Sir, yes, exactly. Whether you accept or reject that evidence is obviously a matter for you, but we say this: you asked rhetorically what are you meant to do with this evidence if you find there was evidence of such knowledge as a matter of generality. And I say "generality" because this doesn't, in my submission, offend the mantra, as it's been called. With respect, despite Mr White's delicate entreaties or the rather heavier salvos by Mr Browne, nothing you said by way of example offends this self-denying ordinance. None of the examples that you posited during the course of discussions offends that self-denying ordinance at all, and if Mr Browne is right, for example, in the way he puts it, this self-denying ordinance is more a straitjacket and a blindfold as well, because in effect you are not able to do anything with that evidence.
We say that cannot be right. The position is much more straightforward. If the Inquiry reaches conclusions that it was well-known that these unlawful or improper practices were taking place, or that those who denied knowledge did so falsely, then these are conclusions which can and should be fully addressed in the report. How else, I ask rhetorically, can the inevitable questions which have been raised in the minds of the somebody about the culture, practices and ethics of the press and which, by definition, will not be dealt with in any criminal investigation -- how else, we say, can they be properly answered?
It's not just a matter, we say, of satisfying the public's interest. It's also a matter of ensuring that this Inquiry fulfils its terms of reference under part 1 as comprehensively as possible.