 and assist the inquiry. However, he is not prepared to do so until he has been given full disclosure of all the undercover reporting about him and has had sufficient time to digest the material and give instructions to his legal team. This position is nothing other than reasonable. We trust that the

02:04:40 other than reasonable. We trust that the inquiry will provide Mr. Brooks with the outstanding disclosure as soon as possible, give him sufficient time to provide an updated witness statement, and ensure that he can give oral evidence during the Tranch 3 hearings in 2026.

02:04:58 2026. Anything else would be grossly unfair to Mr. Brooks. It would also frustrate the inquiry's task of getting to the truth about undercover policing. Sir, in conclusion, given the public order threat assessment in the SDS annual report of 1999 1994,

02:05:10 1994, it is perhaps unsurprising that the police, including the undercover police, got it so hopelessly wrong when

02:05:21 got it so hopelessly wrong when investigating Steven Lawrence's murder. The report makes the following assertions. One, an increasingly violent campaign against racial aggression commenced following Steven Lawrence's murder. Two, the far right pose a

02:05:38 murder. Two, the far right pose a shrinking public order threat. Three, public disorder with an anti-racist theme has been the major feature of the past year. Four, the argument that the presence of the British National Party

02:05:51 presence of the British National Party bookshop in Welling inspires racists to commit acts of violence and directly adds to the increase in the number of racist attacks, quote, is by no means indisputable. End quote. In other words, what this report was saying is that it

02:06:08 what this report was saying is that it was the victims of racist violence and the anti-racist who posed the greater public order threat than the perpetrators of racist violence and the far right. It is precisely this perverse analysis that led to Mr. Brooks, the

02:06:19 analysis that led to Mr. Brooks, the surviving victim of a racist murder, being mistreated by the police and spied on by the SDS whilst Steven Lawrence's murders walked free. It was not until 2010 that the police finally charged uh

02:06:37 2010 that the police finally charged uh two of those responsible with murder. If the police, including the undercover police, had effectively policed the far-right and racist criminal groups instead of persecuting and criminalizing the victims of racist violence, then perhaps some of the racist attacks, including some of the racist murders

02:06:52 including some of the racist murders that plagued our communities during the 1980s and 1990s, could have been prevented. It is noteworthy in this regard that Sir William McFersonson recognized the importance of the police

02:07:04 recognized the importance of the police having good intelligence on racists and racist criminal groups. I quote, "From the report, the extreme nature of their racism and violent tendencies suggest to us that they should have been spotted

02:07:17 us that they should have been spotted for what they were. If good intelligence and information had singled them out earlier and detected their evil presence on the estate, then perhaps they would have been even more obvious targets for

02:07:29 have been even more obvious targets for early arrest. Finally, sir, the inquiry will wish to attach significant weight to the fact that Mr. Brooks and other bl non-state core participants who have provided the inquiry with witness

02:07:43 provided the inquiry with witness statements including Richard Adams, John Berg Manavville, Sesh Grover, Lee Lawrence, Neville Lawrence, Assad Raman, Bernard Renwick, Ma Simpson, and Mark Wodsworth all describe such similar

02:07:57 Wodsworth all describe such similar experiences of racist policing. What is abundantly clear from the thrust of all their witness statements is that so many black individuals, families, and justice campaigns were spied on by the police

02:08:09 campaigns were spied on by the police precisely because they were challenging the injustice of racist policing, not be not because they posed any public order

02:08:20 not because they posed any public order threat. In the circumstances, Mr. Brooks asked the inquiry to unreservedly and unequivocally condemn such police spying and reporting as wholly unjustifiable. Thank you.

02:08:35 Thank you. Thank you. There's only one thing that I should say about Mr. Brooks is giving evidence that because he is unable or unwilling to uh take the slot that was allotted to him

02:08:50 take the slot that was allotted to him in this part of the tr hearings, it may not be possible to hear his oral evidence at a later date. It depends upon um something unexpectedly becoming available. Well, I hope the inquiry will

02:09:05 available. Well, I hope the inquiry will um use its best endeavors to ensure that he is capable of giving evidence in 2026. I note, for example, we often don't sit on Fridays. There are plenty of days here and there uh where I hope

02:09:17 of days here and there uh where I hope his evidence can be slotted in because he his evidence is of critical importance to um your eventual findings when you prepare your report, sir. Thank you.

