Hearing Transcript - 18 September 2003 Afternoon

8/8/2019 Hearing Transcript - 18 September 2003 Afternoon

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Hearing Transcripts

1031 Q. Before we move on to that, you had no involvement with2 the Q and A material at that stage during the morning of3 the 8th?

4 A. No.5 Q. Is that right?6 A. Hmm, hmm.7 LORD HUTTON: Would this be a convenient time?8 MR LLOYD-JONES: My Lord, could I mention I am almost at the9 limit of my permitted time.10 LORD HUTTON: Yes.11 MR LLOYD-JONES: There are a number of other matters12 I should, with your Lordship's permission, canvass with13 Ms Teare. I hope it will be of assistance to14 your Lordship if I did that.15 LORD HUTTON: Certainly, by all means. We will proceed16 after lunch. You would not like to do it now?

17 MR LLOYD-JONES: My Lord, no, if I could do it this18 afternoon I would be very grateful.19 LORD HUTTON: Very well. Thank you very much.20 (1.02 pm)21 (The short adjournment)22 (2.00 pm)23 LORD HUTTON: Yes Mr Lloyd-Jones.24 MR LLOYD-JONES: My Lord, thank you.25 Ms Teare, I think we had reached the afternoon of

1041 Tuesday 8th July and the question of your involvement2 with the Q and A material during the course of the

3 afternoon. What was your contribution to the redrafting4 of the Q and A material, at that stage?5 A. Essentially I looked at the material we had and then6 discussed through with Martin Howard the other7 information that we might include, the gaps that I had;8 and I also took out some of the earlier parts of the9 second draft because they were no longer appropriate.10 Q. What was your contribution and what was Mr Howard's11 contribution to the draft?12 A. It was largely me suggesting the questions we were13 likely to be asked and then him providing the factual14 information.15 Q. Could we have on the screen, please, CAB/21/5? We

16 looked at this this morning. This is the draft which17 you had sent over to the Permanent Secretary's office18 that morning and you were working on. We see in that19 draft it was proposed the individual would be told20 before his name was confirmed. Do you see that?21 A. (Nods).22 Q. That is not in the third and final draft. Can you tell23 us why not?24 A. No. I mean, the -- as I say, the different drafts of25 the Q and A leading up to the final version were very

1051 much work in progress documents. They were evolving on

2 the basis of the information that I had at each point in3 time; and that was why there were some amendments made


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4 to them as time progressed. I had discovered that5 whilst in the Permanent Secretary's office that morning,6 that Dr Kelly had been forewarned that his name was7 likely to enter the public domain and accordingly I felt8 that it was reasonable, therefore, for us to confirm his9 name if the correct name was put to us, given all the

10 other circumstances of the situation that we had to11 manage.12 Q. Did there come a time when Sir Kevin came back from,13 I think it was Portsmouth?14 A. That is right, yes.15 Q. Did he come back to his office?16 A. On his return from Portsmouth he popped back, briefly,17 into the office before going to a meeting at No. 10.18 Q. You have said that at some point you went back to your19 office. You are in the Metropole Building, I think?20 A. That is right.21 Q. Did there come a time you were summoned back to22 Sir Kevin's office?

23 A. Yes. At about the same time Sir Kevin went to No. 10,24 I came back to my own office. Then when he returned25 from No. 10 I was summoned back to his office, which

1061 must have been about 3.30.2 Q. When you saw Sir Kevin on your return and his return,3 what did he say to you?4 A. He said that the -- we were going to issue a statement5 that afternoon, and he had a draft with him on his6 return from No. 10.7 Q. Did he show you the draft?8 A. I cannot remember whether it was copied or not. I know

9 that there was a discussion between Martin Howard,10 Sir Kevin and myself which led to the draft being11 finalised. But I cannot recall the detail of any12 changes that we made.13 Q. Had it changed since you had last seen it? Had the14 version which Sir Kevin brought back changed since you15 had last seen it?16 A. Yes.17 Q. Do you recall in what respect?18 A. I seem to recall that it was a longer document. It was19 certainly a different sort of document to the draft that20 I had produced on the 7th.21 Q. Were any further changes then made to the statement in

22 Sir Kevin's office?23 A. I think there were a couple of changes made, but I am24 afraid I cannot recall the detail of what they actually25 were. I cannot remember whether they were -- I do not

1071 think they were very major but I cannot recall the2 actual detail of them.3 Q. Do you know what happened to the statement then, once it4 had been finalised?5 A. As I understand it, the Permanent Secretary's private6 secretary e-mailed it to Richard Hatfield, so that he7 could clear it with Dr Kelly.

8 Q. Was anything reported to you subsequently about that?9 A. I remained in the Permanent Secretary's office, and


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16 of the person concerned?17 A. Effectively the position that -- well, two points.18 First of all, on the evening of the 8th I am not19 aware -- I certainly did not receive any -- any names20 being put to the press office as to the possible21 identity of the individual concerned.

22 Q. Pausing there, who, amongst you and your staff, knew the23 identity of the person concerned?24 A. The Chief Press Officer and I alone.25 Q. You were the only two?

1101 A. Yes.2 Q. So what would happen if someone in the press office, the3 duty officer, overnight, received a call asking: is it4 Mr Jones?5 A. Well, then they would have had to have contacted us,6 because in the same way that they would not know7 whether -- well, they would not know whether any name

8 put to them was the right one or the wrong one, so they9 would have to refer it to us; and I think during the10 course of the next day --11 Q. Before we get to the next day, during that evening did12 you receive any calls?13 A. I received a number of media enquiries, yes.14 Q. Were any of them enquiring about the identity?15 A. Some of them actually asked me what the name of the16 individual was.17 Q. Did you tell them?18 A. No.19 Q. Did you tell any of them that although you would not20 reveal the name, you would confirm it if they already

21 knew it?22 A. Yes.23 Q. Why did you consider it appropriate to say that?24 A. I felt it was necessary to explain that because I wanted25 to ensure a system where the media would actually check

1111 with us before they printed a name or broadcast a name.2 Q. What interest were you seeking to protect by taking that3 course?4 A. Essentially, it would have two purposes. One was that5 it would prevent those who were not involved from6 wrongly being named in the media; and, secondly, it

7 would give us an indication, and therefore we could pass8 the information on, if Dr Kelly's name was coming9 forward.10 LORD HUTTON: Pass information on to whom?11 A. I am sorry, my Lord?12 LORD HUTTON: Pass information on to whom that Dr Kelly name13 was coming up?14 A. No, I mean we would get -- if we had a system whereby15 journalists were coming to us to check the name first,16 we would get a heads up that Dr Kelly's name was likely17 to appear.18 LORD HUTTON: I thought you said you could pass information19 on.

20 A. In that we could alert Dr Kelly, I mean, and alert21 others in the department.


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22 MR LLOYD-JONES: At this point -- we are still on the23 evening of 8th July -- were you aware, at that time,24 that earlier that day the Secretary of State had written25 a letter to the BBC?

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1 A. Yes, I was aware.2 Q. How were you aware of that?3 A. I had heard of it either from the Permanent Secretary's4 office or direct from the Secretary of State's office,5 one or the other.6 Q. Did the MoD press office release that letter to the7 media?8 A. No, we did not.9 Q. Did you receive any press queries about that letter?10 A. I seem to recall I had one call from the press about it,11 who asked whether --12 Q. Can I ask when that was?13 A. That would have been probably up to an hour after the

14 release of the statement on the 8th. I do not recall15 the time.16 Q. What was the nature of the query?17 A. The best of my recollection is that it was enquiring as18 to whether we had written to the BBC.19 Q. What was your response to that query?20 A. I was not sure, at that point, whether or not we were21 actually discussing this letter, so I said that I would22 have to make enquiries; and I think, in practice, I did23 not actually return that call. It was not followed up.24 Q. Right. Could we have on the screen, please, MoD/32/46?25 You may be able to read that, Ms Teare. I am afraid we

1131 will need to see the full width of the page. Can you2 see a line, about halfway down the page?3 A. Hmm, hmm.4 Q. I am going to ask you in a moment about the entry5 immediately above that line. First, is the press office6 at the MoD open 24 hours a day?7 A. Yes, it is.8 Q. Is a log kept 24 hours a day of enquiries received?9 A. No, the log does not operate over the 24 hour period.10 The log operates purely to recall -- sorry, to record11 calls and activity of a duty press officer.12 Q. So during what hours would the log be kept?

13 A. It varies. If it is a very busy day the duty press14 officer might not actually start to be operating alone15 till maybe 7.30, maybe a bit later. I would have16 thought on average until about 7.17 Q. Until what time?18 A. Until the press officers get in in the morning, so19 I would have thought from about 7 to 8.20 Q. If we look at that entry, on the face of it it appears21 to be an entry in relation to something that happened at22 09.45 on the morning of 8th July.23 A. Hmm, hmm. That cannot be the case because the log does24 not run in the daytime, as I say. It would certainly go25 no later than 8.30.

