4. Opening Statement by Mr Lavery

Mr Lavery: I Won’t hesitate to.

Thank you for giving us the opportunity to address you here in person, and it is great to see so many people here in person.

I represent the Northern Ireland Covid-19 Bereaved Families for Justice, and I’m Ronan Lavery. I’m here with Mr Conan Fegan who is another barrister, and Mr McGowan, and Enda McGarrity and Conal McGarrity are here as well, and we represent our families in Northern Ireland and they will be heartened to hear what you just said, my Lady, in terms of them being at the heart of participation in this Inquiry.

We are here to represent them in London. Northern Ireland is a place geographically removed from here and we’re here to represent them as this Inquiry proceeds.

We have prepared a joint submission to the Inquiry, and I hope that you will see that as a way that we want to collaborate responsibly with the other families from the other jurisdictions, and I endorse entirely what Mr Weatherby was saying and I’m not going to repeat that in that manner.

As I say, we’re heartened to hear some of what Mr Keith said today and what you are saying as well, and that the door will be open and, just as we’re collaborating together, we want to collaborate as well with the Inquiry going forward.

The families I represent were very impressed with the Listening Exercise which did happen in Belfast and were struck with your humanity, my Lady, and it is our wish that that humanity continues throughout this process. It sounds from what has been said today that it will because, although as Mr Keith pointed out we’re dealing here with high-level decision-making, a group of lawyers examining it, scrutinising it, this is of course about human beings and humanity, and that won’t be lost on you, my Lady.

When one is looking at this from a Northern Irish perspective, there are decisions that were made at a UK-wide level that impact on Northern Ireland, and we will collaborate with the other nations on those issues, but there are also decisions that were made in Northern Ireland.

Northern Ireland’s a unique place, not just geographically, as I’ve explained and as set out in our submissions as well, there are some features that are unique to Northern Ireland. So we want to impress upon you the importance of dealing with these issues in Module 1 as well, and they seem to have been looked at in a more separate and different way in Module 2 and simply, I suppose, we want to impress upon the Inquiry the importance of this for our families.

There is no Northern Ireland Inquiry, and so this is their opportunity to shape the outcome of this Inquiry in a collaborative way. Some of the unique features or Northern Ireland are – this may come as a surprise to many people – we don’t actually have an NHS. We have a universal healthcare system which is branded in different ways. We have an amalgamated health and social care system, again different from the England and Wales model. We have a unique constitutional arrangement in terms of decision-making at a devolved level. There is mandatory coalition and hurdles that have to be surmounted before any kind of decision is made. For instance, if they are significant or controversial, then they have to be referred to the executive. So that is a unique feature.

Of course – and I’m back to geography – north and south, the island as one epidemiological unit is something that is of course unique and there was, I understand, a memorandum of understanding between the jurisdictions north and south, and the impact of that the effectiveness of it is something that we would invite the Inquiry to look at.

I’m not going to say an awful lot more, my Lady. Mr Weatherby has dealt with the issues and as I say that’s our collaborative effort.

On the issue of disclosure, we are keen to hit the ground running and, if there we’re looking at a hearing in May, we want to look at materials as quickly as possible and make sure that we’re prepared for that and that we can deal with this as expeditiously as possible and that there won’t be delays in the scheduling.

So just lastly then our families’ concern is that we have a real role in this Inquiry, that the unique Northern Irish situation is dealt with and that it is not somehow dealt with as a footnote to the Inquiry, and that’s the phrase that they have used. So we hope, and it’s our aim as their legal team to make sure that that doesn’t happen.

Lady Hallett: Thank you very much, Mr Lavery. Thank you for your comments about my trip to Belfast. I think as you will recall – I mean, I fail to believe anybody could be not moved by what we heard from the families on that occasion and, indeed, throughout the UK. So thank you very much for your comments and for your offer of collaborative working. I really do appreciate it from all of you.

As far as many of the unique aspects of Northern Ireland are concerned, if I didn’t know about some of them before, I certainly do now, and I can promise the people of Northern Ireland that, for as long as I am the only Inquiry into Northern Ireland, we will ensure that all the aspects that your lay clients’ wish to be considered and, indeed, the public in Northern Ireland wish to be considered, if they are of course what we in the end determine are relevant, then they will be. So thank you very much for your comments.

Mr Lavery: Thank you, my Lady.

Lady Hallett: Ms Mitchell.