02:09:29 Thank you. Now, um I think uh our transcribers need at least 10 minutes, do they not? Um it is now uh 7 minutes to uh and I think we

02:09:40 is now uh 7 minutes to uh and I think we ought to begin at 5. Is that long enough for you? Right, we'll resume at 5.

02:23:58 Mr. Good afternoon. I'm sorry you've been slightly delayed. No problem, sir. I represent Dr. Neville Lawrence OBBE, together with Ellen

02:24:09 Lawrence OBBE, together with Ellen Straw, KC, and Odds Jones and Ellen Solicitors. This opening statement is made on behalf of Dr. Neville Lawrence OB and compliment our written opening filed with the inquiry team. Set across the

02:24:21 with the inquiry team. Set across the transfer period is a defining event in modern modern British life. The racist murder of Steven Lawrence on the 22nd of April 1993.

02:24:33 April 1993. Dr. Neville and Baroness Darin Lawrence led a peaceful campaign that asked only for justice for their son and competence from the authorities.

02:24:46 from the authorities. While the Lawrenes sought justice, state power turned on the family. From the earliest days after Steven's murder, the Metropolitan Police through Special Branches SDS began collecting and circulating intimate information about

02:25:06 circulating intimate information about the Lawrenes and those assisting them. That activity continued for years and reached into the Mcfersoning inquiry itself.

02:25:08 itself. The commissioner now accepts that reporting on Dr. Lawrence and his family was wholly indefensible. In this opening, I start with highlighting some of that surveillance

02:25:21 highlighting some of that surveillance before turning to the question of race discrimination.

02:25:25 Turning first to the surveillance of the Lawrence family. There are five points we wish to highlight in opening. First, surveillance started almost at once.

02:25:36 once. On the day after the murder, family leazison officers, otherwise known as FLOs, visited the home that evening. What should have been a bridge between a bereaveved family and a murder

02:25:50 bereaveved family and a murder investigation became an exercise in control and extraction. Visitors to the Lawrence's home were asked to identify themselves. Names were taken and recorded according to the Fellows themselves.

02:26:02 Fellows themselves. What followed, if the evidence is accepted, is stark. Those names were onward rooted into special branch

02:26:15 onward rooted into special branch channels. Peter Francis says HN86 handed him a list which was state which was said to be from the FLOS. In his words, his task was to quote ascertain the political persuasion of the people on the list. The more militant the people on the list, the

02:26:29 militant the people on the list, the higher risk the campaign would create a public order issue. Chair, it was submitted yesterday on behalf of the designated lawyers that one of the reasons Peter Francis's

02:26:42 one of the reasons Peter Francis's allegation is not credible was the absence of contemporaneous documentation. However, little weight can be attached to the absence of records for the reasons already set out in the Ellison review. Communication was frequently

02:26:56 review. Communication was frequently solely oral, and many documents have been destroyed or lost.

02:27:03 One of the features of this intrusion which is especially significant is the timing. This happened within days of the killing when the family should have been treated with the utmost sensitivity.

02:27:14 treated with the utmost sensitivity. Dr. Lawrence tells this inquiry in his statement that what happened in his home was deeply troubling.

02:27:26 was deeply troubling. He says, quote, "The implication that we were somehow the ones to watch was as perverse as it was offensive.

02:27:37 perverse as it was offensive. It was as though our grief was treated as a threat on our home as a sight of suspicion. Something I never I will never accept or forgive.

02:27:45 Second, Peter Francis's allegation that he was tasked to smear the Lawrenes." Francis says he was quote tasked by HN86 to report anything I could find out about the Lawrence family andor the

02:28:01 about the Lawrence family andor the campaign that could fundamentally alter the perception of the public about the campaign.

02:28:08 campaign. He said the gathering of intelligence on the Steven Lawrence campaign was SDS's number one priority. In tranch 2 we heard from HN78. His account does not contradict Francis.

