Wednesday, 10 April 2019

Bates v Post Office: Recusal judgment


People will be talking about this case in decades to come, and not just in legal circles. Already we've had revelation after revelation about the Post Office's behaviour towards its Subpostmasters, MPs and the concept of justice ("the Post Office seemed to want findings on that only if they were in the Post Office’s favour." Fraser, J. - 3rd judgment)

On Tuesday 9 April at 2pm in court 26 of the Rolls Building we got the judge's perspective on the Post Office's attempt to have him recuse (sack) himself on grounds of apparent bias. He has declined to do so.

The application was received in the middle of the second trial of the group litigation. It was made in the light of the judgment of the first trial, which the Post Office lost hands down. You can read my bluffer's guide to that judgment here.

The judgment of the first trial is known as Judgment No. 3 because there were two preliminary judgments on process (which the Post Office also lost) before the first trial started.

The recusal judgment is therefore Judgment No. 4 - the fourth the Post Office has lost.

In a 44,500 word, detail-rich document J Fraser deals with every angle of the recusal application and its context. You can read it here. What follows in this blog post is a summary of interest to the casual reader and a write-up of the discussion which took place in court immediately after the judgment was handed down, in which we discovered both parties had blown half a million quid preparing and responding to the recusal application: "jam and cream on top" noted Lord Grabiner in court. The transcript of that hearing can be found here.

Let's deal with the judgment first.

Key quotes

"The fair-minded and informed observer would consider all the relevant facts. I consider that the Post Office in this recusal application overlooks a significant number of material facts, and instead, concentrates upon isolated passages and takes them out of context."

"In many places in Judgment No.3... I made it clear expressly that I was not making any findings as to breach, causation or loss, nor was I making any findings on the Horizon Issues... I consider those points – or rather, the same point, made multiple times – are entirely clear and unambiguous. Lord Grabiner was rather dismissive of this. He referred to this as a "mantra"..."

[see my write-up of the recusal application hearing in which the "mantra" concept is fleshed out]

"I do not accept that submission. It suggests some remarkably convoluted thinking on the part of the court, including an awareness in advance that an application to recuse for apparent bias might be made, and a conscious attempt to head that off, but doing so in terms which "would not convince the observer" that I had not prejudged the issues, in respect of which I was expressly stating that I was not making findings. It also suggests convoluted thinking on the part of the fair-minded observer."

"I intend to continue with the Horizon Issues trial, and I intend to continue as the Managing Judge. I am confident that I can resolve all the existing and future issues in this litigation in a wholly impartial and judicial manner."

Juicy detail

The recusal application judgment is long, as the judge himself notes. Its length is partly due to the Post Office relying on 109 separate paragraphs in the 180,000 word common issues trial judgment as evidence of apparent bias. The judge deals with each one in turn, and finds that none of them show any indication of apparent bias. To give you just one example, the Post Office alleges apparent bias in the judge's description of the first day of on-site Horizon training for Subpostmasters as "worthless".

The judge responds:

"The word "worthless" for "day one" training is expressly used in the actual internal Post Office document put to Mr Webb... I... do not understand how reproducing the same word used in the Post Office's own internal document can be relied upon by the Post Office in this recusal application. This is an example of the pitfall of considering a single passage of Judgment No.3, deciding it is critical of the Post Office, and using it to justify a recusal application, without taking into account either its context, or the evidence that unfolded in the Common Issues trial. The fair-minded and informed observer would be assumed to be precisely that – informed."

Give us a waiver

Having responded to every point made by the Post Office, the judge then turns his attention to the timing of the recusal application, which as avid followers of this case will know, arrived on a day of high drama (see my write-up: "Going Postal") in the middle of the second trial in this Bates v Post Office litigation.

I was in court to witness what happened that day and there were people who had spent many years of their careers working in the legal system who were literally shaking their heads in disbelief when the day's proceedings had finished. As J Fraser himself says in his judgment: "Recusal applications, particularly made in the middle of lengthy trials, are not entirely routine. They ought not to be kept up one's sleeve."

What I did not know was that the judge has a perfect right to take the timing of a recusal application into account.

To give you a brief chronology:

8 March - both parties receive common issues trial judgment in draft
11 March - Horizon trial starts
15 March - common issues judgment formally handed down
21 March - recusal application received in court

The surprise element of the recusal application and its delay in being presented to the court is lambasted by the judge:

"the Post Office waited until almost two weeks after it had received Judgment No.3 before it did anything in respect of making an application to recuse.... Here, there was not only silence by the Post Office, and continuing participation in proceedings, but there was active involvement in the actual Horizon Issues trial."

"Rather than acting quickly and promptly, the Post Office delayed, and... acted somewhat curiously. When I asked Mr de Garr Robinson QC about the application at 2.00pm on the day it was issued, he did not know very much about it."

On the written application: "this delay is not explained, in even the most cursory or terse terms... It is entirely ignored. I do not consider recusal applications to be entirely run of the mill events. This is even more so when one considers this recusal application is of a Managing Judge in Group Litigation. It is also even more so when it is made in the very middle of a lengthy trial. An explanation is called for."

The judge says what should have happened is that on the morning the Horizon trial was due to start, a request for an adjournment should have been made.

"The Post Office conducted itself for the whole of the factual evidence that was called during the first two weeks of the Horizon Issues trial (16 different witnesses in total) without any hint of making any application that I recuse myself.... Almost the entirety of the evidence of fact of both parties has already been fully cross-examined in the Horizon Issues trial."

The judge adds:

"It might be thought that the Post Office had taken their chance on how the evidence of fact in the Horizon Issues trial unfolded by waiting until the last day of that evidence before issuing the recusal application."

By acting in such an extraordinary way, the judge decides the Post Office has waived its right to a recusal, and expresses as much in strong terms:

"I have found that there is no apparent bias... However... I consider the delay, and the continued conducting of the Horizon Issues trial, including both the cross-examination of all of the claimants' witnesses of fact, and the calling of almost all of the Post Office's own witnesses of fact, to constitute an unequivocal waiver of any right the Post Office might have had to ask me to abandon the Horizon Issues trial and recuse myself from further involvement as the Managing Judge." [my italics]

There's more

A very interesting side note appears in paragraphs 120 - 122 of the recusal judgment.

The issue of disclosure has been a running sore throughout Bates v Post Office. The judge has commented on the unwillingness of the Post Office to disclose documents, its habit of redacting them and the general tenor of the litigation (from both parties), which has been aggressive, attritional and expensive. The credibility of at least one Post Office witness is in tatters (Angela van den Bogerd, a Post Office director, who was found by the judge to have tried to mislead him on oath), and the Post Office has managed to spend tens of millions of pounds of public money on a litigation it appears to be losing very badly. But the events described below are in a different ballpark altogether.

As part of its preparation for the Horizon trial, the claimants wanted sight of a 2011 Royal Mail/Post Office audit report written by Ernst and Young, which contained statements relating to Horizon and its fitness for purpose.

The Post Office split from Royal Mail in 2012 and the claimants were told that not only did the Post Office no longer have any copies of the 2011 audit report, but Royal Mail, who retained the copies, would not release them to the claimants without a court order.

The precise words of Mr de Garr Robinson (lead counsel for the Post Office in the Horizon trial) were: "last year my instructing solicitors, I think actually Post Office contacted Royal Mail and said "Could we have these documents, they are being requested in these proceedings" and Royal Mail said "We're not going to give them voluntarily, if you want them you will need a court order"."

