14. Submissions on Behalf of Scottish Ministers by Ms Drysdale

Ms Drysdale: Can you see and hear me, my Lady?

Lady Hallett: I can, thank you very much.

Ms Drysdale: My Lady, I appear on behalf of the Scottish Government with my junior Kenneth McGuire.

I have six very brief points to make: firstly, on acknowledgement of loss; secondly, the commitment by the Scottish Government to the Inquiry; thirdly, co-operation and engagement by the Scottish Government with the Inquiry; fourthly, evidence provided by the Scottish Government to date; fifthly, the relationship between the modules; and sixthly, assistance by the Scottish Government.

So, my Lady, turning to the first of my points, the Scottish Government wish to acknowledge the scale of the loss and suffering of those in Scotland and the rest of the United Kingdom during the pandemic. In particular, they welcome the update on the listening exercise, Every Story Matters, and on commemoration by Mr Keith KC.

The Scottish Government recognise the central importance of the bereaved and all those affected by the pandemic to the Inquiry process, the importance of ensuring that their stories are heard and the importance that they receive answers to their questions in relation to the pandemic.

In this context, my Lady, this brings me to my second point, that the Scottish Government wish to stress the seriousness of their commitment to full co-operation with the Inquiry.

Given that the Inquiry is to take a trauma-informed approach, the Scottish Government wishes to emphasise its intention to work collaboratively with the Inquiry team.

We are grateful to Counsel to the Inquiry for establishing good communication with ourselves and to the cordial, respectful and prompt communication of the Solicitor to the Inquiry for Module 2 with the legal team for the Scottish Government.

Turning to my third point, my Lady, the co-operation and engagement of the Scottish Government with the Inquiry, the Scottish Government understands the importance of disclosure to the Inquiry and its full engagement with this aspect of the Inquiry. It has been co-operating fully with the process of disclosure and extensive documentation has been produced, over 9,000 documents already having been disclosed by the Scottish Government.

Turning to the issue of further evidence provided by the Scottish Government, my Lady, the Scottish Government welcomes and supports the approach of the Inquiry to obtaining evidence from witnesses. All requests for statements under Rule 9 have been met. Eight corporate statements have been produced and one personal statement, and the Scottish Government has respected all deadlines and complied with all requests to provide documentation where it holds that, and it will continue to do so.

Turning to the issue of the relationship between the modules, the Scottish Government notes that the Welsh Government seek clarification on the relationship and interrelationship between the different Modules 2, 2A, 2B and 2C, and the Scottish Government welcomes the update by Mr Keith KC on how cross-module disclosure will be made and it would also appreciate further clarification in due course of the precise parameters of Module 2 and how that will interact with Module 2A.

Finally, my Lady, on the issue of assistance to the Inquiry by the Scottish Government, the Scottish Government wishes to emphasise that it will assist the Inquiry to ensure that investigations are conducted as comprehensively as possible in the time available. It will assist the Inquiry in its aim of identifying recommendations to support appropriate and effective decision-making in the event of a future pandemic, and to answer questions for the bereaved and for all those affected by the pandemic.

My Lady, these are the submissions for the

Scottish Government.

Lady Hallett: Thank you very much indeed, Ms Drysdale.

Right, I think the last person to speak – unless

Mr Keith wishes to say anything by way of reply – is

Mr Chapman.

Not the most popular brief today, Mr Chapman,

I think, acting for the Cabinet Office.