02:28:24 His account does not contradict Francis. On his own account, he did not know what personal information about the Lawrence was reported or how it was used. He accepted that he provided quote quite a lot of reporting about the Lawrence campaign and that it quote might well

02:28:40 campaign and that it quote might well have contained personal information and that material capable of smearing the Lawrenes was reported back.

02:28:49 Thirdly, the wider evidence of unjustified surveillance on the Lawrenes.

02:28:51 Lawrenes. By their own admission, both HN78 and Francis confirm a deliberate intrusion by the SDS into the Lawrence's private lives.

02:29:01 lives. Personal materials gathered and circulated, knowing knowing it could be used against them. In a landscape

02:29:14 used against them. In a landscape already scarred by missing and destroyed documents, those frank admissions alone are the chilling touchstones of this inquiry.

02:29:16 inquiry. Within weeks of the McFersonson hearings, intelligence reports notes that Dorene and Neville have quote in reality separated.

02:29:29 reality separated. Another note repeats this saying quote this is not public knowledge. Those are intimate facts logged and circulated as if operational leads. They say nothing about imminent disorder,

02:29:46 say nothing about imminent disorder, subversion or crime. They do however say something plain about the priorities of the SDS.

02:29:49 the SDS. The documents also stray into the subjective commentary and gossip against Dr. Lawrence, his political views, his attendance at justice campaign groups, and his public speaking.

02:30:07 and his public speaking. By December 2000, the reporting includes legally privileged material about the Lawrence's civil claim, including a supposed settlement figure. Two s uh special branch reports carry financial and political gossip. One

02:30:21 financial and political gossip. One asserts uh a donation from BT. Another suggests Dr. Lawrence was running for London Mayor and a donation from the National Lottery. Both are completely false and in any event irrelevant to

02:30:32 false and in any event irrelevant to crime or disorder. The inquiry should establish why these matters were recorded and what they were used for.

02:30:44 recorded and what they were used for. Fourth, I turn to the infiltration of HN81 within Steven Lawrence campaign during the M McFersonson inquiry. It is truly abhorrent and shocking that at the very moment the Lawrence family

02:30:56 at the very moment the Lawrence family stood before the inquiry into MPS racism and failings, the MPS embedded an undercover officer within the campaign space around them, extracted tactical information about the family and its decisions, and channeled that

02:31:09 decisions, and channeled that intelligence into the MPS legal team's response machinery. The Ellison report captured the reality, referring to HN81 as quote a MPS spy in the Lawrence family camp.

02:31:28 the Lawrence family camp. It was said yesterday by the designated lawyers that HN81 infiltrated MFJ, not the Lawrence family. So, the label spying the Lawrence camp is unfair. However, the evidence is clear that private and potentially privileged information about the Lawrenes was

02:31:40 information about the Lawrenes was obtained by HN81 during the inquiry, whatever route he took to obtain it. It was used to furnish what was invaluable assistance to the MPS legal team at the time for the specific purpose of

02:31:52 time for the specific purpose of responding to the McFersoning inquiry. The intelligence gathered by H81 during the McFersoning inquiry was put to use immediately.

02:32:07 immediately. Detective Inspector Bob Lambert arranged a meeting in August 1998 between acting DI Richard Walton and HN81. Walton, an ex special branch officer

02:32:18 Walton, an ex special branch officer himself, was then secundered to the MPS legal team defending the force before McFersonson. The Lambert file of note of the meeting is incredibly damning. A series of quotes are worth uh mention in this opening. quote, "It was a

02:32:31 in this opening. quote, "It was a fascinating and valuable exchange of information concerning an issue which according to RW continues to dominate the commissioner's agenda on a daily basis."

02:32:42 basis." The same note praises HN81's quote invaluable reporting on the subject in recent months and records in-depth

02:32:53 recent months and records in-depth discussion which would be of great value as he continued to prepare a draft submission to the inquiry on behalf of the commissioner. The report adds the wider context

02:33:08 The report adds the wider context stating quote great sensitivity around the Lawrence issue with both the home secretary and the prime minister extremely concerned that the Metropolitan Police could end up with its credibility in the eyes of London's black community completely undermined.

