17. Reply Statement by Counsel to the Inquiry

Ms Carey: My Lady, just a few, if I may.

May I start with an apology to Ms Davies for misattributing to Mind the request that Module 3 considers dementia, which should have been correctly attributed to the John’s Campaign. That was my fault, and I’m sorry to both core participant groups.

May I just make two matters clear by way of reply. This is not a case where Module 3 is using inpatient child and adolescent mental health services to extrapolate into a wider look at mental health services, and it may just be worth for a moment me explaining publicly why the four non-Covid conditions were picked.

Colorectal cancer is the second most common cause of cancer death in the UK, and ischaemic heart disease is an example that we thought an appropriate way to look at serious chronic conditions that might require acute medical intervention. Hip replacements is not just a matter that affects the elderly, my Lady, but an example of a common elective surgery which has real debilitating effects for those that can’t walk, can’t get around, and become generally unable to move about.

My Lady, inpatient child and adolescent mental health services was selected as a way of focusing on the impact of the pandemic on inpatient services; and looking at children and young people who are deemed to be acutely unwell and at the greatest risk of rapidly declining mental health or serious self-harm, we submit, my Lady, that really feeds into your pronounced determination to look at the impact on children and young people. And that is why we are looking at those mental health conditions and those non-Covid conditions: not to try and extrapolate from that wider learning and understanding, but to allow you to look at a broad spectrum of patients in terms of age, sex and background, and treatment that covers primary, secondary and tertiary care; and I hope that brief explanation makes it clear why we are looking at those matters.

My Lady, finally this: you have heard today a number of submissions that spoke of the powerful evidence that you’ve already heard by those who experienced the human impact of the pandemic. May I therefore publicly reiterate Module 3’s commitment to hearing evidence from the bereaved, from patients and from healthcare workers in the public hearings. We are very grateful and welcome the offers of assistance made to date and those made today to help identify those witnesses.

As to all the other matters that you have been addressed about, they require reflection by the legal team, and so I don’t propose to address you about them today. I know there will be particular submissions that you will want to consider carefully, and so I’d ask you to do so, not this afternoon but in the fullness of time.

Lady Hallett: Save for one. Is there nothing to object to my ordering publication of the submissions online?

Ms Carey: No, we wouldn’t object to that at all.

Lady Hallett: Very well, I so order.

Thank you, Ms Carey. Thank you very much, everybody else. As ever, submissions have been extraordinarily helpful and a great deal of food for thought, and I will give very careful consideration to these issues, along with seeking advice from my team.

So, thank you, until we meet again.

(4.25 pm)

(The hearing concluded)