Hence the reason the matter was being put to the judge by the claimants, in the hope he would order Royal Mail to release the report.

Turns out the whole thing was a load of cobblers. As the judge revealed:

"The Royal Mail had not been asked for these important documents; nor had the Royal Mail been reluctant to produce them without an order from the court.... I had already made an order on 14 March 2019 for a hearing of a third-party disclosure application against the Royal Mail (based on what was said to be the "reluctance" of Royal Mail to produce these documents). This hearing turned out not to be necessary, because once asked for them, the Royal Mail was content to produce them. The reason that they had not been produced prior to that was very simple – the Post Office's solicitors had not asked the Royal Mail for them, even though they had told Freeths, and had also told the court (through their Leading Counsel) that they had."

This might not have been deliberate. It could, of course, just be incompetence. The Post Office QC called it "confusion".

Post-judgment hearing

It's a shame silence doesn't transcribe.

There is a moment, after a discussion about costs, in which Lord Grabiner makes the case for appealing J Fraser's judgment.

LORD GRABINER: "In my respectful submission, this is a suitable case for permission to be granted to the Court of Appeal. I have to demonstrate that there is a real prospect of success. In my respectful submission, there is one. And your Lordship is fully familiar with the story, and I do ask for that permission."
MR JUSTICE FRASER:  "Is there anything you would like to add other than real prospects of success? Permission to appeal is refused."

The length of that pause, if there was one, between Mr Justice Fraser's question and his decision not to allow the appeal would have been great to witness. It doesn't quite come across in the same way in print.

Other notes from the hearing:

 - the parties' costs for the whole recusal process total £520,000, most of which will be borne by the taxpayer-owned Post Office.

- the Post Office has until tomorrow (Thursday 11 April) to ask the Court of Appeal for permission to appeal the recusal judgment

- the Horizon trial will briefly re-start tomorrow to hear the final tranche of evidence from the Post Office witnesses before going on a long break. It will resume some time in late May or even June to hear the two weeks worth of expert IT evidence.

Read the full transcript here.

Abusing the use of public money

After the hearing was over, Alan Bates, founder of the Justice for Subpostmasters Alliance (JFSA) reflected on the judgment, saying: “This move by Post Office Ltd to have the judge recused was just another act by an organisation abusing the use of public money to litigate a valid case into the ground in order to protect the reputations of just a few individuals and a dysfunctional business.”

The Post Office said: "We believe the overall litigation remains the best opportunity to resolve long-standing issues in order to ensure a stable and sustainable Post Office network for the benefit of the communities who rely on our services every single day.

"Our relationship with our postmasters, operating more than 11,000 Post Office branches throughout the UK, is of the utmost importance to us and we are continuing with our programme to improve the way we work together with them."

James Hartley from Freeths, which is acting for the JFSA said: “The various procedural twists and turns, which we expect in complex litigation, won’t affect the ultimate outcome, which the Claimants are confident will be in line with the first judgement – namely justice being delivered to the Claimants. We expect PO to appeal on a number of issues and we are ready to deal with that in the Court of Appeal.”

We continue...

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Bates v Post Office: recusal judgment transcript

This is the transcript of the discussion between J Fraser and the Post Office and claimants' barristers which took place in court 26 of the Rolls Building immediately after the judge handed down his decision not to recuse himself from the ongoing Bates v Post Office group litigation.