02:33:23 Various other notes set out in our written opening demonstrate that the information HN81 obtained about the during the inquiry was considered to be of great value and inform the MPS's position to the inquiry. The flow of information was not limited to a single

02:33:35 information was not limited to a single meeting. Contemporaneous minutes record that quote DI Bolton of CO24 receives ad hoc off therecord briefings from SDS

02:33:47 hoc off therecord briefings from SDS with instructions that quote knowledge of the operation goes no further and that he should receive nothing on paper and that a route had been set up to send material.

02:33:57 material. It appears that this manifest abuse court of uh abuse of covert policing occurred at the request of senior officers and with the knowledge of the

02:34:13 officers and with the knowledge of the commissioner. HN81 confirms his product was provided to the commissioner. Sir Paul Condan from whom he received congratulations for excellent reporting. Another SDS officer 1072 states that the tasking in relation to the McFerson

02:34:26 tasking in relation to the McFerson inquiry would have come directly from sir from Sir John Stevens the uh the subsequent commissioner who gave the go-ahad.

02:34:33 go-ahad. Bob Lan Bob Lambert's HN10's representations to the Steven Lawrenson's review include confirmation that the meeting was arranged quote at

02:34:45 that the meeting was arranged quote at the request of senior management and he understood that the purpose of the meeting was so that Richard Bolton could fully brief the commissioner. It is telling uh chair that HN81 later

02:34:58 It is telling uh chair that HN81 later received a commander's commendation for his work. Dr. Lawrence is deeply

02:35:09 his work. Dr. Lawrence is deeply disappointed that H&81 has been excused from giving evidence in person. Much of his sentiments has already been echoed in today's openings by other CPS. We recognize the chair's consideration of medical and risk materials, but the effect is that a key officer who spied

02:35:25 effect is that a key officer who spied on the family is not seen or tested in public after all these years. That compounds the harm to Dr. Lawrence and his family. And we reserve the right to invite the inquiry to treat HN1's

02:35:37 invite the inquiry to treat HN1's evidence with particular caution and to reflect that in its conclusions. Fifth, and finally, in relation to surveillance of the Lawrenes, the question of whether the undercover policing of the Lawrenes was justified.

02:35:52 policing of the Lawrenes was justified. Put simply, there was no justification. The commissioner now accepts that reporting on Dr. Lawrence was wholly indefensible and that this would have quote rightly prompted public outrage if it had become known at the time. We

02:36:09 it had become known at the time. We invite you chair to make findings to at least that effect on the following basis.

02:36:10 basis. First, as CTI correctly stated in an opening yesterday, the Lawrence family had done nothing themselves to justify undercover policing. They were not

02:36:23 undercover policing. They were not engaged in violence, crime, disorder, or subversion. the police materials themselves proceed on that footing. Second, the reporting cannot be justified as necessary to monitor other

02:36:39 justified as necessary to monitor other groups. The contemporaneous record shows that the family did not support any of those groups. Examples are littered throughout the intelligence reports and that of our written opening.

02:36:50 and that of our written opening. Third, the nature of what was collected. The intelligence was in intimate, irrelevant, and sometimes privileged. None of that serves a public order aim.

02:37:04 None of that serves a public order aim. Fourth, the timing. As mentioned, within days of the murder, eos were logging visitors and names were checked for political persuasion that predated any realistic basis to suspect disorder and rested on groundless suspicion.

02:37:19 rested on groundless suspicion. timing is relevant to the fifth uh reason which is proportionality. The undercover policing of the Lawrenes occurred at the times of the utmost uh sensitivity while uh resources should have been

02:37:32 while uh resources should have been focused on finding Steven's killers and during McFersonson. An intrusion in such highly sensit uh periods require a compelling case and there is none.

02:37:44 there is none. The second and final topic I addressed chair in this opening is the question of race discrimination. Chair, the question that sits behind all

02:37:56 Chair, the question that sits behind all of this is why these powers were used in this way.

