Transcript of Module 2 Public Hearing on 31 October 2023

(10.00 am)

Lady Hallett: Mr O’Connor.

Mr O’Connor: My Lady, our first witness this morning is Lee Cain.

Mr Lee Cain

MR LEE CAIN (affirmed).

Questions From Counsel to the Inquiry

Mr O’Connor: Could you give us your full name, please.

Mr Lee Cain: Yes. Lee Edward Cain.

Counsel Inquiry: Mr Cain, you have kindly prepared a witness statement for the Inquiry, which is up on screen. I know that you are familiar with the contents of that statement, and we don’t need to go to it, but on the last page of the statement there is a statement of truth, stating that you believe that the contents of the witness statement are true, and you’ve signed your name underneath that statement, haven’t you?

Mr Lee Cain: Correct.

Counsel Inquiry: And you did that on 25 August 2023.

Mr Lee Cain: Correct.

Counsel Inquiry: Thank you.

Mr Cain, it’s right, isn’t it, that you began your career as a journalist, but subsequently you’ve worked in communications and public relations?

Mr Lee Cain: Yes, that’s correct.

Counsel Inquiry: In 2016, you worked in that field for the Leave campaign in the Brexit referendum?

Mr Lee Cain: Yes.

Counsel Inquiry: You, I think, were the communications head for the Leave campaign?

Mr Lee Cain: Head of broadcast.

Counsel Inquiry: Thank you. And after the referendum, you worked in various – in communications roles in various different government departments, including working for Boris Johnson when he was the Foreign Secretary between 2016 and 2018?

Mr Lee Cain: It was the latter half of his time as Foreign Secretary, so from – you know, for the final year I think he was there, not the entire time.

Counsel Inquiry: So 2018 at least?

Mr Lee Cain: Yes, yeah.

Counsel Inquiry: When Mr Johnson became Prime Minister in 2019, following Theresa May’s resignation, you were appointed as his director of communications at Number 10?

Mr Lee Cain: Yes, and I’d worked as well with him while he was on the backbenches during that sort of period in between –

Counsel Inquiry: Between 2018 and 2019?

Mr Lee Cain: Yeah, yeah, yeah, before he went back into Number 10 after he left the Foreign Office, into Number 10.

Counsel Inquiry: From July 2019, you held that post of director of communications until you resigned in November 2020, so 18 months or so?

Mr Lee Cain: Yeah, just a bit short of that, correct.

Counsel Inquiry: If we look at your statement on that first page that’s on the screen at the moment, Mr Cain, at paragraph 3 you refer to your position as director of communications and you say that you were “one of the Prime Minister’s most senior advisers”.

As director of communications, tell us in a few sentences, what was your responsibility? Did you in fact have responsibility for communications across government or was it something less than that?

Mr Lee Cain: No, I think it’s – your broad role and remit is to provide political advice to the Prime Minister within the sphere of communications, and it’s quite nebulous to some degree what control and authority you have over the wider government machine. There is an executive director, when I was there, it’s a gentleman called Alex Aiken, who is – who oversees the GCS, which is the Government Communication Service, so that is all of the departments and the ALBs and the budget and the marketing, all that side of things, and the civil servants would normally report in to Alex, and we would work together on, you know, various issues, but as a sort of – it’s quite unclear who is in control of certain elements, but mine would be more the political but also more of a sort of counsellor to the Prime Minister as well.

Counsel Inquiry: You use the word “political” and, as we will see, your role was certainly not limited to, shall we say, presentational matters. You were advising him on what his strategy should be, not just how it should be presented?

Mr Lee Cain: That was broadly correct.

Counsel Inquiry: Give us a sense, Mr Cain, of your personal relationship with Mr Johnson in 2020. You say you’d worked with him for some years by then. Was he a friend of yours?

Mr Lee Cain: I think – he was my boss, so, you know, friend is – you know, would be presumptuous for me to say, but I think we were – we were close, we would speak pretty much every day, and I think I had a good understanding of him. I think part of what I brought to the Downing Street operation, having worked with him for quite a long time, was just a good understanding of how he would react to information and, you know, you get a sort of simpatico, almost, relationship between a special adviser and a – and a principal.

Counsel Inquiry: I want, Mr Cain, to take you through some of the events in 2020 in a reasonably chronological way. If we can look, please, at paragraph 4 of your statement, starting at paragraph 16, you make the point here that although as you say:

“There was an awareness of … Covid-19 … early in January [of that year] … It was only one of many issues discussed inside Downing Street …”

And you say it was a “low priority” at that point.

Then if we can look at the next paragraph, paragraph 17, you talk about various other issues that had some prominence in January and into February: Brexit, 5G, a reshuffle of the Cabinet, HS2 and so on.

So can you give us a sense, then, of where Covid fitted into the hierarchy of concern in January and February of 2020?

Mr Lee Cain: I think it was – it started off from a pretty low base, I would say. You know, in Number 10 there is always a … there is always decisions to be made over, you know, what will be the priority issues. As you can imagine, only the most difficult issues are dealt with in Number 10, because if they were soluble they would be solved at a departmental level. So there is that constant balance of what do we need to focus on at any one time. You can see from the issues that I’ve outlined here, these are all pretty taxing and difficult, you know, issues that deserve the Prime Minister’s and Number 10’s attention. But I think at first Covid, you know, we were informed was – you know, we were obviously having conversations with the Department of Health, the view was the UK was incredibly well prepared, there had been a decade of pre-preparedness, and we were, you know, amongst the best in the world to deal with a pandemic, and it was being monitored closely by, you know, officials in the Department of Health.

So I think it was quite rational at that point to assume it would be a departmental lead, and they would continue to inform us as and when was required, when it needed more attention. I think – and you can see it goes up the sort of agenda in Number 10 as we move through January and into February.

Counsel Inquiry: Yes.

Mr Lee Cain: Clearly, you know, we got that assessment wrong, but I think you can probably see why we made the judgments that we did at the time.

Counsel Inquiry: If we can just look at the next paragraph, please, and pick up on one or two of the things you’ve just said, Mr Cain.

Lady Hallett: Could you try and go a little slower, Mr Cain, please.

Mr Lee Cain: Sorry.

Mr O’Connor: We see there, as I think you’ve explained, Covid, at that stage at any rate, wasn’t even, you say, in the “top five” of concerns, but you go on to say, as I think you’ve just indicated, that officials at the DHSC were confident of the strength of the UK’s pandemic preparations and the general view was that it was something that could be dealt with at departmental level.

Does it follow that, at least at that stage, January/February, you weren’t worried about the priority that was or rather wasn’t being given to Covid?

Mr Lee Cain: I think in January, particularly early January, it felt like, you know, we were getting the balance right at the time. I think as we moved into late January and early February, I think, you know, it’d become clear that we didn’t particularly have that balance. But then I think it becomes – you know, the focus, from what I saw yesterday, was quite a lot on individuals but I think the actual institutions, the organisations within the Cabinet Office and, you know, in the Department of Health, the feedback was, you know: we are well prepared to deal with this and things are in hand.

The question of whether Number 10 should have been kicking the tyres more and checking those issues, if they were in place, I think is a valid one but I think, you know, we were probably complacent to the fact that the work was being done elsewhere, when, you know, obviously, it was not.

Counsel Inquiry: You’ve mentioned a couple of times, and you refer here to officials at the Department of Health providing that assurance, talking about the plans, and so on. Was it just officials or was it the Secretary of State, Matt Hancock, as well?

Mr Lee Cain: The Secretary of State as well was confident on the pre-preparedness. I think in defence of the Secretary of State as well, he did raise the issue early in January, he did speak about it, you know, at a frequent basis, so it’s not like it wasn’t being raised, but there was an assurance that, you know, we were well set to deal with, you know, whatever come our way.

Counsel Inquiry: He raised it but he followed that by assuring those he was talking to –

Mr Lee Cain: Correct.

Counsel Inquiry: – that the plans were in place and that the UK was well placed to address the threat?

Mr Lee Cain: And that, of course, was still the sort of – I say “official” but, you know, it was still the government position even when the action plan was launched in, I think, early March that, you know, we were well prepared to deal with Covid and, you know, we’d had this decade of preparedness, that was language from the action plan. So rolling into March, that was still the government view.

Counsel Inquiry: We’ll come to the action plan in a moment.

Can we look forward, please, on to the next page of your statement and look at paragraph 22. You refer here, Mr Cain, to I think perhaps a conversation, or a contact, anyway, that you had with a senior adviser to Matt Hancock, I think it must have been 31 January, who, according to this at any rate, suggested that perhaps the plans weren’t as well prepared as the assurances that were being given.

Can you tell us a little more about that exchange you had?

Mr Lee Cain: Yes. That was the first time for me somebody had raised questions about pre-preparedness at that point. You know, they mentioned that while the no-deal preparations had helped support some of the government’s planning, they were just concerned about supply chain issues and other such things and were not sure we were in as good a place as potentially was being represented. It wasn’t a sort of panic, it was just someone flagging that maybe this needs a bit more attention.

Counsel Inquiry: As you’ve just said, and as we will see, the mood of confidence lasted long beyond 31 January –

Mr Lee Cain: Correct.

Counsel Inquiry: – so did you do something about this warning that you had been given or not?

Mr Lee Cain: So at that point, and I can’t quite remember the beginning dates, I started to host a sort of cross-Whitehall meeting with the communication professionals, which we would invite departmental heads and arm’s length body heads, like the NHS, to come into Number 10, and just raise the sort of issues that they were getting, because I think part of the problem the communicators were feeding in to me was: we’re being asked a lot of questions by the media and we don’t really have any answers to many of these questions. So we tried to begin then a sort of central hub where at least I was getting the information from source, so to speak, and then we’d try and shake the tyres a little bit – kick the tyres, sorry – in Number 10. I think soon after Mr Cummings as well started a senior team sort of meeting in Number 10, focusing on Covid. I think this was more sort of mid-February, I would – I would suspect.

Counsel Inquiry: All right.

Let me ask you, Mr Cain, about the Prime Minister, about Boris Johnson’s approach at this time.

At paragraph 21 of your statement, you refer to the fact, of course, we know, that he did not attend or in fact chair a whole series of early COBR meetings. You say that he was “focusing his time on the issues outlined” – I think you mean those other priorities that –

Mr Lee Cain: Yes, correct.

Counsel Inquiry: – were just mentioned, don’t you? And he took a two-week holiday. But you go on to say that you don’t now, I think, criticise the Prime Minister for using his time in that way during that period because this was a reflection of the prioritisation that we’ve discussed; is that right?

Mr Lee Cain: Correct. I think also, you know, in defence of the Prime Minister, and there are certainly things that the Prime Minister got wrong, but I think in this early stage he is receiving assurances that, you know, everything actually is being well prepared and we are in a good situation to handle things, and nobody’s sort of setting up the warning flares to him or to the core team so, you know, his behaviour at this point isn’t, you know, irrational, to focus on some of the other issues that, you know, we shouldn’t forget were large-scale, significant issues at the time.

Counsel Inquiry: If we could look back, please, at paragraph 18 of your statement, the last sentence or so, you refer to the fact that the Prime Minister at this stage was stressing the importance of not overreacting in the response, something he said often resulted in greater damage than the initial threat, and that he linked or likened Covid to past viruses, such as swine flu.

Is that something that he said more than once during that period?

Mr Lee Cain: It was. I think he was alive to the fact that previous health issues that had sort of taken hold, you know, in years gone by had proved to be sort of not as first anticipated, and I think he was worried about the government being swept up in a sort of media hysteria, and overreacting and causing more harm than it would otherwise. And again I think that, you know, he has a certain colourful phrase of language sometimes, but I think it was right and proper that we were looking to provide challenge to, you know, what potential options were at that point.

Counsel Inquiry: Now, this is January or so. As we will see, it’s right, isn’t it, that, in fact, Mr Johnson carried on stating that he didn’t want to overreact to Covid for some considerable time after that, even when perhaps other indicators were that this challenge was going to be more serious?

Mr Lee Cain: Yes, that’s correct.

Counsel Inquiry: Let’s just look, if we can, at INQ00048313, please, it’s a lengthy document, page 49 of that. This is, let’s say, a month on, it’s the end of February, and it’s a message from you to a number of people within Number 10, including Boris Johnson, and we see towards the bottom of your message you’re saying:

“Pm should … chair a COBR every Monday with Hancock and officials doing the rest of the week …”

Can we take it then that some time has passed and you are now saying: things are more serious, we’ve got to move up through the gears?

Mr Lee Cain: Yes.

Counsel Inquiry: We can see Mr Johnson’s response, suggesting that he’s keen to fall in with that plan?

Mr Lee Cain: Yes, that’s correct.

Counsel Inquiry: We know that in fact the first time that Mr Johnson chaired a COBR was a day or two after this, on, I think, 2 March.

If we can then move on, please, to page 68 of this document, and zoom in on the bottom, the green message at the bottom, please, here is a message from Dominic Cummings to you on 3 March, so the day after Mr Johnson chaired his first COBR, a month after that January period that we were just discussing, where the message seems to be that Mr Johnson still:

“… doesn’t think it’s a big deal … he doesn’t think anything can be done … his focus is elsewhere, he thinks it will be like swine flu and he thinks his main danger is talking the economy into a slump.”

Now, you very fairly said a moment ago that in January you didn’t criticise the Prime Minister for thinking more about 5G, HS2, and so on. What about in early March?

Mr Lee Cain: I think the Prime Minister was not alone in not doing as much as we should by early March, given the scale and the evidence that was all over our TV screens at the time. So, yes, the Prime Minister should have done more, but I think also, you know, the team around him and across Whitehall should have done more.

Counsel Inquiry: What about you, did you think by early March it was a big deal or not?

Mr Lee Cain: I think so. I think we all thought it was a significant challenge and something that was going to be, you know, the only thing that we were focusing on for an awful long time. I think it was more of, you know, how and what should we be doing at that point. I don’t think there was any clarity of purpose, any really serious outlined plan to deal with Covid at that particular point, and I think that was the core failure, was, you know, what were we supposed to do. You know, I’m not an epidemiologist, you know, that’s not the expertise I would bring. I think, you know, there was the lack of clarity of what we should be doing at that point, really.

Counsel Inquiry: Well, let’s come on to that, Mr Cain, because of course that message was sent on 3 March, and that was the same day, in fact, as the Covid action plan that you’ve already mentioned was published.

You refer to this at paragraph 30 of your statement, on page 7. I think it’s fair to say you’re quite dismissive of this plan in your statement, Mr Cain. You refer to, we can see, about four or five lines down, as:

“… a swiftly prepared document, published to provide some context to the options we had and the thinking behind our covid response.”

But then a few lines further down you said:

“… many in government – including senior officials and politicians – repeatedly referred to the action plan as the actual government plan to manage the pandemic. This was surprising, as the document had little detail and was clearly only useful as a communications device.”

Now, you, of course, were the director of communications. At the time, in early March 2020, did you see it as just a piece of PR, or did you think that it was actually the plan?

Mr Lee Cain: I mean, anyone who reads the document, you know, will see that it’s not a – it’s not a plan to deal with Covid, if you – you know, the – it is a very thin overview of how we may manage the virus if, you know, if it progresses.

I mean, the first element of it was contain, and even by that point I think contain was really off the table. So, you know, it just felt a strange document for people to be referring to as an actual government plan at that particular time, and I think that was an area when, you know, quite a few people in Number 10 were starting to get concerned because if this is the plan, then we clearly don’t have a plan.

Counsel Inquiry: Did you take a part in drafting that plan, or the document?

Mr Lee Cain: I’m sure I would have been involved in – you know, in discussions with it. I can’t quite remember the depth of my involvement.

Counsel Inquiry: Did you have the concerns that you’re expressing now at that time?

Mr Lee Cain: I think I had concerns that we didn’t have – I mean, the document itself was not – that – it wasn’t the issue. The document itself is fine. The purpose for the document was a concern, and I think that’s when there was, you know, challenges, the challenge made of: okay, well, what is our actual plan at this point?

Counsel Inquiry: We can see the last sentence of that paragraph there, you say:

“The fact that many senior figures kept referring to the document as ‘the plan’ [this document that you’ve described as being very thin] shows that in reality the government had no plan to deal with a pandemic.”

Is that something that you felt at the time?

Mr Lee Cain: Yes, it was. I mean, there was – you know, as I say, we talk about flattening the curve, and, you know, there was – there was a strategy, but there wasn’t a plan, which I think is – you know, the detail of how you’re going to do these things was somewhat absent.

Counsel Inquiry: Did you raise concerns about it then?

Mr Lee Cain: I honestly can’t remember the details of the concerns I raised at this point. I think I would have – I would have spoke to, you know, people about – you know, because I think the challenge for us is we were getting information from the media, it would be like, “Okay, what are the fundamental details around that?” And I remember at the time we were not able to provide a lot of that, you know, colour and detail underneath it. So I’d have raised that from a media perspective, but I wouldn’t have been challenging the sort of scientific assumptions, no.

Counsel Inquiry: It was at around this time, and we may hear more detail later today, that Dominic Cummings was demanding to see the plans, calling particularly for the Department of Health to provide these pandemic plans that everyone had spoken so much of. Were you aware that he was making those enquiries, requests, demands?

Mr Lee Cain: Yes, yes, I was. I think at that particular time there was probably only Dominic who was really forcefully being agitated and sort of, you know, kicking – as I say, kicking the tyres quite robustly. I don’t think he got a great deal of information back, if I recall.

Counsel Inquiry: Now, we know that the week that followed the publication of the action plan, the week starting on Monday 9 March, leading up to the 13th, was an action-packed week, there were at least two COBR meetings, and we’ll come on to mention the discussions at the end of that week and the weekend that followed.

First, I’d like to go back to the earlier INQ00048313 document, please, and look at page 22.

Yes, thank you.

So this is a text or a WhatsApp sent by Dominic Cummings to Boris Johnson on 12 March, so the Thursday of that week, where he says:

“We got big problems coming. CABOFF [Cabinet Office] is terrifyingly shit, no plans, totally behind pace, me and Warners and lee/slacky are having to drive and direct.”

I take it that the Lee there is a reference to you?

Mr Lee Cain: Yes.

Counsel Inquiry: Okay.

I don’t think you received that WhatsApp, but do you remember during that week being one of those group of political advisers who were somehow having to drive and direct the government machine? Is that something you would normally expect to have to do?

Mr Lee Cain: I think that the communications side drove a huge amount of the government machine during my entire time. Often, actually, in terms of looking at areas of policy, it’s often comms colleagues that can find the holes and see where the problems are, because you get an understanding of where journalists will look and where things might unravel, so you’re often kicking the tyres.

I felt, in Covid more than anything, actually there were periods when a lot of the policy was having to be drafted by or certainly shaped by communications professionals because there wasn’t really anybody else doing it to any great level, which was a surprising thing to have to be dealing with from my side.

Counsel Inquiry: I want to press you a little bit, Mr Cain, about the extent to which you endorse what Mr Cummings was saying here. He is clearly saying, isn’t he, that the reason that you and others are driving and directing is because those who should be doing it, that is the Cabinet Office, are not. I mean, to use his words, they are “terrifyingly shit”. I mean, do you agree with that?

Mr Lee Cain: I might not quite use the same language but, you know, generally, yes.

Counsel Inquiry: Can you give us a bit more detail then? I mean, who was it, individuals or sections within the Cabinet Office that were failing at that crucial moment?

Mr Lee Cain: I think the point – the point really was nobody quite knew, you know, who was the point person, who was in charge, who should be driving this machine, who is meant to be in charge of co-ordinating of all the policy. If you ask me now who was supposed to be doing that in those early weeks and months, I couldn’t tell you, there was nobody holding their hands up taking responsibility. It would move around and it fundamentally, like all problems, comes into Number 10 and a small group of people who have to make the best of things.

Counsel Inquiry: Just finally on this, presumably the Cabinet Secretary would usually be someone who would take a lead in responding to a developing crisis. Mr Cummings makes no bones about his views about Mark Sedwill’s conduct at this stage. He says he’s:

“… out to lunch – hasn’t a scooby whats going on and his own officials know [that].”

What do you say to that?

Mr Lee Cain: You know, I always had a good relationship with Lord Sedwill and I think he’s, you know, an incredibly talented official. I, you know – I wouldn’t have known where the responsibility came for – who should be doing X in the Cabinet Office, I would be looking probably at a lower level, DG level, maybe someone to lead that. So, you know, I couldn’t really comment on that.