                                          Tuesday, 9 April 2019
   (2.00 pm)
                             Judgment
   MR JUSTICE FRASER:  This is an application by the
       Post Office to have me recuse myself as the managing
       judge from the litigation and to abort the
       Horizon Issues trial, which started on 11 March.
           I have done a written judgment on the application,
       which my clerk will now provide to the parties.  For the
       reasons included in that written judgment, I am going to
       dismiss the application.
           There are two copies in files for each set of legal
       representatives.
                     (Judgment handed down).
           There are also extra copies in court for members of
       the public, should they wish to have them.  The judgment
       is also going to be put on BAILLI this afternoon, that
       is www.BAILII.org with the neutral citation [2019] EWHC
       871 (QB).  It is also going to be put on the Judicial
       Office website, which is www.judiciary.uk.  If anybody
       would like an emailed copy, if they give their email
       address to my clerk at the conclusion of today's
       hearing, then she will email you a copy this afternoon.
           So the issue arises in terms of any consequential
       applications and directions in respect of resumption of
       the trial.  So would either of you like to say anything?
                           Housekeeping
   MR GREEN:  My Lord, we would obviously have an application
       for costs of the application.
   MR JUSTICE FRASER:  Yes.
   MR GREEN:  We did write on the eve of the application to the
       Post Office on a without prejudice case, save as to
       costs basis, to invite them to withdraw their
       application on the basis that we would not, provided we
       heard the following day, make any claim for our costs
       expended up to that point.  That was not an invitation
       which was accepted.
   MR JUSTICE FRASER:  What's the date of that letter?
   MR GREEN:  That was the dated 21 March.
   MR JUSTICE FRASER:  On the day it was issued.
   MR GREEN:  On the day it was issued, that evening.  They had
       obviously had not provided particulars.  They were
       obviously going to have to reconsider that and we
       invited them, in the course of doing so and before we
       had to go through the particulars they then did provide,
       to withdraw the application.
           And on that footing, we'd invite the court to make
       an order for the Post Office to pay the claimant's costs
       on an indemnity basis.  We made them an offer, they
       didn't accept it and we have done better than the offer.
   MR JUSTICE FRASER:  Right, Lord Grabiner.
   LORD GRABINER:  I want to say something about the costs
       first and then -- so first of all, I don't know if your
       Lordship would be proposing to deal with them on an
       assessment basis.
   MR JUSTICE FRASER:  It seems to me there are three issues in
       respect of costs.  First is incident of costs, the
       second is summary assessment or detailed assessment, and
       the third is the basis of assessment.
   LORD GRABINER:  Well, I mean --
   MR JUSTICE FRASER:  I have had schedules from both sides in
       respect of a summary assessment.
   LORD GRABINER:  So I don't know if my friend is pressing for
       a summary assessment today.
   MR GREEN:  My Lord, I would invite your Lordship to consider
       making a summary assessment, but if you were minded not
       to do that, to make an order for a detailed assessment,
       but with a substantial payment on account, which may be
       the easiest way of dealing with the matter.
   LORD GRABINER:  All I want to say about the costs' position
       is really this: that your Lordship has seen their figure
       for the day, which is about £100,000 more than ours.
   MR JUSTICE FRASER:  I think theirs is -- just remind me.
   LORD GRABINER:  314 against 212.
   MR JUSTICE FRASER:  And yours is 212.
   LORD GRABINER:  We had to prepare the application and its
       associated documents.  They merely had to respond.  And
       there is a very short passage of time between 21 March
       and 3 April.  They also appeared by five counsel.  We
       appeared by three.  I wouldn't have thought -- well,
       a matter for your Lordship, what I think is irrelevant,
       but five would be --
   MR JUSTICE FRASER:  Yes.
   LORD GRABINER:  -- jam and cream on top.
           Moreover, from the sheets that your Lordship has
       been provided with, it would appear that they are
       claiming in respect of four fee-earning solicitors.  We
       are claiming in respect of two.
   MR JUSTICE FRASER:  Yes.
   LORD GRABINER:  They are also claiming in respect of two
       hearings on 21 March and 27 March.  On 21 March, they
       were here in any event.  I think they were already in
       front of you.  And on 27 March, there was what I would
       respectfully suggest was a rather pointless exercise
       when they came across and asked your Lordship to make
       further orders, I think, for disclosure, which I think
       your Lordship rejected.
   MR JUSTICE FRASER:  I think it was for more evidence, but
       I did reject it.
   LORD GRABINER:  But, in my submission, neither of those days
       should figure in the assessment exercise.
   MR JUSTICE FRASER:  Yes.
   LORD GRABINER:  So I am content if your Lordship does it
       either on an assessment detailed basis or on an
       assessment on the day basis, as long as you take account
       of those points that I have been -- just been making.
           And then I also want to make an application for
       permission to appeal, but your Lordship may want to hear
       my friend on the costs point first.
   MR JUSTICE FRASER:  I will deal with costs first and then
       I'll come on to your application.
           What I am minded to do is I am minded to make an
       order for the claimant to have their costs of the
       application, because that is consequential on the event,
       to be subject to a detailed assessment and to leave the
       questions of whether that should be on a standard or an
       indemnity basis and whether or not there should be
       a payment on account to be dealt with on a date to be
       fixed.
   MR GREEN:  I am grateful.
   MR JUSTICE FRASER:  So you will have an order in your favour
       as of today for the costs of the application, and those
       other matters can be swept up and dealt with in due
       course.  I am sure they won't be forgotten.  So that
       deals with the costs.
           I'll deal with your application for permission to
       appeal, Lord Grabiner, now.
   LORD GRABINER:  I would -- I should have objected to the
       indemnity suggestion, but that's academic now in view of
       what your Lordship has just said.  So that can be dealt
       with on another day.
           In my respectful submission, this is a suitable case
       for permission to be granted to the Court of Appeal.
       I have to demonstrate that there is a real prospect of
       success.  In my respectful submission, there is one.
       And your Lordship is fully familiar with the story, and
       I do ask for that permission.
   MR JUSTICE FRASER:  Is there anything you would like to add
       other than real prospects of success?
           Permission to appeal is refused.
           That then takes us on to consequential directions.
       In my judgment, there's -- and I'll just make the
       following observations and then each of you can address
       me on them.
           There is a balance that has to be struck between the
       fact that this is -- this application was made in the
       middle of an ongoing trial on the one hand, with the
       fact that the Post Office has the right to seek
       permission to appeal from the Court of Appeal on the
       other.
           I am, therefore, subject to what each of you have to
       say, minded to approach it in the following way, and
       I'll just tell you what it is in outline terms and you
       can then either persuade me or explain to me that
       I should adopt a different course.
           There's only half a day's evidence of fact left and
       in my judgment, that should be swept up and dealt with
       as soon as possible.  There was, in any case, then going
       to be a delay or an interval before the evidence of the
       experts was going to be heard.  And it seems to me that
       that interval now has to take account of the fact that
       the Post Office will seek or says it will seek
       permission to appeal, and the consequences that go with
       that, so it seems to me, that the experts can't possibly
       be heard until a period some time after the Easter
       vacation ends.  Term starts again on 1 May.
           I am minded to order the Post Office to issue an
       application or issue its application for permission to
       appeal and its appeal within an extremely short
       timeframe, but that still means that there would need to
       be a period of time for the claimants to, if it wishes,
       comply with the Practice Direction to Part 52.
           So that's my outline thinking.  Would either of you
       like to address me on any or all of those points, and in
       whichever order?
           Mr Cavender.
   MR CAVENDER:  My Lord, in my submission, it would be quite
       wrong, in light of where we are, to continue with the
       Horizon trial at all, as a matter of principle.  Your
       Lordship has dismissed the application.  It is a serious
       application for which we have told your Lordship we are
       going to seek permission to appeal.  We will obviously
       do so urgently, and your Lordship has indicated you
       would give us limited time anyway.
           And given the result of that is obviously, by
       definition, outstanding, at least until the permission
       application be heard, in my submission, it would be
       obviously sensible to continue the adjournment or stay
       you have in place.  And to be tempted to hear one or two
       witnesses and go along a little bit because of neatness
       almost is, in my submission, wrong in principle.
