Certainly, sir. That's the second basis on which I put my application. She has been asked by the Inquiry to give evidence on a wide range of issues which are within Module 3, and I say that certainly does bring her within 5(2)(a).
But I also say, on the basis of her experience of modules 1 and 2, that that exposes her to the possibility of criticism by others -- we know that such criticism has been made of her in the past -- and that therefore she is one of those people for whom the protections of 5(2)(c) were designed.
So I put my application on both bases, sir, but of course either would be sufficient.