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1 Q. Yes. Have you caused any enquiries to be made in the2 press office about this?3 A. Yes, I did. I asked for the duty press officer4 involved, Howard Rhodes, actually to be contacted. He5 was on holiday, but we have spoken to him. And he6 confirmed that call was received on the evening of

7 8th July; and whilst it says 09.45 it should in fact say8 21.45. I think he merely slipped from using the 24 hour9 clock to the 12.10 Q. Have you made enquiries as to whether Mr Rhodes was, in11 fact, the duty press officer that night of the 8th to12 the 9th?13 A. I know that he was in the duty press office, because I14 was in the press office that evening.15 Q. If we look at the entry, the press officer was16 Howard Rhodes. Caller Finlo Nelson -- can you read it17 on your copy? Thank you. Finlo Nelson Rohrer.18 Origination, BBC online:19 "Can we have a copy of Geoff Hoon's letter to

20 Gavyn Davies?"21 We see recorded there the response -- would that be22 the response made by Mr Rhodes?23 A. Yes.24 Q. It reads:25 "This is private correspondence and will remain so

1151 as far as we are concerned."2 Did you survey the press coverage on this matter3 following the 8th July?4 A. Yes, I did, obviously not on just this particular aspect5 but coverage across the board.

6 Q. So far as this particular aspect is concerned, did you7 examine press reports?8 A. Yes, I read all the press reports.9 Q. In those reports did you find any direct quotes from the10 letter which the Secretary of State had written to the11 BBC?12 A. I did not find any at all, no.13 Q. Did you draw any conclusion from that?14 A. I felt that, at the most, journalists obviously knew15 that we had written to Gavyn Davies, but again not least16 one of the reasons they knew that was because the BBC17 themselves actually issued to the media their response18 to that letter. So I concluded, from that, that they

19 knew that we had written but that they had not seen the20 contents of our letter.21 Q. Was the MoD press office aware of whether any reply had22 been received to that letter?23 A. We were aware that a reply had been sent or -- because24 we were getting calls from the media to respond to it.25 But in actual fact -- although the media had been given

1161 copies of it, we had not, neither had the Secretary of2 State's office.3 Q. On the evening of Tuesday 8th July, did the press office4 do anything to assist Dr Kelly once the statement had

5 been published?6 A. Yes. I had discussions with the Chief Press Officer,


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7 Kate Wilson, and we agreed that there was a need to8 telephone him and to alert him to the high levels of9 media interest in the statement, and to make sure that10 he knew how to make a -- how to have access to 24 hour11 media handling advice and also to say that he might want12 to consider staying with friends.

13 Q. Moving on, then, to 9th July, was there a Secretary of14 State's briefing meeting that morning?15 A. Yes, there was.16 Q. Did you attend it?17 A. Yes, I did.18 Q. How clear is your recollection as to what was discussed19 at the meeting?20 A. I mean, I recall there was a meeting. I can recall what21 the key topics of conversation were, but I do not recall22 exactly who said what.23 Q. Do you recall who was there?24 A. The Secretary of State, his principal private secretary,25 Richard Taylor, special adviser, myself. I think that

1171 was all.2 Q. What is your recollection as to what was discussed?3 A. Well, it was a fairly brief meeting, because I know we4 had another one that was about to start very shortly5 afterwards. But my recollection is that the bulk of the6 meeting was to do with discussions of how we might7 follow up with the correspondence with the BBC.8 Q. Was anything said about the Q and A material?9 A. I think it is likely that I might have run through10 the -- an outline of the Q and A material and the11 approach that we were adopting.

12 Q. Would you have had any particular reason to do that?13 A. No, other than at that meeting it has several purposes:14 one, I go through the press coverage of the morning and15 I would normally outline how we were handling sort of16 main issues of the day. And it would be in that line17 that I would have done so.18 Q. Later that morning, do you recall, when back in your own19 office, receiving a telephone call from Mr Tom Kelly?20 A. I recall I had a call from Tom that morning, yes.21 Q. Was anyone else in the room with you at that time?22 A. The Chief Press Officer.23 Q. Was she able to hear the conversation you had with24 Mr Kelly?

25 A. I put the call on speaker.

1181 Q. How clear is your recollection of the conversation which2 followed?3 A. Again, it is not that clear. As I understand it, his4 enquiry related to something that had -- or an exchange5 rather that had occurred at the 8.30 No. 10 meeting,6 which I had not attended but the Chief Press Officer had7 attended, so she dealt with it.8 Q. Were you aware of what information may have been9 supplied to Mr Kelly by the Foreign and Commonwealth10 Office --

11 A. No, I was not.12 Q. -- following that conversation?


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19 MR LLOYD-JONES: At that point who in the press office staff20 knew the name of Dr Kelly?21 A. Just myself and Kate Wilson.22 Q. Did that remain the case?23 A. No, that position changed shortly after I had confirmed24 the name. This was purely to take account of the fact

25 that there was a duty press officer who would be taking

1211 over shortly and obviously he needed to know the correct2 name; but he was only made aware of this once the name3 had been confirmed.4 Q. Do you recall Kate Wilson being in your room later that5 evening when she received a call from The Times?6 A. Yes.7 Q. Did you overhear that conversation?8 A. I did not overhear, I could only hear her end of it,9 obviously. She was again being pressed for the name by10 The Times and she said to me: now that the name has been

11 confirmed, you know, can I tell The Times what the name12 is? She was -- you know, she was seeking my advice,13 which is perfectly reasonable.14 Q. What did you say?15 A. I said very firmly that we could not reveal the name and16 so that is what she said.17 Q. Ms Teare, was it ever your intention the Q and A brief18 or the way in it which it was used should be some device19 for secretly leaking Dr Kelly's identity and making it20 public?21 A. No, it was not.22 Q. Were you aware what the press office was doing on that23 evening of the 9th to assist Dr Kelly?

24 A. On the evening of the 9th, again once the name had been25 confirmed, we were anxious that we should identify and

1221 have ready to go, or in fact send, a press officer to2 Dr Kelly's house.3 Q. What would have been the point of sending a press4 officer?5 A. The point had been that had Dr Kelly chosen to stay6 there, the likelihood, in fact the certainty, was that7 large numbers of media would turn up outside his house,8 and the role of the press officer is to act as a buffer9 between the media and Dr Kelly and to give him advice on

10 handling and to deal with the media on the scene.11 Q. Do you know why that was not done sooner?12 A. It was not done sooner because (a) the name had not been13 confirmed; but also we were working on the assumption14 that once the name had been confirmed it would take15 journalists a number of hours to work out where he lives16 because, in the normal way, they would go through the17 electoral role and then operate a policy of elimination.18 We had assumed after the name had been confirmed there19 would be a couple of hours -- a few hours, actually20 where we could arrange to send someone.21 Q. Was a press officer in fact sent to Dr Kelly's home?22 A. No, a press officer was not sent but one was identified

23 and one was on standby ready to go.24 Q. When you confirmed the name of the individual to the


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25 Financial Times, whom did you tell that you had done

1231 that?2 A. I told the Chief Press Officer that I had done it.3 I think that is all I told. She then -- I cannot

4 remember what I -- I was busy with something else, but5 she then telephoned the Secretary of State's office and6 the Permanent Secretary's office, plus the press offices7 of the Foreign and Commonwealth Office and the No. 108 press office, to let them know that the name had been9 confirmed. In talking to the Permanent Secretary's10 office she requested that arrangements be put in hand11 for Dr Kelly to be told.12 Q. Finally, and very briefly, Ms Teare, the FAC hearing13 took place on 15th July and Dr Kelly appeared to give14 evidence. Did the press office provide any assistance15 to Dr Kelly in respect of that appearance?16 A. Yes, a press officer was sent to accompany Dr Kelly.

17 Q. What was the press officer's role on that occasion?18 A. Essentially to ensure that the media did not hassle or19 pester Dr Kelly in any way.20 MR LLOYD-JONES: Thank you, Ms Teare.21 I am very grateful, my Lord, for the additional22 time.23 LORD HUTTON: Yes. Mr Gompertz.24 Cross-examined by MR GOMPERTZ25 Q. Ms Teare, let us start with the 9th July. The first

1241 identification was made at 5.30 approximately in the2 evening.

3 A. It was 5.30 or very shortly thereafter.4 Q. Yes. Why was it that Dr Kelly was not notified of this5 fact at all until he telephoned at about 8 o'clock?6 A. Well, as I say, the Chief Press Officer rang the7 Permanent Secretary's office and they were going to make8 the appropriate arrangements for him to be told. We9 felt that -- it was certainly my view that there were10 two things: 1. It would be better for him to talk to11 someone who knew him about this; and also that while the12 press office role was there to provide practical media13 handling advice, you know, we did not have any14 responsibilities for a welfare role; and again, we15 thought it was better that his line manager should

16 contact him so that he could also discuss, you know,17 availability of hotel accommodation if that was what18 Dr Kelly was seeking. Now, I understand that Dr Wells19 did speak to him but you would need to check the times20 with him.21 Q. Had you alerted Dr Wells to the fact that he might be22 needed in order to inform Dr Kelly of his23 identification?24 A. Not specifically, but --25 Q. Why not?

1251 A. Because I did not think that it --

2 Q. Why had he not been notified he might be needed as3 a matter of urgency to telephone Dr Kelly?


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4 A. I think that the way the situation was unfolding at the5 time, Dr Kelly was in very regular contact with all of6 those involved -- sorry, Dr Wells was in very regular7 contact with all of those involved, and that the8 Permanent Secretary's office had numbers to contact him9 in and out of working hours.