           If there is a realistic prospect -- in my
       submission, there must be -- of the Court of Appeal
       reviewing this, then the sensible thing to do is hold
       matters as they are and for the Horizon trial, both,
       that is, the balance of the factual witnesses and the
       expert evidence, to await the outcome of that process,
       whatever it is.
           Obviously if that process comes to an end and
       permission to appeal is refused, then of course one is
       in a different ball game then.  You then have to come
       back to your Lordship for directions to get the thing
       back on track.
           Otherwise, my Lord, the risk is this: if we proceed
       as your tentative suggestion indicates, then you have
       the prospect of an ongoing appeal before the Court of
       Appeal unheard.  You have then very expensive expert
       evidence starting to be heard, which is then potentially
       tainted.  In the event that the trial has to start
       again, you can imagine a situation where one or other
       party decides that the witnesses and the way they've
       gone, et cetera -- it is not beyond the bounds of
       possibility they might want to review that or at least
       the evidence will start to be tested in a way.
           And, in my submission, it is much neater to keep
       that evidence, very expensive, careful evidence, clean
       and neat, to be heard together in a situation where
       there's no risk of it being half-heard and then the
       whole process coming to a halt.  That is a recipe, in my
       submission, for disorder and potentially huge wasted
       costs.
           I mean, at the end of the day, if this trial does go
       on with factual and expert evidence, and then the
       results of that are going to be overturned by a recusal
       application, that surely must also fit into the balance
       of the overriding objective and how sensibly to deal
       with this.
           So for all those reasons, my Lord, in my submission,
       the sensible thing to do at this stage is to -- for us
       to apply for permission to appeal, see how that goes.
       If that is unsuccessful, then the results are pretty
       clear.  If it is successful, in my submission, the
       results are equally clear and it would be quite wrong in
       principle to continue with this trial.
   MR JUSTICE FRASER:  If the results are as the Post Office
       contends, any consequential activity as a result of that
       is going to be dictated by the terms of their order, it
       is not going to be up to me.
   MR CAVENDER:  Sorry, your Lordship lost me.
   MR JUSTICE FRASER:  You were explaining the -- you said you
       were dealing with the different contingencies on your
       application for permission to appeal.  One was if it was
       unsuccessful, then the results are pretty clear.  If it
       was successful and you were given permission, then there
       would obviously be directions given by the Court of
       Appeal in respect of that, wouldn't there?
   MR CAVENDER:  There would, but one of them might be to stop
       the trial that may then be ongoing.
   MR JUSTICE FRASER:  I understand that.
   MR CAVENDER:  So the fact that is a possibility would lead,
       in my submission, to the thinking: why would we put
       ourselves in that position with all the wasted costs and
       difficulty that may cause?  In my submission, there is
       no good reason to do that, unless my learned friends can
       give you one, and a number of reasons I have given you
       why that would be a bad idea.
   MR JUSTICE FRASER:  Understood.
   MR CAVENDER:  So those are my submissions.
   MR JUSTICE FRASER:  All right.
           Mr Green.
   MR GREEN:  Your Lordship appreciates we wouldn't have
       started here as claimants.  Given where we are,
       I wouldn't disagree with my learned friend that
       actually, we would have no objection to having those
       last two fact witnesses just before the experts.
   MR JUSTICE FRASER:  There is a period imposed though for
       there to be a gap between the fact and the expert
       witnesses.
   MR GREEN:  My Lord, yes.  What I am suggesting is that we
       might -- that was on the premise that we would be able
       to consider the fact evidence.
   MR JUSTICE FRASER:  One of them is a potentially important
       technical witness from Fujitsu --
   MR GREEN:  My Lord, that's right.
   MR JUSTICE FRASER:  -- whose evidence will need -- well, may
       need to be taken into account by the experts before they
       give their evidence.
   MR GREEN:  What we wondered was whether it might be possible
       for the court to accommodate on a Thursday, before we
       resume with the experts in due course, that evidence so
       it is fresh in the court's mind, rather than do it at
       some point next term.  So I think in terms of
       efficiency --
   MR JUSTICE FRASER:  Let me be completely clear with all the
       parties.  The Court of Appeal has been notified of the
       potential of a pending appeal in this matter, which --
       it is not for a first instance judge to dictate to the
       Court of Appeal how they deal with things in terms of
       urgency.
   MR GREEN:  Of course.
   MR JUSTICE FRASER:  But they have been notified that it is
       in the context of an ongoing trial.
   MR GREEN:  Indeed.
   MR JUSTICE FRASER:  So there is no question that the
       experts' evidence cannot start sensibly this side of
       Easter, for at least three reasons.
   MR GREEN:  Yes.
   MR JUSTICE FRASER:  One is Mr Cavender is right, that expert
       evidence ought to be heard together.  Two, there needs
       to be a decent interval so that the Court of Appeal have
       an adequate period of time to consider the question of
       permission.
   MR GREEN:  Indeed.
   MR JUSTICE FRASER:  And three, there is not enough time to
       deal with the experts this side of Easter anyway.
   MR GREEN:  No.
   MR JUSTICE FRASER:  So expert evidence is effectively
       a preordained issue.
   MR GREEN:  Indeed.
   MR JUSTICE FRASER:  The question of the last expert -- the
       last witnesses of fact, who were going to be just
       fractionally longer than two hours, is rather different.
       The majority of the evidence of fact has been heard
       already.  The period of time within which the
       Post Office considered and decided that it was going to
       issue this application was being done in parallel with
       the evidence of fact.
   MR GREEN:  Yes.
   MR JUSTICE FRASER:  If that's resolved this side of Easter,
       then both the experts know the totality of the evidence
       of fact before they even come to give their evidence,
       which reduces the risk of further delay down the line.
           And thirdly, it is important -- it is not a question
       of neatness.  Mr de Garr Robinson was entirely neutral
       on the afternoon of 21 March whether we continued that
       afternoon and dealt with all the witnesses of fact in
       any event, which is another feature.
   MR GREEN:  Indeed.
   MR JUSTICE FRASER:  So as far as I'm concerned, the expert
       evidence and the witness evidence don't necessarily fall
       to be considered in the same way.
   MR GREEN:  No, my Lord, no.  The only observation I was
       making was that given that we couldn't do the experts
       now and we might have to await the outcome of at least
       the permission application to the Court of Appeal, and
       we'd have to be coming back later anyway, we would
       certainly have no objection to dealing with the fact,
       that little element of fact evidence we have left,
       shortly before we begin the experts.
   MR JUSTICE FRASER:  You might not, Mr Green.  However, the
       trial's underway.
   MR GREEN:  No, I understand.
   MR JUSTICE FRASER:  My intention is to resume it, taking
       account of the practical issues.
   MR GREEN:  Yes.
   MR JUSTICE FRASER:  And your suggested course of action does
       open the door to risk of further delay, which is that
       the experts say they need longer to consider the
       cross-examination, for example, of Mr Parker because it
       has only just occurred.
   MR GREEN:  Indeed.
   MR JUSTICE FRASER:  They might, for example, want to have
       a meeting about it.
   MR GREEN:  Indeed.
   MR JUSTICE FRASER:  So is there anything you would like to
       add to what you've said?
   MR GREEN:  My Lord, not in relation to that.  And obviously,
       we agree.  I discussed it with my learned friend,
       Mr Cavender, and we agree that, for reasons of the
       balance that your Lordship adverted to, it wouldn't be
       wise necessarily to have the experts come back until the
       permission application has been resolved.
   MR JUSTICE FRASER:  Well, there's a solution to that.  Let
       me just check.
           Mr Cavender, is there anything you would like to
       add?
   MR CAVENDER:  Yes, I would like to reply to my learned
       friend's submissions, if I may.  My learned friend and
       I, before we came in, had discussed this and reached
       a joint position that whatever the outcome, that the
       party that lost would seek permission and in that
       situation, it was sensible that the trial generally
       remained stayed, as, in fact, it is.
   MR JUSTICE FRASER:  It is adjourned.
   MR CAVENDER:  Adjourned.  My learned friend at your
       Lordship's instigation is now trying or taking your
       Lordship's suggestion perhaps you deal with it expert
       evidence on the one hand and factual on the other.  But
       both are subject to the same point of principle, that
       there is a real risk that the Court of Appeal will give
       permission and may recuse your Lordship, in which case,
       continuing on with the trial in the face of that
       possibility is, in my submission, wrong in principle.
           As my learned friend says, very sensibly, if
       permission is not granted, then this will need to come
       back in any event.  And as my learned friend also said,
       there is some connection between at least the evidence
       of Mr Parker on technical issues and the experts.  And