Counsel Inquiry: But overall, is this fair, you may not use those words, you perhaps didn’t have as much to do with Lord Sedwill, as he is now, as Dominic Cummings, but the general theme of lack of leadership, chaos, if you like, is one that you agree with?

Mr Lee Cain: Yes.

Counsel Inquiry: Let’s move on. I want to ask you about the discussions around the first lockdown decision. If we can start by going to page 8 of your witness statement, we see there the heading “Amended strategy – nationwide lockdown”. That’s the description, isn’t it, of the change from the mitigation strategy to the lockdown, suppression strategy that we’ve heard a great deal about in the last few weeks?

We’ve also heard from other witnesses, and we will hear from others, about that series of meetings that took place on Friday the 13th and then into the weekend, where that decision crystallised. Is that fair?

Mr Lee Cain: Yes.

Counsel Inquiry: I just want to ask you really about two issues relating to that sequence of events, and the first, if we look at paragraph 33, you describe there, as part of the reason for this change of tack, what you describe as new modelling overseen by Marc and Ben Warner, showed that unless the government urgently changed course the NHS would be overwhelmed within weeks.

If we just zoom out, again we can see that you make a similar point again at paragraph 34(B), we don’t need to go to it, but you refer to the “new modelling”, which I take it you mean the modelling you describe in paragraph 33.

Mr Lee Cain: Yeah.

Counsel Inquiry: Was your impression, then, that at around this time, towards the end of that week, something had changed in the modelling or the numbers which was telling you something about the threat to the NHS which hadn’t been known before?

Mr Lee Cain: So our assumptions at this particular time, and what we’d been told in the weeks prior, that a suppression strategy wouldn’t work, people could only sort of undergo sort of 12 weeks of this kind of, you know, hard measures. So I think it’s important to understand this, so suppression wouldn’t work. And if we did suppress, as soon as we unlocked we would then see a second spike, NHS overwhelmed. So I think it’s important initially to say that the reason we didn’t even consider or discuss a suppression strategy at that point is because the information was it was just – it wouldn’t work.

Now, on – at this point we’re obviously on the mitigation sort of strategy, which the core of that was a long – you know, the flatten the sombrero, wherever we were –

Counsel Inquiry: Squash the sombrero?

Mr Lee Cain: Yeah, that’s the one – which was a sort of long, elongated sort of peak that would, you know, stay underneath the capacity levels for the NHS and ensure that, you know, when we did alleviate those message – alleviate those measures there would be a certain amount of herd immunity within the system. Important again to reinforce that herd immunity wasn’t a goal, we were told that herd immunity was an inevitability, therefore, you know – but how would we manage that. So that was the plan.

I think what this – I say “new modelling”, I was first aware of – Mr Cummings grabbed me on the Friday and said that, you know, he – I wasn’t in the actual core meeting, I think, that happened that day, I was dealing with something else. He’d grabbed me and said, you know, Ben and Marc had gone off and crunched the numbers and – whether it’s new modelling, whether it’s – they got through, and actually our current plan means that we’re, you know, going to not just go through the NHS capacity level, we’re going to absolutely smash through the NHS capacity level and, you know, we’re going to be looking at, you know, thousands of additional beds that we don’t have and ventilators and all these sort of things, so tens of thousands of people are going to die on this particular plan and the NHS is going to be totally overwhelmed and it’s going to be worse than the scenes that people have seen in Lombardy and elsewhere.

So at that point, you know, the only course was an urgent change of plan, so on the Saturday, you know, he said to me, “We’re going to speak to the Prime Minister, with a very select core team, talking through the issues of the three scenarios I’ve seen”, and …

Counsel Inquiry: I’m going to come to that meeting in a moment, but I want to come back, if I may, to this point about the NHS being overwhelmed, Mr Cain, and I think you’ve explained it very well, which is that you had previously understood that the mitigation strategy, as well as being one that was necessary because suppression wouldn’t work, as you’ve said, but the mitigation strategy could be achieved without overwhelming the NHS, and that this was something new that you were being told in these few days –

Mr Lee Cain: Yes.

Counsel Inquiry: – that actually that’s not right, that the NHS is going to be overwhelmed; is that fair?

Mr Lee Cain: Correct. And I think the lack of data that we had at that point is absolutely staggering in terms of – you know, in most – very early on there was no dashboard, there was no live information flow, no understanding of – you know, we would basically have a meeting where Dominic would ask certain people like Simon Stevens on, you know, how much bed capacity there was and it would be jotted down on a whiteboard. You know, there was no use of serious technology and data to try to get a live sort of minute-by-minute update. So we were very much behind the curve on all those sorts of areas.

Counsel Inquiry: Just sticking with this point about the NHS, Mr Cain, because the evidence the Inquiry has heard is that other people, in particular, for example, on SAGE, the scientists there, it had been apparent to them for some time, for example Professor Medley said that, in his words, “throughout February … it became increasingly clear that NHS capacity in the UK would be overwhelmed”, and that’s under the mitigation strategy –

Mr Lee Cain: Mm.

Counsel Inquiry: – and others gave evidence to a similar effect.

But if that is what they were thinking, and they tell us it was, it seems that wasn’t a message that was getting through to you at the heart of Downing Street?

Mr Lee Cain: No. I mean, obviously SAGE is a very broad church, and, you know, with a lot of different views and different counterpoints, and we would rely a great deal on, you know, Chris Whitty and Patrick Vallance to – which I think both did an exceptionally good job of broadly giving a sort of coalesced view of that broad church. So we would often, you know, take the steers from them, which I think was the right approach.

Counsel Inquiry: Short point, 13 March, or thereabouts, the Warners say, “Look, under mitigation the NHS is going to be overwhelmed”, that was news to you? That was not something that you had heard before?

Mr Lee Cain: Yes, that was news to me at that point.

Counsel Inquiry: The second point I want to take you to, that takes us back to the meeting on Saturday the 14th, which you referred to a moment ago, I think there was a late night discussion between advisers on the Friday and then a meeting with the Prime Minister and others, I think probably more than one meeting, the next day, on the Saturday.

Mr Lee Cain: Yes.

Counsel Inquiry: If we can look, please, at paragraph 35, it’s on the screen, you refer to that meeting. We’ve heard from others about it, and we’ll hear from more people still, but if we look five or six lines down, you say there:

“The collective agreement in the room was that a full lockdown was the only strategy which could suppress the spread of Covid-19, save the NHS from collapse, and ultimately buy the Government more time … ‘flattening the curve’ could only really work as an interim measure until full lockdown could be achieved.”

So is it fair to say, Mr Cain, that there wasn’t a sort of a decision made at that meeting to impose a lockdown, but, as you put it, there was a collective agreement that really that was inevitable?

Mr Lee Cain: Yes.

Counsel Inquiry: As we know, that lockdown was indeed announced but not for over a week. It was on Monday the 23rd, so ten days later, that it was in fact announced.

Looking back, was that a longer period than you would have anticipated as of the Saturday 14 March?

Mr Lee Cain: Yes, but I think you also have to consider, it’s quite a big undertaking to lock down the entire country. You know, there needs to be provisions, there’s got to be guidance drafted, there has to be legislation penned, you have to be able to take people with you, the Cabinet have to have agreement. So there’s an awful lot that does have to happen in that space – all the communications we had to plan. So while it was longer than we would like, I think there is justifiable reason as to why it has taken that time.

Counsel Inquiry: There’s a lot to do, and I’m going to bring you to these points in a moment, you’ve described many of the things that had to be considered and the wheels of government perhaps don’t necessarily turn as fast as you would like, but also it’s important to say that this was a very grave decision to take, and so the damaging effects of lockdown had to be considered as well –

Mr Lee Cain: Yes.

Counsel Inquiry: – is that fair?

Let’s look, please, at paragraph 40 of your statement on page 10. You do say in the first sentence there:

“The implementation of the policy …”

And that’s the lockdown policy, isn’t it?

Mr Lee Cain: Yes.

Counsel Inquiry: “The implementation of the policy was delayed …”

Then you go on in the rest of that paragraph to make very much the point that you’ve already made about the wheels of government turning and all the things that had to be put in place to achieve that decision.

I want to ask you about what is perhaps another theme, though, of your statement, which is that another cause of that delay, if we want to call it that, was indecision on the part of the Prime Minister. If we go to paragraph 42, please, so it’s –

Mr Lee Cain: Yep.

Counsel Inquiry: Yes, we already have it. You say:

“Another challenge was that the Prime Minister would occasionally oscillate between lockdown and other potential policy options (a recurring theme during the critical decision points of Covid and, to some degree, understandable given the gravity of the decisions).”

You say he worried about the impact on the economy, we’ve already seen that, and then you say this in the next paragraph:

“The system works at its best when there is clear direction from No 10 and the Prime Minister, and these moments of indecision significantly impacted the pace and clarity of decision making across government.”

What were the Prime Minister’s concerns around this time, Mr Cain?

Mr Lee Cain: I think they were similar to the ones we’ve raised earlier on, you know: is the government overreacting and will the cure be worse – worse than the disease?

I would say that it’s pretty easy for advisers like myself to say the Prime Minister should have done X, the Prime Minister should have done Y. I do think that, you know, this was probably one of the biggest peacetime decisions, you know, in recent years a Prime Minister’s had to undertake, and it clearly weighed incredibly heavy on him and, you know, I think it’s him and him alone who has to take that decision. So it is understandable that he wrestled with it. I think – so I have few real concerns over this period of time. I think – well, I’m sure we’ll come later to the summer and the second lockdown, where I think it’s slightly more difficult to defend.

Counsel Inquiry: It’s of course right that such a profound decision as locking down, with all of the damaging consequences that would follow, has to be carefully thought through, but it’s right also, isn’t it, that if one adds to that factor, your word, “oscillation”, a degree of inability to take a decision, that can be a damaging thing, can’t it?

Mr Lee Cain: Yes. I mean, indecision can sometimes be worse than the wrong decision in certain circumstances, and I think indecision probably was the theme of Covid that people did struggle with inside Number 10.

Counsel Inquiry: I would like to ask you about a WhatsApp exchange between you and Lee Cain (sic), that took place during this period, the week between Friday the 13th and –

Mr Lee Cain: Sorry, between myself and?

Counsel Inquiry: Dominic Cummings.

So it’s INQ000267920, please.

Lady Hallett: Whilst Mr O’Connor is getting that document up, Mr Cain, do I understand from what you said earlier that you would defend the ten-day gap between the decision taken that there had to be a national lockdown and actually implementing that decision? Because I find that curious.

Mr Lee Cain: As I said, I think it is longer than you would like, but I think it’s important just to emphasise the amount of things that had to be done and the amount of people we had to take with us to deliver a nationwide lockdown. It’s a huge, huge undertaking. And to be honest, my understanding of government, that is government moving at a tremendous speed, which maybe says more about government than other things, but, you know, the machinery did feel like it moved quick for the machinery. But it’s long. You know, it’s definitely longer than you would hope.

Mr O’Connor: Thank you.

Let’s look here, Mr Cain, let’s not worry about the very top message, but the second one down. There is a series of four messages from Dominic Cummings to you, and I think it’s apparent that Mr Cummings is in a meeting with Boris Johnson and Rishi Sunak, and he says, first of all:

“Get in here he’s melting down.”

Before I go on, let’s just note the date. So it’s 19 March, so the Thursday of the week after that Saturday meeting that we were just discussing.

Then he says:

“Rishi saying bond markets may not fund our debt etc. He’s back to Jaws mode wank.”

What does he mean by that?

Mr Lee Cain: The PM at the time would refer to the mayor of Jaws, from the film, who wanted to keep the beaches open. I think he had a routine from previous in his career where he would use that as a joke from one of his sort of after dinner speeches, but he’d sort of said, you know, there’s more harm coming – the mayor was right all along to keep the beaches open because it would have been a long-term harm to the community. So it’s a sort of reference to that.

Counsel Inquiry: Then Mr Cummings says:

“I’ve literally said same thing ten fucking times and he still won’t absorb it. I’m exhausted just talking to him and stopping the trolley.

“I’ve had to sit here for 2 hours just to stop him saying stupid shit.”

And you say:

“I’m exhausted with him.”

There is then a gap for an hour and it may be that there was then a press conference, because you then forward a tweet about someone who perhaps was watching that press conference, saying that they were confused by what Boris Johnson has said at it, and you say as your message:

“No words.”

And then Mr Cummings says:

“what did I say – it’s only a matter of time before his babbling exposes the fact he doesn’t know what to say.”

Now, the first thing to ask you, Mr Cain – I mean, I think it’s apparent from what you’ve already said that Dominic Cummings was someone you’d worked with for some time, you clearly had a close relationship with him. Was this just chatter, was this just banter, if you like, were you just agreeing with him because he was your friend? Or did you actually mean that you were exhausted with the Prime Minister and that you were despairing, if you like, of what he was doing and saying?

Mr Lee Cain: I think anyone that’s worked with the Prime Minister for a period of time will become exhausted with him sometimes. He can be quite a challenging character to work with, just because he will oscillate, he will take a decision from the last person in the room. I think, you know, that’s pretty well documented in terms of his style of operating, and it is rather exhausting from time to time.

Counsel Inquiry: You made the point in your statement, and you’ve made it again today, Mr Cain, that if one is in the position of the Prime Minister and considering such a profound decision as ordering a lockdown, it’s perfectly appropriate to weigh that decision carefully and to think about all of the negative consequences that will follow. But that’s not what you’re describing here. What we’re seeing here, in that critical period, is someone who simply can’t make up their mind and with whom two of his closest advisers are exhausted.

Mr Lee Cain: I mean, so I think there’s a – that’s correct. I think there is a difference between weighing up the evidence and, you know, looking for challenge on policy issues and being sure that we are making the right decision. I think issues like the – if I remember correctly, the tweet there from Steve Swinford was regarding the press conference where I think he announced that we were going to turn the tide within 12 weeks, which we were frustrated by, because I think the whole point of the suppression strategy, Chris and Patrick had been very clear that the suppression strategy would be a long-term endeavour. We were looking at, you know, probably a year where we were going to have to do pretty hard measures, alleviate them a little bit, go back into hard measures again to keep control of the virus until, you know, we were in a situation where a vaccine or another method came online, testing, that would allow us a route out.

But we all knew it was a long-term challenge. And I think from a communications point of view, the Prime Minister indicating that, you know, basically we could be finished with Covid in 12 weeks was unhelpful because it set a very unrealistic – a very unrealistic sort of expectation of where the nation needed to be, because it’s all about compliance at this point and being honest and transparent with the public about what to expect and how to expect it.

Counsel Inquiry: Mr Cain, you say it was unhelpful. One might think that was quite a well-chosen word from the communications world. Mr Cummings is clearly expressing the view to you at the time, in the context of that, that he doesn’t think the Prime Minister is up to the job. Did you agree with that?

Mr Lee Cain: I think at that point – and that’s quite a strong thing to say. I think what will probably be clear in Covid, it was the wrong crisis for this Prime Minister’s skillset. Which is different, I think, from not potentially being up to the job of being Prime Minister.

Counsel Inquiry: What do you mean by the “wrong crisis for this Prime Minister’s skillset”, Mr Cain?

Lady Hallett: Could we use just straightforward English, Mr Cain, please?

Mr Lee Cain: So I think he’s somebody who would often delay making decisions, would often seek counsel from multiple sources and change his mind on issues. Sometimes in politics that can be a great strength. I think if you look at how he navigated Brexit, he allowed others to make decisions and, you know, jumped in at the last minute, can take political advantage.

If you look at something like Covid, you need quick decisions and you need people to hold the course and, you know, have that strength of mind to do that over a sustained period of time and not constantly unpick things, because that’s, you know, where the problems lie. So I felt it was the wrong challenge for him, mostly.

Mr O’Connor: All right.

Let me move on, Mr Cain, I want to ask you a few questions about the various communications strategies during the pandemic.

Lady Hallett: Just before you do, Mr O’Connor, the meeting on 14 March, everybody at the meeting – and the Prime Minister at the time was there, so Boris Johnson was there?

Mr Lee Cain: The Saturday meeting I think was quite inner team, so I can’t remember if the CMO and CSA were there, but it was more the private office, political advisers. The following day was a wider cast list, if I recall, for a subsequent meeting on it.

Lady Hallett: But it was agreed that we would have to go into national lockdown?

Mr Lee Cain: Broadly. I mean, it was agreed that we needed to suppress and we need to suppress urgently, and then it was a case of how we do that, yes.

Lady Hallett: What I want to know is: did the message then go out to all go government departments: basically we’re in war mode, you’re going to have to start working out how we’re going to cope with a national lockdown, how we get it into place. Was that the message that went out or was there still oscillation in the days that followed as to whether we were going into a national lockdown? Had the decision been taken that weekend or not?

Mr Lee Cain: The decision can only be taken by Cabinet, so I think it had to go through Cabinet processes before that could move forwards. But I still think there was a certain degree of uncertainty of exactly what it would look like.

Lady Hallett: Presumably a Cabinet meeting could be called very quickly, in times of emergency?

Mr Lee Cain: Yeah, I think it could, yes.

Lady Hallett: Was it?

Mr Lee Cain: I can’t remember when – I think it was in days, but I can’t remember how quickly.

Lady Hallett: Sorry to interrupt, Mr O’Connor.

Mr O’Connor: No, my Lady.

As I say, Mr Cain, I want to move on and ask you about some of the communications exercises during the pandemic, and I think if we can turn, please, to page 22 of your statement, you describe there – you talk about the “Stay Home, Protect the NHS, Save Lives” campaign, which I’m sure probably everyone in this room will remember.

If we look at paragraph 98 of your statement, you refer to that campaign having been conceived by what you describe as a small group of political advisers, including you, and some – one or two people from a digital creative agency, who, between you, put that campaign together.

Then at the next paragraph, paragraph 99, you refer to the fact that it has been well – it was well regarded at the time and people have praised that campaign subsequently.

I mean, do you personally hold the view that that was a successful and effective campaign?

Mr Lee Cain: Yes, I think the only critique we got that it was too successful, which – and, you know, subsequently people – some behaviours were, you know, hard to remove people out of. But I would push back on that really and say, you know, it was – it did what we needed it to do.

Counsel Inquiry: I want to ask you a little bit about the middle section of the campaign slogan, the “Protect the NHS”.

Mr Lee Cain: Mm.

Counsel Inquiry: We know of course, we were discussing it a few minutes ago, that the need to stop the NHS being overwhelmed was one of the triggers for the lockdown, but it’s also right, isn’t it, that, even at that very early stage of the pandemic, it was known that certain groups within society – elderly people, the disabled, people in care homes, and so on – were at a heightened risk from Covid? Wouldn’t it have been better to, instead of saying “Protect the NHS”, come up with some language to encourage people to protect those people who were at the greatest risk from Covid?

Mr Lee Cain: Erm, no, I think – in all due respect, you know, I don’t think so. I think that this was about ensuring we had maximum compliance. It was about ensuring that, you know, we were stopping the spread of the virus. That is the best way to protect everybody. The NHS has a very sort of special place and significance in sort of, you know, in British culture, it’s very powerful, and I think, you know, the slogan, as it stands – you know, as I say, you know we had sort of – we were looking at numbers of 94% of the public understood it and taking part and the compliance rates show that it was very successful.

As with anything there’s always things you can do better but I think, as a campaign, as a call to action, delivering what we needed to do, I genuinely don’t think it could have been much better.

Counsel Inquiry: Given that you decided to use the reference to the NHS in the slogan, did you consult with the leadership of the NHS about how they should be referred to and the fact they were going to be included in this slogan?

Mr Lee Cain: I didn’t directly have conversations with leaders of the NHS. The government machine will obviously keep everybody informed as to what the plans are and, you know, what we are communicating, that it will always go through, and no concerns were raised to me at any time.

Counsel Inquiry: Are you aware that subsequently, and I think during the pandemic, the NHS leadership did criticise this campaign, in particular because the concept of protecting the NHS created a risk that people would delay seeking medical treatment that they needed for other urgent non-Covid-related health problems, such as sort of heart problems or cancer or those sorts of matters.

Did you know that that was a concern that the NHS had and, frankly, I think that their view was that they weren’t consulted on using that term?