10 Q. I do not follow that. I am sure it is my fault. Had11 anybody contacted Dr Wells to say: you may be needed at12 short notice to contact Dr Kelly to tell him he has been13 identified by the press?14 A. That had not been done so by the press office, that is15 all I can say.16 Q. Why could not Mrs Wilson telephone Dr Kelly direct? She17 had done so the night before after all.18 A. She could have done that but, as I have explained, we19 felt that it was better that Dr Kelly should receive20 this news from his line manager. As I say, we did not21 have in our gift any arrangements vis a vis hotel22 accommodation should Dr Kelly have decided that he

23 wanted to take that up.24 Q. You do not think, with the benefit of hindsight, it25 would have been very much better if Dr Kelly had had

1261 something like two hours' notice rather than 10 minutes'2 notice to leave the house?3 A. I think that what was important in handling this4 situation and in the media advice he was given was the5 crucial time was when the statement was first issued on6 the 8th; and on that day Dr Kelly was contacted. He was7 told of the very high levels of media interest and he8 was advised, at that point, to consider staying with

9 friends; and I think that actually was the most10 important time.11 Q. Can I go to the Q and A material, please? In the first12 draft produced by yourself and Mrs Wilson on the evening13 of Friday 4th July, the first two questions were to the14 effect: who is the official? Answer: we are not15 prepared to name him. Question: why not? Answer: we16 have released all the relevant details. There is17 nothing to gain by releasing the name of the individual18 who has come forward voluntarily.19 You thought that was the proper approach, did you?20 A. As I say, the draft we produced on 4th July, and indeed21 the one on 7th July, they were not freestanding

22 documents that had been agreed and approved, they were23 drafts. They were -- it was a document that was24 evolving to reflect the information and thought that25 I had given to the subject. So accordingly the draft

1271 that I had produced on the night of the 4th was --2 I have to say, a great deal of thought had not been3 given to it because I had not had much of the4 information for very long, I was getting the information5 second-hand and, what is more, certainly the situation6 is that if Dr Kelly's name had become public over the7 weekend, because that draft says we would not reveal the

8 name, what that draft also shows is that we had not had9 sufficient time to think through how we would react if


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10 his name actually appeared in the press; and if it had11 have done, I would have had to consult with the senior12 officials involved and it is conceivable that we may13 have had to have confirmed the name over that weekend.14 So I do not feel that you can say from the draft of15 the 4th that automatically we would not have confirmed

16 the name that weekend. It was all very much --17 Q. I think the answer to my question was a simple "yes"18 rather than an answer taking something like several19 minutes. The question I asked you was: on the Friday20 evening when you put those first two questions and21 answers in the draft Q and As, did you think that that22 was a proper approach? The answer surely is "yes", is23 it not?24 A. Obviously that situation was to deal with a position25 where Dr Kelly's name had not appeared in a paper. It

1281 would not have --

2 Q. Well, it had not appeared in a paper on the Monday,3 either, had it?4 A. No, it had not.5 Q. And yet in the second draft, which was produced on the6 Monday, the position had changed very radically, had it7 not?8 A. I would suggest that there was not a change because to9 say that there was a change suggests that there was10 already one agreed position from which we changed11 towards another; and as I have said, the document of12 4th July was not in any way a formal document. It had13 had no approval. It was a working document.14 LORD HUTTON: Ms Teare, accepting that but just going back

15 to Mr Gompertz's question, and I appreciate you say the16 situation was changing and evolving, but the question to17 you was: when you drafted that first question and18 answer, and it contained the view that the name would19 not be given, did you think that was the proper approach20 to take, at that time, in those circumstances?21 A. Yes, I did, my Lord.22 LORD HUTTON: Yes.23 A. But what I was trying to explain was that that -- the24 suggested responses in that document would only cover25 a situation where if, over the weekend, someone had

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1 asked us for the name.2 LORD HUTTON: Yes.3 A. But that document would not have dealt with a situation4 whereby if the name itself had appeared in the media;5 and in that latter set of circumstances we would have6 had to have taken advice, and we may well have ended up7 confirming the name over that weekend.8 LORD HUTTON: Yes. I see. Thank you.9 MR GOMPERTZ: The name had not appeared in the media by the10 Monday evening, had it?11 A. No, it had not.12 Q. So that had not changed, had it?13 A. No.

14 Q. So why did the change take place in the second draft,15 which by all means look at if you wish, but I am sure


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22 A. I will accept it reflects a different approach.23 Q. Who authorised that approach?24 A. As I say, these documents were evolving and reflecting25 my advice, at the time, on the basis of the information

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1 I had at the time.2 Q. Would you like to answer the question?3 A. I am trying to help you with the question. And4 accordingly no decision was taken -- you say: who took5 the decision? I did not consider that any of this6 material was available for use by the press office until7 it had been agreed by a senior official and approved.8 Other than that, it was just a document that reflected9 my advice and my views and was subject to approval.10 Q. Yes. Who approved it?11 A. It was agreed with Martin Howard and it was approved by12 the Permanent Secretary.13 Q. Thank you. Did the Secretary of State see this draft?

14 A. Not to the best of my knowledge.15 Q. No?16 A. No.17 Q. What about the routine press meeting on 9th July which18 you attended and which other people attended as well?19 A. That was the day after the draft had been approved.20 Q. Yes. Did the Secretary of State see that document at21 that meeting?22 A. I do not recall.23 Q. You see, we have heard some evidence to suggest that he24 did, and that there was some brief discussion about this25 document at that meeting.

1331 A. Hmm, hmm.2 Q. You know that, I expect. Do you agree or disagree with3 that evidence or do you not remember?4 A. I do not recall there being a long discussion about the5 Q and A.6 Q. Nobody said that there was a long discussion.7 A. No.8 Q. A brief discussion is what I put to you.9 A. I cannot recall the detail, though I think it is highly10 likely that I would have outlined some of the material11 in the Q and A, but I cannot give you a verbatim12 account.

13 Q. To the Secretary of State?14 A. Yes.15 Q. And no doubt in order to outline the material you would16 have had the document with you.17 A. Yes, I suspect I would have done.18 Q. And no doubt you would have shown it to him?19 A. He may have already had it. He may have already --20 Q. Do you know or not know?21 A. I do not know. I did not show him a document at that22 meeting, because, as I say, the bulk of that meeting was23 about how to follow up the correspondence with the BBC.24 Q. Yes. Let us look at the history of the statements, very25 briefly.

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1 Can we look, first, at MoD/17/2, which, for whatever2 reason, we, on behalf of the family, saw for the first3 time this morning.4 A. I had --5 Q. I am not suggesting it is your fault.6 What I would like to know is: is that your draft or

7 not?8 A. I would need to see the full document.9 Q. Certainly. Can we scroll down?10 A. (Pause). Yes, that is my draft.11 Q. Thank you. Submitted to whom and when, please?12 A. Sent to the Permanent Secretary's office on the evening13 of 7th July.14 Q. Thank you. What was actually used as a press statement15 we can see on MoD/1/67. Is that right?16 A. Yes.17 Q. That was what you released on 8th July at 5.45 pm.18 A. Yes, about that time.19 Q. Yes. Upon whose instructions did you release that

20 statement?21 A. On the Permanent Secretary's.22 Q. Thank you. Is that the document that he brought back23 with him from the meeting at No. 10?24 A. In the main it is the document. I think that a couple25 of small changes were discussed, principally between he

1351 and Martin Howard and myself; but I could not detail for2 you exactly what changes were made for the final version3 as compared to the version that he brought back from4 No. 10 with him.5 Q. Very well. There are changes, however, are there not,

6 from the draft which you had submitted --7 A. Yes, there are.8 Q. -- to the Permanent Secretary?9 A. Yes.10 Q. So they were inserted, as you understand it, at No. 10?11 A. Yes --12 Q. Is that right?13 A. As I said in my earlier evidence, I recalled14 a conversation with Godric Smith where he had suggested15 something along the lines of the penultimate paragraph.16 I certainly recall that discussion; but I do not recall17 discussing, in detail, a statement of this length.18 Q. Thank you. One other matter. If the MoD did not wish

19 to release Dr Kelly's name, could it not, in response to20 an enquiry, say this: we will neither confirm nor deny21 any name?22 A. That is one approach, but I had considered --23 Q. What is wrong with it? You were about to tell us,24 I apologise, I interrupted you.25 A. It is one that I had considered; but again, it did not

1361 deal with the difficulty of other people who were2 involved in the similar field from being named in the3 media; and that was something we felt that was not4 acceptable.

5 Q. So on the one hand it was not acceptable that they might6 be wrongly identified.


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7 A. It was not just a question of wrongly identified,8 because certainly my view was that anyone that was named9 would actually be subject to very high levels of media10 interest.11 Q. Yes. Did you consider, though, that if that did happen12 it would not be through the agency of the MoD, would it,

13 because you had not either confirmed nor denied their14 name?15 A. But the effect would have been the same; and what I was16 seeking to avoid was that individuals who had nothing to17 do with this situation were subject to high levels of18 media intrusion.19 Q. Do you know whether any assessment was undertaken as to20 the pros and cons of releasing information of the kind21 that appears in the statement and in the Q and As which22 would lead to Dr Kelly's identification, against23 adopting a stone wall attitude, if I can put it in that24 way, of declining to cooperate with the press at all?25 Was anything like that undertaken?