       in many ways, that being fresh has many advantages as
       it, you know, being one done before Easter and one
       coming in sort of May or June or some other time.
   MR JUSTICE FRASER:  Well, after Easter is May.
   MR CAVENDER:  Quite, but at the end of the day, the idea of
       restarting the trial just for a little bit of factual
       evidence, in my submission, is -- and I don't shy away
       from the submission -- for the sake of neatness really
       when, in fact, the point of principle is that if there
       is a real possibility, and, in my submission, there is,
       of the Court of Appeal upholding the recusal objection,
       then to go on in the face of that possibility is wrong
       in principle, unless there is some very, very overriding
       benefit that can be identified to counteract it.
           In my submission, your Lordship has come up with one
       potential, which is, well, it may result in further
       delay.  But, in my submission, I am not sure that's
       right.  All one is talking about is, it would seem,
       I think your Lordship said a couple of hours immediately
       before you called the experts.  That, in my
       submission -- if it is a benefit at all, it is a very
       small benefit and when you put that against the
       potential prejudice and waste of costs which may be
       involved in that, in my submission, the answer to that
       balancing exercise is obvious.
           So, my Lord, that's what we say about that.
   MR JUSTICE FRASER:  All right.
   MR GREEN:  My Lord, I should say in fairness that it was our
       view, before we heard your Lordship's proposal, that
       everything would go off together until permission had
       been -- I just want to --
   MR JUSTICE FRASER:  It is not a proposal in the sense that
       I am brokering some sort of three-way agreement.
   MR GREEN:  My Lord, no, but your Lordship invited us --
   MR JUSTICE FRASER:  I thought it was important to give you
       an idea of the -- because obviously, the timetable for
       the resumed trial is something that I have probably been
       thinking about a little bit longer than the parties,
       because I've known the outcome of the recusal
       application for a little bit longer than you two have.
   MR GREEN:  Indeed.
   MR JUSTICE FRASER:  And I appreciate you all came into court
       not knowing who had won and who hadn't.
           I am going to explain what I am taking into account
       and then I am going to explain what I am going to do.
           It seems to me Mr Cavender's submission that it is
       wrong in principle to finish the evidence of fact
       ignores two fundamental points.  One is that the
       evidence of fact is practically completed.
           The second is the subject matter of Mr Parker's
       evidence.  Mr Parker's evidence goes to remote access to
       branch accounts, which is something that featured very
       heavily in the cross-examination of the other witnesses
       in the Horizon Issues trial before it came to an end and
       in respect of which Mr Parker has had to serve three
       separate witness statements.
           The evidence that emerges on his cross-examination,
       whatever that evidence might be, is undoubtedly
       something that the experts are going to need to
       consider.  They might even want to have a further
       meeting about it.
           I am going to order that the Post Office file its
       appellant's notice by 4 o'clock on Thursday of this
       week.  Taking into account the provisions within the
       Practice Direction to CPR 52, the claimants in any event
       have a 14 day period to provide their observations on an
       application for permission to appeal.
           I am also taking account of the Easter vacation,
       which is effectively two weeks, and the fact that the
       first day of term after Easter is not until 30 April.
           So I am not going to commence the expert evidence
       until 15 May.  That gives the Post Office, should it
       wish, ample time to make representations to the Court of
       Appeal about whether or not that should, in fact,
       commence on that date.  And it should also -- it also
       takes into account a desire not to put unnecessary
       pressure of time on the Court of Appeal.  The time
       estimate for the expert evidence remains as it was
       before, which is effectively two trial weeks or a trial
       week for each of them.
           So far as the evidence of fact is concerned, which
       is about two hours' worth, it seems to me that that has
       to be dealt with as soon as possible.  I am not going to
       order that it happens tomorrow, but the last day of this
       trial -- the period was the Thursday of this week and so
       the Horizon Issues trial will resume with the sole
       purpose of resolving the final two witnesses of fact
       from the Post Office on Thursday of this week, which is
       the 11th, at 10.30.
           Mr Green, you remain restricted to the amount of
       time you would have had and on my analysis, I think
       that's two hours, 15 minutes.
   MR GREEN:  Indeed, my Lord.
           My Lord, your Lordship was saying that the expert
       evidence would not resume before --
   MR JUSTICE FRASER:  Until 15 May.
   MR GREEN:  I am in the Court of Appeal for three days for
       the National Health Service in a long running --
   MR JUSTICE FRASER:  Which day?
   MR GREEN:  -- issue on the 14, 15 and 16 May.
   MR JUSTICE FRASER:  Well, it obviously can't be then.  Given
       this is a part heard trial, then obviously the things
       that take priority over it are Court of Appeal and
       Supreme Court.  So effectively, that week -- so it
       cannot be before the 20th, then.
   MR GREEN:  Indeed.
   MR JUSTICE FRASER:  All right.
   MR GREEN:  There is a slight -- this may be a difficulty
       shared by a number of people, but I'll raise it because
       it is a difficulty I face, which is I am not in the
       country from the 27th.
   MR JUSTICE FRASER:  That is judicial vacation anyway.
   MR GREEN:  Exactly.  So if we were to begin on the 20th for
       a week --
   MR JUSTICE FRASER:  There is one full week this side of the
       judicial vacation and then it would have to resume
       afterwards.
   MR GREEN:  Have to resume afterwards.  My Lord, I don't know
       whether we've all -- whether my learned friend has his
       dates for Court of Appeal and above here.
   MR JUSTICE FRASER:  Mr Cavender is not actually doing the
       Horizon issue.
   MR GREEN:  No, quite, Mr de Garr Robinson.  But my only
       other difficulty is later on in June, which is in the
       Supreme Court.
   MR JUSTICE FRASER:  So far as today's order is concerned, it
       seems to me the sensible thing or the most efficient
       thing to do is to do the following --
   MR GREEN:  My Lord, can I just mention one thing --
   MR JUSTICE FRASER:  Yes.
   MR GREEN:  -- which is, of course, the experts.  I know that
       Mr Coyne is unavailable for a period of three weeks.
   MR JUSTICE FRASER:  Mr Green, if you left me finish.
   MR GREEN:  I am sorry.
   MR JUSTICE FRASER:  You are entirely right, but that was why
       I was going to say the important thing for today is to
       identify, effectively, the following headline points.
           The first is the dismissal of the application, the
       second is the outcome of the application by
       Lord Grabiner for permission to appeal, the third is the
       time and deadline for the Post Office to file its
       appellant's notice and application for permission to
       appeal.  The next point is the costs.  The next point is
       resumption of the Horizon Issues trial, solely for
       dealing with fact, to be on Thursday.
           Then the next point is the resumption of the
       Horizon Issues trial so far as the expert evidence is
       concerned to be on a particular day and then a provision
       within it for further directions, because we have two
       professional witnesses and a number of different
       counsel, and that can all be dealt with when everybody
       has a much clearer picture.  We could even have a case
       management hearing on Thursday afternoon, having heard
       the evidence in the morning.
           But I don't think there's much to be gained by me
       standing here while you go through your diary, and then
       we have other people's diaries which are of equal
       importance, and Mr de Garr Robinson isn't even here.
           Based on the Post Office counsel, who I have
       obviously come to know through the hearing, I think it
       is the Common Issues and recusal team here.  Mr Draper
       is not here and he is Horizon Issues, and I don't think
       any of the other Horizon Issues counsel are here,
       actually.
           Mr Cavender, is there anything you want to add?
   MR CAVENDER:  My Lord, no.
   MR JUSTICE FRASER:  All right.  I'll draw up the order.  If
       junior counsel wait in court, please, I will go to my
       room, draw up the order, my clerk will bring you a copy
       down as soon as possible.
           And, Mr Cavender, one point which I am also going to
       add in the order, or Mr Cavender and Lord Grabiner, is
       I am also going to direct that your appellant's notice
       be accompanied by a letter simply on its face
       identifying that it relates to an ongoing trial, the
       date when I propose to call the remaining evidence of
       fact and my direction in terms of the expert evidence,
       so that whoever is first tasked with looking at it in
       the office can see what the state of play is as of now.
   MR CAVENDER:  My Lord, of course.
   MR JUSTICE FRASER:  And the reason I have given a relatively
       short period of time for you to lodge the appellant's
       notice is obviously this is the last full week of the
       Court of Appeal before the Easter vacation.
   MR CAVENDER:  Indeed.
   MR JUSTICE FRASER:  Anything else?
   MR GREEN:  My Lord, no.
   MR JUSTICE FRASER:  Anything else?  No.  Thank you all very
       much.
   (2.30 pm)
       (The hearing adjourned until a date to be notified)