Mr Lee Cain: Only after, you know, I’d left government, I think that had been brought to my attention. I would – again, I would strongly stand by the campaign. I think, you know, our overarching goal was to protect and save as many lives as possible, and we believed that this was messaging and a campaign that did that. I think if we look at why people weren’t going to hospital at the time, it’s because they were looking at what the scenes were in Lombardy and elsewhere and were frightened. I think there’s a false perception that the messaging caused fears in people, but if you actually look at the metrics of where fear spikes, fear spikes when the virus spikes. People are very rational, they can see when they’re most at risk, and they look to protect themselves in, you know, very sensible ways.

Counsel Inquiry: Mr Cain, one of the reasons people weren’t going to hospitals is because your campaign was telling them to not use the NHS at that time because it was needed for the Covid pandemic; isn’t that right?

Mr Lee Cain: No. And, you know, I don’t think that is what the campaign is telling people to do, and I think we were – we were clear throughout Covid, in interviews and other forms of messaging, that obviously people with serious health concerns should seek help and go to – you know, to – whether it’s emergency care or wherever it is, as they would previously do so.

What we were highlighting – that, you know, there was a broader need for people to break contact. That was in order to, you know, provide care for those who needed it and that would fundamentally save lives. And I’m very proud of what the team achieved during that period.

Counsel Inquiry: We have evidence that, in fact, the NHS were so concerned about the impact of this messaging that they had to develop their own communications campaign, as it were, encouraging people themselves to come back to hospitals with non-Covid-related issues. Were you aware of that? It was called the “Help us help you” campaign.

Mr Lee Cain: So, we would have regular meetings with senior communicators from NHS England and from Department of Health. Never was this issue raised at any time with myself directly. And, as I say, we would have these calls every week, if not multiple times a week. And I would also say that it’s of course right and rational that the NHS should look to do sort of micro-targeted campaigns to those who may be at greater risk. That’s of course very wise.

But our approach, you know, in Number 10, is to try and have the maximum benefit as possible and save as many lives as possible. So, you know, if you’re looking to move into more nuanced spaces, you know, it obviously breaks down the overarching message and you could have wider negative contexts of, you know, if we had lower compliance, the negative outcomes overall would be worse. So it’s sometimes, you know, not making the perfect the enemy of the good.

Counsel Inquiry: I’m going to move on just to a related subject, Mr Cain. We have heard evidence about the SPI-B committee. The Inquiry heard evidence from Professor Rubin, who was one of the co-chairs of that committee, and we’ve also seen their terms of reference when they were set up by SAGE, which emphasised the importance of public messaging, and one of, if not the most important part of, their role was to provide the government with behavioural science advice, including in relating to public messaging.

To what extent did you, as the director of communications during this period, utilise the expertise of SPI-B when formulating government messaging?

Mr Lee Cain: I think the broad view was slightly questionable of some of the insights of SPI-B. So I didn’t have a huge amount of dealings with them at that particular point, and the sort of dealings I did, I didn’t find particularly helpful. We had a fast research loop that we would do via focus groups, via polling, things that we’d seen – you know, we’d used pretty readily in political campaigning that was incredibly effective. Often they would be slightly different places to where SPI-B, you know, were, and I would trust the judgement of the campaigners and the messaging people we used, which were some of the best in the world, if not in Western Europe, in terms of, you know, building the sort of messaging that we needed.

Counsel Inquiry: The evidence that the Inquiry has received from Professor Yardley was that SPI-B was not consulted about the “Stay Home, Protect the NHS, Save Lives” campaign, nor about its successor, “Stay Alert, Control the Virus, Save Lives”, nor about “Eat Out to Help Out”, nor about the “freedom day” slogan.

So is it, in fact, the case that you simply didn’t take their advice on any of these major campaigns during the pandemic?

Mr Lee Cain: I think some of those slogans were ones that, you know, I myself didn’t agree with and weren’t particularly consulted on, so it’s slightly different, but I think on the main government messaging we – as I say, I’ve seen the critiques of the “Stay Home” messaging, the critiques that we shouldn’t use, you know, some of the fear messaging, and they were at odds with the feedback we were getting from our own research, which, you know, I think the evidence of compliance and other things would suggest were correct.

Counsel Inquiry: Mr Cain, one of the functions of this Inquiry is to think about future pandemics. We know that SPI-B or a similar committee had existed in, I think it was, the 2009 swine flu epidemic. It was – SAGE thought it was a useful body to reconstitute in 2020, as I’ve said, with messaging being one of its most important focuses.

I mean, is your evidence to the Inquiry that when the next pandemic takes place, we shouldn’t bother with seeking advice from behavioural scientists about – at least about public communications and messaging, we should just rely on focus groups and experts in the communications field?

Mr Lee Cain: I think that we should seek – we should seek advice, wherever we can get it, but I think we should also say that, you know, the behavioural science isn’t always correct. I think, you know, there’s different kind of messaging challenges. I think I spoke regularly with Chris Whitty and Patrick Vallance throughout this period, I would inform them about, you know, a lot of the communications. They would provide feedback. At no point, you know, did they say, you know, we should be taking on board some of the SPI-B advice that was provided. And, as I say, the things that I did see I disagreed with.

Now, if I got them – those things wrong, then that’s my responsibility, but I fundamentally believe the messaging and the communications that we had were the right ones. I think the team who were part of those did an exceptionally good job and I think, you know, there is – you know, government has some absolutely incredibly talented communicators that I was proud to work alongside.

Counsel Inquiry: It’s still quite a striking thing though, Mr Cain, and you as director of communications had at your disposal a committee of scientists, of behavioural scientists set up to assist with messaging, and I think the evidence you’re giving is not that you engaged with them and had discussions with them and, in the end, perhaps disagreed with them but that you just cut them out of the loop?

Mr Lee Cain: I – you know, I think it’s wrong to say we cut them out. They – you know, I basically didn’t have the discussions with them, nobody approached me with advice or feedback. The feedback you’re saying, nobody came to me with that feedback at the time. I was hosting, you know, numerous messages, and the evidence that was presented to me, which was normally via email form or, you know, through – was at odds with the research that we were doing. And I think, you know, I would say to look at the outcomes, to look at the compliance, look at the evidence of the strength of the campaigns, and I would stand by those campaigns being incredibly effective. As I say, the “Stay Home” campaign, you know, was seen as one of the most powerful public health campaigns in modern memory, with 94% of people understanding and complying with the messages that it sent. And that framework it gave us, I think, went a long way to saving a significant number of lives, and I’m very proud to have been part of it.

Counsel Inquiry: Mr Cain, I’m going to move on to just a couple more issues around communications.

Firstly, I want to ask you about the extent to which you considered communications across the UK as opposed to England. Of course, we’re focusing on 2020, and the messaging during the pandemic. Did you regard it as your role to be thinking about communications across the UK, or communications in England? Or did you not really think about the difference between those two things?

Mr Lee Cain: I think we would, you would broadly look at, you know, across the UK and, you know, that is where I think part of the work with Alex Aiken, who focused a lot more on the paid advertising, for example, where I think that – you know, your paid media is slightly different from your earned media. The earned media we would have would focus predominantly more on the Prime Minister and England, where the paid media would be more of a UK-wide approach, which Alex would lead and push through.

The challenges I assume you’re moving to actually become more about politics than communications, quite often, and I think that’s where the challenges in this space really came.

Counsel Inquiry: Well, let’s look at a document, Mr Cain, it’s INQ000214168, please. I know you’re familiar with this document. The context is, is it not, that, as the first lockdown was being eased, at least in England, and the “Stay at Home” message that we were just discussing was being replaced in England by the “Stay Alert” message, there was push-back at least from Scotland and Nicola Sturgeon’s government to say they didn’t want that message to be used in Scotland because it didn’t, in fact, reflect their public health decisions that they were taking in Scotland; is that a fair summary?

Mr Lee Cain: Correct.

Counsel Inquiry: What we see here is an email responding, if you like, internally, so it’s from Alex Aiken, who you have mentioned, to Martin Reynolds, but we can see you’re copied in on the response just above it, describing this problem and, if we cut down to the headline, which is at point 9 in bold:

“Recommendation: …”

Brackets, for ourselves, despite the objections from Scotland:

“… Run the campaign nationwide and work with devolved administrations to deliver most affective campaign and deconflict if necessary.”

Was that what you understood –

Mr Lee Cain: Yes.

Counsel Inquiry: – the policy to be?

Mr Lee Cain: So there’s different things. We’re talking about the messaging and the policy. This is fundamentally a question of politics and policy, in the sense of the devolved governments had been clear that they wanted the harder measures for a longer period of time, while, you know, the UK – sorry, the PM wants to lift measures and move into a slightly different stage. That is a very difficult conflict, I think, for communicators generally when there’s divergence in policy direction, that does make life more difficult. But the crux of it was about politics and about policy.

Counsel Inquiry: It’s not that difficult, is it? I mean, surely the answer is, if the Scottish Government, for example, wants to run one type of message and the English or the UK Government wants to run a different message in England, then you simply don’t buy the advertising space in Scottish newspapers and, if Mr Johnson is giving a press conference that’s going to be broadcast throughout the UK, he makes it clear that the message is only one for England. I mean, is that difficult?

Mr Lee Cain: I agree, and I think that sort of moves broadly into where we ended up with the sort of regional spaces but I think in terms of the – I think the PM at the time was concerned about the politics, as well, of the issue, with a lot of pressure coming from the media at that point, that, you know, the measures were too hard and they should be alleviated, and I think this was a starting point of some of that conversation. But, you know, Alex would have led on the paid campaign work in this sort of space, as you can see from the email.

Counsel Inquiry: The appearance from point 9 there, Mr Cain – and you were, as you’ve said, involved in the politics as well as the communications – the appearance is that the Scottish Government’s objections were going to be ignored and that the campaign was simply going to be run and that they would try and smooth around the edges after it had been run, which would seem to be disregarding the views of the Scottish Government in a sphere that they had responsibility for.

Mr Lee Cain: Well, yeah, that’s Alex’s advice on the piece, it’s not mine.

Counsel Inquiry: Is it advice that you agreed with?

Mr Lee Cain: To be honest, I can’t remember what position I took on that at the time.

Counsel Inquiry: Let me move on, Mr Cain.

Back to your statement, please, paragraph 78 on page 18. You refer here to the press conferences with the Prime Minister and, as we will all remember, a sort of varied cast of people who appeared on those press conferences, which, at least for a time, were daily events, and you are here – I think there’s a wrong word there:

“The popularity and impact of the press conferences should not be [underestimated].”

I think you mean. You were saying that they were very important –

Mr Lee Cain: Yeah.

Counsel Inquiry: – events in the communication cycle; is that fair?

Mr Lee Cain: Correct.

Counsel Inquiry: We have been told, Mr Cain, by Anne Longfield, who was the Children’s Commissioner of England at the time, that she, her words, “constantly asked” the PM and others to have some form of briefing or press conference “especially for children”.

It was something, she says, that they had done in many countries and her view was that it was very important for children to know that politicians were thinking of them.

Were you aware of that lobbying that she was doing, and do you know why a special children’s press conference or briefing was never held?

Mr Lee Cain: I was not aware. I think it’s a good idea. It’s probably something we should have done. I think there are many things we probably should have done. But in the heat of everything there are – you know, will always be gaps, but I think it’s a – it’s a good idea.

Counsel Inquiry: If she is right that she was constantly talking to the Prime Minister about it, isn’t it something he might have mentioned to you?

Mr Lee Cain: I mean, I don’t recall him mentioning it to me.

Mr O’Connor: All right.

My Lady, I’m about to move on to another topic, I wonder if this is a good moment to take a reasonably short break.

Lady Hallett: Yes, of course.

I hope you were warned, Mr Cain, that we take a break every so often, for everybody’s sake. I shall return at half past.

(11.13 am)

(A short break)

(11.30 am)

Lady Hallett: Mr O’Connor.

Mr O’Connor: My Lady.

Mr Cain, one more question, if I may, on communications before I move on.

The “Stay at Home” campaign that we were discussing before the break created, did it not, an obvious problem or a risk in the field of domestic abuse, in the sense that those who were victims of domestic abuse and who, for obvious reasons, would not want to stay at home, would feel that they were being instructed nonetheless to stay in an environment where they were suffering abuse?

Were you aware during the pandemic of suggestions that not enough was done by the government to speak to those victims and to make it clear that they were not expected to stay at home if they were suffering abuse?

Mr Lee Cain: I think if I recall there were questions raised by members of the media, and I think we tried to do a lot of the sort of microtargeting of messages in the daily press conferences. It was a time where the media was coming, aired their questions, and then we could talk directly to people in huge numbers in their own homes about specific issues. And that is broadly how, I think, we used to tackle a lot of those things. There would also be individual departments that would lead on those issues that again, as we saw earlier on with the Department of Health, that would target certain groups and certain sectors. They wouldn’t necessarily come to my desk on sort of those sort of scale communication issues, they’d often be held departmentally or we’d deal with them, as I say, by the press conferences.

Counsel Inquiry: You mention press conferences and I think one of the concerns at the time was that, although Priti Patel, Home Secretary, was vocal about this issue, it was something that the Prime Minister, Boris Johnson, either didn’t mention at all or certainly didn’t mention enough during his press conferences when he had the opportunity to send that message?

Mr Lee Cain: I think it would be unfair to criticise the PM on that particular issue. I mean, it would depend on if he’d been briefed, if there was something particularly we were trying to get across. There’s obviously a lot of other issues at all similar times, and again we’d expect it to be a – you know, more of a department-led issue. I think, you know, Priti Patel did press conferences from time to time herself, and again, you know, Chris and Patrick would also reinforce some of those messages at different times, as well as the, you know, microtargeting.

Counsel Inquiry: Looking back on it now, do you think more should have been said about this issue during the pandemic?

Mr Lee Cain: I think there’s a range of issues that we could have gone into in more detail and tried to be more targeted, but I think we did genuinely the best we could with a lot of those issues, I think, because there was a huge amount to communicate to so many groups, you know, it was a challenge to get your arms around it all from Number 10.

Counsel Inquiry: All right.

I’m going to move on, Mr Cain, although not too far in terms of themes, to talk about some of the parts of your statement where you refer to a lack of diversity amongst core decision-makers and some of the consequences of that.

So if we can go, please, to page 28 of your statement, at the top, it’s 121(d), the top paragraph, you refer there to your own initiative in pushing for the bubbles policy for families, to accommodate, if you like, families that had split and how they would deal with lockdown. Towards the end of that paragraph you say that:

“One of the challenges you face when you work on policy is the dynamic of the room, which in this case was white and middle aged. They were doing their best, but without diversity, some policy decisions slipped through the cracks.”

Do we take it that this particular one about split families was an issue that you felt was at least in danger of slipping through the cracks?

Mr Lee Cain: Yes, correct.

Counsel Inquiry: Let’s go back, please, to the page before, because you refer there to another policy, or issue, the free school meals issue, at the bottom. If we pick it up, the third line down, you say:

“[You] remember asking the Cabinet Room of 20 people, how many people had received free school meals. Nobody had – resulting in a policy and political blind spot.”

And you describe the government’s resistance to Marcus Rashford’s campaign as a “huge blunder”. Can you expand on that?

Mr Lee Cain: So I think, you know, firstly on the diversity point, I think, you know, it’s quite clear that there were challenges of gender diversity, socioeconomic diversity and ethnic minority diversity at the very top of the, you know, the PM’s top team, and I think, as I say, you know, this does have a challenge, because people have their own lens through which they view problems – through no fault of their own, you know, it’s just a world view or experiences that they’ve lived. But I think with the Marcus Rashford – you know, it was a fantastic campaign, it was one that was obviously gaining huge amount of media attention, but there was a view from the PM at the time that, you know, we were spending huge sums of money and, you know, we needed to have a bit more restraint on public finances.

Now, this was a – of course, you know, it was sensible of him to start looking at public finances and look at where we could, you know, develop slightly more rigid structures, but, you know, I said to him at the time, you know, I don’t think hungry children is the place to start, just from, you know, a moral or political standpoint. It was the wrong decision.

But I just think there was a lack of understanding of what families were potentially going through at that time because – and, you know, this is solely just because I think people don’t really – have never lived it, they don’t appreciate it and they don’t appreciate those challenges. So I think this was just one example, you know, of many where, if you had more diversity in the room, and again it’s a range of diversity, I think it would improve decision-making and improve policy making.

Counsel Inquiry: Can we look at a document on screen, please, INQ000273901, page 164. I know you’ve seen a copy of this, Mr Cain. This is a transcript of one of the notes that Patrick Vallance made during the pandemic. We can see it was in September 2020, and it relates to another issue that perhaps is in a similar category. It’s the issue of providing funding, financial support to those who were on low wages, in order to make it financially viable for them to isolate.

We can see Patrick Vallance’s record is “Cx”, that means Chancellor, doesn’t it?

Mr Lee Cain: Yes.

Counsel Inquiry: “[Chancellor] blocking all notion of paying to get people to isolate, despite all the evidence that this will be needed.”

Let me ask you two questions. One is: were you aware of this resistance, perhaps a bit like the free school meals issue, to providing this function; and, secondly, is it, in your view, a similar point, where an issue fell through the cracks because of a lack of diversity in the room?

Mr Lee Cain: I think it’s difficult without knowing the full context of this, because it’s not something I can fully remember from the time to look at, you know, the reasons why the Chancellor may be blocking. It could well be very valid on asking for more, you know, evidence and data, you know, to the costings and all other such things you would expect from the Chancellor.

The Chancellor, who, I think we should also reflect, did bring in a furlough scheme that was, you know, incredibly generous and did provide, I think, for an awful lot of people. And of all the policies that we did at that time, the feedback I got more than anything else was of furlough and what a huge success that was. But on this particular issue, I don’t remember, you know, in isolation.

Counsel Inquiry: Okay.

Let me move on, then. In fact, sticking with this time period, if we can look at the bottom of page 25 of your statement, please we see the title “Coming out of lockdown”, and so we’re in the summer of 2020, and it’s at paragraph 116, you describe a tension between some advisers, officials and ministers who wanted to take a slow, cautious approach, and others who wanted to unlock much more quickly, and get back to how life had been before the pandemic had started.

This is a theme in this part of your statement, how those tensions worked out.

In the following paragraphs, I won’t take you to them, but you describe, is this right, that the more aggressive approach of unlocking quickly was one that was favoured by the right wing of the Conservative party and also in the printed media, The Telegraph is an example you give; is that right?

Mr Lee Cain: Yes.

Counsel Inquiry: But you also say that your own research showed that the general public mood was actually more towards the cautious end of the spectrum, the opposite to the view held by, on your understanding, the Conservative Party, and this was all fed into that tension that you describe at the bottom of that page that we’re looking at; is that fair?

Mr Lee Cain: Yes.

Counsel Inquiry: Was this one of the factors which underpinned the Prime Minister’s indecision later in 2020, September/October time, about whether or not to have a circuit break lockdown?

Mr Lee Cain: Yes, it was. I think the Prime Minister was torn in this issue. I think, if he would have been in his previous role as a journalist, he would probably have been writing articles saying we should open up the beaches and, you know, how we should, you know, get ahead with getting back, and I think he felt torn where the evidence on one side and public opinion – and scientific evidence was very much “Caution, slow, we’re almost certainly going to have to do another suppression measure, so we need to have that in mind”, to, you know, media opinion and the bulk – certainly a rump of the Tory party was pushing him hard in the other direction. So I think that was probably part of the reason for the oscillation, because, you know, the rigid measures were very much against the sort of what’s in his sort of political DNA, I guess.

Counsel Inquiry: In your statement you refer to two schemes, two policies, over the summer of that year, the back to work policy and the “Eat Out to Help Out” policy, which were both trying to send the, shall we say, “business as normal” message. You’re very critical of both of those policies now. Were you critical of them at the time?

Mr Lee Cain: Yes.

Counsel Inquiry: Can you tell us what you said and who you said it to?

Mr Lee Cain: So, I think, you know, I and particularly the other communicators as well would just find it very, very difficult, because a huge part of what our role and responsibility is – at that point is: what are we signalling to the public?

There’s a huge amount of focus that goes on particularly in Westminster, which is, you know, what is being said as apart from, you know – sorry, how – how things are being said rather than what it is you’re trying to communicate. And at this point of developing policy, we are indicating to people that Covid’s over, go back out, get back to work, crowd yourself onto trains, go into restaurants and enjoy pizzas with friends and family, you know, really build up that social mixing.

