3. Submissions on Behalf of Scottish Covid Bereaved by Mr Henry

Mr Henry: Yes, good morning, my Lady.

I appear on behalf of the Scottish Covid Bereaved as instructed by the Inquiries team at Aamer Anwar & Company.

Your Ladyship has received our written submissions and I adopt those submissions. I propose to use my time this morning to make brief further submissions in relation to disclosure, expert reports, other witnesses and timetabling.

Turning first to the issue of disclosure, the Scottish bereaved note all that has been said by Counsel to the Inquiry in relation to that this morning. It is hoped that your Ladyship’s notices under section 21 of the 2005 Act allow for the all the matters in the relevant Rule 9 requests to be addressed and for evidence to be provided to the Inquiry timeously.

Your Ladyship has submissions from a number of core participants in relation to the issue of disclosure. I don’t intend to rehearse those submissions, save to repeat our submission that, standing the volume of disclosure, it is hoped that all possible steps are taken to allow for the disclosure process to be finalised in good time to allow for all matters to be finalised in advance of the substantive hearings.

Moving on, my Lady, to expert reports, your Ladyship has the Scottish bereaved’s comments in relation to the report concerning Long Covid and we will provide our comments on other reports in due course.

Scottish Covid Bereaved note that in relation to primary care and emergency pre-hospital care, Professors Snooks and Edwards have been instructed to provide a report in that regard. We note what has been said this morning by Counsel to the Inquiry about these reports covering all four nations of the UK, but, given the different healthcare system in Scotland, it may be that we have additional submissions about the need for a discrete report in relation to Scotland, but we await the disclosure of that report, my Lady, and we will make any submissions required in due course.

We note the submissions of the UK and Northern Irish bereaved about the need for reports to cover issues of structural and institutional discrimination. That is an approach that the Scottish Covid Bereaved would welcome, although we do note all that has been said by Counsel to the Inquiry this morning.

Turning, my Lady, to other witnesses, the Scottish bereaved consider that the Inquiry requires to hear the evidence of the former Scottish Chief Medical Officer, Dr Catherine Calderwood, during the substantive hearings. We are of course aware of the issues surrounding securing Dr Calderwood’s evidence which arose in Module 2A, and it is hoped that steps can be taken to allow for Dr Calderwood to give evidence, even if that is outwith the hearings currently set.

Finally, my Lady, moving to the issue of timetabling, the Scottish Covid Bereaved understand that a great many issues will require to be addressed during the substantive hearings. We have concerns about whether this can be done in the assigned hearings and we would welcome a further preliminary hearing to address the issue of the witness list and timetabling. We do, however, welcome Counsel to the Inquiry’s confirmation this morning that the two-week break in the hearings will not be pushed back. Although I understand that other core participants have submissions on this matter, my Lady, were the two-week break to be pushed back it would no longer coincide with the October week school holiday in Scotland and we’d have issues for those in Scotland who have childcare responsibilities.

So, my Lady, those are my submissions, unless there are any matters which your Ladyship requires to be addressed.

Lady Hallett: No, thank you very much for your help, Mr Henry, I’m very grateful.

Right, Ms Weereratne. You’re hiding back there.