Just this, and I'm sorry to be an irritation, but the protocol ought not to be limited just to core participants, if the allegations are made against those who are not core participants.

I'm grateful.

Quite whether one goes -- how far one goes in respect of an individual. I have to say I am -- I thought it right to air the concern that we have in the way that we hope will be most helpful to the Inquiry.

Sir, to go back to what you have previously said. This may simply be a question of the granularity of this.

The difficulty at the moment, sir, is I don't know, because unless we know -- for example -- what the different witnesses are saying, both whether giving evidence or submitting or, and this will touch on anonymous witnesses as well, whether, for example, allegations are being made. To go back to ...

No, I'm conscious of --

What I am suggesting is that those -- while everyone may be affected by that general proposition, there is a category of persons, of whom my client is one, who are in a peculiarly vulnerable position at the moment.

I'm not suggesting that either.

The danger then arises is in relation to questions posed of others, where they touch upon her position, quite what happens.

If you go back to the questions that were raised in the notice in August, it's pretty clear that those questions are specific.

Well, that I am reassured by, but I have to say, sir, that up until today we had not quite understood that to be the position.

It's paragraphs 21 and 22 and 27 and 28. The difficulty, of course, arises that she, in common with a number of others, is going to be, if giving evidence, going to be giving evidence in the full glare of live TV, and therefore the raising of that right ...

My Lord, I don't resile from that. That remains the position. The difficulty that is now layered upon that is the approach being taken in terms of her ability to deal with things and also the public perception.

For example, I raise this in the context, and it's ...

It's an area that we have specifically raised.

Yes.

I understand that, but it's a question of having notice of those lines in advance rather than having to meet them on the hoof.

That's why we ask, as the conclusion of our submission, whether there are some lines drawn in terms of what is going to be asked and is not going to be asked.

Even those macroscopic topics cover precisely the area of, as I understand it, the various police investigations.

The macroscopic and microscopic approaches, we have no difficulties with that as an approach. The difficulty is that the macroscopic approach involves a broad consideration, for example whether at different levels of the organisation the activity was encouraged or condoned in any way, or whether that activity was confined to ...

Precisely.

Can I just make some supplementary submissions in that case?

I don't touch, sir, if I may say so, on issues of abuse or potential abuse or contempt. It's premature at this stage. What may happen, we simply don't know, and how that may be viewed, we ...

Yes.

Yes, thank you very much.

Just this, I raised two issues in terms of what I might generally call disclosure, the evidential and the procedural. We are anxious when any procedural questions arise, so for example, matters such as standard of proof, that we have an opportunity to be heard and if there are draft ...

It does, but we would be concerned if that had become -- and I am sure it hasn't -- but if that had become a de facto default position because, in our submission, that would not, in fact, enable the Inquiry to get the assistance that it deserves.

There has already, and it is unfortunately, in our submission, been a default position adopted, for example, in relation to today's hearing, which is unfortunate, which is simply this: we were provided with Mr Jay's helpful note for today's hearing very shortly before it went on the ...

-- I am afraid, but that is water under the bridge.

Sir, I don't want to go back to the submissions that I have previously made and upon which you have ruled. I don't quite agree with that approach --

The position essentially is this: that, as is apparent, she is likely to have a very particular perspective to offer, which is different to the core participants who, after all, are either, in terms of individuals, victims, as they have been described, or organisations.

Yes, it is diminished very substantially.

So the position is this: that while we do not make the request that has just been made, that we should have necessarily all of the materials supplied to the core participants, bearing in mind her position, we do ask that consideration be given ...

But the difficulty that arises is that, unless she or I or my solicitor are present throughout the Inquiry or every moment of it, and in a position to say to Mr Jay, "Can we invite you to deal with this or that or the other", our contribution is -- I ...

No, that is the difficulty, but what I am seeking to do is -- frankly, what I am seeking to do is to prevent the needless expenditure on attendance and work which is completely unnecessary by trying to focus on what we need to focus upon, and it is only if ...

The answer, actually, is simple: we wouldn't know. We wouldn't know until we saw the transcript unless we were here every day, unless, of course, we had advance notice of issues that may touch upon that. We have no --

I am talking about both, both procedural issues and evidential issues. So far as procedural issues, such as the approach that the Inquiry should take to standard of proof, for example, we certainly will have a contribution to make. But also, in terms of evidential issues, there are likely to ...

But as a preface, I ought to set out that Mrs Brooks, whom I represent, is determined to assist this Inquiry, not because she is required to do so but because she believes she has both important evidence and information which will substantially inform and assist this process, and she ...

Sir, I can be quite short but can I preface my remarks with this, this is not a review of your decision as to core participation.

Sir, before that happens can I just raise the submission I make, because that may touch upon the view that is expressed?

Thank you very much, sir.

I understand.

Would you just give me a moment?

But ...

I don't press for that at this stage.

So far as the relationship between the press and the public?

I understand that.

This part of the Inquiry is not as acute as subsequent parts.

To no real extent. In terms of what she can provide, she is in a position to provide information which may be similar not necessarily in content but in subject matter terms to a number of different editors. But in terms of how significant that information is, that obviously is ...

That is the basis upon which the application is made.

Sir, I am Mukul Chawla, I am representing Mrs Rebekah Brooks, instructed by Kingsley Napsley.

I intend to be very brief, but can I just set out her career history so that you have that, sir.

Mrs Brooks was first employed by the News of the World in 1989, before ...