Now, that is fine if you are intent on never having to do suppression measures again, but from all of the evidence we were receiving, from all of the advice that we were receiving, it was incredibly clear we were certainly going to have to do suppression next again. We knew that all the way through, that was the strategy from the start.

So to then move forward and say “Hey, we’re going to get back into work” when business wasn’t even asking for people to come back into work, in fact they were encouraging their employees to stay at home still, you know we developed all of these tools for remote working, but it was – government seemed to be on its own demanding people go to work when, you know, the research we had was saying people, you know, were still quite cautious. Businesses were feeding back they didn’t want to do it, the scientific opinion was people didn’t – you know, that we were going to have to have another lockdown. So to me it made absolutely no sense whatsoever why we were talking about getting everyone back to work. And that was the stories that ended up being on the front pages, which was a cause of great frustration.

Counsel Inquiry: We know that there were calls for a circuit breaker lockdown from September of that year. Were you a supporter of those calls at that time?

Mr Lee Cain: I was, yes.

Counsel Inquiry: We also know that that didn’t happen, at least not in the first place, and that instead there were rules around tiering throughout the country and the rule of six, and so on.

Can we look, please, at INQ000048313, page 54.

This is an exchange between you, Simon Case and Dominic Cummings, Mr Cain. It’s one the Inquiry has seen before. It starts with Mr Cummings talking about discussions with ministers being “moronic”, they don’t understand what they’re talking about. Mr Case agrees and you say “This is embarrassing”. Mr Cummings says:

“By weekend he’ll be saying ‘6 is untenable a total disaster we’ve got to get everyone back to work’.”

Was that a reference, do you think, to the rule of six or it’s not quite –

Mr Lee Cain: I think there was a discussion at the time we were going to do two households, a rule of six, there was a sort of broad policy conversation. So I assume it’s around those issues, yes.

Counsel Inquiry: Just reading down, we see references then to, in fact, Mr Johnson did change his mind again rather sooner than perhaps had been anticipated. You say:

“What’s his issue? Xmas cancelled stuff?”

Is this another emergence of the – I think your word was “oscillation”, but the indecision that we were discussing before the break?

Mr Lee Cain: Yes, and I think this point was – probably these sort of months was when it was at its most pronounced because he did not want to do any harder measures, he didn’t want to go back into suppression. But I think most of the advisory team knew that was an inevitability, and I think the crucial thing was – I think you can forgive some of the errors in the first lockdown because things were moving at incredible speed, we were, you know, sort of building the train tracks as the train was moving in that first period, which meant it was – you know, there was inevitably going to be mistakes but I think we tried to learn as best we could.

I think by the time we moved into this later period, I think the rump of Number 10 felt that, okay, we’ve learned all these lessons from the first period of lockdown, why are we now trying to ignore them again and repeat the exact same mistakes, which will be: too slow to act, a denial of the measures that are going to be necessary to control the virus, moving too late, and allowing the R to get, you know, out of control, too much virus, which means a longer lockdown in the end, more harmful to the economy, more harmful to health outcomes.

So I think, as you see in this, there’s a real frustration that we weren’t just gripping things and putting in the lessons that we’d learned.

Counsel Inquiry: Frustrations which here you’re sharing with Mr Cummings and Mr Case. Did you share them with the Prime Minister?

Mr Lee Cain: Frequently.

Counsel Inquiry: At the bottom of this page, Mr Cain, we see a reference that you make to Matt Hancock. You say:

“Hancock has got to go. Joker.”

And Mr Cummings says:

“Yep. And liar.”

It’s right, isn’t it, that there were discussions at around this time as to whether Mr Hancock and indeed other ministers should be losing their jobs?

Mr Lee Cain: I think there was – there was probably more focus on the Health Secretary than others. There was a general view, I think probably most robustly pursued by Mr Cummings, which was that we weren’t getting all the accurate information from the Health Secretary in meetings, and that, again, was causing frustration.

Counsel Inquiry: Let me ask you to look at another document, please.

If we could have up on screen INQ000283369, page 38.

Now, it’s a reasonably lengthy exchange, although I hope to ask you about it fairly quickly, Mr Cain. It’s an exchange between you and Mr Cummings and Mr Johnson on 23 August, so a week or two before that WhatsApp that we were just looking at. We can see it starting with Mr Cummings saying he doesn’t think it’s “sustainable for GW”. Who would that be?

Mr Lee Cain: Gavin Williamson, I would assume, it –

Counsel Inquiry: So, it’s “not sustainable” for Mr Williamson to stay at the Department for Education.

“Think lee needs to brief reshuffle after SR …”

Is “SR” summer recess?

Mr Lee Cain: Spending review, I imagine.

Counsel Inquiry: “… ASAP. Will get people in line. Focus minds …”

And so on, talking about a reshuffle.

He then repeats another message, saying it’s going to be turbulent but “We need a path through” it.

Then a message from Boris Johnson saying he agrees but it’s fatal – it will be fatal to brief the Cabinet about the upcoming reshuffle.

Then a longer message from Dominic Cummings emphasising the position, and perhaps – I’m going to ask you about this – giving us some clue as to the state of the government at the time. He says:

“… [it’s] a big mistake … not sustainable – if you don’t get the [Cabinet] back into line you will have months more of the mayhem briefing and leaking – this has seriously damaged your authority – you need to get this back, you need to read the riot act to [the Cabinet] and SW1 shd know there’s a reshuffle coming between [the spending review] and Xmas. At the moment the bubble thinks you’ve taken your eye off ball, you’re happy to have useless fuckpigs in charge, and they think that a vast amount of the chaotic news on the front pages is coming from no10 when in fact it’s coming from the Cabinet who are [feral]”, and so on.

And then the last paragraph:

“I also must stress I think leaving Hancock in post is a big mistake – he is a proven liar who nobody believes or shd believe on anything, and we face going into autumn crisis with the cunt still in charge of the NHS still – therefore we’ll be back around that cabinet table with him and stevens bullshitting again in [September]. Hideous prospect.”

I’m going to come back to that but let me just go to one or two other of these messages.

Just going on, there is a series of responses from Mr Johnson talking about whether sacking people really solves things, quite what the timing of this reshuffle should be.

Then if, we can look at the top of page 40, please, you contribute, you say:

“Problem leakers – Hancock, Grant, Wallace, truss. There are other second order ones but these four have caused real problems this year.”

Then you say that you agree with domestic policy agenda:

“We do need to up the fire power in key areas … Whenever we do a reshuffle it should be bold and filled with those you are convinced will deliver for you …”

So two questions, Mr Cain.

The impression created is of a number of key Cabinet ministers, whether because they’re leakers or because Mr Cummings has expressed such strong views about them, who weren’t trusted as part of the government. Choose your adjective: is it chaos? Is it dysfunction? Help us understand whether things were really as bad as are painted in these messages.

Mr Lee Cain: I think, you know, it’s obviously a time of significant stress and, you know, the challenges that we were dealing with are greater probably than any since, you know, 1945, which – you know, it’s important to highlight that context.

I think government has a huge problem with leaking, I think, and it was really pronounced during Covid. You know, you’re having conversations, you know, daily on potential options and you would read about them in the next day in – you know, in various newspapers. And that, I think from a messaging point of view on public health, caused huge problems because people then want answers, “Okay, what does this mean for me, my family, my lives?” And you’re then trying – you haven’t got a policy developed and you’re trying to sort of mop that up, all – and that was all the time. We couldn’t have a single conversation. And I think that’s because the sort of politics and the sort of knockabout view of sort of almost like politics as entertainment is now so entrenched in the relationship between the media and with the government it’s hard to stop it.

And I think, you know, it’s something you deal with as part of politics during normal – normal days. I think in a crisis like this it was one of the most difficult issues we faced, was the constant leaking of stories.

Counsel Inquiry: Second question: reading through it, one – of course these are private exchanges, we must remember that, but the language that is used repeatedly about colleagues is rude, it is dismissive, it is aggressive. We will hear evidence of a so-called macho culture in Downing Street at the time. Is this a fair reflection of the culture?

Mr Lee Cain: So, firstly, I would like to point out it’s not, you know, not my language or what I would have used. I would say that, as I mentioned earlier, there is a problem in – within Mr Johnson’s sort of senior team that there was a lack of diversity and that was, as I say, in gender, in socioeconomic and in ethnic minority, and I think if you – if you lack that diversity within a team you create problems in decision-making, policy development and culture. So I think that’s all part of the equation, but I think fundamentally any Number 10 is a direct reflection of the principal, and I think that’s probably the case here.

Counsel Inquiry: Right.

Finally, Mr Cain, I want to just ask you one or two questions back on the question of the circuit breaker lockdown, and you describe in your statement – I won’t take you to it – the meeting that happened on 20 September where Professor Heneghan, Professor Gupta and others were brought in – brought in virtually – to Downing Street to discuss, and you in your statement make it clear that you regarded, at that stage, it as essential that a lockdown should take place, but that the Prime Minister disagreed, and emphasised the economic arguments.

At around this time, a few weeks later – I want to take you to INQ000267902, please.

This is a text or a WhatsApp between you and – sorry, between you and the Prime Minister, on, we will see, 15 October. He says:

“I must say I have been slightly rocked by some of the data on covid fatalities. The median age is 82-81 for men 85 for women. That is above life expectancy. So get COVID and live longer.

“Hardly anyone under 60 goes into hospital …

“… I no longer buy all this nhs overwhelmed stuff. Folks, I think we may need to recalibrate.”

You say:

“All understood – but how does this change the policy? Still not politically viable … to change course …”

He says:

“It shows we don’t go for nation wide lockdown.”

Previously we’ve talked about the economic arguments against lockdown. This seems to be introducing a slightly different theme, and I want to show you very briefly some other entries in Patrick Vallance’s dairies from around this time. So could we look at them sequentially, please.

First of all it’s INQ000273901, first of all, page 50. So this was a little bit earlier, in August, where Patrick Vallance has recorded that the “PM WhatsApp group kicks off because [the] PM” had read about the infection fatality rate. And it says this.

“He is obsessed with older people accepting their fate and letting the young get on with life and the economy going. Quite a bonkers set of exchanges.”

If we can look at page 308, please. On a similar theme, picking it up a couple of lines down:

“[PM] says his party ‘thinks the whole thing is pathetic and Covid is just Nature’s way of dealing with old people – and I am not entirely sure I disagree with them. A lot of moderate people think it is a bit too much’.”

Lastly, please, page 312. By this time we’re in December. We see:

“… Chief whip says, ‘I think we should let the old people get it & protect others’. PM says ‘a lot of my backbenchers think that & I must say I agree with them’ …”

Now, the theme in those notes is similar, is it not, to that WhatsApp we looked at between you and the Prime Minister? It’s not saying that the economy is the main argument, it’s related, but it’s different. It’s saying: look, it’s only old people who get this disease, why don’t we just let them get it so the young people can live their lives?

Is that something which you think influenced the Prime Minister during this period?

Mr Lee Cain: I think, you know, you could see from the evidence that he was, you know, look, I think he was concerned about the damage on society as a whole, and he was trying to view it through that lens. I think some of the language is obviously not what I would have used, but for me the core argument was always the same, which was: your choice is that we lock down and control the virus and we do so as quick as possible to minimise the cost to health and cost to the economy at the same time.

The only reason you could start having any of these conversations is if you have no intention of bringing in further suppression measures, which for me was always morally and politically, you know, a non-starter. It was never something any responsible government or any responsible Prime Minister could or would undertake. So I felt a lot of this was just noise and distraction, and when reality became clearer, as it would, he would, you know – and did actually take out the measures responsible. I think some of it is important to focus on. I think he acted too late on some of the – particularly the later lockdowns, but he did actually do what I believed to be the moral and responsible course of action, it was just later than it should have been.

Mr O’Connor: Mr Cain, thank you very much. Those are all my questions.

My Lady, there are, as you know, two sets of questions from core participants.

Lady Hallett: There are.

Mr Metzer.

Questions From Mr Metzer KC

Mr Metzer: Thank you, my Lady.

Mr Cain, I ask questions on behalf of the Long Covid groups.

I don’t think we need to go to it, but if you need to let me know. There is an email to the CSA and the CMO’s office dated 25 June 2020 in which DHSC reported that the Cabinet Office had asked DHSC to look at communications around the recovery of patients following Covid-19 infection.

Were you aware of this request for information about the recovery of patients following Covid-19?

Mr Lee Cain: I was not, no.

Mr Metzer KC: You say you weren’t?

Mr Lee Cain: No.

Mr Metzer KC: Can you help as to whether there was any discussion in Number 10 about communicating publicly the risk of long-term health impacts of Covid-19 at the time?

Mr Lee Cain: I think initially the understanding around Long Covid was minimal in Number 10. I think we were still, you know, gathering evidence for much of my time, which, you know, obviously I left in the November of 2020, so during my time I think we were still quite unclear on some of it, but it was becoming more pronounced. But I don’t recall any specific campaigns to it at that point. I think, again, it would have been the sort of press conferences where we’d have discussed it, but I think at the time I was there the evidence maybe wasn’t as advanced as it, you know, later became.

Mr Metzer KC: That’s right through until November 2020, you say?

Mr Lee Cain: Yes.

Mr Metzer KC: I see. I might come back to that in a moment.

Can we put up INQ000283370, please. On 5 July 2020, NHS England announced Your Covid Recovery service, online rehabilitation service, and Sir Simon Stevens said the service would benefit, in quotes, and it’s there, “tens of thousands of people who are suffering long-term effects of coronavirus”.

You’ve said today that you met with the NHS regularly, even many times a week. In any of those regular meetings was this announcement ever discussed?

Mr Lee Cain: Not that I recall, but, you know, you’ll appreciate there was a huge number of meetings and, you know, issues raised. But I don’t recall that, no.

Mr Metzer KC: Okay. You’ve spoken today about individual responsibility, saying that people look to protect themselves in very sensible ways. Would you agree, Mr Cain, that communications about the risks of the long-term effects of Covid-19 was important for the public to know, so that they could protect themselves from this risk?

Mr Lee Cain: I think certainly once we understood what those dangers were, yes.

Mr Metzer KC: Do you agree that you were aware of that many months before you left office?

Mr Lee Cain: I was aware of, you know, conversations developing on Long Covid and what it meant, but it was not – it was not a primary focus for, you know, my – my work, which was slightly different and more sort of political messaging space. This would – this kind of – this is the sort of thing that would have been led departmentally or by the NHS, I mean by that.

Mr Metzer KC: Yes. But following those meetings with the NHS, are you aware as to whether there were any discussions in Number 10 about raising awareness of the long-term effects of Covid-19 at the time of this announcement in July 2020?

Mr Lee Cain: I was not, but, again, it would have been something that I’d expect to be led departmentally or by the ALB.

Mr Metzer KC: But you agree by that time you were aware of the long-term effects, risks?

Mr Lee Cain: To be honest, I can’t remember the timings of when I would have been, you know, up to speed with what the long-term risks of Long Covid were.

Mr Metzer KC: Or at the very least, would you agree you would certainly have been aware after the DHSC announcement on Long Covid in October 2020?

Mr Lee Cain: Probably, but again, there was a huge amount taking place at that point, so again, as I say, it’s not an area of focus that I particularly recall in any great detail, which I apologise for.

Mr Metzer KC: At paragraph 89, page 20, of your witness statement, you said:

“At the beginning of the Covid response … Vital public health messages were distributed via a mixture of the Department of Health, Department of Transport or the Cabinet Office digital channels. Did the fact that different government departments were distributing public health advice result in inconsistent messaging?

Mr Lee Cain: It’s a good question. I think there is a general practice that a lot of government departments act as sort of communication fiefdoms in their own right, and that can sometimes make all sorts of messaging challenges, which is – one of the things that we did in Covid was to create a central campaigning body that reported directly in Number 10 to try to pull together a coherency within our political campaigning so we didn’t have that sort of fighting, and I think it’s something that’s continued, thankfully, since I left.

Mr Metzer KC: But the existence of those fiefdoms, as you put it, would you agree did have a genuine risk of inconsistent messaging?

Mr Lee Cain: Well, I think we fixed that particular problem, I think. You know, that was something I was acutely aware of in part of the changes I wanted to make to the government communication system. So we did try to fix that with, you know, sort of command and control Cabinet Office centre that oversaw the campaigns as opposed to pushing them through but that, you know, obviously came in sort of in the summer I think more than – in the sort of summer of 2020.

Mr Metzer KC: And what was that central campaigning body?

Mr Lee Cain: It’s a group that’s within the Cabinet Office that will consist of highly trained campaigning professionals who understand a lot of the sort of newer media techniques, and the general thesis would be that departments themselves would have to pitch into that sort of central body to have, you know, campaigns they wanted to do green lighted, because the government spends hundreds of millions on campaigns, and 162 a year when I was there, most of which people don’t notice, metrics for measuring them are pretty poor, so we just wanted to professionalise that particular area.

Mr Metzer KC: So do you say through that central body there are attempts to co-ordinate public health messages communicated by different departments?

Mr Lee Cain: Correct.

Mr Metzer KC: How were public campaigns on Covid-19 updated by the government as information became available?

Mr Lee Cain: I think, you know, as policies change we would try to, you know, make those amendments into, into our public communications.

Mr Metzer KC: I’m not sure you’ve answered the question. How were the campaigns updated?

Mr Lee Cain: Well, policy – the policies – you know, changes would be fed into the communications, team, we would then look at, you know, certain research, best ways to communicate them, and then make changes to, you know, public announcements, so campaigns, wherever they were, as appropriate.

Mr Metzer KC: So who, if anyone, was ultimately responsible for communicating through government messaging that there was a risk of Long Covid?

Mr Lee Cain: I think it’s – it would fall in between, you know, the Department of Health and Alex Aiken within the Cabinet Office would – or indeed the NHS. So there’s a – you know, the different areas would pick up different responsibilities. I’m not sure where the full responsibility would lie with that, it depends on the severity and how – you know, I assume it would be in the Cabinet Office.

Mr Metzer KC: Sorry, do I read between that there’s a danger that it would fall between and not be dealt with by anyone?

Mr Lee Cain: I think, you know, in the size and scale of government that is indeed possible.

Mr Metzer KC: The last question I want to ask you, Mr Cain, is: in the absence of a clear co-ordinated communications plan on Long Covid, do you agree that Number 10 and the Cabinet Office failed to alert the public sufficiently about the long-term effects of Covid-19?

Mr Lee Cain: I can only really comment during my own time, and I think part of the problem was just, you know, developing the evidence stream, I think at the time, and the focus was on the live issue of dealing with the – you know, the immediate response during my time.

I think – you know, I’m not sure how that subsequently changed as, you know, I departed and the pandemic itself changed and our understanding changed.

Mr Metzer KC: Certainly would you agree, then, by the time – until you left in November 2020, as you’ve said, you would agree that there was a sufficient – insufficient – failure to alert the public about the long-term effects?

Mr Lee Cain: Again, from the evidence that we knew and had, I think we probably acted responsibly, but I think, you know, you can’t communicate what you’re unaware of, and I think in a lot of those early stages we weren’t overly aware of, you know, the dangers. But I think we did discuss them, we did talk about them, they were raised within the press conferences. I think it was something that, you know – and those press conferences alone, you know, we’re looking at 10 million people watching every single evening, huge numbers, so these were issues that were raised.

Mr Metzer: All right. Thank you, Mr Cain. Thank you, my Lady?

Lady Hallett: Thank you, Mr Metzer.

Mr Weatherby.

Questions From Mr Weatherby KC

Mr Weatherby: Mr Cain, I’m going to ask you just about a couple of topics on behalf of the Covid Bereaved Families for Justice UK, which represents many bereaved families from across the UK.

Both of the topics had been touched on by Mr O’Connor, so I’ll cut to the chase, if I may.

At paragraph 118 of your statement, you write this:

“At this time [and you’re talking about six or seven weeks into lockdown] the Prime Minister was becoming increasingly concerned about the impact of lockdowns on the economy and the political impact it was having on the right wing of the Conservative Party and the coverage of the right-leaning media. For example, on May 8th 2020 the Daily Telegraph – a newspaper that had been robustly anti-lockdown – printed its front page on a favourable interview with the Leader of the Opposition. The Prime Minister called me that evening and expressed significant concern, stating our policies were causing us to lose the backing of generally supportive elements of the media and he felt they may well be right …”

Then you add in brackets:

“… (a position that conflicted with all the evidence available).”