02:38:00 this way. We're grateful that uh council to the inquiry yesterday underlined the importance of a full examination of race in these hearings and we welcome the inquiry's commitment to make clear findings on it. This inquiry should

02:38:11 findings on it. This inquiry should publicly investigate and find whether the undercover policing of the Lawrenes and others like them was race discrimination or otherwise racist. That goes to the inquiry's core function

02:38:25 goes to the inquiry's core function under section one of the 2005 act to address matters of public concern. Public concern about race discrimination by the MPS is longstanding identified by McFersonson and unddeinished to this

02:38:40 McFersonson and unddeinished to this day. It affects confidence, cooperation, and public safety. Only a thorough examination will meet that concern. Three principles guide that analysis. One, direct discrimination is less

02:38:59 One, direct discrimination is less favorable treatment because of race. The question is whether the Lawrenes were treated worse than comparable white families.

02:39:01 families. Two, discrimination is often unconscious. Overt proof is rare and inferences from sounding facts are from surrounding facts are critical.

02:39:12 surrounding facts are critical. Three, tribunals may draw common sense inferences including from patterns and similar fact evidence. Race need not be

02:39:28 similar fact evidence. Race need not be the sole motive. If it had a significant influence, discrimination is made out on the disclosed material. There is weighty evidence that the undercover policing here was racially discriminatory. I sum I summarize it in five short areas.

02:39:45 five short areas. One, disproportionate surveillance on black people. The materials show a striking disproportionality. Black bereie families, black justice campaigns, and anti-racist organizations were treated as objects of suspicion routinely infiltrated and written about

02:39:57 routinely infiltrated and written about in intimate detail. While violent white racist groups received marketkedly less intrusive attention,

02:40:08 intrusive attention, Trevor Morris accepts he provided quote quite a lot of reporting on the activities of the SWP around the Lawrence campaign. SDS undercover officers also reported on campaigns for Cherry Gross, Blair Peach, Brian

02:40:20 Cherry Gross, Blair Peach, Brian Douglas, Ricky Will, Roland Adams, and others. and across civic organizations such as New Monitoring Project, Youth

02:40:36 such as New Monitoring Project, Youth Against Racism in Europe, the Anti-Nazi League, and Anti-Fascist Action. These were peaceful attempts at accountability, yet were treated as matters of subversive interest. By contrast, sustained SDS penetration

02:40:49 By contrast, sustained SDS penetration of violent racist organization is thin. This was not for lack of targets. The period saw NF, BNP, Combat 18, British Movement, National Socialist Movement,

02:41:00 Movement, National Socialist Movement, Blood and Honor, and Associated Violence

02:41:11 Blood and Honor, and Associated Violence up to and including David Copelan's 1999 nail bombings. Yet, the evidence shows very limited undercover work against these groups, aside isolated short deployments and some security service files. nothing comparable to the systemic attention given to the black

02:41:23 systemic attention given to the black family justice and anti-racist campaigns that we've already heard today in opening. If the inquiry concludes that there was a disparity, the next question it must ask is why? The suggested

02:41:38 it must ask is why? The suggested explanations don't hold. The notion that the farright was too violent to infiltrate is untenable. Undercover policing has long operated in violent environments and the size and spread of groups like the BNP offered multiple lower risk entry points. If

02:41:53 multiple lower risk entry points. If public order was the touchstone, the police purpose for infiltrating the racist groups was stronger, not weaker, than for surveilling ber families and community groups.

02:42:04 community groups. Two, overt evidence of racism. A further indicator that the undercover policing of the Lawrenes and similar groups was discriminatory is the overt racism evidenced in the chain of

02:42:22 racism evidenced in the chain of command. In 1993, it is alleged HN86 referred to the Lawrenes with the phrase, "The monkeys were being organized." Robert Potter was said to routinely use the N-word. A complaint that was made

02:42:33 the N-word. A complaint that was made about him uh for racist behavior in a public place led to the end of his police activities. Peter Francis describes Potter as having quote a hatred of black people. We do not say that every SDS manager