1371 A. I am not aware of anything, no, nor would I expect to2 be.3 MR GOMPERTZ: Thank you very much.4 Cross-examined by MR KNOX5 LORD HUTTON: Mr Knox, yes.6 MR KNOX: You said in your evidence that production of7 Q and A material is quite normal in a case when a press8 announcement is being put out, is that correct?9 A. Yes. I think I said "standard practice".10 Q. Is it standard practice that the following should11 happen: first, that a press announcement is agreed with

12 a civil servant concerned in a story which contains some13 information about that civil servant but at the same14 time Q and A briefings are prepared which give more15 details about the identity of that civil servant over16 and above those agreed in the press statement?17 A. I cannot agree with you that it is standard; and the18 reason that I cannot accept, you know -- accept that, is19 that the situation with which we had to contend was20 totally without precedent, so there was not, you know,21 such as a thing as standard practice. There was no22 yardstick with which to judge it. That is one of the23 reasons why it was such a difficult situation.24 Q. It certainly would not be a standard practice to agree

25 a press statement expressly with a civil servant which

1381 contains some details about him and not tell him about2 further details you are going to be releasing as part of3 a Q and A briefing if necessary, is it?4 A. As I say, there is not a standard practice in this5 situation. There are no rules that govern the release6 of civil servants' names. We were dealing with an7 unprecedented situation.8 Q. It is not really usual at all, is it, to even make press9 statements about civil servants or indeed to prepare10 Q and A briefings in relation to them?

11 A. As I said, this situation we were dealing with was12 unprecedented.


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13 Q. I think the answer to my question is "yes", is that14 right?15 A. I think you have now confused me that I am not sure what16 I am saying "yes" to.17 Q. It is not usual, is it, to give a Q and A briefing and18 also prepare a press statement when you are talking

19 about the identity of civil servants, is it?20 A. I have not been involved in a situation similar to this,21 even similar to this one, so I cannot say what is usual.22 Q. I just want to consider the question of the fairness23 with which Dr Kelly was dealt with.24 Your duty, presumably, in the press office, is to25 give advice and support to Dr Kelly relating to the

1391 practicalities of dealing with the media; is that right?2 A. (Nods).3 Q. You presumably wanted to deal fairly with Dr Kelly; is4 that right?

5 A. That is right.6 Q. That was, presumably, very important?7 A. That was important.8 Q. By the time that Mr Hatfield spoke to Dr Kelly at about9 4.30 or so on Tuesday afternoon, 8th July --10 A. Hmm, hmm.11 Q. -- he had a press statement which he was going to try to12 agree with Dr Kelly; that is right, is it not?13 A. (Nods).14 Q. By that time you had already worked out the basic15 Q and A strategy which you were going to use in16 connection with that press statement when the press made17 calls as a result of the press statement; that is right,

18 is it not?19 A. Over the lunchtime I had agreed Q and A material with20 Martin Howard; but, as I have said, it could not be used21 or deployed by the press office until approval by the22 Permanent Secretary. Now, that -- he read the material23 and approved it -- I am not quite sure, some time,24 I would say, between 4 and 4.30, maybe a bit later.25 Q. So it is probably right -- and I think we heard from

1401 Mr Hatfield this morning anyway, it is probably right2 that by the time the press statement had been drafted to3 agree with Dr Kelly, the Q and A briefing material had

4 also been prepared. That is right, is it not?5 A. I do not -- all I am saying is I am not quite sure as to6 whether it had been approved by then. My understanding7 was that when the press statement had been finalised the8 Permanent Secretary's private secretary then e-mailed it9 to Richard Hatfield for him then to clear with Dr Kelly;10 and then Martin Howard and the Permanent Secretary and11 I went through the Q and A material.12 Q. Shall we assume for present purposes it had been13 approved by the time that Mr Hatfield agreed the press14 statement with Dr Kelly? Assume that for present15 purposes.16 Could we just call up MoD/1/62? It is right, is it

17 not, that the press statement, we need not go to that18 for the moment, does undoubtedly contain some details


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19 about Dr Kelly, without naming him? That is right, is20 it not?21 A. That is right.22 Q. If you drop down this page you will see that further23 details are going to be given to the press:24 "How long has he been in the MoD?"

25 "He has been in his current position for 3 to

1411 4 years. Before that he was a member of UNSCOM.2 "Did the official play any part in drawing up the3 dossier?4 "He was involved in providing historical details ...5 "Is he a senior figure? ...6 "Is he still working for MoD?7 "Yes.8 "Is he in Iraq?9 "No, though he visited recently for a week.10 "Is he a member of the ISG?

11 "No."12 Those are further details about Dr Kelly that were13 not agreed with him in the press statement.14 A. Perhaps I should just say again that Q and A material is15 not released in its entirety. I would say that the way16 you were reading that -- those Q and A -- those Q and As17 out there suggested that we were giving this information18 out wholesale. That was not the position, nor should it19 be.20 Q. You would not give it out wholesale but you would give21 it out if you were asked the relevant questions?22 A. We would give it out if we were asked the relevant23 question. I rather felt you were suggesting we would

24 give that material out in one batch, which is not the25 position.

1421 Q. So in other words, perhaps you could explain, at what2 point would you give out the individual bits of3 material?4 A. If we were asked those specific questions.5 Q. So if someone said, "Is he in Iraq?", at that point you6 would say "No, though he visited Iraq recently".7 A. Yes.8 Q. These are effectively additions to the details provided9 in the press statement?

10 A. Again, that is part of the standard practice in11 Q and As.12 Q. I think we have already agreed this is a totally unusual13 situation.14 A. But the principle of Q and A material is not different.15 Q. Surely, in fairness to Dr Kelly, to help him deal with16 the media, should you not have ensured that Mr Hatfield17 told Dr Kelly (a) that his employers were going to tell18 journalists all these extra details; and (b) you, that19 is the MoD, his employers, were going to tell20 journalists in terms that you would confirm his name.21 Should that not have been done as well as agreeing the22 press statement with Dr Kelly?

23 A. I am not quite sure when you say in your question "to24 help him deal with the media". I think our point was we


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25 wanted to make sure the situation was that we dealt with

1431 the media, rather than him.2 Q. Let us just deal with the matter, as a matter of3 fairness. Dr Kelly is called in the afternoon in order

4 to agree a press statement with him; that is right, is5 it not?6 A. (Nods).7 Q. He would naturally suppose from that that certain8 information is going to be released about him in that9 press statement.10 A. Hmm, hmm.11 Q. He is not told by the MoD that further information will12 be released about him by the MoD press office, is he?13 A. No, he is not, but as I say --14 LORD HUTTON: Yes, carry on Ms Teare. You were going to add15 something.16 A. As I say, it is standard Civil Service practice when any

17 statement is released that a Q and A is also produced to18 support it which contains some factual information19 related to the statement. That is not an unusual20 practice.21 MR KNOX: I understand "unusual" or "not unusual". What22 I am trying to understand is this: why did you not tell23 Dr Kelly this is what you were proposing to do?24 A. I saw there to be no reason to tell him, because the25 material that we had was in the Q and A, it was largely

1441 factual, and that Dr Kelly had already been forewarned2 that his name was likely to enter the public domain.

3 And what is more, we -- when -- you know, in the run up4 to that happening we would -- I knew that we would be in5 touch with Dr Kelly to provide him with advice on media6 handling. So I saw no role for me to insist that the7 Q and A should be run by him.8 Q. Was there any reason for not telling Dr Kelly what you9 were intending to do in answer to questions from10 journalists?11 A. No, there was not any reason why he could not have been12 told. As I say, there was no discussion of it because13 it was not felt to be an issue.14 Q. Would it not have been better and fairer to Dr Kelly to15 give him the full picture? Namely: (1) we will put out

16 this press statement; (2) if we get asked certain17 questions we are going to have to answer them this way18 and thereby reveal further details about you. Would19 that not have been the fairer way of dealing with it?20 A. I do not actually accept it was unfair because21 Dr Kelly -- for a start, I felt that Dr Kelly's name was22 likely to emerge because he was quite well known in23 media circles anyway. But on the substance of the24 Q and A material, I do not see that there was anything25 there that we needed to consult him about in any way.

1451 As I say, if he had not have been -- if he had not been

2 told and it had not been discussed with him and that he3 had no expectation of his name becoming public, if he in


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4 no way had been given to believe that might happen, then5 I think there would have been a question of fairness.6 But I do not see it at all in this case.7 Q. What was the point of agreeing the press statement with8 him?9 A. The point of agreeing the press statement was that so he

10 would know (a) exactly when it was happening and (b)11 what was said. That is quite standard to agree the12 actual contents of the statement.13 Q. If that was the point of agreeing the press statement,14 surely there was every reason to tell him the whole15 story: not only are we going to put this statement out,16 but we are also going to give further details out which17 will almost certainly speed up the process by which your18 name comes into the public domain?19 A. No, I do not accept that because for a start we were not20 going to give out further details, it would only be if21 we were asked on certain points. What is more,22 I believe that the issue of the statement certainly

23 accelerated the process of journalists wanting to24 identify the unnamed individual. I do not believe that25 the Q and A did. It was the statement that alerted

1461 journalists to this new situation; and I felt sure they2 would use all their energies to discover who it was.3 I also believe, from some of the evidence that4 the Inquiry has heard, that some journalists had5 a number of -- you know, seemed to think already that it6 was Dr Kelly, without having seen the statement.7 Q. It was part of the Q and A strategy that you would8 actually tell journalists you would confirm his name if

9 the right name was given, was it not?10 A. That was done, as I have already explained, to make sure11 that journalists would actually come and check names12 with us before going to print or before broadcasting13 them.14 Q. That was one part of the strategy. The other part of15 the strategy was to give out further details if the16 right questions were asked. That is right, is it not?17 A. No, you are suggesting this is a strategy. What I am18 saying to you is the production of Q and A material is19 standard practice to back up a statement; that is one20 thing.21 Q. Yes. With respect, Ms Teare, the answer to my question

22 is surely: yes, we would give out further details about23 Dr Kelly's identity to journalists if they asked the24 right questions. For instance: is he in Iraq? You25 would answer: no, though he visited Iraq recently for

1471 a week. That is the position.2 A. The Q and A represents a balance. Its contents3 represent a balance between not identifying Dr Kelly4 personally but being able to answer factual questions5 that journalists could legitimately put to us.6 Q. Ms Teare, the answer to my question is "yes", is it not?7 You would give out more information to journalists if

8 they asked you the right questions. That was part of9 the Q and A material.