Mr Lee Cain: Yes.

Mr Weatherby KC: So, just for clarity, what you are expressing there is a frustration at Mr Johnson’s prioritisation of media views, he was prioritising that over the actual evidence, over the views of advisers such as yourself and over public opinion at that time; is that right?

Mr Lee Cain: So I think it’s slightly more complex in the sense that he, I think, was unsure about the policy that we were taking forward, so I think it was people reinforcing some of his own concerns. You know, I think he probably would have, as I’ve said before, been writing these sorts of leaders in The Telegraph himself. This isn’t a criticism of The Telegraph, which was, you know, shining a light of on where they thought the issues were, but I think, you know, the Prime Minister himself, this was part of his sort of oscillation and concerns over –

Mr Weatherby KC: Yes.

Mr Lee Cain: – policy development.

Mr Weatherby KC: The point I’m trying to get you to clarify really is the point in the brackets that you seem to need to make clear, that it conflicted with all of the evidence. So he is preferring the views of the right wing of his party and The Daily Telegraph over the actual evidence and his advice. That’s what you’re conveying, isn’t it?

Mr Lee Cain: That’s correct.

Mr Weatherby KC: The second topic, again it’s been touched upon so I’ll be brief, and it’s about diversity. Mr O’Connor took you to deal with the lack of focus or consideration at all of split families and the Marcus Rashford issues, but you say in your statement, and again I’m not going to put it up, but it’s at paragraph 121(d) that some policy decisions slipped through the cracks due to this lack of diversity, and you’ve already said – you’ve already referred to middle aged and white people only in the room, and that’s the problem.

What other, apart from the ones you’ve already mentioned, policy decisions slipped through the cracks because of this lack of diversity?

Mr Lee Cain: Erm … I think part of the problem is – and I can’t really sort of recall the specifics off the top of my head, but I think part of the problem is just very much having a situation where people’s own lived experience isn’t in the room. So, you know, if you have predominantly middle-aged, white men you’re going to miss out on a whole load of different areas of expertise and lived experience that will, you know – so again, like the Marcus Rashford was obviously a huge part of that. You know, some of the bubble sections they’d be the sort of things that I’d highlight.

Mr Weatherby KC: Okay, so for example, the disproportionate effects of the pandemic on people from ethnic minorities, that’s something that slipped through the cracks?

Mr Lee Cain: I think that was something that was discussed. I think this – I think it’s part of the challenge, I think these issues will be discussed but are they given the weight necessary without some of the lived experience? And that’s – I don’t know the answer to some of that. It felt to me that sometimes we missed things or didn’t give enough attention that we could have done. You know, I – but I genuinely don’t know if, you know, how much that would have impacted.

Mr Weatherby KC: What steps, if any, were taken to address this diversity gap, which presumably was obvious at the time?

Mr Lee Cain: So, you know, it’s not, unfortunately, for me to pick the Prime Minister’s senior team. I think, you know, I can only control the elements of – you know, the remit which I control, and I think we had a very diverse, particularly gender diverse, but we had a very diverse team within the Number 10 press office and, you know, they were incredible individuals to work with and –

Mr Weatherby KC: Bearing in mind that diversity, and the lack of diversity you’ve pointed up at paragraph 121(d), did you advise the Prime Minister or anybody else that this was a problem that needed to be addressed?

Mr Lee Cain: I think it was something that was frequently raised, I think, you know, particularly by many female members of Number 10 who, I think – it really sort of shone a light, because within – within Covid what tends to happen is there was a small core room, often in the Cabinet Room, where the individuals would be round the table.

Now, in non-Covid times there would be a lot more people in that room so it would sort of mask some of these issues. During Covid, the sort of secondary cast, if you will, would be outside watching on a Zoom, and what became very clear is it was predominantly women in the building who were outside watching on a Zoom and predominantly white, middle-aged men around the table.

Mr Weatherby KC: Yes.

Mr Lee Cain: So I would receive messages from members of my team sort of, you know, highlighting this gender disparity and the fact that we needed to change –

Mr Weatherby KC: You advised about it, but did anything change? That was my question.

Mr Lee Cain: No, nothing – nothing did change.

Mr Weatherby: Thank you, my Lady.

Lady Hallett: Thank you.

Thank you very much, Mr Cain, thank you for your help.

(The witness withdrew)

Lady Hallett: Just so people understand, we will probably have a shortened lunch because I think we have overrun a little with Mr Cain.

Mr Keith: Thank you, my Lady, that would be very helpful.


Mr Keith: So, my Lady, the next witness is Dominic Cummings.

Mr Dominic Cummings


Questions From Lead Counsel to the Inquiry

Mr Keith: Mr Cummings, could you commence your evidence, please, by giving us your full name.

Mr Dominic Cummings: Dominic Mckenzie Cummings.

Lead Inquiry: You have provided the Inquiry with a lengthy witness statement dated 12 October, to which you have appended a declaration of truth. We take it, therefore, that the contents of your witness statement are true. And you’ve also helpfully provided us with a lengthy letter, dated 11 November, in which you included a large number of screenshots of WhatsApps, texts, materials, and so on.

Could we commence, please, with your career. The Inquiry understands that from 2007 to 2014 you were a special adviser to Michael Gove MP; is that correct?

Mr Dominic Cummings: Yes.

Lead Inquiry: In October 2015, you became a director of the organisation Vote Leave, which culminated of course in the June 2016 referendum, and I think it’s fair to say you were an architect in the successful Leave EU campaign.

Mr Dominic Cummings: Forgive me, sorry, our campaign was called Vote Leave, the other one was called Leave EU.

Lead Inquiry: Thank you.

On 24 July 2019 you became a senior adviser to the then Prime Minister; is that correct?

Mr Dominic Cummings: Yeah.

Lead Inquiry: A general election was called relatively shortly thereafter. Did you, as is customary, resign as an adviser once Parliament had been dissolved or did you stay in that post throughout the election campaign and then continue thereafter?

Mr Dominic Cummings: I’m afraid I can’t remember the exact legal status that I had between the election being called and through the election. There are complicated rules. And also I had a slightly odd role in that time, because I wasn’t – I was neither in campaign headquarters nor was I full-time in Number 10. I was kind of in a separate room, and I continued doing some government work during that time, for example with NATO and some national security things, I think there was a terrorist episode, floods, various things, so I was sort of hopping around between two different things.

Lead Inquiry: All right.

Mr Cummings, I’m going to ask you please to remember that whilst you give evidence it’s essential that you try to keep your voice up and you speak as slowly as possible. That way we may better understand your evidence.

Did you play a part in the general election campaign, culminating in the 12 December election?

Mr Dominic Cummings: Yes.

Lead Inquiry: All right.

I’d like to turn, please, to some of the government structures which form the large part of your witness statement, and about which you express, I think, what may fairly be described as very trenchant views, starting with the Cabinet.

You say in your statement that:

“Cabinet was largely irrelevant to policy or execution in 2020. The combination of its size, the Prime Minister’s inability to chair it, and its constant leaks meant it was seen by everyone in No10 as not a place for serious discussion.”

You go on to describe how:

“… those working in No10 see it as another problem to manage while real discussions happen elsewhere.”

The Inquiry material shows that there were, although this may not be reflected in the minutes, frank and constructive debates held in Cabinet, as they say in diplomatic circles, and that there were important decisions made in Cabinet, and important matters debated.

Is that a fair summary, therefore, of the role of Cabinet during the coronavirus crisis?

Mr Dominic Cummings: I think it depends – to some extent it depends what you mean by the word “decision”. I mean, formally a lot of things are decided in Cabinet, obviously that’s the formal constitutional structure, but very rarely is that actually a reflection of the reality of how the “decision” has actually been made.

Lead Inquiry: So is it more of a reflection of the fact that important decisions started to become taken elsewhere, predominantly in Number 10?

Mr Dominic Cummings: I wouldn’t say started to be. I think that was the case in 2019. And of course it’s been a feature for many decades of this trend increasing.

Lead Inquiry: If we may call that process a sidelining of Cabinet, did you contribute to that process, do you think?

Mr Dominic Cummings: Erm, I would say more that I just managed it as a – sort of like the weather, I mean, it was just a sort of fact of life. It was a combination of the constitutional crisis in 2019, the Prime Minister’s own personal temperament, habits that had grown up in the Cabinet Office over many years going back a long period. I actually said to the Prime Minister –

Lead Inquiry: Slow down, Mr Cummings, please.

Mr Dominic Cummings: Sorry.

Lead Inquiry: Slow down. You said to the Prime Minister?

Mr Dominic Cummings: I suggested to the Prime Minister both in the last week of the election campaign in 2019 and in the first week of January, when we discussed the future generally, that he should strongly consider (a) a major reshuffle and (b) radically shrinking the size of the Cabinet back to where it was something like a hundred or so years ago, because as anyone knows who has dealt with very large organisations, it’s impossible to have serious conversations with 25, 30 people in a room around a table like that. The Prime Minister did not want to.

Lead Inquiry: Due in large part to your own WhatsApps, Mr Cummings, we’re going to have to coarsen our language somewhat.

Mr Dominic Cummings: I apologise.

Lead Inquiry: You called ministers “useless fuck pigs”, “morons”, “cunts”, in emails and WhatsApps to your professional colleagues. Do you think you contributed to a lack of effectiveness on the part of ministers and of the Cabinet?

Mr Dominic Cummings: No, I think I was reflecting a widespread view amongst competent people at the centre of power at the time about the calibre of a lot of senior people who were dealing with this crisis extremely badly.

Lead Inquiry: Slow down, please, Mr Cummings.

Are you suggesting that your views, expressed in those revolting ways, were shared by others?

Mr Dominic Cummings: Well, the – my appalling language is obviously my own, but my judgement of a lot of senior people was widespread.

Lead Inquiry: Do you feel that you expressed your views too trenchantly, that your opinion of ministers and of the Cabinet overstated the position?

Mr Dominic Cummings: No, I would say, if anything, it understated the position, as events showed in 2020.

Lead Inquiry: Cabinet meetings appear, according to your statement and the material that we’ve seen, to have been to some extent scripted but, insofar as Cabinet committee meetings were concerned, they were very largely scripted: ministers were given scripts to read out, bullet points were written by officials who had exchanged them in advance, and the conclusions were largely scripted in advance. Is that a fair summary of Cabinet committee meetings?

Mr Dominic Cummings: It is. Obviously not always, and obviously there are exceptions, and there were some people who chaired Cabinet committee meetings who did an extremely good job, so I’m not claiming that this is universal. I’m saying it was a general feature and it was much more often true than not.

Lead Inquiry: You refer in your statement to Cabinet and Cabinet committee meetings being “Potemkin meetings”; what did you mean by that?

Mr Dominic Cummings: They were Potemkin in the sense that they were for show, as part of the sort of show of the constitution, that unfortunately a large part of how the system works is that ministers parade up Downing Street, the cameras click, people act like Cabinet is actually deciding things, but everyone behind the Number 10 door actually in power knows that that’s very rarely actually what’s going on, that usually what’s happening is that senior officials have actually decided what’s happening and the ministerial performance is often/usually a performance.

Of course that changes according to historical situations and crises and sometimes Cabinet, even in 2019/2020, became genuinely important, but I’m just trying to give a general picture.

Lead Inquiry: On the cusp of the coronavirus pandemic, where was power exercised? Where was the effective decision-making?

Mr Dominic Cummings: By “cusp”, where do you mean, sorry?

Lead Inquiry: January/February.

Mr Dominic Cummings: Erm, well, it certainly wasn’t in Cabinet.

Lead Inquiry: Where was it?

Mr Dominic Cummings: Well, most power really is in – is nominally in the hands of the Prime Minister and, to a very large extent, in the hands of the Cabinet Office. I would say the Cabinet Secretary is something like ten times or a hundred times more powerful than anybody else in the Cabinet Office apart from the Prime Minister. All sorts of elements of real power actually now, in our system, answer to him, but a large part of the performance and the media coverage is aimed at trying to cover up this fact and to try to portray the ministers as actually in charge.

Lead Inquiry: Over time, you recommended and you brought into effect two very important meetings or two important processes. One was the 8.15 officials’ meeting, at which you and other officials discussed the day’s events, resolved to raise important matters that needed to be debated, and then at 9.15 daily there became meetings with the Prime Minister. In his study or in the Cabinet Room; where did that take place?

Mr Dominic Cummings: The sort of formal part of it was in the – so, sorry, the 8.15 was in the Cabinet Room every day. The 9.15 was usually also in the Cabinet Room. Sometimes that would be preceded by a smaller meeting in the Prime Minister’s study, which adjoins the Cabinet Room through a kind of joint door.

Lead Inquiry: Were your 8.15 officials’ meetings minuted or noted?

Mr Dominic Cummings: I’m not sure exactly what the – well, the process changed. Obviously, the 8.15 and 9.15 meetings I originally created out of the kind of air of disaster, and they were very informal. But they went through different iterations, so they became called different things, the 8.15 and the 9.15, I think there was at least three different formal iterations, and the bureaucratic processes will have been different for each one. I think right at the very beginning, at 8.15, there were kind of action points taken because it was very much an action-oriented thing, it wasn’t any kind of formal structure. So I would guess that there were not formal minutes at those meetings to begin with, but there were certainly action points that Imran, the private secretary, and others would write live during the meeting and then circulate afterwards.

Lead Inquiry: By and large, as you say in your statement, there was little transparency or visibility, traces of discussions might only be in an email or WhatsApp if they exist at all; is that correct?

Mr Dominic Cummings: I think it’s certainly correct about the very first part, as I said, when we just created the meetings because they had no kind of formal position of any kind, though I don’t think that’s accurate about later on.

Lead Inquiry: The Cabinet Office, to which you’ve referred, you describe in this way, that it had:

“… ‘more sand in the petrol tank’ [rather] than ‘the [Rolls Royce] gearbox’ it is often described as.”

What did you mean by that?

Mr Dominic Cummings: Well, if you speak to many people who have been in – who have knocked around the system for a very long time, the Cabinet Office over a long period of time has accumulated more and more power, formal and informal, it’s become incredibly bloated, it’s acquired huge numbers of people, huge numbers of teams, and particularly, on the whole – the sort of deep state, national security side, crisis management has become in all sorts of ways extremely opaque and effectively completely invisible to any political figure, including the Prime Minister. So it was extremely difficult to know in Number 10 who exactly in the Cabinet Office was doing what, whose responsibility it was, who were we supposed to talk to, to get action. And that was critical in – particularly in the first couple of months.

Lead Inquiry: Was this a function of staffing levels, inadequate staffing levels, or overstaffing, in particular parts of the Cabinet Office, or a reflection of the personalities, the people who were actually in the Cabinet Office?

Mr Dominic Cummings: I think it was a mix. Like all dysfunctional systems, it was a mix of a lot of the wrong people in the wrong job, decades of accumulated power, no real scrutiny and insight, a culture of constantly classifying everything to hide mistakes, and hide scrutiny.

Management was bad, incredibly bloated with so many senior figures that they themselves – as Helen MacNamara’s statement makes clear, the senior people themselves didn’t know who on earth was in charge of what.

Lead Inquiry: In your statement to the Inquiry, you say that:

“31. In 2020 a handful of senior officials were the wrong people for the posts.”

And this is in the context of your views on government generally, so not just the Cabinet Office, but Number 10.

“This meant they were unable to replace other people who were wrong for their posts.

“32. However, it is the [Prime Minister] who is responsible for the wrong people remaining in crucial jobs.”

Were, in your opinion, the wrong people in those crucial jobs in the Cabinet Office?

Mr Dominic Cummings: Yes, I think there clearly were some people in the Cabinet Office who were in the wrong jobs. The Cabinet Secretary and I had had quite a few frank discussions about some of these problems going back into 2019. He actually removed some of the people at my request, and moved them on to other things, though of course, Whitehall being Whitehall, they were often promoted rather than being actually removed. So, yes, there were – I agree with the thrust of your question.

Lead Inquiry: Who else did you have in mind by that observation that there were the wrong people in those jobs?

Mr Dominic Cummings: Well, I think the – the Cabinet Secretary at the time himself said to me that he had never sought that job and he had serious doubts about the wisdom of combining the Cabinet Secretary’s job and the National Security Adviser job. I think that that was correct. Mark was a very able diplomat, he had enormous skills in all sorts of ways, but that … the way in which the Cabinet Office has evolved – so if we take –

Lead Inquiry: Well, perhaps we’ll pause there. We’ll just stay on the issue of the Cabinet Secretary.

Mr Dominic Cummings: Okay.

Lead Inquiry: That Cabinet Secretary, Mark Sedwill, now Lord Sedwill, whom you have described as “a talented and able diplomat”, an able diplomat in all sorts of ways, you denigrated and insulted by your WhatsApps and text messages, did you not?

Mr Dominic Cummings: Er, I guess so. I’m not sure exactly what you’re referring to, but it’s certainly the case that I came to the view that he did not have visibility of the fundamental disasters that were unfolding inside the Cabinet Office.

Lead Inquiry: You used obscenities to describe him and then, in a series of texts and WhatsApps, you said he was off the pace, his staff knew he was off the pace, he was unable, essentially, to function at all as the head of the Cabinet Office?

Mr Dominic Cummings: I don’t think I actually said that he was unable to function at all, but the rest of what you said is correct. And this was not just my view. Part of what I was expressing to the Prime Minister was that other people in the Cabinet Office and crucial people in – officials not political people – the Prime Minister’s office had said to me, “We fear that both the Cabinet Office has gone dreadfully wrong and that Mark doesn’t understand just how badly wrong this has all gone”.

Lead Inquiry: You were unimpressed by the principal private secretary, you believed that he deferred too much to the Prime Minister, he didn’t force him to face up to hard choices; is that correct?

Mr Dominic Cummings: Yes. I think that one of the – I think – so that role is highly, highly underrated, I think, in understanding how government really works. It’s an extraordinarily powerful position in all sorts of ways. Again, much more powerful, really, than anybody in the Cabinet, apart from the Prime Minister. It’s a critical role. And my view was that a role like that, in a country like ours, should be filled by one of the absolutely most able people that we can possibly muster in our country, and I made that argument to the Prime Minister before January, during the election actually, about making a change in January. I lost the argument.

Lead Inquiry: Slow down, please, Mr Cummings. Slow down. You lost that argument?

Mr Dominic Cummings: I lost the argument. I made it again after the first wave and I lost the argument again.

Lead Inquiry: Your views on the Secretary of State for the Department of Health and Social Care are very well known and we’ll be looking at some of your remarks about him in due course. Overall, the tenor of your statement is to the effect, and this is to use your words, that senior ministers, senior officials, and senior advisers like yourself, fell disastrously short of the standards that the public had to expect. Is that a view you adhere to still?

Mr Dominic Cummings: It is. I also think there were many exceptional people, as I’ve also tried to explain in my statement, but they were all enmeshed in a fundamentally dysfunctional structure and that meant that even the great people were often unable to do great work.

Lead Inquiry: You also say that it is “completely crackers” that someone like you should have been in Number 10. Is that a view you still maintain?

Mr Dominic Cummings: For sure.

Lead Inquiry: Ultimately, who bears the responsibility, Mr Cummings, for appointing the individuals whom you have described in these terms?

Mr Dominic Cummings: Well, lots of them obviously were appointed – lots of the critical Cabinet Office roles were appointed before me and the Prime Minister arrived. The Prime Minister obviously bears responsibility for the Cabinet, he appointed the Cabinet in summer 2019. Contrary to all the media reports, I had zero involvement with that. I tried to get him to change it in January and failed, tried to get him to change it in February and almost completely failed.

Lead Inquiry: Who appointed you, Mr Cummings?

Mr Dominic Cummings: The Prime Minister.

Lead Inquiry: The Inquiry has heard evidence that the Cabinet Office plays a vital role in government as the co-ordinating centre: it liaises with other government departments, it brokers issues, it resolves debates and issues between line departments. It is the hub of government.

On your arrival in Downing Street in July of 2019, did you believe that the Cabinet Office was effectively performing that role?

Mr Dominic Cummings: No.

Lead Inquiry: The Cabinet Secretary, the Inquiry has been told, has an equally important function of exercising such institutional levers as may be required in order to make other parts of government work. Were those institutional levers being effectively operated by the Cabinet Secretary when you arrived in Downing Street in July 2019?