02:42:46 We do not say that every SDS manager shared those views. The legal point is simpler. Direct evidence of racist language and attitudes within relevant supervisory lines is probitative of discriminatory decision-making, especially where, as the case law

02:42:57 especially where, as the case law recognizes, discrimination is often unconscious and proved by inference from surrounding facts. that some of this language went

02:43:13 that some of this language went unchallenged at the time strengthens the inference that race had a significant influence on targeting, tasking, and reporting in this case. Thirdly, racial profiling and categorization. Across the disclosure, people are

02:43:25 Across the disclosure, people are routinely labeled by race rather than risk. Reports speak of quote other colored groups. A meeting of quote chaired by an unidentified male negro about half were colored.

02:43:37 about half were colored. Head counts like quote some 60 people were present half of them black. A child described as half cast and even a specific note of a quote black

02:43:52 specific note of a quote black heterosexual member of MFJ as if that in of itself were operationally significant. We also learned special branch maintained a quote black and browns desk. The habit of counting black

02:44:03 desk. The habit of counting black attendees or noting ethnicity as a standalone feature evidences race conscious surveillance and supports the

02:44:16 conscious surveillance and supports the uh inference that race was a reason for the extent of the undercover policing. Four wider evidence of race discrimination. The surveillance on the Lawrenes did not occur in isolation. bereieved families, anti-racist campaigners, and police monitoring groups, some of which you've already heard today uh chair were

02:44:31 already heard today uh chair were treated as intelligence targets as set out in our written opening. The chair also uh sorry chair, you have also uh the benefit of extensive submissions from the other core participants on those matters.

02:44:45 participants on those matters. That similar fact record is probitative of improper purposes here and is relevant to the inferences in this case. There is substantial wider evidence of race discrimination within the MPS.

02:44:56 race discrimination within the MPS. McFersonson found institutional racism in the MPS in its treatment of the Lawrenes. More recently, the Casey review concluded that institutional racism persists across a range of MPS functions.

02:45:11 functions. Taken together, these reports show a problem that is systemic rooted in culture and systems.

02:45:17 Fifth, and finally, the lack of race discrimination training. The systems safeguards against race discriminations were threadbear at best and calls for an examination in tranch 3. HN81 says he

02:45:32 examination in tranch 3. HN81 says he received just one day of race equality training. Francis recalls racial awareness training at Henden, but none thereafter. The combination of scant and peruncter race training may explain how

02:45:46 race training may explain how discriminatory practices could persist and is capable of supporting an inference of discrimination in of itself.

02:45:54 Taken together, chair, these factors provide cogent primmaacy evidence that the undercover policing of the Lawrenes and other black justice or anti-racist groups was racially discriminatory. We invite the inquiry to carefully examine

02:46:09 invite the inquiry to carefully examine these issues. At the end of this tranch, if the evidence does not demonstrate uh an even-handed approach and there is no good reason for the disproportionality,

02:46:21 good reason for the disproportionality, Dr. Lawrence will invite you to to come to a clear conclusion of race discrimination. Chair, in conclusion, we ask the inquiry to examine closely why covert power was turned on a berieved black family

02:46:39 turned on a berieved black family to find the surveillance of Dr. Lawrence was wholly indefensible and unjustified as it is now accepted by the commissioner to examine how it was used and whether race played a significant part. We welcome the council to the inquiry's

02:46:52 welcome the council to the inquiry's commitment to test those issues fully. Thank you, sir. Thank you very much and thank you for completing your opening submissions in slightly under the time that you were allotted. It's enabled us to catch up

02:47:03 allotted. It's enabled us to catch up with ourselves. Very grateful to you. Thank you

02:47:07 Dave Morris.

02:47:19 Good afternoon, Mr. Morrison. Thank you for waiting patiently and uh you're you're at the back of the queue, I'm afraid.

02:47:27 afraid. No problem. Thank you very much. Can you hear me? Okay. Yes, we can. Okay. So, I am a core participant and make this short oral opening statement as one of the McGllants.

02:47:41 as one of the McGllants. The other defendant is fellow core participant Helen Steel. She is currently preparing her own detailed witness statements on wider issues, including the shocking extent of the SDS's impact on her life.