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10 A. Yes, we would answer --11 LORD HUTTON: I think Ms Teare may be dwelling on your word12 "strategy", Mr Knox.13 A. Yes.14 MR KNOX: Leave aside "strategy". The effect of the Q and A15 was if journalists asked further questions you would

16 give out further information about his identity.17 A. Yes, and that had been approved.18 Q. That had been approved but it had not been passed by19 Dr Kelly, had it?20 A. No, but if I may, the information that was given in the21 Q and A is information that relates to the statement.22 Q. I understand that. But why not tell Dr Kelly -- it23 comes back to the same point. As a matter of fairness24 to Dr Kelly, so he knows precisely where he stands with25 his employers, that you his employers are proposing to

1481 release further information in certain circumstances

2 about him over and above the press statement you are3 asking him to agree, as a matter of fairness to Dr Kelly4 why not tell him that?5 A. I do not really see what it would have added to the6 situation. Dr Kelly, I think it is highly likely, as7 a civil servant, would be aware of the Q and A8 procedure. I do not know that for a fact but I think it9 is likely. There is nothing in the Q and A with which10 he could disagree.11 Q. No. What I want to know is: why did you not tell him?12 A. I did not feel it was necessary, as I have already13 explained.14 Q. Was there any consideration as to whether or not he

15 should be told?16 A. No, there was no discussion of it.17 Q. Can I just ask you to look up CAB/21/5? If you scroll18 down a little bit, you will see, under the heading: "Is19 it X (ie the correct name)?":20 "If the correct name is put to us from a number of21 callers, we will need to tell the individual we are22 going to confirm his name before doing so."23 Do you see that?24 A. Yes.25 Q. We know in the eventual Q and A you prepare there is no

149

1 equivalent provision for telling Dr Kelly that his name2 is now being put by journalists.3 A. Hmm, hmm.4 Q. Presumably, therefore, there was a conscious decision to5 change from the approach you see in the first of these6 Q and As I have showed you to the eventual approach7 adopted in the final Q and A, is that right?8 A. As I have tried to explain already, it is not -- when9 you say there was a decision to move from one to the10 other, that suggests that the existing one was11 a freestanding, approved document; it was not. The12 drafts of the Q and A represent the information and my13 thinking at that point in time --

14 LORD HUTTON: Ms Teare, I appreciate the point you have been15 making that the question and answer has to be approved


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16 by a policy maker --17 A. And indeed it -- sorry.18 LORD HUTTON: -- but if you would look at the question this19 way: was it the position that your thinking on this20 matter was changing, in that in this draft you had said:21 if the correct name is given we will have to tell the

22 individual we are going to confirm his name before doing23 so; and there is a change from that to the latter draft24 where that does not appear.25 What was your thinking as to that change, contrary

1501 to anything -- just what was in your mind?2 A. Yes, to get from the second to the third?3 LORD HUTTON: Yes.4 A. That reflected the development of my thinking, also that5 I had acquired more knowledge about the situation,6 because I had been told, during the course of the 8th,7 that Dr Kelly had been forewarned that his name was

8 likely to become public.9 LORD HUTTON: Yes.10 A. So, therefore, I felt that there was no need to retain11 the qualification that I had set out in the second12 draft.13 MR KNOX: Ms Teare, it is right, is it not, that Dr Kelly14 had not been told that the MoD would make his name15 public, had he?16 A. The MoD did not make his name public, it confirmed it17 when a journalist had identified it.18 Q. Well, I appreciate your difference, the distinction you19 make, but he had not been told the latter point either,20 had he? He had not been told: if the correct name is

21 put to us, we will I am afraid have to give it out.22 A. No, he had not.23 Q. In those circumstances, why did you not retain some24 provision for giving Dr Kelly express notice as to the25 time at which his name would come out?

1511 A. As I have already explained, that was because I had --2 I then learnt that Dr Kelly had been told that his name3 was likely to enter the public domain; and I think we4 have heard that this morning from Mr Hatfield. And, as5 I have said, we already would put in place arrangements6 to make sure that Dr Kelly had what media handling

7 advice and support he needed.8 Q. We know that after Mr Hatfield spoke of that to Dr Kelly9 to agree the press statement with him, Kate Wilson also,10 on Tuesday evening, spoke to him --11 A. Yes.12 Q. -- on the telephone.13 A. (Nods).14 Q. It is right, is it not, that even she did not tell15 Dr Kelly what you in the press office were doing, namely16 telling journalists that you would give his name if the17 correct name was put? She did not tell him that, did18 she?19 A. As I understand it, it was a very -- she had two

20 conversations, I think, both of them very brief; the21 first one exceptionally brief and the second one fairly


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22 brief too because, you know, he was not at home.23 Q. I cannot understand, why did not even Kate Wilson tell24 Dr Kelly: look, journalists are ringing in at the moment25 and we have told them we are going to give your name if

152

1 they get it; why did not even she tell him?2 A. I think the explanation or rather the description of the3 situation you are describing is not quite right. It was4 not that we were sitting in the press office just5 repeating the fact, you know -- repeating to everyone6 that we are going to confirm the name if asked. I mean,7 that is not what was happening. I think that might have8 been said to maybe one or two people who specifically9 pressed for the name, so, you know, as opposed to the10 picture you are painting, which is one of everyone in11 the press office saying that to every caller. I mean,12 that is just not what was the situation.13 LORD HUTTON: Could you just explain that a little more?

14 Certainly some callers from the press were told: if you15 give us the correct name we will confirm it; is that16 right?17 A. I think I told -- I think I said that to one person and18 that was, as I say, because they were specifically19 pressing on: who is the individual concerned?20 LORD HUTTON: Yes.21 A. But there were -- there were a number of others -- we22 had a lot of media calls. They were not all asking what23 the name was. Some of them were interview requests for24 the Secretary of State. Some of them were different25 things.

1531 LORD HUTTON: Yes.2 A. So it is not the position that everyone who rang up that3 evening was told this.4 LORD HUTTON: But if we just concentrate on those who did5 ring up to try to find out the name of the civil6 servant.7 A. Hmm, hmm. I would have said that was a small proportion8 of the calls received overall.9 LORD HUTTON: As regards those people who rang on that10 particular point, were they all told that: if you give11 me the correct name I will confirm it or were only some12 of them told it, or was it just the occasional one who

13 was particularly pressing?14 A. I could not say overall. All I could say was the15 ones -- the calls I took.16 LORD HUTTON: As regards the calls you took, if the call was17 about the name of the civil servant, you said: if you18 give me the correct name I will give it to you.19 A. No I did not put it in those terms. If I was being20 pressed to reveal the name, I was saying that I was not21 prepared to do that. If I was being pressed -- when22 I was pressed further, I said: look, we are not going to23 give out the name but if you put the correct name to us24 then we would be prepared to confirm it.25 LORD HUTTON: Yes.

154


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1 A. As I say, that was because we wanted to protect the2 identity -- you know, the identity of those who were not3 involved and therefore have a position whereby4 journalists would be willing to check names with us5 before either printing or broadcasting them.6 LORD HUTTON: Yes. Thank you.

7 MR KNOX: In any event, Kate Wilson did not pass this on to8 Dr Kelly.9 A. No, she did not. As I say, I do not really accept why10 you think it should have been passed on.11 Q. It is right, is it not, that on 7th July you had several12 chats with Mr Campbell; is that right?13 A. On 7th July?14 Q. Yes. Monday, 7th July. Would it be right that you had15 several chats with Mr Campbell about this matter?16 A. I do not recall talking to Alastair on 7th July.17 Q. The reason I mention it is we have seen certain diary18 entries which seem to refer in terms to several chats19 with you, amongst other people. Do you not recall any

20 discussions with Mr Campbell on 7th July?21 A. I can recall a very brief discussion with Alastair after22 the 8.30 meeting at No. 10 that morning.23 Q. And that would have been about the Dr Kelly matter; is24 that right?25 A. Yes.

1551 Q. Was not Mr Campbell very keen indeed to get Dr Kelly's2 name out into the public domain?3 A. That was not the nature of the brief discussion we had.4 Q. But it was about the question of Dr Kelly, was it not?5 A. Yes.

6 Q. Can you remember what the discussion was, then?7 A. It was more about the issue in general terms and the8 fact that it was quite -- it was difficult to judge9 whether or not the individual who had come forward in10 MoD voluntarily was Andrew Gilligan's source. That was11 what the -- you know, that was the main pitch of it.12 Q. Ms Teare, with hindsight, thinking back on what13 happened, the inevitable effect of the Q and A approach14 was this surely: first, it was likely to increase the15 interest of journalists because you have this almost16 game of 20 questions; is that not right?17 A. I do not accept that. I mean, I do not understand what18 you mean by why the Q and A would encourage that. As

19 I said, the Q and A is produced in support of any20 statement; and in terms of the guessing game, the21 guessing game was of the journalists' own making, it was22 not ours.23 Q. Do you think it did have the effect of increasing the24 journalists' interests, the way that information was25 gradually being given to them?