Mr Dominic Cummings: No, but I would also obviously – it was the middle of the worst constitutional crisis in a century, and I certainly – it would be extremely unfair to blame the/’Cabinet Secretary for all the problems that we had at that time.

Lead Inquiry: Throughout the rest of that year and at the beginning of 2020, did you discern any improvement in the structural system concerning the Cabinet Office?

Mr Dominic Cummings: In some ways, yes, I think it did improve, on the very first day that I arrived I sent an email to the Cabinet Secretary regarding how I thought that the – that Brexit should work in terms of the Brexit – what became known as XS, Brexit Strategy, and Brexit Operations, XO. The Cabinet Secretary agreed with me, we set that up. I think almost everybody involved with the process thinks that it radically improved how the government dealt with such an extremely complicated question, and I think also everybody that I know who I spoke to about it thinks that, contrary to the impression that one often gets in the media, in fact going through that admittedly nightmarish process of XO during 2019, actually proved extremely useful in terms of dealing with the Covid crisis.

So overall I would say – I did say to the Prime Minister in December 2019, as the election was ending, overall the system is completely dysfunctional, but within that the Cabinet Secretary did make very important improvements, I think.

Lead Inquiry: Do you think your description of your colleagues, the way in which you described them, their functions, abilities, talents, added to that dysfunctionality?

Mr Dominic Cummings: No, I think the opposite. I think my job – a huge part of the problem with the culture of Westminster and Whitehall that was so disastrous in Covid is people not speaking out about core problems and I regarded my job as – you know, I’m not a very smart person, I’m not a specialist in all sorts of ways, but I had built very effective teams, and I felt that part – a crucial part of my job was to say to the PM and to other people if I thought that someone couldn’t do the job, then to make that clear because (a) that’s so fundamental to performance and (b) the issue is so often buried in Whitehall.

Lead Inquiry: On 3 May, so after the initial crisis and the first wave –

Mr Dominic Cummings: Third of what, sorry?

Lead Inquiry: – 3 May 2020, INQ000253940, you sent an email to Martin Reynolds, the principal private secretary, Stuart Glassborow, Clare Brunton, Imran Shafi, the private secretary for health matters, education and other policies, Hannah Young and Emily Beynon, as well as Munira Mirza, and you copied it back to yourself.

You said:

“We’re wasting far too much time in crap meetings, we’re not using the PM’s time well. We’re not using the PM’s time well. Changes from tomorrow.

“1. No papers go to PM on anything related to [Covid-19] including from CABOFF [Cabinet Office] and HMT unless they’re cleared by Shinner …”

That’s Tom Shinner?

Mr Dominic Cummings: Yes.

Lead Inquiry: “… or me – NOBODY ELSE.

“2. Any Chair brief on anything related to [Covid-19] … must be cleared by Shinner or me – NOBODY ELSE.”

Then there are some further directions concerning papers for Prime Ministerial meetings:

“4. Shinner – hire whoever else you think you need.

“5. We must start cancelling meetings and telling the PM”, and so on.

Did that direction, that nothing would go to the Prime Minister on Covid from the Cabinet Office and HMT, include anything from the Cabinet Secretary?

Mr Dominic Cummings: You mean did that mean that the Cabinet Secretary could not write directly to the Prime Minister?

Lead Inquiry: Unless cleared by you or Tom Shinner.

Mr Dominic Cummings: No.

Lead Inquiry: So who was being excluded, in effect, within the civil service from communicating papers to the Prime Minister without your intervention?

Mr Dominic Cummings: So, essentially, what I was trying to do here, the actually – “or me” is actually not really very relevant. What I was actually trying to do was empower Tom Shinner, who was an excellent official.

We had a fundamental problem – well, we had many fundamental problems. Two most obvious ones were: the Cabinet Office was a bomb site, and we had a huge problem of quality control of documents going into meetings, and inconsistent data, inconsistent facts being read out, and many officials had come to me and said, “This is causing chaos, there has to be some – a formalised system to actually grip this”, because the Cabinet Office was a dumpster fire, and Shinner was extremely able.

Essentially, what I was trying to do here was say: there has to be someone who actually takes responsibility for saying that they and a team have checked the information and it – and are certifying that it’s accurate, so that we could would get away from these nightmare meetings that we had had all the way through the previous few weeks of documents coming up, people then saying, “This is wrong, this is out of date”, everyone looking at each other like the Spiderman meme, not being clear who’s actually responsible. So I was trying to say, “Let’s actually establish a proper structure for this”, with someone who everybody respected.

Lead Inquiry: Tom Shinner was, like you, an adviser with the civil service to the Prime Minister?

Mr Dominic Cummings: With respect, he was not really like me, no. He was –

Lead Inquiry: He was an adviser – insofar as he was not a member of the civil service, he was an adviser to the Prime Minister?

Mr Dominic Cummings: No, with respect, that’s not correct.

Lead Inquiry: What was he?

Mr Dominic Cummings: He had been an official, he had then left, he then came back in as an official. I think he was – well, to begin with, I think his exact status was slightly unclear, obviously for the first few days, because he arrived on 16 March.

Lead Inquiry: Did you bring him in?

Mr Dominic Cummings: But he was a civil servant, not an adviser.

Lead Inquiry: Did you bring him in, Mr Cummings?

Mr Dominic Cummings: I did.

Lead Inquiry: Was it wise, in hindsight, to concentrate this degree of control in yourself and Mr Shinner?

Mr Dominic Cummings: I think bringing Tom in and empowering him the way I did was one of the single – probably handful of best decisions I’ve made in the whole nightmare.

And by the way the Cabinet Secretary strongly agreed with me. I think he had worked with Tom Shinner on a lot of Brexit issues and with Jeremy Heywood a few years earlier. So it wasn’t like I was imposing this on them, I actually spoke to Mark and said “Here’s my idea are you happy with it?” And he said, “Yeah, it sounds great, sounds great.”

Lead Inquiry: On 15 May, according to your statement, you had a long discussion with the private office in Downing Street to review what had gone wrong with the Cabinet Office. You raised issues about lack of co-ordination across Whitehall, the duplication of requests. In essence, a failure to grip whatever issues or problems confronted the Cabinet Office.

What was your view of the private office within Downing Street with whom you were having those conversations?

Mr Dominic Cummings: Erm, I think the private office, as I made clear in my statement, was in all sorts of ways absolutely excellent and I think it had some of the finest public servants in the whole system. I think the country was lucky to have – have them. I think though that there was – I would say that there was one very obvious problem, which was that, apart from the leadership of the private office, he was a notable exception, but there was a core problem, which is that private secretaries in the Prime Minister’s office are generally quite junior officials, quite a few of them are young women, and at that meeting on 15 May and other – and on other occasions, some of the young women in the private office said to me that they thought there was a serious problem with senior people in the Cabinet Office not paying attention to what they were saying, talking over them, generally just a bad culture of a lot of the senior male leadership in the Cabinet Office, which was something which I agreed with.

Lead Inquiry: Well, we’ll be looking in due course at some of your emails and texts to other members of the team.

Is it fair to say that you were critical also of the private office, that you sent emails and texts saying the private office is systemically flawed in certain regards, as well as the Cabinet Office?

Mr Dominic Cummings: So I think there are two separate things. I was generally highly impressed by the private secretaries in the private office, who I thought did an absolutely extraordinary job, but I thought that the overall structure in which the private office operated clearly didn’t work, and, you know, you had a relatively tiny number of people with, as – I say, relatively junior people suddenly being completely swamped by being asked to solve huge numbers of problems from all across the system.

So when I say the private office didn’t work, it wasn’t that – this is not a criticism of most of the people in it, it’s that it was swamped by the broader dysfunction of the Cabinet Office.

Lead Inquiry: Could we have, please, the letter that you sent to the Inquiry, INQ000048313 at page 56.

This I think is – if we go back to the previous page, thank you very much – we can see this is an email you sent on Monday 13 July, right at the bottom of the page. It’s a lengthy email, isn’t it, Mr Cummings, in which you set out your views on a number of different parts of the government machine.

Mr Dominic Cummings: Yes.

Lead Inquiry: There had been for some time – you’d raised the issue in January, of the overall structure of the government, you’d raised it again in May, you had repeatedly returned to this subject and you returned to it in July.

Mr Dominic Cummings: Yeah.

Lead Inquiry: Over the page, on page 57, there are references to the Cabinet Office not working for anyone, in the second paragraph.

Mr Dominic Cummings: Yeah.

Lead Inquiry: Further down the page, you are critical – it’s about halfway down – of COBR and CCS – is CCS the Civil Contingencies Secretariat –

Mr Dominic Cummings: Yeah.

Lead Inquiry: – and how it failed in multiple ways?

Mr Dominic Cummings: Yeah.

Lead Inquiry: You are critical of the data system, correct?

Mr Dominic Cummings: Yeah.

Lead Inquiry: Over the page, page 59, you are critical of “institutional friction”, “turf wars”, the existence of “blame games”.

Page 60, you refer to bloating, a “copy list culture”.


“We’ve experienced disaster. The PM has said sort it out …

“We are still a low performing entity while dealing with the next phase of covid and economic horror.

“… we need a timetable for key actions …

“Simon and Tom shd informally scout out possible key people for this now.”

Was there any part of the government machine, Mr Cummings, in which you did not find fault?

Mr Dominic Cummings: Erm … well, in summer 2020 I spent quite a lot of time talking to British Special Forces and I found that they were exceptional.

Lead Inquiry: Well, now, Mr Cummings, you know perfectly well that this is evidence directed at the coronavirus pandemic and we’re debating the mechanics of Number 10, the Cabinet Office, and the government response.

Mr Dominic Cummings: There were isolated – so if you’re asking purely about the Number 10 and Cabinet Office system –

Lead Inquiry: I’m talking about the structure concerned with the response to the coronavirus pandemic.

Mr Dominic Cummings: So I would say overall widespread failure, but pockets of excellent people and pockets of excellent teams doing excellent work within an overall dysfunctional system.

Lead Inquiry: In your statement you describe how, following this email, the Prime Minister, whilst initially agreeing with the sentiment of your trenchant views on aspects of the government machine, listened to, to use your words, pop-ins, and then got cold feet. What are pop-ins?

Mr Dominic Cummings: So obviously the context for this – for this document is it comes after eight weeks of a nightmare situation kicked off by the PM –

Lead Inquiry: I do apologise, Mr Cummings.

Mr Dominic Cummings: Sorry.

Lead Inquiry: What are pop-ins?

Mr Dominic Cummings: Pop-ins are what people in private office refer to when the Prime Minister would make a decision about something, some element of the system, often in the Cabinet Office, would not like what had been agreed, and in the best Sir Humphrey “Yes, Minister” style they would wait for me and other people to not be around the Prime Minister and they would pop in to see the Prime Minister and say, “Dear Prime Minister, I think that this decision really wasn’t the best idea, very brave, Prime Minister, perhaps you should trolley on it”, and this was a general problem.

Lead Inquiry: “You should trolley on it”, meaning?

Mr Dominic Cummings: Well, I’m using the sort of generic term that we often used about the PM.

Lead Inquiry: The term you used and his Cabinet Secretary used and his director of communications used, and other officials no doubt, about his propensity to –

Mr Dominic Cummings: Pretty much everyone called him the trolley, yeah.

Lead Inquiry: – change direction.


Lady Hallett: If you’re moving on, Mr Keith. I appreciate that it’s a little early, but I think we’ve had quite a long stint.

Mr Keith: Yes, indeed.

Lady Hallett: And Mr Cummings, like me, does speak very quickly. So I think we will take a break now. I shall return at 1.45.

Mr Keith: Thank you.

(12.56 pm)

(The short adjournment)

(1.45 pm)

Lady Hallett: Mr Keith.

Mr Keith: Mr Cummings, COBR. In your statement, you say COBR works well where the crisis is not too big. It became clear that less and less was done in COBR from March, April, May onwards. Why was COBR not effective in the context of the coronavirus crisis?

Mr Dominic Cummings: Erm, there’s multiple reasons. So one obvious thing was that … so there’s a terminology called “STRAP”, which I’ll briefly explain.

Lead Inquiry: No, we’re not going there. If you wish to refer to the fact that there are levels of national security sensitivity, just say there are levels of national security sensitivity.

Mr Dominic Cummings: As you say, sir.

So that’s one problem, which means that both the data that goes into Number 10 – sorry, into COBR is strictly controlled, and so is the hardware strictly controlled, so there were physical and data limitations on how COBR worked – entirely properly, because of the requirement to keep the physical area secure from Russia and China, and blah, blah, blah.

Lead Inquiry: Right.

Mr Dominic Cummings: That was one –

Lead Inquiry: So that’s a practical consideration?

Mr Dominic Cummings: Yes. Also it just didn’t scale.

Lead Inquiry: Meaning?

Mr Dominic Cummings: So it was used to dealing with relatively small things like floods, like, you know, terrorist attack with five people getting killed or something like that. But with a crisis like this, which is much more on the scale of a war, it was just – it just couldn’t – physically it couldn’t function, data-wise it couldn’t function, all of the systems going in and out of it didn’t scale.

Lead Inquiry: Was the Prime Minister rather averse to attending COBR on account of its physical location?

Mr Dominic Cummings: Er, it’s hard to say. I mean, he certainly preferred to be in his study, and he didn’t like going to COBR. I deliberately put the – so, as I referred to earlier on, when we created the XS and XO structure, I deliberately put that in COBR so that there were kind of live screens on the wall, we could record action notes in real time, it was just a more effective way of handling the ministers and handling the decision-making. He wasn’t enormously keen on it, no.

Lead Inquiry: Right.

COBR was still used from March 2020 onwards, despite the institution of the 9.15 daily meetings in Downing Street. Was an important part of the continuation of the COBR system the fact that it allowed the devolved administrations to take part in the process?

Mr Dominic Cummings: Correct. I mean, my sort of impression/memory is that from, roughly speaking, mid-March, the main function of COBR after that was actually the sort of – just the process, a rather Potemkin process of handling the DAs. In fact, I’m not sure that even I went back to COBR for Covid after something like 12 or 15 March.

Lead Inquiry: You ran down the COBR system, Mr Cummings, because your view was that with the devolved administrations party to that process, there was an unacceptable risk of leaks, you were violently opposed to the fact that the media was briefed afterwards, and you were against, therefore, the continued use of COBR as a crisis resolution machinery?

Mr Dominic Cummings: I’d say that that’s overstating things, so first of all I didn’t have the authority to run it down and didn’t run it down. I think it’s more accurate to say that it was superseded by – by broader things, it was superseded by the 8.15 meeting that I started, the 9.15 meeting, how those two meetings evolved into the Covid Taskforce. So I didn’t run it down, it continued, and I’m sure in some ways it did very useful work.

And also it’s important to point out, unlike other parts of the system that I have been critical of, the people who ran COBR, in my opinion, did an extremely professional job. The problem was not, in this instance, so much the Cabinet Office where a lot of the people were unsuitable, the problem here was a much more structural one that the COBR thing just didn’t scale to what was needed.

Lead Inquiry: Could we have page 22, please, of your letter to the Inquiry, INQ000048313. This is a message, a WhatsApp, between yourself and Mr Johnson, dated 12 March 2020.

Mr Dominic Cummings: Excuse me. Sorry, sir, it hasn’t popped up. I can’t see –

Lead Inquiry: It will come.

Mr Dominic Cummings: – if it’s important.

Lead Inquiry: 12 March 2020:

“You need to chair daily meetings in the Cabinet room – not COBRA – on this from tomorrow. I’m going to tell the system this.

“NOT with the DAs on the [fucking] phone all the time either so people can’t tell you the truth.”

Well, you did run down the COBR system, Mr Cummings. You thought that if the COBR system continued, people either wouldn’t tell the truth or the devolved administrations would leak to the media or brief the media thereafter?

Mr Dominic Cummings: So I certainly thought that the COBR meetings that we’d had with the PM were very Potemkin, they were extremely scripted, and then, having had these sort of pointless things, you then had all sorts of people running straight out and yabbering to the media about what had just been said in a completely undisciplined way, which then undermined public confidence in things, caused a lot of trouble.

But, with respect, I wouldn’t say this is running down the COBR system. The COBR system continued. What I would say was that it was clearly completely unable to cope with the scale of the crisis, and that a different system needed to be created.

Just one very simple thing, we literally couldn’t show the PM crucial data in the COBR room because it couldn’t be piped through because of the STRAP restrictions.

Lead Inquiry: You’re going back now to the practical considerations and the practical difficulties of which you spoke earlier.

Could we have INQ000174673, page 1.

This is an email between yourself, I think Helen MacNamara, and others, dated 13 March. Your email is in the middle of the page:

“The PM view (and mine) on those COBRAS is that they are hopeless as decision making entities and actively cause trouble for comms given they just brief immediately.”

So there you’re focusing not on the practical difficulties of data or the national security restrictions over the use of the room, but because you thought they were hopeless as decision-making entities and they caused trouble for comms?

Mr Dominic Cummings: Yes.

Lead Inquiry: On 15 March in a WhatsApp thread, “NumberTen action”, INQ000236371, page 52, this is a WhatsApp sent after Mark Sedwill, now Lord Sedwill, the Cabinet Secretary, had produced a note to the Prime Minister concerning the committee structure moving forward, the institution of something called ministerial implementation groups, and the 9.15 meetings:

“PM, it would be good if you could sign off the note from Mark [Sedwill] on moving to the next phase – structures etc, ideally before the meeting this pm so we could get things moving on that.”

Dominic Cummings:

“Can u send on whatsapp my work computer battery flat and i can’t recharge for an hour. the draft i saw looked ok as it was basically drafted by us …”

Who is “us”?

Mr Dominic Cummings: I’m not sure exactly but some combination, I think, of me, Imran and Ben Warner.

Lead Inquiry: “… except it’s still too keen on COBRA with DAs. The PM daily mtgs must be in [Cabinet] room with spider phones and screens – NOT in cobra where nobody can take laptops/phones.”

So there is a clear reference to the practical considerations, but also you were not keen on the devolved administrations being concerned in and attending COBR?

Mr Dominic Cummings: No, that’s not – they’re different issues. If you’re having meetings to actually figure out the truth, then meetings like that have to be conducted in a very different way. They can’t be one of these things with 50 people on a video conference with the DAs, when things immediately – those DA meetings were not meetings to try to figure out the truth about hard issues, they were meetings as part of the kind of performance and co-ordination and the – and a constitutional function. And my concern was that, even at this late stage in the crisis, a lot of people in the Cabinet Office were still fixated on the kind of Potemkin – maintaining the Potemkin aspects, rather than actually getting to the heart of things, and we couldn’t get to the heart of things in that room because you literally couldn’t take in the information and show it to the PM and have a proper discussion about it.

Lead Inquiry: Why did you want Michael Gove to be in charge of regular devolved administration updates and not the Prime Minister?

Mr Dominic Cummings: I thought Gove would handle it ten times better.

Lead Inquiry: Handle what ten times better?

Mr Dominic Cummings: Handle the process of dealing with the DAs.

And also bear in mind that I’d – as I said before, the whole XS, XO structure, Michael Gove had more experience of anybody –

Lead Inquiry: Slow down, please, Mr Cummings.

Mr Dominic Cummings: Michael Gove had more experience of anybody in that room, the COBR briefing room, because he was in there literally daily from July, August, September, et cetera, all the way through 2019, so I knew that he understood the whole rhythm, the process, the structure, the staff, and it just seemed like an obvious sort of way of divvying up responsibilities.

Lead Inquiry: Mr Gove was the Chancellor of the Duchy of Lancaster, was he not?

Mr Dominic Cummings: Yeah.

Lead Inquiry: Was he the Prime Minister?

Mr Dominic Cummings: Was he what, sorry?

Lead Inquiry: Was he the Prime Minister?

Mr Dominic Cummings: Obviously not.

Lead Inquiry: No. Did you not want the Prime Minister to be in a meeting room with the devolved administrations, the constituent parts of the United Kingdom?

Mr Dominic Cummings: I thought it – I thought it preferable to have the Prime Minister actually focused on the impending catastrophe that we faced on that day, and I thought that, generally speaking, him talking to the DAs did not advance any cause.

Lead Inquiry: The devolved administrations had an entitlement, surely, to be able to confer with the Prime Minister of the United Kingdom in the face of this unprecedented crisis.