Friday, 5 April 2019

Common Issues trial judgment: cheat sheet


Interested in the Post Office Horizon story? Want to know the outcome of the first trial? Don't fancy reading all 180,000 words of the judgment? You've come to the right place.

Hang on - I don't know anything about this story.

Ah - go to the bottom of this post, read the "Backgrounder", then come back. Quick, now.

What is this judgment, then?

It was handed down on 15 March 2019, and it is the judgment to the Common Issues trial in the Bates and others v Post Office High Court group litigation. Bates and others are a group of 550+ former Subpostmasters and branch post office assistants who have been made to pay money (or worse) to the Post Office in disputes over balances and trading statements generated by the Post Office's accounting and point-of-sale counter IT system, Horizon.

Why is it the third judgment in this litigation? I thought it was the first trial?

It is. There were two (much shorter) pre-trial judgments. One followed a disclosure hearing, the other was a strike-out application. The Post Office lost those, too.

What are the Common Issues?

A list of 23 issues relating to contractual relationship between the Post Office and its Subpostmasters which both the claimant Subpostmasters and the Post Office's legal teams agreed needed sorting out. The judge was asked to make findings on each of those issues so the obligations between Subpostmasters and the Post Office under all post-Horizon iterations of the Subpostmasters' contracts would be settled - both going forward and retrospectively.

A trial of a contract? How does that work?

It wouldn't work without having some claimant and Subpostmaster witnesses who could explain to the court how the contract was enforced in the real world. So that's what happened. 14 Post Office witnesses were called and six claimants were chosen from the 550 - three by the Post Office and three by the claimants. The rest of the trial was taken up with legal argument over contract law.

What happened? 

The attitude and behaviour of the Post Office around this litigation and the evidence of its employees in the witness box came in for plenty of comment from the judge. Here are some choice quotes:

"these submissions by the Post Office are bold, pay no attention to the actual evidence, and seem to have their origin in a parallel world. It is unclear to me how someone can be expected to ask for a copy of something that they do not know exists."

"It does appear to me that the Post Office in particular has resisted timely resolution of this Group Litigation whenever it can, and certainly throughout 2017 and well into 2018."

"the Post Office seemed to want findings on that only if they were in the Post Office’s favour. This is a peculiarly one-way approach by any litigant."

"The Post Office seemed to adopt an extraordinarily narrow approach to relevance, generally along the lines that any evidence that is unfavourable to the Post Office is not relevant."

On the Post Office witnesses:

"Mr Beal was completely unrealistic... [his] way of giving evidence was very much the house Post Office style, certainly for the more senior of its management personnel who gave evidence. This was to glide away from pertinent questions, or questions to which the witness realised a frank answer would not be helpful to the Post Office’s cause."

"Mr Breeden is articulate, intelligent and also acutely aware of how much the reputation of the Post Office hinges on these proceedings. His evidence was presented in terms obviously designed to put the best possible gloss for the Post Office on matters, and some of his statements simply did not stand scrutiny."

On Post Office director Angela van den Bogerd: "she did not give me frank evidence, and sought to obfuscate matters, and mislead me."

On Post Office Retail Transformation Integration Manager Timothy Dance: "His witness statement contained statements about matters of which he had no knowledge whatsoever."

On Post Office Security Team Leader Helen Dickinson suggestion she had never heard of the Enron fraud case: "Mrs Dickinson is a fraud specialist and it is simply inconceivable that she was not familiar with the Enron case, at least in outline terms. I reject her evidence that she did not know about Enron, which I find incapable of belief. The only reason to claim ignorance, as she did, was simply to be unhelpful, which is what I find she was being."

(For what its worth I thought Mrs Dickinson came across as being a bit thick, so I am not so sure she was lying about not knowing about Enron)

On the Post Office way:

"the Post Office doesn't tend to focus on the precise words of a contract, it knows what its interpretation is and that is what everyone works to. This could be described as the Post Office method of contractual construction."

"This is yet another example of documents produced and used by the Post Office being incorrect and consisting of reference to archaic items which no longer existed."

"The Post Office appears, at least at times, to conduct itself as though it is answerable only to itself. The statement that it is prepared to preserve documents – as though that were a concession – and... to refuse to produce them, is extremely worrying. This would be a worrying position were it to be adopted by any litigant; the Post Office is an organisation responsible for providing a public service, which in my judgment makes it even worse."

"it was expressly submitted by the Post Office – and also put to some of the Lead Claimants – that a Subpostmaster did not have to accept debts with which they did not agree at the end of a branch trading period. That proposition is plainly incorrect in fact."

"[There is a culture] of excessive secrecy at the Post Office about the whole subject matter of this litigation. They are directly contrary to how the Post Office should be conducting itself."

"If one wished to become a Subpostmaster, then it was the Post Office’s terms that were available, and those terms alone. There was no negotiation permitted whatsoever.... The two parties are not remotely equal. In fact, they are almost uniquely unequal."

What did the judge think of the claimant witnesses, then, eh?

He accepted all their evidence. And he added: "there is a lot to be desired from the Post Office’s behaviour as identified in the cases of the Lead Claimants"

So the claimants won, then? 

Yes - and on the Common Issues themselves, these are the big points:

1)  If a Subpostmaster contacts the helpline to dispute Horizon's figures in any given trading period, then the Branch Trading Statement they are required to sign off before rolling into the next trading period cannot have the status of a "settled" account.

It means the Post Office cannot treat any branch discrepancy as a debt (or worse - evidence of dishonesty) if the Subpostmaster has flagged the fact they are having problems. The judge goes on to say:
"The issue of a Subpostmaster as an agent deliberately rendering a false account to his or her principal, in relation to any such Branch Trading Statement for such a period therefore simply does not, in my judgment, arise."
Rather important when you consider the number of prosecutions for false accounting.

2) The impossible bind Subpostmasters used to be in where they would be held liable for a discrepancy unless they could prove it wasn't their or their assistants' fault has now gone. The judge ruled:
"It is not for a Subpostmaster to demonstrate that there was no negligence, carelessness or error on his or her part. It is for the Post Office to demonstrate that there is."
If the Post Office has ever suspended, sacked or prosecuted a Subpostmaster without first demonstrating the above, it is now on very shaky ground.

3) Several parts of the Subpostmaster contract [SPMC] and its successor, the Network Transformation Contract [NTC] were ruled to be so onerous, unusual or unfair that they were and are unenforceable. Key examples:

i) The clauses in the NTC contract which hold the Subpostmaster strictly liable for any negative discrepancies in their branch accounts for any reason (save a robbery), or any negative discrepancy discovered in the Subpostmasters absence.

ii) The clause in both contracts which allows the Post Office to suspend Subpostmasters without pay without giving good reason.

iii) The clause which allows the Post Office to "terminate" (ie sack) a Subpostmaster for any breach of contract, no matter how small.

iv) The clause in the SPMC which allows the Post Office to terminate a contract with three months notice, without giving a reason.

v) Clauses in both contracts which do not entitle a Subpostmaster to any compensation in the event they are terminated.

4) Finally, the judge found Subpostmasters' contracts are not strict agency/principal or business-to-business contracts, they are relational contracts. As per the judgment: "This means that the Post Office is not entitled to act in a way that would be considered commercially unacceptable by reasonable and honest people."

So what happens now?

1) The Post Office can't point to a discrepancy between a Horizon-generated balance and the amount of cash and stock in a branch and tell the Subpostmaster to make it good. It has to prove it was made by the Subpostmasters' "carelessness, negligence or error."

2) Its branch auditors can't suspend Subpostmasters arbitrarily. It needs to provide a good reason and it needs to provide a reason why it needs to stop a suspended Subpostmaster's pay...

