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Contracted with
the Legal Aid
Agency
Bindmans LLP
236 Gray’s Inn Road London WC1X 8HB
DX 37904 King’s Cross Telephone 020 7833 4433 Fax 020 7837 9792
www.bindmans.com info@bindmans.com
Bindmans LLP is a limited liability partnership registered in England and Wales under number OC335189. Its registered office is as
set out above. The term partner means either a member of the LLP or a person with equivalent status and qualification.
SENIOR CONSULTANTS
Sir Geoffrey Bindman QC*
Stephen Grosz QC*
Saimo Chahal QC*
Lynn Knowles
PARTNERS
Tayab Ali
Tamsin Allen
Liz Barratt
Jules Carey
Jon Crocker
Yagmur Ekici
Kate Goold
John Halford
Charlotte HaworthHird
Alison Leivesley
Siobhan Kelly
Elizabeth McGlone
Alla Murphy
Olivia Piercy
Jamie Potter
Paul Ridge
Amrit Rana
Amy Rowe
Alison Stanley
Anna Thwaites
Katie Wheatley
ASSOCIATES
Salima Budhani
Emma Cohen
Maud Davis
Neil Emery
Ashley-Jayne Fleming
Roberta Haslam
Laura Hobey-Hamsher
Catherine Jackson
Jude Lanchin
Alison Mackintosh
Karen May
Jessica Skinns
Sheetul Sowdagur
SOLICITORS
Karan Ahluwalia
Sumaiyah Anwar
Clara Barry Born
Joanna Bennett
Nasbin Begum
Jessie Brennan
Elizabeth Cleaver
Samuel Cronin
Alice Davis
Rachael Davis
Emily-Jade Defriend
Abigail Evans
Christian Hansen
Rachel Harger
Ella Jefferson
Robert Maddox
Hannah Marshall
Carla Mirallas
Joseph Morgan
Oliver Oldman
Patrick Ormerod
Shelly Pastakia
Jen Parker
Farhana Patel
Caroline Robinson
Basmah Sahib
Emma Varley
William Whitaker
Rosaleen Wyllie
Louisa Zangina
Daniel Zona
LAWYER
Melissa Arnold
CONSULTANTS
Liz Dronfield
Tony Taylor
*Honorary
Direct dial:+
Direct fax: +
Your ref:
Our Ref:
Direct email:
Paralegals:
Date: 27 November 2020
FAO
Government Legal Department
Litigation Group
102 Petty France
By email only:
Dear
R (on the application of Doctors’ UK Association & Ors.) –v- Secretary
of State for Health & Social Care & Ors.
Claim No: CO/2074/2020
1. Introduction
1.1 We continue to act for the claimants in the above claim and write
further to the NAO Report, “The supply of personal protective
equipment (PPE) during the COVID-19 pandemic”, as published on
25 November 2020 (the “NAO PPE Report”). As you are aware, the
claim was stayed by consent pending the publication of that report.
1.2 In light of that Report we invite the Defendant to now accept that
he is under a duty to commission an enhanced Article 2 investigation
into whether failings nationally and/ or locally in the procurement,
stockpiling, distribution and provision of PPE, and the provision of
information about PPE, both before and during the ongoing COVID- 19 pandemic may have caused or contributed to the deaths or
serious illness from COVID-19 of workers in the health and social
care sectors, as well as patients (including nursing and care home
patients) (‘the PPE Issue’).
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1.3 We also invite him to provide details of the legal framework, timing,
constitution and terms of reference of such an investigation.
1.4 If that is accepted then, subject to agreement on the details of any
such investigation, it may be possible for the claim for judicial
review to be settled and it is likely to be appropriate for there to be
a short stay while this is resolved.
1.5 If that cannot be agreed, we invite the Defendant to at least agree
that permission to apply for judicial review should be granted and
sign the attached consent order timetabling this case towards a
substantive hearing.
1.6 If the Defendant refuses to agree permission, then we seek his
agreement to further directions for a speedy determination of the
permission stage following the lifting of the stay on 30 November
2020. We attach a further, alternative consent order for this
purpose.
2. The NAO PPE Report
2.1 Your client relied in his Summary Grounds of Resistance on the NAO
PPE Report as a report that would investigate “precisely the sort of
systemic issues that the Claimants are concerned about.” Indeed,
it was the only independent mechanism identified by the Defendant
as being able to identify and address systemic issues beyond the
death or illness of a particular individual.
2.2 This was prescient. As was our letter of 2 July 2020, which predicted
the NAO Report would “unearth” evidence, draw interim
conclusions and make recommendations of relevance to the claim.
All of that evidence and those conclusions and recommendations
reinforce the need for the Defendant to unequivocally commit, now,
to an Article 2-complaint investigation.
2.3 In particular, the Report identifies a host of problems in the
procurement, supply and distribution of PPE:
(a) The Report identifies significant deficiencies in the stockpile
of PPE available in the case of a pandemic, including the
absence of gowns, and out-of-date or unsafe PPE (paragraphs
1.8, 1.9 and 1.16). Collectively, the stockpiles provided an
estimated two weeks’ worth or less of most types of PPE
needed by the NHS and social care during the pandemic
(paragraph 8 of the Exec Summary and see figure 4 on p.20).
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(b) The Report identifies a failure to recognise within an
appropriate timescale that these supplies would be
insufficient. Even by mid-March 2020, despite the warnings of
Sage to the contrary in February, the Government believed
existing stockpiles “would provide most of the PPE needed to
manage a Covid-19 pandemic” (paragraph 1.13).
(c) The Report identifies substantial deficiencies in the pre- pandemic distribution / supply chain models, including
warehousing and logistical problems and inadequate legacy IT
systems (paragraphs 1.16 and 1.17).
(d) The Report also identifies deficiencies in the supply chain
introduced in response to the Pandemic, noting that despite
the efforts made, “there are important aspects that could and
should have been done much better” (Exec Summary,
paragraph 23). These aspects included on initial reliance on a
“push” model, whereby all Trusts got the same amount and
type of PPE regardless of need, PPE had to be procured at
inflated prices, some of the PPE procured did not meet safety
standards, and there were concerns about the propriety of
some of the contracts awarded (as dealt with in another NAO
Report) (paragraphs 2.5-2.20).
2.4 Unsurprisingly, in the time available, the NAO was unable to draw
final conclusions as to the extent of actual shortages, but the
extraordinary divergence of views between stakeholders underlines
the need for an Article 2-compliant investigation. By way of example
only:
(a) The DOH maintained that it had never “entirely run out of
PPE” (paragraph 2.9).
(b) NHS Trusts reported that they also has never entirely run out
of PPE although they often did not know what PPE they would
get and what they got did not necessarily correspond with
their need (paragraph 3.8).
(c) Social care providers acknowledged that they came
“extremely close to running out of PPE” (and the NAO notes
they may have been unwilling to admit they had run out even
if they did so). Such providers also considered they had
insufficient support from Government in obtaining PPE
(paragraphs 3.11-3.12). We understand that permission has