Mr Dominic Cummings: They did, and they did confer, but, generally speaking, it was better for them to confer either with officials or with Michael Gove than with the PM.

Lead Inquiry: Was Number 10 any better? You describe it as a “hopeless structure” for dealing with a major crisis. What did you mean by that?

Mr Dominic Cummings: I mean, I don’t know how much detail you want me to go into.

Lead Inquiry: Well, be succinct, please, Mr Cummings. Why was it a “hopeless structure”?

Mr Dominic Cummings: Well … Number 10 is not configured to be the nerve centre of a national crisis like Covid –

Lead Inquiry: Because of the absence of personnel, or the absence of structure that allows people in Number 10 to liaise with all the other parts of government?

Mr Dominic Cummings: In every way: physically, in terms of date – in terms of the physical layout and the lack of flow – the proper rooms that you would have for a crisis centre, in terms of the personnel, in terms of the power. As I’ve tried to explain, real power on these things is almost entirely in the Cabinet Office, not in Number 10. So Number 10 was just completely unsuitable for this. That’s why I tried to change it in January and tried to change it again in the summer.

Lead Inquiry: In paragraph 301 you say:

“As … viz the Cabinet Office, its problems and lack of specialist skills combined with its responsibility for [human resources] and recruitment …”

There were problems with the Number 10 structure.

You brought in friends or colleagues, Tom Shinner, who may have been a member of the civil service but he was also an adviser, Marc and Ben Warner, Demis Hassabis. Why didn’t you approach the relevant parts of the Cabinet Office and Number 10 and say, “We need other people taken from other parts of government and brought into Number 10”? Why was it necessary to have your friends, your colleagues, put into Number 10?

Mr Dominic Cummings: Well, I did do exactly what you just asked, what – you said why didn’t I do that, but I literally did do that, at scale. I spoke to the Cabinet Secretary about it, the Deputy Cabinet Secretary, multiple other people in the Cabinet Office. Part of the whole point of bringing Tom Shinner in was that I knew that he had been involved in the Cabinet Office with the whole Brexit – Brexit no-deal preparations, which was as close as anybody had had, probably since World War II, to actually managing an extremely large-scale very, very complex set of operational and logistical questions. I knew also that Tom had had, because of this and also because of some other aspects of his career, which I won’t go into, extensive networks across the system, into the military, into all sorts of things, so he could – he was perfect – he was much better placed than me or anybody else really in Number 10 to know, oh, we should call General so-and-so and get him to help with this, we should get so-and-so in to help with that. So that was the logic behind bringing Tom in.

Lead Inquiry: Was Marc Warner a member of the civil service?

Mr Dominic Cummings: No, Marc Warner was – is a CEO of an AI company, but he was working at that time with Simon Stevens and Patrick Vallance on data issues around the NHS, completely fortuitously. So it obviously made sense, given that him and his company were kind of embedded in the NHS structure.

So, sorry, just to make it completely clear. Marc and Faculty got involved with the NHS and data before Covid ever started, so they were already in there working on these issues, so it obviously made sense for us all to kind of integrate, and then they helped build the dashboard.

Lead Inquiry: Was Ben Warner a member of the civil service?

Mr Dominic Cummings: He was a special – well, I think his status at this time was – actually might not have been officially confirmed but he became a SpAd?

Lead Inquiry: When you asked him to join Number 10, did he come from the civil service?

Mr Dominic Cummings: He did not.

Lead Inquiry: Did Demis Hassabis come from the civil service when you asked him to attend SAGE and to assist you in your hour of need?

Mr Dominic Cummings: He was CEO of DeepMind, he was very different category of person.

Lead Inquiry: Was he a member of the civil service?

Mr Dominic Cummings: Of course not.

Lead Inquiry: No.

Mr Dominic Cummings: Neither was Tim Gowers, he was professor of maths at Cambridge.

Lead Inquiry: A number of witness statements before the Inquiry refer to the fact that there was a dysfunctionality, a lack of a proper working relationship between the Cabinet Office, Number 10 and other departments. There was a lack of clarity about who was leading. There was an overall absence of a sufficiently organised response. Nobody knew, in essence, who was in charge, who do you go to in order to get decisions out of the government machine. Would you agree with those sentiments?

Mr Dominic Cummings: That was a general description of 2019 and 2020. I’d say it improved obviously once the Covid Taskforce was created. That brought in a lot more clarity in the kind of Covid-S, Covid-O, so things certainly improved from the summer, partly thanks to Tom, Helen MacNamara and others, but certainly until we did that it was extremely chaotic.

Lead Inquiry: You attempted, according to your statement, to bring about a major reorganisation in the layout and structures of Number 10, initially in late January?

Mr Dominic Cummings: Early January, the first week of January.

Lead Inquiry: All right, well, late January is taken from your statement. You then returned to this subject in May, and we know, of course, that there were changes to the Cabinet Office structure and to the committee structure in Number 10, or the meeting structure in Number 10. Did you, in general terms, have success in your attempts to reorganise the structures?

Mr Dominic Cummings: Erm … I would say generally failure, with pockets of success. So I think we managed to create the Number 10 data science team, which I started working on in the first week of January. It was obviously interrupted by the Covid first wave nightmare, but we created that, and that proved really critical, it brought in crucial different skills, crucial different people, people with a very different mentality to the civil service. So that was, I would say, a rare success. If you’re asking –

Lead Inquiry: Just pause there, please, Mr Cummings. So in relation to the establishment of a proper data science team and a process, a system for getting in data and disseminating it around Number 10 –

Mr Dominic Cummings: Yeah.

Lead Inquiry: – that broadly worked, and we know, of course, there was a dashboard and there was a 10DS team set up?

Mr Dominic Cummings: Yes, in January there was some scepticism about the whole thing, in the Cabinet Office, and resistance, but once everyone had gone through February, March, April and the nightmare, then actually resistance completely flipped and the Cabinet Secretary and many other senior people actually completely supported doing it.

Lead Inquiry: Were there substantive changes to the personnel in Number 10 or the Cabinet Office –

Mr Dominic Cummings: There were –

Lead Inquiry: – on the human resource side?

Mr Dominic Cummings: Yeah, there were huge changes in the Cabinet Office and core teams that were put in charge of Covid were repeatedly created, repeatedly dissolved. We were repeatedly told at Number 10 that they had burnt out from stress and they had gone. So, yes, there was – I would say until – by September it was a little bit more stable, the taskforce structure existed, people had a much better sense of what their job was. It was still dysfunctional in various ways but it was much different than it had been in May.

Lead Inquiry: What about the Department of Health and Social Care as the lead government department? Your statement states that the DHSC was overwhelmed by the scale of the crisis in February to May, it couldn’t build capacity on testing, on drugs, and was bad at asking the Cabinet Office for help.

When it became apparent that the DHSC was unable to discharge the heavy burden placed on it as the lead government department, why were changes not instituted?

Mr Dominic Cummings: Well, I think the Cabinet Office was – remember the Cabinet Office is responsible for dealing with a problem like that and the Cabinet Office itself was overwhelmed. It was overwhelmed by the crisis, it was overwhelmed by its own staff being out with Covid, it was overwhelmed by, you know, internal ructions about how the hell this had all been allowed to happen. So I think the Cabinet Office was slow in getting to grips with the problem at the Department of Health.

I think though, also, undoubtedly, I’m afraid that the … the story that the Secretary of State for Health kept telling us around the Cabinet table contributed to that. As the Cabinet Secretary himself said, “Hancock has not been clear in asking us for the help he needs and that’s contributed to the problem”. So I think, you know, as they say in Moscow, everyone is white and everyone’s unhappy. This is one of those examples that the Cabinet Office had serious problems, the Department of Health had serious problems, the co-ordinating mechanism to solve that itself had crumbled under the pressure.

Lead Inquiry: It is very obvious that there were a large number of criticisms made by you of the Secretary of State for Health and Social Care, Matt Hancock, we’ll look at some of those observations later. Where did you or Number 10, however, suggest structural changes to the lead government department, to the DHSC, changes in the way in which it operated in order to ensure a better service in the face of this crisis? Where is that debate? Where were those changes proposed?

Mr Dominic Cummings: So also bear in mind that in April, when we really started to discuss this, I discussed it with the Cabinet Secretary – of course the PM had just nearly died and was off in Chequers, so discussing it was inevitably very tricky, but I talked to the Cabinet Secretary in April about these issues. We discussed the possibility of splitting up the Department of Health in various ways, formally, informally. We discussed creating various taskforces to take critical work away, and of course we actually did that. One of the – in an ironically odd way, the scale of the nightmare in March/April actually made it much easier for us to make such a monumental decision as taking vaccines out of the Department of Health and creating a separate taskforce. Similarly on testing.

Lead Inquiry: Just to pause you there, I’m going to ask you please to keep your answers a little more concise. I appreciate it’s difficult.

So the way in which taskforces were set up was a reflection, if you like, of the understanding that the DHSC was not performing, so you had a test and trace taskforce, you had a vaccine taskforce, PPE taskforce, and so on?

Mr Dominic Cummings: Yes.

Lead Inquiry: Is that correct?

Mr Dominic Cummings: Correct, but to be fair, not just that they were performing poorly, you know, it was a once in a century event and they were clearly overwhelmed and, even if you imagined everything had been working ten times better, there would still have been very powerful arguments for having specific taskforces aimed at specific things.

Lead Inquiry: All right. The Inquiry has heard a great deal of evidence about the workings of SAGE and the majority of that evidence has been received from members of SAGE, its constituent parts. From the viewpoint of Number 10, did the SAGE government liaison, the process by which the government received advice from SAGE, work well?

Mr Dominic Cummings: So I think SAGE did a brilliant job at co-ordinating scientific expertise. I think Patrick Vallance did a brilliant job in chairing it and organising it. But I think that the … the kind of … the mechanism whereby SAGE’s thought processes were conveyed to Number 10 could be radically improved, because they were fundamentally oral briefings from Patrick Vallance and Chris Whitty, on the one hand, and the consensus minutes on the other hand, and then often very confused interpretations of what they had heard by officials in the Cabinet Office who did not necessarily have the skills and background and technical understanding to be able to explain those things well to Number 10. That –

Lead Inquiry: So, pausing there, just to split those answers up, please, Mr Cummings. In relation to the reporting system through the Chief Medical Officer and the Government Chief Scientific Adviser, were those briefings by them to government recorded or were they oral?

Mr Dominic Cummings: What do you mean by “recorded”? Do you mean minuted?

Lead Inquiry: Were they minuted, did they produce papers in support of everything they said, or was this funnel of communication largely an oral one?

Mr Dominic Cummings: It was largely an oral one, though of course the private secretary would record notes from the meeting and then issue action points and other things from – in the normal way from the private office.

Lead Inquiry: The SAGE minutes were, as you’ve described them, consensus documents, and others have described them similarly. Did Number 10 get a proper understanding of the width of debate that had taken place before SAGE and of the nuance of these extremely difficult and complex issues?

Mr Dominic Cummings: In my opinion, obviously not, I mean, there’s no substitute for actually listening to these conversations oneself and interrogating people.

I’m not saying by that that the SAGE minutes themselves were a bad product, I think they were a good product and a useful product, but if you’re asking about the nature of a crisis like this involving the Prime Minister, you know, having to make extraordinary decisions, he obviously needed much richer information than the SAGE minutes could provide.

Lead Inquiry: You are critical in your statement of the way in which the Cabinet Office commissioned work from SAGE and you say on occasion the wrong questions were asked of SAGE. You and, we know, I think, Demis Hassabis, your friend, attended SAGE. Why did no one say to SAGE, bluntly and plainly, “We want you to indicate much more clearly what your recommendations are, we need a much clearer understanding of what you suggest, and this is our – the government’s – strategy, so that you know to what you should direct your advice”?

Mr Dominic Cummings: Well, with respect, it wasn’t my job to try to take – commandeer SAGE and start giving them orders about how they should operate. I spoke privately to Patrick Vallance about things. I suggested, for example, getting some external people, like Gowers and Hassabis, to attend and listen and review the papers. But it wasn’t for a political adviser to start giving SAGE orders about how it should operate.

Lead Inquiry: Well, if you’ll allow me to suggest, Mr Cummings, you weren’t just a political adviser, you were in a position to exercise a significant degree of control and power at the heart of Number 10. If you saw there was a problem in terms of the route of advice and the communications that you were receiving, why was this not publicly raised?

Mr Dominic Cummings: Well, as you know from the various evidence, I sent Ben Warner to attend the meetings and discuss them. I listened to some of them myself. Also from the beginning of January I had weekly meeting – at least weekly meetings, sometimes two or three times a week, with Patrick where I would talk to him myself about the – about all sorts of things about science, but also obviously, as time went on, increasingly about Covid.

So I did push on these things and I did probe and I did talk to Patrick about them all. My criticism is not of Patrick. I think the fundamental problem was the interface between SAGE, DHSC and the Cabinet Office, and my point that you refer to in my evidence is: this is not my – you know, I’m not a technical person, so this is not my expertise I’m reflecting. The data people who were extremely smart and able who came in to help us, they said to me: the Cabinet Office is asking the wrong questions and misinterpreting the answers. And that was a problem both before the first wave and as we emerged out of the first wave.

Lead Inquiry: You asked your friend Ben Warner to attend SAGE?

Mr Dominic Cummings: I did.

Lead Inquiry: You spoke privately to the Government Chief Scientific Adviser, Sir Patrick Vallance. You hadn’t held back from making recommendations in relation to structural changes that, in your view, were required to be made to the Cabinet Office, to Number 10, to the DHSC. Why did you not publicly say, “There is a real problem with the structural route by which SAGE advises the government and we are not getting a proper understanding of the picture”?

Mr Dominic Cummings: Well, I don’t think it would have been a good idea for me to say publicly something like that. But I did –

Lead Inquiry: Well, to your colleagues in government?

Mr Dominic Cummings: I did say that to colleagues in government. I also spoke to Patrick about making the SAGE – I also had a very strong view that the SAGE minutes and other documentation should be made public in February for scrutiny, and actually Patrick was very good about that, and Patrick completely agreed. Unfortunately, again, the culture of secrecy in the Cabinet Office blocked that, not just February/March, but actually kept blocking it for I can’t remember how long but for a very long time.

Lead Inquiry: In your statement, in relation to the issue of the substantive advice you received from SAGE or rather the advice that the government received from SAGE, you say that it was represented to the government that SAGE was broadly in agreement with the strategy of mitigation, and we’ll come back in a moment to look at that in more detail, or plan A, as you call it.

Mr Dominic Cummings: Yeah.

Lead Inquiry: But that subsequently you were told that SAGE members, members on the SAGE committee, denied that they had been generally in support of a mitigation strategy.

Mr Dominic Cummings: Yes.

Lead Inquiry: When were you told that that representation of SAGE’s position was inaccurate?

Mr Dominic Cummings: I’m not sure exactly, but you could start to see it in what they themselves said after the first lockdown happened. From that point on, a lot of people around SAGE started to talk as if they’d been recommending this for a long time. Whereas, as you can all see from the evidence, they weren’t even recommending it the week of 9 March.

Lead Inquiry: That was obviously an extremely serious problem. The government’s sole scientific advisory group for emergencies was not, it would seem to you and what you were told, accurately giving you a proper reflection of the debate in that committee.

Mr Dominic Cummings: Well, I wouldn’t put it like that. I think actually I would say the problem in lots of ways was actually worse than that.

Lead Inquiry: All right.

Mr Dominic Cummings: That it was represented to us, even in the week of 9 March, that SAGE collectively agreed with the DH plan of single peak herd immunity by September, and indeed, as you can see from the public record in YouTube, many people from SAGE actually gave interviews that week articulating that plan A strategy.

Lead Inquiry: So at least after the first wave, Mr Cummings, it was obvious to you that the information that you had received from SAGE, on behalf of the government, was to some extent inaccurate, it hadn’t been a fair reflection on what you’ve said of the views of its members. SAGE, you say in your statement, had not made plain that there was a viable alternative to mitigation, they had not made plain, at least until quite late in the day, that the numbers of deaths and hospital cases would be massive –

Mr Dominic Cummings: Sorry, I would – I would – the last sentence is not accurate.

Lead Inquiry: Until quite late in the day. When did SAGE tell you that they had concerns that the infection fatality rate and the infection hospitalisation rate would mean an inevitable wave of death and hospital cases?

Mr Dominic Cummings: I don’t remember the exact date, but if you look at multiple graphs from COBR that went through SAGE, you can see that people were envisaging a scale of death that would overwhelm the NHS certainly in February.

Lead Inquiry: Late February, wasn’t it, Mr Cummings?

Mr Dominic Cummings: I would say early February.

Lead Inquiry: Well, we’ll have a look and you can tell us where those documents are.

Did SAGE tell you that, effectively, there was no means of controlling the virus once it had reached the United Kingdom?

Mr Dominic Cummings: I wouldn’t say that SAGE told us that, I would say that that was – that Number 10 was told that that was the consensus view of CCS and the Cabinet Office and the Department of Health and SAGE that fundamentally – fundamentally Number 10 was told in January and February that the most significant danger that we faced was a second wave happening later in 2020, and that was what everyone was trying to avoid, and that’s why the single peak by – single major peak by September approach was taken.

Lead Inquiry: We’ll come back to that doctrinal debate, that strategy. But I’m asking you, Mr Cummings, why, if it had become apparent to you that you had not been able to understand accurately what SAGE believed or you had not received a fair reflection on what SAGE was debating and what it thought, why after the first wave did you not bring about changes to the SAGE structure and the advisory structure in the way that you had advocated for the Cabinet Office, the DHSC, Number 10, the Civil Contingencies Secretariat, and so on?

Mr Dominic Cummings: Well, I literally did. I mean, we created the data science team, and part of the whole point of the data science team was that you had actual very deep technical experts that could red team and explore what SAGE was saying and give the Prime Minister advice on what was coming from SAGE, how to interpret it, potential problems with the advice that was coming from SAGE, et cetera, and that team actually did that job.

Lead Inquiry: Excuse me. That was data within Downing Street, you set up the 10DS, the 10 data system or 10 Downing Street data system.

Mr Dominic Cummings: Mm-hm.

Lead Inquiry: What changes did you advocate or propose in relation to the constitution of SAGE and the means by which it informed government of its advice?

Mr Dominic Cummings: So the main thing that I personally did was to institute the 10DS data science team because that was the exact appropriate kind of thing that Number 10 needed to interpret these scientific and technical questions with skills, with tools that didn’t exist at all in January, February, March in Number 10, or the Cabinet Office.

I did not regard it as my job to tell the SAGE people and Patrick Vallance how to manage SAGE. My view was that Number 10 and the Prime Minister’s office critically needed deep technical scientific and data science skills and tools right at the heart of power, that could interpret information coming in not just from SAGE but from everybody all around the whole system, including test and trace, including the Joint Biosecurity Centre and, you know, dozens of other entities.

Lead Inquiry: All right.

We’re going to move on to a new issue, which is the consideration of vulnerable and at-risk groups in the course of the decision-making between February and the lockdown decision of 23 March.

Can you tell the Inquiry, please, to what degree the position of vulnerable and at-risk groups was considered by decision-makers in Downing Street during the run-up to the decision to impose the national lockdown?

Mr Dominic Cummings: Could you say exactly what you mean by “vulnerable and” – whatever it was, I’m sorry?

Lead Inquiry: Yes. Persons who would be potentially vulnerable to the impact of a lockdown: members of minority ethnic groups, people who were vulnerable in terms of socioeconomic deprivation, victims of domestic abuse, people for whom there was plainly a case to be made that they would require specific consideration in terms of what the impact of the lockdown decision would be.

Mr Dominic Cummings: I would say that that entire question was almost entirely appallingly neglected by the entire planning system. There was effectively no plans or any plan even to get a plan for a lot of that. As you could see from the evidence, one of the most appalling things of the whole enterprise in lots of ways was on 19 March when we realised that there was essentially no shielding plan at all and the Cabinet Office was trying to block us creating a shielding plan.

I think there was a brilliant young woman in the Number 10 private office called Alexandra Burns who tried to raise warnings about things like wives who were being abused and children in care, and a lot of similar things, and I don’t think the system ever properly listened to her.

Lead Inquiry: Do you recall when the Prime Minister was advised of the risk of long-term sequelae arising from Covid infection?