02:47:56 SDS's impact on her life. But firstly, I'd like to say having listened to the harrowing statements made today, let me extend my solidarity to the other non-state core participants. We have all been heavily impacted by

02:48:08 We have all been heavily impacted by what the Met Police yesterday admitted was a dysfunctional undercover unit, the human toll of which they now accept was severe and wide ranging.

02:48:21 severe and wide ranging. Your your own 2023 interim report as the inquiry chair had already concluded that the SDS should have been brought to a rapid end in the early 1970s.

02:48:34 rapid end in the early 1970s. If it had been, its industrialcale breaches of people's rights and lives and the undermining of movements for

02:48:45 and the undermining of movements for positive change would not have taken place.

02:48:50 place. The McDonald's Corporation versus Steel and Morris court case resulted from a London Greenpeace campaign against the burger giant in the mid 1980s. We were sued for liel in 1990.

02:49:04 We were sued for liel in 1990. It became the longest trial in English history.

02:49:08 history. We had been denied legal aid so had to defend ourselves supported for free behind the scenes by a barristister Karma. It ended with a victory in the European Court of Human Rights in 2005.

02:49:21 Court of Human Rights in 2005. The proceedings involved a prolonged and colossal effort by the three of us and a great deal of stress. The inquiry has has begun to shine a

02:49:33 The inquiry has has begun to shine a light on a dark and highly significant secret. The involvement of the SDS and the two-way collusion between the

02:49:45 the two-way collusion between the Metropolitan Police and McDonald's in the 1980s and 1990s. But there remain vital questions which now need answering by witnesses,

02:49:57 now need answering by witnesses, admissions, and disclosure during trance three, including how long did the collusion go on for, who knew about it, and who authorized it. Inquiry documentation has already

02:50:13 Inquiry documentation has already revealed a great deal of evidence, which I have outlined in detail in my written statement published today, I believe. So, what are some of the things that we know already?

02:50:28 HN10 Bob Lambert helped to research and write the what's wrong with McDonald's fact sheet which became the subject of the liel action.

02:50:41 became the subject of the liel action. He and another infiltrator HN5 John Dyn both enthusiastically took part in the anti- McDonald's campaign and distribution of the fact sheet. Dynineered a long-term intimate relationship with London Greenpeace participant Helen Steel, characterized

02:51:02 participant Helen Steel, characterized by council to this inquiry a year ago as quote cold, calculating emotional and sexual exploitation.

02:51:18 McDonald's themselves hired seven spies to infiltrate London Greenpeace for an 18-month period to identify who was active in the campaigning. Dyn became aware of these individuals and who they were.

02:51:30 and who they were. The security services were made aware of McDonald's spies and asked for a more detailed report from the SDS. McDonald's head of security, Sid Nicholson, and his deputy, Terry

02:51:43 Nicholson, and his deputy, Terry Carroll, both former Met Police Chief Superintendants in Brixham Police Station in the early 1980s before being employed by McDonald's

02:52:01 by McDonald's were aware of Dyn and the SDS operation. It should be noted that Bob Lambert had been a special branch officer with responsibility for the Brixton area also in the early 1980s. Nicholson Sid Nicholson testified during

02:52:22 Nicholson Sid Nicholson testified during the Mcll trial that Macdonald's security were quote all ex police and he could get information on protesters from former contacts.

02:52:33 1867, Alan Alan Bond told Dyn that he had known about the McDonald's spying operation from the outset and that McDonald's knew who Dyn was.

02:52:44 and that McDonald's knew who Dyn was. Dyn was arrested at the Trfalga Square pole tax disturbances. Commander Gun, who I'll talk about later,

02:52:54 later, pulled Dyn's charges and the paperwork was destroyed. HN67 bond was temporarily transferred to a special branch unit investigating the Trafalga Square events. An officer of

02:53:09 Trafalga Square events. An officer of that unit had meetings with one of the McDonald spies and they shared confidential information about

02:53:20 confidential information about participants in London Greenpeace. We later successfully sued the Met over this, but they concealed the much greater collusion with McDonald's through the SDS.