3) Subpostmasters cannot be held liable for disputed Branch Trading Statements.

4) The Post Office cannot act unreasonably and can be held liable for doing so.

The court is due to hold a breach trial later in November. If the Post Office is found to be in breach of any or all of the above terms, it is in breach of contract and acting unlawfully.

With the above situation as its starting point, most or all of the litigants' claims will likely succeed.

Is that it?

No - the Post Office has announced it intends to appeal the judgment and is trying to have the judge sacked on grounds of bias.

Oh.

Yes. Let's see what happens next, shall we?

And thanks for reading this far. The reporting of this litigation has been crowdfunded. If you can spare a few quid, please scroll to the tip jar at the bottom of this post. Many thanks.

*********************

Backgrounder

Subpostmasters use an accounting and Electronic Point of Sale system called Horizon. You will see a Horizon terminal sitting on the counter of every single Post Office in the country. Every transaction at every branch goes through Horizon. At the end of each month, taking into account all these transactions, Horizon tots up exactly how much cash and stock should be in each branch. It presents that figure to each Postmaster to sign off as a settled account to the Post Office. 

If the figures on the Horizon screen do not match the amount of cash and stock in branch, Postmasters have to make up the difference with their own money. The Postmaster might be certain, from their own record-keeping and internal investigation, that there is a problem with Horizon's figures, rather than a problem in their branch, but the Postmaster has no right to any investigation of the Horizon system. 

Postmasters are therefore responsible for their branch accounts, but not in control of them. 

The Post Office's current approach is to initiate debt recovery proceedings against Subpostmasters on notification of a discrepancy which isn't made good immediately.

Postmasters who have disputed discrepancies have often been told they have no choice but to make them good (either immediately, via a payment plan or out of their salaries), no matter how large the sums involved. 

Some have refused and been sacked, losing their source of income and instantly devaluing their attached retail businesses. Some have made good at crippling personal expense. Some of those Subpostmasters who shovelled thousands of pounds of their own money into Post Office tills to balance their discrepancies found the discrepancies returned. 

Out of ignorance, desperation and extreme duress, knowing the Post Office would just treat a further inexplicable discrepancy as a further debt, some Subpostmaster accepted the Horizon-generated cash and stock figure on their screens as a correct reflection of the cash and stock in their branches when it wasn't.

Why have so many Subpostmasters been sent to prison?

Postmasters having difficulties or flagging large discrepancies or problems with Horizon would often be "audited" and if a cash/stock discrepancy was fond they would be suspended without notice or pay. Some would be "investigated" by Post Office staff and sacked. Some would be prosecuted for theft and false accounting.

Many of those prosecuted for theft and false accounting were naïve and badly advised. Some were advised to plead guilty to reduce a potential prison sentence. Some lawyers would negotiate dropping a theft charge in return for a guilty plea to false accounting.

Once a guilty plea had been secured, the Post Office could apply for a proceeds of crime act order against their former Subpostmaster for the value of the Horizon-generated discrepancy. Live savings were taken. 

I have spoken to quite a few former Subpostmasters dragged through the criminal justice system on this basis. They have horrendous tales to tell.

How did this end up at the High Court?

In 2016 after more than a decade of campaigning, Alan Bates, a sacked Subpostmaster and founder of the Justice for Subpostmasters' Alliance, got funding to start a legal action against the Post Office at the High Court. He wanted redress (and damages) for himself and fellow Subpostmasters who claimed they had suffered at the hands of the Post Office.

The Post Office has said in court documents "If the Claimants were right in the broad thrust of their case, this would represent an existential threat to Post Office’s ability to continue to carry on its business throughout the UK in the way it presently does."

They are right. As a result, they are fighting it tooth and nail, with their bottomless pockets of taxpayers' cash. The hope is that the claimants' will eventually run out of money.

Surely if the Post Office were that bad an outfit, the government would have stepped in long ago?

The government owns the Post Office, but it is known as an ALB  - an Arms Length Body. That means successive Ministers for Postal Services have left it well alone. The Cabinet Office is meant to oversee the relationship between the government and ALBs and a senior civil servant sits on the Post Office board. As far as I am aware, no government department has ever scrutinised the Post Office's behaviour over Horizon, its mass suspensions and sackings and its prosecutions of Subpostmasters for Horizon-based discrepancies.

Why aren't the unions shouting from the rooftops about it then?

The judge's damning comments on the Subpostmasters' "union", the National Federation of Subpostmasters, is worth a blog post to itself, so I have written one here.

***************************

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Thursday, 4 April 2019

Bates v Post Office: recusal write-up


I was told the CWU would be demo-ing outside the High Court's Rolls Building in support of the JFSA and claimant Subpostmasters from 9.30am. What I didn't realise is that they'd be done by 10am. I rocked up (phrase of the day - see below) at 10.05am to find a few CWU members lurking outside, but no placards.

Thankfully, efficient people took photographs and forwarded them on.

There was a definite buzz around, both inside and outside the Rolls Building. Court 26 was the fullest I've seen it. At least a dozen claimants were in attendance, including Seema Misra, Jo Hamilton, Sue Knight, Lee Castleton and Pam Stubbs.

Ron Warmington from Second Sight was also there, as were many of the CWU reps who had been stationed outside early doors (including National Organiser Andy Furey and Postmaster Mark Baker - the latter singled out by the judge in the Common Issues trial judgment for his "redoubtable" Freedom of Information campaigning).

Mark "redoubtable" Baker
On the hack front, Karl Flinders from Computer Weekly put in a shift, as did Jane Croft from the Financial Times. It was great to see Joshua Rozenburg wander in, too. He is a legend in legal journalism and I remember watching him on telly as a kid. When he came over to say hello I didn't tell him that, but I wanted to.

The court was so full a couple of claimant supporters arrived late and saw the only chairs available were on the solicitors' benches. Not knowing any better they plonked themselves down and became the only members of the public to have their own personal court documentation screen. The solicitors were either too polite or worried about disrupting proceedings to tell the visitors to push off, so they stayed there.

After lunch the same supporters came back and sat in exactly the same spot without anyone batting an eyelid.

So what did everyone witness today? Why were we there?

It is possible to ask a judge to recuse (sack) him or herself of grounds of apparent or actual bias. The Post Office believes that J Fraser, in his Common Issues trial judgment has displayed apparent bias against the Post Office.

It is an objective test. A recusal application will succeed "if a fair-minded and informed observer, having considered the facts, would conclude that there was a real possibility that the judge was biased"

The "fair-minded and informed observer" took on almost mythical proportions as the day progressed. It is s/he who will tell the judge if he is biased. Unfortunately s/he doesn't exist.

It was a day of two halves, Brian. In the morning, Lord Grabiner QC for the Post Office took the judge to pieces by isolating specific parts of his judgment and pointing out that any reasonable person could not impute anything other than apparent bias. In the afternoon, Patrick Green QC for the claimants built the context around those specific parts of J Fraser's judgment and argued his comments were entirely justified.

In fact you could almost draw parallels with the Brexit situation.

Post Office: How could we possibly lose? You've done it all wrong!
Claimants: You lost. Get over it.

I'll delve into what was said in a moment. First, the headlines:

1. The Post Office will appeal the common issues trial judgment.
2. The decision to apply for the recusal was made at Post Office board level.
3. The judge has reserved his decision on recusal until Tuesday 9 April at 2pm at the earliest.
4. If the recusal is successful the Post Office wants the Horizon trial to be stayed and restarted.