1561 A. No, I do not. I think what stimulated the journalists'2 interest was the release of the statement; and it was on3 that same day that Dr Kelly was contacted by the press4 office, warned of the high level of media interest and,

5 as I say, offered media handling advice there and then.6 Q. Did not the approach also mean this: that Dr Kelly's


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7 name would come out at a wholly unpredictable time?8 A. Short of actually including Dr Kelly's name in the9 original statement, I do not see how we could have10 controlled when his name would have emerged.11 Q. It would follow, would it not, also, that Dr Kelly12 himself would not have any proper notice of the fact or

13 time at which his name was going to be revealed? That14 must be right.15 A. Dr Kelly was told on the evening of the 8th July that16 a statement had been issued, there were very high levels17 of media interest and that he might want to think about18 staying with friends. That to my mind was the key19 point, because once we had issued the statement then20 journalists from that point were going to try hard to21 identify the individual. He was made aware of that high22 level of interest.23 Q. Yes. Would it not have been better to adopt a rather24 more upfront approach with Dr Kelly, in hindsight, and25 simply agree a particular time at which his name could

1571 be given to the press, so he would know exactly what was2 going on?3 A. I think we certainly are talking hindsight there. The4 position that we were in was one where, as we have5 heard, although the idea of including Dr Kelly's name6 with the original statement that Kevin Tebbit had asked7 should be pursued, it was not in fact pursued. The8 position that we would have put Dr Kelly in is that we9 would have been finishing, finalising the statement and10 then sort of springing on him the notion of including11 his name in it. So I think that would not have been

12 fair either.13 Q. You did not want to spring anything on Dr Kelly, is that14 right?15 A. I did not want to say to Dr Kelly, with a few moments --16 no more than a few moments to consider it: we are going17 to put your name in the statement.18 LORD HUTTON: Just on that point, Ms Teare, and I appreciate19 you say we are discussing the matter with hindsight,20 looking at what happened and bearing in mind the point21 you made that Mrs Wilson in fact rang him on the evening22 of the 8th July and said to consider alternative23 accommodation. But looking back, with hindsight, might24 it not have been better to have said to Dr Kelly that

25 the MoD were proposing to name him in the statement but

1581 it would not be released for 24 hours and it would be2 released at a particular time? Suppose you would have3 said to him on the Monday afternoon: it will be released4 at 6 pm on the Tuesday afternoon. Then he would have5 known precisely when his name was going to come into the6 public arena, and if he had wanted to leave home he7 would have had the time to do it.8 A. Again, with hindsight, that could have been9 a possibility; but I do not think -- again, to get to10 that position you would have to unpick so many of the

11 things that happened.12 LORD HUTTON: Yes.


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13 A. As I say, because the issue of including Dr Kelly's name14 in the original statement was never addressed with him.15 LORD HUTTON: I quite appreciate that and you are making the16 point a lot of things would have to be unpicked. But17 even on that basis, it would have been open, let us say18 over the weekend, or on Monday 7th July, to have had

19 a meeting with Dr Kelly and to have said to him: this is20 a matter of great public importance, the Ministry of21 Defence feels, because of the interests of the FAC and22 the general public interest, that we will have to put23 out a statement that you have come forward, and we24 consider that it would be better for you, as well as for25 the MoD, that we name you in the statement, and we are

1591 proposing to issue a statement in 24 hours' time.2 The point I am putting to you is, with hindsight,3 that that would have made it clear to him precisely when4 his name would become public and there would not have

5 been the matter of him having to leave his home with6 Mrs Kelly in a rush, within about 10 minutes.7 A. As I say, that would have been a possibility; but one of8 the reasons I feel that we did not get to that point was9 because there remained uncertainty as to whether10 Dr Kelly was Andrew Gilligan's source or not.11 LORD HUTTON: Yes, I see. That has been mentioned by other12 witnesses. I appreciate that.13 A. I think it was that uncertainty that sort of meant that14 a decision was not taken until sort of, you know, the15 Tuesday afternoon, really, to make a statement.16 LORD HUTTON: Yes, I see. Yes.17 MR KNOX: There are just two more points, Ms Teare. The

18 first is this: you say the name would come out anyway.19 Surely it is not that simple for the press to print20 Dr Kelly's name, as there is no doubt they eventually21 did print it, as the mole or anything like that, because22 they would be worried about defamation questions, would23 they not?24 A. I do not understand what you mean by "the mole".25 Q. Well, if Dr Kelly was named as the person who had spoken

1601 to Mr Gilligan there would inevitably be questions as to2 whether that was a defamatory statement.3 A. Well, I am not an expert in media law, I could not

4 answer that question.5 Q. You see, we have heard a lot about it being inevitable6 that Dr Kelly's name would have come out. But that is7 not necessarily the case at all, because unless the MoD8 confirmed that Dr Kelly is indeed the man there is some9 risk for the press in printing his name.10 A. I think it highly unlikely that the press would not have11 printed either his name or, if they had wrongly12 identified others, those names.13 Q. I think you have also mentioned, in connection with this14 inevitability of the name coming out, that there was15 enormous press interest in the matter, is that right?16 Certainly Mr Baldwin in his evidence said that by

17 9th July the story had become a bit "anorakish", to use18 his word, and that interest was waning, and you said in


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19 your initial evidence last time round that after20 9th July there was rather little interest in the story.21 A. Yes.22 Q. That rather suggests that perhaps the story was not23 quite as of much interest to the press as you are now24 saying.

25 A. I mean, I found Mr Baldwin's remarks interesting, given

1611 that he had written articles on both the 5th and2 8th July on this subject, so that is two articles in the3 space of a very short period. So I did not think that4 actually represented waning interest.5 Q. Finally, I want to ask you one question about Mr Blitz.6 After you -- I think it may not have been you, but one7 of your assistants had confirmed the name of Dr Kelly to8 Mr Blitz?9 A. No, the name was not confirmed to Mr Blitz.10 Q. Mr Adams?

11 A. The name was first put to me by Mr Adams of the FT, and12 I confirmed it.13 Q. But Mr Blitz, we understand, then asked you to ask for14 an interview with Dr Kelly; is that right?15 A. Yes.16 Q. You refused?17 A. Yes.18 Q. We know some time later Blitz got a call from Whitehall19 officials giving him further details about Dr Kelly.20 A. Hmm, hmm.21 Q. Are you able to explain how that came out?22 A. No, I have absolutely no knowledge of it, I do not know23 who it was.

24 MR KNOX: Thank you very much.25 LORD HUTTON: Any re-examination?

1621 MR LLOYD-JONES: I have no re-examination, my Lord.2 It may assist if I mention that document MoD/17/2,3 which is a draft of the press statement produced on4 7th July, to which Ms Teare referred in her evidence,5 was supplied to the Inquiry by the Ministry of Defence6 on 19th August. The covering letter from the Treasury7 Solicitor is MoD/17/1.8 LORD HUTTON: Thank you very much indeed.9 Thank you very much indeed, Ms Teare.

10 We will rise now, Mr Dingemans, for 5 minutes.11 (3.23 pm)12 (Short Break)13 (3.28 pm)14 MR EDWARD WILDING (called)15 Examined by MR DINGEMANS16 Q. Can you tell his Lordship your full name?17 A. I am William Edward Wilding.18 Q. Qualifications?19 A. Educational or?20 Q. Professional.21 A. I have been a computer investigator for the last22 10 years and I have been in the computer industry, IT

23 industry, for 14 years.24 Q. Any publications?


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25 A. I published a book called Computer Evidence, a computer

1631 investigations handbook published by Sweet & Maxwell in2 1997.3 Q. Has anyone instructed you in relation to this matter?

4 A. Yes, I have been instructed by Farah & Co.5 Q. They are solicitors for Mr Gilligan?6 A. Correct.7 Q. What did they ask you to do?8 A. They instructed me to examine the contents of a Sharp9 personal organiser that was the property of Mr Gilligan10 and to find out the circumstances by which two memoranda11 came to be entered on to that machine.12 Q. Are there many types of computer like that?13 A. To my knowledge, at the moment there are over14 400 different types of organiser in the world, from more15 than 70 manufacturers.16 Q. Are you an expert in all 400?

17 A. By no means.18 Q. How have you analysed this organiser?19 A. I decided to take a common sense approach and try and20 produce real computer evidence on the advice -- in21 a manner that would follow the ACPO guidelines, which is22 the Association of Chief Police Officers.23 Q. So what did you do?24 A. The rules are that you should not destroy the data on25 the organiser or change it in any way. So what we do is

1641 we export the data from the organiser to a computer and2 we look at the exported data to see whether we can work

3 out the circumstances.4 Q. Before you had seen the organiser, had it been5 preserved, as it were, evidentially?6 A. No, it was clear to me that we were looking into7 memoranda that were dated ostensibly the 22nd May 20038 and the machine has been in a lot of use since then and9 has been subjected to -- has been in operational use10 since then for a long period.11 Q. So how did you extract the data from the machine?12 A. We used a piece of software for extracting -- produced13 for Sharp organisers specifically; and this software14 extracted the data in a large block from the machine to15 the computer, in a way that was non-invasive and would

16 not damage the data on the original machine.17 Q. Before you extracted the data, did you do any other18 checks on the machine?19 A. We switched the machine on because we wanted to20 establish what the time and date on the clock was at the21 time of our analysis.22 Q. Was it accurate?23 A. On the machine, on the organiser that we examined, it24 was 1 hour and 16 minutes slow, I believe.25 Q. Is that usual?