02:53:35 Dianne's witness statement explains that he was quote emitted from the RIT served by McDonald's originally on five of those active in the campaign and that this action obviously by senior officers in collusion with McDonald's threatened to compromise his deployment.

02:53:50 threatened to compromise his deployment. It seemed to be a risk they were willing to take.

02:53:58 to take. Dyn reported in advance the exact date McDonald's had planned to serve the Rits.

02:53:59 Rits. Once the Rits had been served, McDonald's security manager Terry Carroll said he was going to contact Special Branch for an assessment.

02:54:13 Special Branch for an assessment. Dyn reported, presumably by exploiting his relationship with Helen Steel, on an early closed meeting of the five original defendants in which we discussed legal strategy

02:54:27 discussed legal strategy and also on later legal strategy meetings.

02:54:29 meetings. Dyn has admitted it is accurate to say I was by the side of Helen Steel and Dave Morris in 1991

02:54:41 of Helen Steel and Dave Morris in 1991 and relaying the legal advice i.e from Karma

02:54:43 Karma back to my bosses in the SDS.

02:54:53 Bob Lambert was SDS manager during the midl trial. Sid Nicholson was overseeing the litigation for McDonald's. Establishing the facts on who had been involved in helping create and publish

02:55:07 involved in helping create and publish the anti-MC McDonald's fact sheet was a fundamental issue during the McLeel proceedings at every level up to and including the European Court. The courts were misled at every stage.

02:55:33 Lambert was in charge of a major operation to try to prevent Helen Steel tracking down her exartner Dyn who had disappeared without trace faking a mental breakdown. He reported that if she found him and discovered the truth then they that is Helen, myself and Kia

02:55:45 Helen, myself and Kia would give serious consideration to subpoenaing dynor the commissioner to

02:55:59 subpoenaing dynor the commissioner to give evidence at the McDonald's liable case. In other words, the SDS and MPS were knowingly sabotaging the opportunity to call a key witness during a major trial.

02:56:11 a major trial. Would this have led to the collapse of the MLE trial and the closure of the SDS?

02:56:21 As can be seen, there was extensive collusion, breaches of legal privilege, misfeasence in public office, interference with legal process, and maybe most significantly, lying to and misleading courts by the failure to

02:56:37 misleading courts by the failure to disclose vital evidence throughout the MLE hearings right up to the European level.

02:56:41 level. When asked about some of this in tranch 2, SDS managers testified that such collusion would have to be authorized at a higher level than the SDS, probably commander level.

02:56:57 commander level. I understand that commander gun produced who was the commander at the time produced a position paper regarding the special branch having established excellent links with commercial and industrial organizations

02:57:10 industrial organizations including through delivering presentations and briefings and offering what he termed quote a consultancy service.

02:57:21 service. Commander Gun is giving evidence next Monday

02:57:27 Monday and Deputy Assistant Commissioner Felen at some point. They're both during Yes. So they will both be giving evidence during this phase. They were the higher levels at

02:57:46 phase. They were the higher levels at the key early stages of the MLE story. So need to be robustly questioned. Who knew about these matters? How long did it go on for? How was the collusion conducted? How high up was the authorization given? Who liazed with McDonald's?

02:57:59 Who liazed with McDonald's? What was the role of Bob Lambert? What was the role of the security services? Why was it allowed to happen?

02:58:18 I I also ask who now is going to take responsibility and apologize unreservedly for this scandal. I acknowledge and welcome that a number of apologies have already been made by the Metropolitan Police for the serious wrongdoing by the SDS.

02:58:34 wrongdoing by the SDS. Like many core core participants, I am currently awaiting a full witness statement from the home office and for an apology from the home secretary for

02:58:50 an apology from the home secretary for successive governments authorizing and signing off these secret political policing deployments. Thank you.

02:59:02 Thank you. Thank you very much indeed. Um we will resume tomorrow at 10:00 when the final opening submissions on behalf of core participants will be made. Uh I anticipate we will finish um by mid or early late afternoon tomorrow.

↩ All hearings