My Lord, I don't want to say anything more than is in writing. You've seen from the written submissions -- and it may be that if others haven't seen the written submissions I ought to briefly summarise them -- that we put the application on two bases.
Firstly, that the government ministers concerned have been asked to give evidence, I think in the case of at least one case -- that is the Chancellor of the Exchequer -- at present that invitation is to give evidence in writing, but the others in the group have been asked at this stage to be prepared to give evidence orally. The application is therefore made first on the basis that the central theme of this Inquiry is -- of this module is to look at the press and the impact and effect that the press has had on the public, the police and politicians, and it's in those circumstances fair and proper that these witnesses should have access on the same basis as other witnesses who are directly concerned with those issues. That's the first basis.
The second basis is that, more generally, government as a group -- and this group of individuals, this group of ministers, can be taken as fairly representative of government for this purpose -- also have a clear, as it were, public interest in the proceedings because they will be responsible for the policy matters, they have carriage of the policy.
Those are the twin bases on which the application is put.