Secondly, the nature and breadth of the offences under consideration which are listed in our skeleton. These do involve offences in which the surrounding circumstances and the knowledge of others are highly relevant and the proof of an agreement may be made by a matter of inference in relation to relation to conspiracy, for example.
So in these circumstances, it's very difficult, I would submit, for the Inquiry to be sure that any finding of knowledge isn't going to impact on any future criminal proceedings, and I would refer you, sir, to the list of paragraph 8 of our submissions on that point.
The third matter that I wish to raise was that on 12 March, sir, you indicated that you were considering findings that individuals falsely denied knowledge to this Inquiry. Again, we would submit that that is a highly risky area for the Inquiry to embark upon, in particular because this may lead to later arguments that there was a violation of Article 6 if those who were found in the Inquiry's judgment to have lied, effectively, on oath, are then being relied on --