Off the ropes and playing cards

Bearing in mind we are three years and £20m into this litigation, if the Post Office is successful, we will almost be back where we started. Which is, of course, exactly what the Post Office wants - a big reset to regain the initiative, and a ramping up of the costs to make everything as expensive as possible. That way the claimants will hopefully run out of money and throw in the towel.

In litigation, no one said you had to play nice.

To be fair, the Post Office is bossing things right now. It has successfully seized the initiative from the claimants after the Common Issues trial judgment. Anyone who reads even a few hundred words of that judgment can see the pasting the Post Office got. Factually, legally, reputationally and culturally the Post Office was massively exposed by the judge's findings.

For an organisation which is obsessed with its public image and shrouded by a cult of "excessive secrecy", this must have been a shock. On 15 March, when the judgment was handed down, the Post Office was not just on the ropes, it was floored. Yet within a week it was back. Off the canvas and swinging like a champion.

A recusal application is still a massive call, though. To switch metaphors, aiming to sack a senior judge because you don't like some of the things he's said is the legal equivalent of going all in on a pair of tens. You have to be feeling lucky.

But as every gambler knows, it isn't just about the cards, it's about the player.

Enter Lord Grabiner.
Big Dog

On the evidence of today, m'learned friend could stroll into any long-running, hotly-contested™ litigation and own it. He has a presence and charisma which might persuade a casual observer that everything which happened in the litigation before he got involved didn't really matter.

This is a man who presumably doesn't take instruction unless he is being paid several thousand pounds an hour, or knows he's going to win. Or both.

And so the slow, brutal dissection of J Fraser's judgment was borne by the court as Lord Grabiner went to work, picking out phrases for their invective, irrelevance and potential bearing on future trials. eg:
"the expression "extraordinarily
 serious behaviour" is a strong expression.  It is an
 eye-catching expression.  And in the context of this
 debate, there was no warrant for it and, in my submission, it is extremely prejudicial and certainly
 wasn't necessary for the purposes of the Common Issues.
"
and
"your Lordship makes a very general statement
 about Post Office's house-style of giving evidence. That shows that from now on you are likely to disbelieve
 Post Office's evidence because it comes from
 Post Office.  In my submission that is how it would be
 viewed by an objective observer."
In fact, Lord Grabiner was so assured that towards the end of his allotted time he stopped making arguments and just read out sections of the judgment, adding:
"Well, I mean, your Lordship can imagine what I would be saying about that, but my submission is that the passage speaks for itself.
"
It was quite something to behold.

Caveata Mantra

The coup de grace was the trap Lord Grabiner laid for the judge at the beginning of the day. Lord Grabiner would read out sections of J Fraser's judgment, selectively omitting comments such as: "I make it quite clear that I do not speculate... nor is it possible to know what the outcome
 of the trial of the Horizon Issues will be later this
 year."

J Fraser would mention that Lord Grabiner had omitted his qualifying statements and caveats and Lord Grabiner would acknowledge this, but add he was coming to it later.

Eventually he did. These qualifiers were a "mantra" said Lord Grabiner, which were fooling no one:
"It...  would not
 convince the observer that your Lordship had not
 pre-judged the issues which still fall to be tried by
 your Lordship.
.. The real question is whether in the eyes of the
 reasonable observer that is a real possibility that
 your Lordship has prejudged matters which are still due to be tried by you... Lord Justice Bingham says: "In most cases we think the answer, one way or the other, will be obvious, but if in any case there is real ground for doubt that doubt should be resolved in favour of recusal." Your Lordship's use of what I have called, I hope not disrespectfully, the mantra, demonstrates your
 understanding that you should not have made findings for
 example about Horizon or breaches of contract or
 breaches of duty.
 Our case is that your Lordship nevertheless went
 ahead and made those findings."
You can read the transcript here and my unrolled live tweets here. It must be hard to hear one's professional integrity being taken apart in such an eloquent and public way. But the judge took it on the chin. And after lunch, he turned to Patrick Green QC for the claimants.

Green machine

Mr Green went in all guns blazing, hooting:
"this is an application without merit
 and without foundation... it wholly ignores the proper role of context.... it appears to proceed on
 a misapprehension as to the correct approach to analysing apparent bias [and] it proceeds
 specifically on a misapprehension as to the proper judicial assessment of the proceedings."
He went on to address the mythical "fair-minded and informed observer":
"The informed observer is
 someone who is presumed to actually have been at the trial and know what happened, not commenting on it from afar and not island-hopping between different findings and observations to make assertions about those without
 having regard to the judgment as a whole."
Really? Said the judge. Yuh-huh, said Mr Green:
"the informed observer test is (a) an
 objective one and (b) an informed one. So the informed
 observer knows about the trial as it was presented to your Lordship.
 In one case, there is even a point about knowing
 things that perhaps even weren't in the public domain
 about the trial. So "informed" I would underline in relation to the approach of the informed observer test.
"
And he was off. The main two points he made were that the Post Office was not once saying that any of the judge's findings were wrong, just that they were irrelevant. His second point was that in the context of the trial, the proceedings preceding the trial and litigation as a whole... actually they really were very relevant.

Mr Green said in the context of someone who has been through all the pre-trial shenanigans, and the framing of the way proceedings happened, the judge was justified in what he wrote in his the Common Issues trial judgment. Yet according to Mr Green, the judge was not just expected to take into account what was happening in his courtroom, he was, by case law, required to make findings on it.

Rock on

Mr Green continued:
"In fact, there is an irony in that Post Office's
 position was effectively to seek a trial that was
 one-sided, when it didn't get it, to then complain on the footing of apparent bias about that and then to invite the court effectively to consider the recusal
 application as if the trial had been one-sided, which it
 plainly wasn't."
At one stage, when discussing the admissability of written witness statements which may or may not have been written by a witness he got a bit carried away:

"when I started and certainly when my
 noble and my learned friend Lord Grabiner started, we
 didn't have [written witness statements]. You rocked up in court, the witness
 stood up and you found out what they said and then you cross-examined them without knowing what they were going
 to say.
MR JUSTICE FRASER:  I am not sure "rocking up" is right.

MR GREEN:  I might have put that a bit lightly.

MR JUSTICE FRASER:  You might have rocked up. I am not sure
 that is the correct way of putting it, in all
 seriousness. Evidence-in-chief was given orally.

MR GREEN:  Yes, evidence-in-chief was given orally.  What
 I was trying to convey, albeit rather slightly clumsily,
 was you didn't pore over somebody's evidence for weeks
 in advance of arriving at court and listening to what they were going to say."

Knuckles rapped.

Mr Green ended on a roll, giving the Post Office both barrels:
"They have adopted internally inconsistent positions in relation to the relevance of evidence and essentially tried to ride two horses going off in completely different directions, and your Lordship has had to try and manage the consequence of that, and clarify it, where possible, on credibility, still leaving an extremely unsatisfactory position, make findings in the light of the litigation as it was presented before court, and then be accused of apparent bias for having done so."
I have spoken to a number of senior people since the hearing finished, some of whom were legally qualified. They broadly agreed there is a minuscule chance the judge will recuse himself and an even smaller chance the Court of Appeal will make the decision for him.

I'm not so sure. Grabiner was good.

***************************

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