1651 A. In my experience it is very, very common for computer

2 clocks to be either fast or slow or generally3 inaccurate.


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4 Q. Where did you upload the data to?5 A. We uploaded it to a computer, a standard PC which was6 supplied by Farah & Co.7 Q. How long did that take?8 A. May I refer to my notes?9 Q. Yes. I do not need an exact time.

10 A. It was approximately 20 minutes, I think.11 Q. Was all the data extracted from the organiser?12 A. The data that would be input by a user was. I have been13 consulting Professor Sammes on this point though and14 I have read his report and he tells me, informs me, that15 some data was not extracted but that data has not16 affected this investigation.17 Q. Who is Professor Sammes?18 A. Professor Sammes is arguably, probably, one of the most19 pre-eminent experts on organisers in the world.20 Q. And he has been instructed by the Inquiry.21 A. He has indeed, yes.22 Q. But he is based at Shrivenham, is that right?

23 A. That is correct, yes.24 Q. Or has offices there which is near to a Ministry of25 Defence building, is that right?

1661 A. That is correct, yes.2 Q. Is it for that reason that Farah & Co instructed you3 rather than Professor Sammes?4 A. I think that is an issue for Farah, but my understanding5 is they have been very concerned about the6 confidentiality of information on the organiser.7 Q. So were you the person that looked at the uploaded data?8 A. I was not.

9 Q. Who did that?10 A. That was Mr Julian Pike on the evening of the 27th.11 Mr Pike is a solicitor with Farah & Co.12 Q. And did you tell him what to do?13 A. We instructed him in the use of our proposed analytical14 method and Mr Pike then proceeded to extract memoranda15 from the upload that we had taken and printed those out.16 Q. How did he extract those memoranda?17 A. I advised him to use key words that appeared in the18 questions memoranda and to search for these in the19 uploaded file, and when he found those key words20 I advised him to extract the memoranda in an21 intelligible format that could be read fairly easily.

22 Q. Did he extract any memoranda, having gone through this23 process?24 A. He did, yes, quite a large number.25 Q. How many?

1671 A. If I may refer to my report?2 Q. May we have ANG/5/4?3 A. Yes, on the evening of 27th August there were4 29 extracted memoranda.5 Q. Is this the first one, JP1? Go to the next page, JP2?6 A. Yes.7 Q. I rather infer that that is Julian Pike 1, 2, 3?

8 A. Yes, indeed.9 Q. If we carry on scrolling through the pages you can see


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10 that. So 29 memoranda. Did he show those to you?11 A. I watched them being printed. He would then consult12 Mr Gilligan. They would decide then whether there was13 a redaction exercise needed to remove sensitive14 information. Then they did show them to me. If15 I recall, on those 29 memoranda they decided not one

16 redaction needed to be made.17 Q. How do you get 29 memoranda when we have only had two18 printouts, as it were?19 A. Yes, it is to do with live and residual data or deleted20 data. Two of these memoranda are live on the system and21 you can access those through the interface of the device22 and see them readily --23 Q. So you would not have needed any special software to24 read those?25 A. No, you could have read those on the organiser.

1681 Q. And the others?

2 A. These are in areas of memory which are not usually3 obtainable to the user of the organiser. These are in4 deleted clusters or deleted areas of memory.5 Q. But left on the hard drive, as it were, of the6 organiser?7 A. Left on the flash memory of the organiser, which is8 similar in concept to a hard drive.9 Q. As sort of electronic fingerprints?10 A. As electronic fingerprints, yes.11 Q. Are they dated?12 A. They are.13 Q. And how are they dated?14 A. They are dated in a very interesting way by the

15 computer's -- by the organiser's clock.16 Q. If we are looking at JP1 or whatever JP we have on the17 screen, JP3. Can I take you to the top left-hand18 corner?19 A. Yes, you can see there "memo" at the top. Then you can20 see "2003". Then you can see --21 Q. That is the year, is it?22 A. 06 is June and 26 is the day. So it is 26th June 2003.23 Q. Why is it dated 26th June?24 A. Because that is a memo, I believe, that was produced25 subsequent to the 22nd May, which is a date that we were

169

1 interested in examining and investigating.2 Q. Were there any memoranda dated before 22nd May?3 A. We found, on that --4 Q. With this text on it?5 A. On that evening, we found -- well, Mr Pike produced one6 memorandum produced on 21st May. Subsequent to that and7 subsequent from our examinations more recently we found8 another memo dated 21st May.9 Q. So what is an explanation for that, that the meeting we10 heard took place on the 22nd?11 A. Correct. I -- initially, and ostensibly that could look12 quite suspicious but when I examined the computer,13 personal organiser, currently used by Mr Gilligan and

14 when I looked at other memos produced by him, I saw15 a consistent slippage of a day in terms of a day


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16 backwards, his memos being out of kilter by a day.17 Q. When you examined the organiser it was out by 1 hour18 16 minutes; that is right, is it not?19 A. That is correct.20 Q. But this meeting we know took place at either 4 or21 5 o'clock in the afternoon.

22 A. Correct.23 Q. So if it was still out by an hour and 15 minutes it24 would have got the right day, is that right?25 A. No, I believe the clock has been adjusted at least once,

1701 from a statement of Mr Gilligan's. It may have been2 adjusted many more times than that since the meeting of3 the 22nd.4 Q. How do you adjust your clock? Is it like any other5 computer, you can alter the date and time?6 A. You can alter the date and time at will. There is7 evidence in a statement of Mr Gilligan that the clock

8 was adjusted subsequently to that meeting; and there is9 clear evidence, to my mind, from looking at10 Mr Gilligan's current personal organiser, that the clock11 was out of kilter, may have been out of kilter on the12 day of 22nd May.13 Q. Being out of kilter would be affected by changing14 batteries and the like?15 A. It might be changed by battery changes. When you change16 the batteries on this device you do not have to but you17 are given the opportunity to reset the clock. As I say,18 Mr Gilligan says he did set the clock. I also19 discovered some experimentation on the Sharp where they20 were -- somebody was looking at creating memos and

21 seeing if dates and times could be changed.22 Q. Someone had been experimenting on the memo?23 A. Not on the memo. They had been creating a memo, and24 I have put that in my report, a reference in my report.25 Q. Yes. If you have a Sharp organiser, you have a lot of

1711 material there, it is a bit of a risk, you might lose2 it?3 A. Yes.4 Q. Do you save it anywhere?5 A. Yes, the normal procedure for anybody with one of these6 devices is to back the system up, usually to a computer,

7 so you have all your data safe and secure should your8 machine become damaged or become unusable.9 Q. When you examined the memoranda you had expected did you10 identify any anomalies?11 A. I identified five seeming anomalies, yes.12 Q. They may all be capable of explanation?13 A. Five anomalies.14 Q. Can you explain what they were and what explanation15 there might be?16 A. Five anomalies identified, yes.17 Q. The first one was what?18 A. If I may refer to my report?19 LORD HUTTON: What paragraph are we at, Mr Dingemans?

20 MR DINGEMANS: 27, my Lord.21 A. This is my report, 27(a). The first seeming anomaly,


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22 I use that word advisedly, in the sequence those memos23 were produced from the organiser we do not see an24 obvious chronology. The memos on the 21st and 22nd May25 are inserted between memos dated 26th June 2003 and then

172

1 30th June 2003.2 Q. Is there an explanation for that?3 A. Yes. After some very careful experimentation on a Sharp4 we had bought specifically for the purpose of5 examination, we managed to reproduce this effect.6 I also got confirmation from Sharp in Japan that this7 was a perfectly natural effect and that memoranda and8 other data may be allocated randomly in the computer's9 memory.10 LORD HUTTON: Does that mean if you enter a memorandum on,11 let us say, 1st September of 2003 if months later you12 search back through that organiser in the way that you13 have done you may find that actual memorandum but with

14 a quite different date on it?15 A. No, not with a different date stamp, my Lord. What you16 would find is that you might find memos created after17 that memo not in a logical sequence as stored in memory.18 So you might find a memo from 1st June 2003 stored after19 a memo dated October 2003.20 LORD HUTTON: Yes, I see.21 A. So there is no logical sequencing in the memory.22 MR DINGEMANS: Second two anomalies?23 A. Yes, there was a version of a memorandum called24 kelly.txt.25 Q. Yes.

1731 A. This is dated 21st May 2003. There is also a version of2 a memorandum called kelly[underscore]cont.txt which is3 also dated 21st --4 Q. If we look at BBC/1/54. What Mr Gilligan told us when5 he produced this memoranda is he had run out of space on6 the first one, this is the first one, and then if we go7 to the next page you have Kelly continued.8 A. Yes.9 Q. He says they were both made at the same meeting.10 A. Yes.11 Q. But the one you saw, going back to the date in the text,12 had 21st in the time clock?

13 A. Correct.14 Q. Does it give a time or just the date?15 A. Unfortunately we do not get the time, just the date.16 Q. What is the explanation for that anomaly?17 A. Well, from my experimentation and from looking at18 Mr Gilligan's current organiser, which will reflect the19 same date as the back up from his old organiser, and20 from looking at other files on his machine I have seen21 a consistent slippage of about a day, which tends to22 explain this phenomenon.23 Q. The fourth anomaly, what is that?24 A. This is where we have many versions of kelly.txt and25 kelly[underscore]cont.txt on Mr Gilligan's organiser.

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1 This may be explained by the fact that I believe, as I2 say, this machine has been in continual operation or use3 since 22nd May 2003 and these may have been created4 either by Mr Gilligan perhaps accidentally saving these5 memos as he looked at them --6 LORD HUTTON: Accidentally doing what?

7 A. Accidentally saving them when he came out of these8 memos, as he looked at them.9 MR DINGEMANS: If you look at it, do nothing to it but save10 it again, you get another fingerprint?11 A. Yes, that may be one explanation; and I believe also12 that he may have been cutting and -- there is13 some possibility that he may have cut and pasted memos14 for his own records subsequent to the Inquiry and other15 things.16 Q. Right. Fifth anomaly?17 A. Yes. This has worried me quite a lot. The version of18 kelly.txt dated 21st May 2003 is different to the19 version produced by Mr Gilligan to the Inquiry.

20 Q. If we compare JP1 and JP15, and I think people have21 available that in hard copy, is JP1 the one dated22 21st May? -- sorry, JP11. JP11 and JP15.23 A. JP11 is from the 21st, that is right; and the one that24 was submitted to the Inquiry, if I could see it again on25 screen --

1751 Q. BBC/1/54, from recollection.2 A. Could we have that on screen? Yes. Well, we can3 clearly see that there are differences here. The4 difference that struck me as interesting particularly is5 there is no mention of "Campbell" in this memo.

6 Q. In JP11?7 A. In JP11, which also produces a hexadecimal -- sorry, I8 am leaping ahead of myself. Yes, JP11.9 Q. When is the first time you see the word "Campbell"10 mentioned?11 A. I do not see the word "Campbell" mentioned in this memo.12 Q. No. If I take you to JP15.13 A. Yes.14 Q. Is that the first memo that mentions the word15 "Campbell"?16 A. I believe JP12 does, which is -- sorry, memo, yes. You17 are quite right. The first memo was JP14 that mentions18 Campbell.

19 Q. Right. I think we are looking at JP11 and JP15. They20 are in those respects effectively the same, are they?21 A. Yes.22 Q. What were your conclusions from this?23 A. There are two -- well, there are a number of24 possibilities, to my mind. One is that the clock was25 back and during the meeting, if these notes were

1761 contemporaneous, the clock went forward through midnight2 and changed date, which I believe to be a possibility.3 Another possibility is that JP -- sorry, JP --4 LORD HUTTON: Sorry, I am afraid I am not best in these

5 technicalities, you will have to help me. If the clock6 went forward during the meeting, how does that explain


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7 the omission of the word "Campbell"?8 A. Well, that concerns me. The reason -- if the clock went9 forward it would explain that there are two related10 memos; but I do not really understand why the word11 "Campbell" is not there.12 MR DINGEMANS: That is something Mr Gilligan may be able to

13 assist with.14 A. I think he should, yes.15 Q. I will ask him those questions. So there are no16 technical explanations for that. But if we look at JP1117 and JP15. On JP11, top left-hand corner, we have the18 21st May 2003, 05 for May and 21, is that right?19 A. Yes.20 Q. And yet the first memo with Mr Campbell's name in it at21 JP15, if I am looking at that, that has 20030522, is22 that right?23 A. Correct.24 Q. Which means that we can tell this -- tell me if I am25 getting this wrong, the memo, JP11, predates the memo

1771 JP15?2 A. Correct.3 Q. And, secondly, if they were both made at the meeting4 then the clock must have been some -- assuming the5 meeting was 4 o'clock for these purposes, lasts an hour,6 then the clock must have been some 16 hours out?7 A. At least 16 and at maximum 40 hours is my calculation.8 Q. Right. You said computer clocks are frequently9 inaccurate.10 A. Yes.11 Q. Between 16 and 40 hours sounds quite a lot of

12 inaccuracy.13 A. Not in my experience.14 Q. Well, that is what I am asking about --15 A. Yes.16 Q. -- so that you can deal with that.17 A. Very often people do not work by their clock on these18 sort of devices.19 Q. You have referred to some experimentation on the date20 and time. Do you know or have you been told who carried21 that out?22 A. My understanding is that it was some technical people23 from the BBC.24 Q. Right. There is only one set of experimentation, is

25 that right?

1781 A. It appears so, yes.2 Q. After you produced your report, when did you produce3 your report?4 A. My report was dated, I believe, 12th September.5 Q. When were you instructed by Farahs on behalf of6 Mr Gilligan?7 A. I was instructed on 27th August, in terms of: yes, we8 want to do this particular exercise.9 Q. After you produced your report did Professor Sammes see10 it?

11 A. Yes, he did and I was very keen that he should.12 Q. Did he make any comments on it?


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13 A. Yes, he did.14 Q. We are going to hear from Professor Sammes. Can you15 explain to a lay person like myself what the gist of the16 comments were?17 A. He made it clear to me that I had not followed best18 practice, which I did not find surprising given his

19 eminence in this area and given the rather esoteric20 nature of the exercise we had to do.21 Q. Did he give you any pointers as to how you might remedy22 that?23 A. Yes he did.24 Q. When did that take place?25 A. We had a very constructive meeting yesterday of about

1791 two and a half hours.2 Q. Which is why you did not come and give evidence3 yesterday.4 A. Yes. We needed to resolve these issues.

5 Q. And as a result of that what did you do?6 A. We came to an agreement whereby the admissibility of my7 evidence was called into question by Professor Sammes8 and yesterday we worked out a method whereby the9 admissibility of that evidence --10 Q. On these two memorandum?11 A. On these memorandum, could be retained, which was fixed12 yesterday I believe, but Professor Sammes will probably13 have more detail about that. So at least we can trust14 the memoranda are true representations of what --15 Q. What did Professor Sammes need you to do?16 A. He needed us to produce the memoranda that we found in17 what is called a hexadecimal format, which is --

18 Q. Do not bother. In a format. And he asked you to send19 that to him?20 A. Yes, indeed: yes.21 Q. Did you send to him the documents that we see in hard22 form here?23 A. We do. There is a continuity issue because24 Professor Sammes, last night, received all of the --25 I am going to use the word again -- hexadecimal format.

1801 Last night he received all of that by e-mail. Just on2 a continuity issue, I can cover for that and say that3 all the material that is represented here in hexadecimal

4 format is the same material that went to him last night,5 although it is referred to as different exhibit numbers6 here.7 Q. Why was he concerned before?8 A. He was very concerned because he had advised me that on9 this type of organiser there is a form of data10 compression that might materially affect the reliability11 of the evidence, in terms of: I had said that the word12 "Campbell", for instance, was not in one of these memos13 and Professor Sammes pointed out that because we had not14 decompressed the upload file, which is -- that we might15 have missed evidence or that evidence in these memos16 might not be in a contiguous form. So he wanted to

17 assure himself that these memoranda were true18 representations of what was stored on the organiser.


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19 Q. Did you find out whether or not Mr Gilligan had saved20 this material to any other document at the time or any21 other computer at the time?22 A. Yes, on 27th August when I was instructed I asked23 Mr Gilligan about the back up system that he used. And24 he regularly used to back up the organiser, the data

25 from the organiser to a laptop computer. And it was my

1811 concern on the 27th that it would be useful to look at2 that data as well.3 Q. Have you been given access to that by Mr Gilligan?4 A. On the evening of the 27th, on grounds of the5 confidentiality of the data, it was decided that I would6 be only given access to the organiser itself.7 Q. So you were not even able to do what you did with the8 organiser on that computer material?9 A. No.10 Q. A final document, if I may, JP37. I am not sure I can

11 call it up. What does this relate to, in relation to12 experimentation?13 A. Yes. We cannot call this up but --14 Q. I am sorry, I told a lie. ANG/5/40. That should call15 it up. Is that JP37, if we scroll down to the bottom of16 the page?17 A. Yes, it is.18 Q. Going up again, what is this about?19 A. I believe that -- well, it is clearly somebody trying to20 test whether memos -- why clock dates would slip on21 memos, or the circumstances under which memos might show22 a wrong date and time. Well, date in this particular23 instance.

24 Q. Right. Thank you.25 Subject to that, is there anything else that you

1821 wanted to say in relation to your report?2 A. I believe that in the light of Professor Sammes' report3 that there may be further work that might be advisable4 and I think perhaps that the Inquiry should take that5 into consideration.6 MR DINGEMANS: Right. Okay. Thank you very much indeed.7 LORD HUTTON: Thank you.8 MR DINGEMANS: Professor Sammes, please.9 PROFESSOR A J SAMMES (called)

10 Examined by MR DINGEMANS11 Q. Professor, I am sorry, I am going to have to take you12 reasonably shortly.13 A. Indeed.14 Q. But it is important you tell me anything that I am15 missing out.16 First of all, what is your full name?17 A. Anthony John Sammes.18 Q. And your qualifications?19 A. I have a Bachelor of Science, a Master of Philosophy and20 a Doctor of Philosophy in Computer Science.21 Q. Have you written any books in relation to computers?22 A. Yes, I co-authored a book called "Forensic Computing:

23 A Practitioners Guide".24 Q. Where are you based at the moment?


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25 A. I am currently based -- I am actually a Professor of

1831 Computing Science and Director of the Centre for2 Forensic Computing of Cranfield University, but I am3 based at the Royal Military College of Science at

4 Shrivenham, and Cranfield University provides higher5 education facilities to that college.6 Q. And the Royal Military College of Science is a Ministry7 of Defence establishment?8 A. It is indeed.9 Q. You have been instructed on behalf of the Inquiry; is10 that right?11 A. That is correct, sir.12 Q. To consider the report that was produced by Mr Wi

Documents

Hearing Transcript - 18 September 2003 Afternoon