Mr Dominic Cummings: Sorry, I don’t know what “sequelae” means.

Lead Inquiry: Consequences, so persons who suffered from what is now know as the syndrome Long Covid. When was it first understood that there could be long-term health problems, health conditions associated with –

Mr Dominic Cummings: It was obviously discussed in January in general terms, in the sense of Patrick and Chris and others saying to us: of course, you know, we don’t know what the long-term consequences of this might be.

They essentially said: you know, there’s kind of problem A, how many people it just kills immediately, but then there’s problem B, what the long-term health consequences might be. At the moment, obviously by definition, we’ve got no data and information on that.

So we knew of it as a general problem in January, but it really kind of bubbled up, I would say, but I’m guessing, if that’s – I’m not sure if that’s helpful, in roughly May.

Lead Inquiry: I think in May the Prime Minister shared on a WhatsApp group with you, the Chief Scientific Adviser, the Chief Medical Officer, you and Matt Hancock WhatsApp group an FT article entitled “Mystery of prolonged Covid-19 symptoms”. Do you recall that?

Mr Dominic Cummings: Vaguely.

Lead Inquiry: What about the issue of the disproportionate number of deaths in the black and minority ethnic communities?

Mr Dominic Cummings: I mean, it was discussed after the first wave.

Lead Inquiry: When did it first become apparent that there was a disproportionate fatality rate in those communities?

Mr Dominic Cummings: I can’t remember, I’d be guessing, but I think the data that came out of the first wave showed that that was an issue.

Lead Inquiry: All right.

Preparedness. Much of your statement focuses on your opinion that there had been a critical failure to plan for the type of pandemic which in the event ensued, and an absence of critical capabilities, as you described them. In essence, that in January and February 2020 there was no system, no plan, no structure in place that could have allowed either the borders to be sealed or for any kind of scaled-up test and trace process.

Dealing with those two aspects in turn, in relation to the borders, the material shows that in Downing Street there were – there was regular consideration, reconsideration, of what could be done in terms of keeping the virus out of our border. What was the advice that was received from SAGE as to whether or not that would be an efficient or effective process?

Mr Dominic Cummings: It was two-fold – sorry, three-fold. First of all, we didn’t actually have the capability to do it, because obviously Britain has not been able to control its borders for many years. It doesn’t have the data to do it, it doesn’t have the infrastructure to do it in general, never mind for a pandemic.

So, first of all, there wasn’t the capability. Second, we were told, even if we had the capability it would only delay things by a relatively trivial amount. Third, of course, people – at that time, the reaction from a lot of people was closing the borders is racist. You remember when the supermodel Caprice said on TV, “Why aren’t we closing the borders?”, a lot of people, public health experts mocked her as if she was an idiot. That was the prevailing conventional wisdom from the public health system. And was reflected – the dismissal of Caprice, I would say, was reflected in Number 10 by the public health system.

Of course if you’re going for a single – for a single wave herd immunity by September fundamental strategy, then faffing around at the borders wasn’t regarded as relevant or coherent with such a strategy.

Lead Inquiry: By that do you mean, if the strategy of the government was to accept that by mitigating the worst severity of that first wave of the virus and thereby allowing a proportion of the population to become infected nevertheless, there was no point in trying to shut our borders because part of that strategy entailed allowing part of the population to become infected?

Mr Dominic Cummings: Correct, that’s what the Prime Minister and I were told, and – yeah.

Lead Inquiry: But SAGE and NERVTAG specifically advised the government against border screening because they took the view that it would be ineffective: you can’t test, in the absence of a testing system, for asymptomatic patients; you can conceal your symptoms; you may even become infected on a plane and no symptoms will show until after you’ve arrived.

So did the government not appreciate that, in practical terms, such a step would be extremely difficult to put into practice?

Mr Dominic Cummings: Well, yes, we would – I’m not sure if I’ve misunderstood but – one of us has misunderstood. We were told that it was impossible. We were told the British state couldn’t do it in January. We didn’t have the infrastructure to do it, they didn’t have the tests to do it, they didn’t have any of the things that you needed to do it, to control the border.

But at the same time it wasn’t regarded as a big problem given that people didn’t want to control the border anyway.

Lead Inquiry: Is that fair, Mr Cummings? SAGE and NERVTAG produced papers which were sent to the government, and which you presumably saw, setting out why in practice screening, restrictions, even an elemental quarantine system would not work in practice. It wasn’t a doctrinal position, was it?

Mr Dominic Cummings: No, well, I think that – obviously, if you’re just saying do you create – do you actually control the borders, does that solve the problem, of course the answer is no. And if you’re looking just at the specific issue of what the effective control of your borders would be then, of course, the answer is clear and what SAGE and NERVTAG said makes sense.

But that’s obviously not the real question. The real question is: should you have the capabilities, like Singapore or Taiwan, to combine actual serious border controls with a domestic test and trace regime and the data to support it and all the other things you need to support it and then roll out mass testing?

If you had the capability to do that, which I very strongly suggest this country ought to acquire, then obviously controlling the borders is a critical issue.

Lead Inquiry: Mr Cummings, without a scaled-up test, trace, contact, isolate system, shutting the borders will not suffice of itself?

Mr Dominic Cummings: Correct.

Lead Inquiry: So the problem here was not that there was a doctrinal decision not to consider shutting the borders, it was that, in practice, it would do no good and without a test, trace, contact, isolate system, and there was none, it would never work?

Mr Dominic Cummings: Correct.

Lead Inquiry: Is that the nub of the issue?

Mr Dominic Cummings: It’s half of the nub of the issue, but the other half of the nub is that if you regard the whole thing in a fatalistic way anyway, which DH and the Cabinet Office and SAGE did at the beginning, and you think that there is no effective alternative to herd immunity – if you are saying that at an overall conceptual level there is either (a) shape a curve towards herd immunity or (b) try to build your way out of the problem, the entire system in January, February, early March thought that the only plausible approach to this was to shape the curve of herd immunity. No one thought it was really practical to build our way out of the problem. The fundamental U-turn that we shifted to was to try to build our way out of it instead of fatalistically accepting.

Lead Inquiry: The material shows that you spent a great deal of time in April, May, June, trying to get on top of the test problem.

Mr Dominic Cummings: Yeah.

Lead Inquiry: At what point in January and February, or indeed even March, did the penny drop in the government that the absence of a scaled-up or significant test and trace system effectively meant there was no means of controlling the virus once it had reached the United Kingdom?

Mr Dominic Cummings: Well, of course until the week of 9 March, the entire system was just sort of rolling along the single – single peak strategy by September. And there were conversations and references before that week to: we’ve obviously got to do more testing. But that wasn’t really in the – that was more just sort of, you know, we need more tests for the NHS and maybe a few thousand, and blah, blah, blah. It wasn’t conceived – testing wasn’t conceived at the end of February, beginning of March, in the context that it would be seen in April, May, June, ie scaling to hundreds of thousands, then millions, then potentially tens of millions.

I think what really brought it home certainly to me and the PM was when we were suddenly told in that week of the 9th, and it was one of the things that involved pennies dropping, that essentially testing had been stopped.

Lead Inquiry: 12 March?

Mr Dominic Cummings: Yes, if you say so, but, I mean, I know it was around then.

Lead Inquiry: So that we can understand the importance of this issue, is it your position that if there had been a sophisticated, competent system for test, trace and isolate in existence or brought into existence in January, February, March, and other countries, the Inquiry is aware, did precisely that – South Korea is a very good example – it may not have been necessary to go the whole hog and to order, to mandate the imposition of a national lockdown because the means of controlling the virus would have been at hand, with the test and trace system and, therefore, no need to control it with a lockdown?

Mr Dominic Cummings: Yes, my view is that what ought to have happened is that, as soon as the first reports came at the end of December, New Year’s Eve 2019, we should have immediately closed down flights to China, we should immediately have had a very, very hardcore system at the airports and borders, and there should have been a whole massive testing infrastructure ramping up both for test and trace in a kind of conventional sense but also a manufacturing and industrial capacity system to manufacture the rapid tests at scale, and I mean a massive scale, the scale of tens of millions a week.

I think if you had had the combination of actual serious border control in this country for the first time ever, actually controlling its borders and taking it seriously, with test and trace, and then a kind of out of the box “Here’s how you massively scale rapid testing”, and you put all of those things together – brackets, arguably also with huge hunch(?) trials on vaccines, close brackets – then I think in retrospect that’s clearly the right – it would have been a much better approach, not just in terms of deaths but also in terms of us being able to keep open the economy, you know, to a massively greater extent than we were able to, so it’s essentially both ways.

Lead Inquiry: You say, Mr Cummings, in retrospect, no one, not even you, with your keenness to ensure that the government system could be made to work efficiently, appreciated in February/March that without such a scaled-up test and trace system the options for the United Kingdom Government were going to be extremely limited indeed?

Mr Dominic Cummings: So I wouldn’t quite put it like that. We did appreciate that we didn’t have these things and, as you can see, there are references from me to Singapore and whatnot in multiple groups and emails and whatnot, and people like Marc Warner were saying to me, “Why is there just this fatalism on the subject?”

Lead Inquiry: Slow down.

Mr Dominic Cummings: So we were aware of it.

Lead Inquiry: But nothing could be done –

Mr Dominic Cummings: But it was obviously too late. You can’t just pull a system like this out of thin air in a few days.

Lead Inquiry: Conceptually, doctrinally, the British Government’s position in February and the early part of March had been: viruses come in waves, in order to ensure that the first wave doesn’t strike us during the winter months, the best policy is to mitigate it, to take the top off, delay it, so it’s closer to the summer, and that way we’ll avoid the risk of that wave, if it is completely suppressed, re-coiling like an uncoiled spring later in the year with a devastating second wave.

Plan A. Why was it not appreciated after March and April and the first wave that such a test and trace system would avoid the risk of a second devastating wave?

Mr Dominic Cummings: Well, with respect, I think it was appreciated, certainly parts of the system. You can see I wrote it on whiteboards around about 13/14 March as part of shifting to plan B.

So people in Department of Health and elsewhere were building up testing in February, early March, there were plans to do that, but we were not thinking – they were not thinking at that time about test and trace. Once we made this flip around about the 13th to the 15th, we talked to – I talked to the PM about it on Saturday 14 March and Vallance and I talked to the PM about it on Sunday 15 March as part of this alter – different conceptual approach of building our way out of the problem.

Lead Inquiry: You misunderstand me. During that first stage with plan A, with mitigation, the argument being put against suppression was: it will re-coil like an uncoiled spring with a devastating second wave. If you push the first wave down it will spring back?

Mr Dominic Cummings: Yes.

Lead Inquiry: So before the change in strategy, why was it not understood: well, don’t worry, we will deal with the first wave but by the time the second wave comes along, if it does re-coil like an uncoiled spring, we can deal with it with a proper test and trace system? Why wasn’t that debate had when the government was still in the first strategic response?

Mr Dominic Cummings: So if you’re asking me why were we not talking about test and trace before, roughly, say 13 March –

Lead Inquiry: Yes.

Mr Dominic Cummings: – the answer is because no one, before – remember, in the – the first time that – there was no plan for lockdown at all in the week of the 9th. The plans for lockdown only came after we started to change. So there was no – the whole point of the problem up to the week of the 9th was that the whole system fatalistically thought there was no way you could possibly do a lockdown in Britain, it was thought of as the completely crazy idea, so of course people were not thinking, “Well, let’s do lockdown and then build test and trace”, everyone thought, “Well, we obviously can’t do lockdown, and lockdown’s mad because it will all come back”.

Lead Inquiry: But they were thinking about and they were advocating suppression, that is to say the squashing down completely of a first wave?

Mr Dominic Cummings: No, sorry, who do you think was arguing for that?

Lead Inquiry: The one wave strategy, Mr Cummings, envisaged a mitigation and then this argument arose as to whether or not a suppression strategy which allowed the wave to re-coil, the spring to uncoil, would result in a second devastating wave, so why was there not a debate about what could be done to prevent that second wave? Why was it not thought about?

Mr Dominic Cummings: Well, I think I’m not quite – possibly I’m confused by your language here, I’m not quite understanding your question. But I’ll try and put it this way: up to and including the week of the 9th, the assumption was – so you’re suggesting there was some great debate. The whole point was there wasn’t a debate. There was an assumption across government, across the Cabinet Office, Department of Health and SAGE that lockdown was impossible in a western country: anyway we didn’t have all of the things that you needed in place to actually do it, you didn’t have test and trace and whatnot that you would need to have afterwards, that vaccines were almost definitely not going to have any impact at least in 2020 and possibly never. So the whole point was that, up to and including the week of the 9th, the debate you keep referring to, there wasn’t a debate, that was the whole problem.

There wasn’t a debate about the fundamental assumptions underlying plan A. There wasn’t a debate until me and others started saying “Hang on a second, if you actually follow the logic of what plan A is, it’s going to be a catastrophe and we have to ask these questions and we have to consider an alternative plan B”, but before that there was no debate about this, it was just assumed.

Lead Inquiry: There was a debate at the scientific level between mitigation and suppression, but it may be that that debate and the merits of mitigation versus suppression simply didn’t reach your level in government –

Mr Dominic Cummings: Of course –

Lead Inquiry: – and you weren’t aware the scientists were debating the pros and cons of mitigation versus suppression?

Mr Dominic Cummings: Of course it was discussed by people, but as you can see in all of the SAGE and DH documents, the assumption from everybody was that it was simply completely impractical, and everyone was still on the mindset of a flu pandemic. So of course there were debates, you know, in one sense going on and there were scientists, you know, et cetera, et cetera, but the core of what we were presented with in Number 10 was: there is unanimity between the Cabinet Office, Department of Health and SAGE behind the propositions that the real danger is a second wave in the winter and, therefore, you have to manage a single peak strategy so there’s herd immunity by September. That was the core argument that we were presented with. And that was never really properly – the first time I actually saw that being tested was on 18 March when Demis Hassabis said to SAGE, essentially, “I think this whole plan is mad and you should immediately lock down, like, now, this hour, tell the PM to do it immediately”, and that kicked off various discussions.

Lead Inquiry: The consequence of the absence of debate, the failure to consider any alternative, the failure to consider strategic options, other than mitigation and squash the sombrero, was that there was a woeful absence of plan, any sort of written document for dealing with controlling borders, protecting care homes, shielding, quarantine?

Mr Dominic Cummings: Correct. I mean, I would say it’s actually worse than that, and sort of doubly ironic, because if you actually – if plan A had been what ended up being plan B, ie we’d actually got on top of it and controlled it, and you had a test and trace infrastructure and everything else, then there would actually be a much stronger argument for saying, well, a lot of the shielding stuff we don’t need, a lot of this we don’t need, a lot of that we don’t need because we’ve actually controlled the virus.

Lead Inquiry: Mr Cummings, please slow down. You’re making it extremely difficult to record your evidence.

Mr Dominic Cummings: Apologies.

Lead Inquiry: And to be fair –

Mr Dominic Cummings: Sorry, just to finish that point, because it’s important.

Lead Inquiry: Yes.

Mr Dominic Cummings: The situation is worse than what you’re describing, because if you are not going to control the virus, if you are not going to have test and trace, if you are just going to have single peak herd immunity by September, it actually makes the lack of a plan for shielding and care homes and everything else even more crackers, do you see my point?

Lead Inquiry: Yes. And to be fair, you texted Mr Hancock on 23 January about the existence, the whereabouts of pandemic plans and preparations. I think you asked, “To what extent have you investigated preparations for something terrible like Ebola or flu pandemic?” And you were reassured that there were full plans up to and including pandemic levels prepped and refreshed.

It became obvious, and it’s obvious from your statement, that you appreciated that there were no plans of the type that you’ve described.

By the middle of March, so 16 March, a week before the national lockdown, had Number 10 still been provided or had it been provided in any way with departmental plans, Cabinet Office plans, from line departments dealing with these various aspects of a coronaviral pandemic?

Mr Dominic Cummings: Essentially, no. There were – odd dribs and drabs came in. You can see from various evidence of texts and emails from me, after talking to Hancock I pushed on some of these things through February. Imran did as well, from private office. But we gradually became aware through the course of February that, essentially, what Hancock had told me on the 25th – sorry, correction just on the date, by the way, the Inquiry and I have wrongly changed the date from the 25th to the 23rd of that text message. So my statement is now wrong, but it should be 25th, but we’ll correct that afterwards.

Lead Inquiry: Well –

Mr Dominic Cummings: But yes, during the course of the 25th, we – sorry, in the course of February we realised gradually, as we pushed and probed and asked questions for these plans, that they fundamentally didn’t exist, and on the 16th I think you’re probably referring to a shocking email in Number 10 that says, essentially, the Civil Contingencies Secretariat says that these plans are not even held centrally at all.

So it turned out, to our horror, that the system that we’d been told repeatedly in Number 10, trust the system, SPADs shouldn’t get involved, world leading, best prepared in the world, blah, blah, blah, it then turned out that this supposedly brilliant system that the Civil Contingencies Secretariat had not even seen these documents at that time because they were not held centrally, which was … I mean, when that email was circulated, people thought it was almost like a spoof.

Lead Inquiry: All right. In fact, we do have, of course, your text message to Matt Hancock and his reply, your very own letter and statement have a screenshot, and it shows 23 January. It says in terms, 23 January 2020 –

Mr Dominic Cummings: It does, the reason for that is –

Lead Inquiry: – “To what extent have you investigated?”

Mr Dominic Cummings: It does, the reason for that is I was told by the Inquiry that I got the date wrong and I should change it from the 25th to the 23rd –

Lead Inquiry: Well –

Mr Dominic Cummings: – but I actually checked it and it should be the 25th.

Lead Inquiry: Don’t trouble yourself. Your own screenshot provides the date of 23 January 2020.

So there were a number of COBR meetings at the end of January and the beginning of February. I want to ask you about an important COBR meeting on 5 February, INQ000056215.

Page 1 sets out the ministers who attended.

Page 2, the officials, and those who dialled in. We can see that, on behalf of Number 10, Imran Shafi attended, along with Sir Ed Lister.

Page 3, the attendees in terms of the chief medical officers.

Page 5, paragraph 2, the CMO provides an update to COBR providing information about the number of individuals who had died and how long they had been in hospital before they died. This is all to do, of course, with cases abroad, in particular China. The two most high risk groups appeared to be the elderly and those with pre-existing illnesses.

If you could scroll back out, page 6, between paragraphs 9 and 11 there is a debate about planning for a reasonable worst-case scenario, and the director of the Civil Contingencies Secretariat sets out the planning priorities for the work under way to develop planning assumptions for the pandemic flu reasonable worst-case scenario.

There is then a debate about communication strategy, an emergency Bill, and work with local resilience forums.

On this day or the day after, you sent a text to a WhatsApp group, the “NumberTen action” WhatsApp group, saying:

“chief scientist told me today it’s [probably] out of control now and will sweep the world.”

Were you aware of the tenor of the debate and what was being discussed in COBR on 5 February?

Mr Dominic Cummings: Probably, I mean, I don’t remember that particular – all of these meetings now, I’m afraid, blur into one another.

Lead Inquiry: Had you seen this minute of the 5 February COBR, you would immediately have understood that the thinking expressed in this meeting was not that which you had been told, which was to the effect that the virus was probably out of control now and will sweep the world. Did that not concern you?

Mr Dominic Cummings: Yes.

Lead Inquiry: What did you do around 5 and 6 February to say “This COBR appears to be proceeding on an incomplete, inaccurate basis, it isn’t reflecting what I understand to be the reality, which is that the virus is probably out of control and will sweep the world”?

Mr Dominic Cummings: So, I – I can’t remember exact – obviously now it’s three years ago, I can’t remember the exact days and whatnot, but around this time – so I spoke to Patrick before obviously that text was sent. I spoke to Patrick again – I probably spoke to him each day, actually, 5th, 6th, 7th. We had a conversation about this and about the briefing of the PM. Patrick and I agreed that we thought the PM had not been sufficiently briefed on a lot of this – on these questions and we were concerned about it, and we agreed that I would fix up for there to be a meeting as soon as possible with the PM in his office, and that meeting happened on – I mean, it will be in the documents, I can’t remember exactly when, but very shortly after – after this.

I think Patrick said to me something like, you know, this needs to happen straightaway, it’s possible that that was the Friday and I organised it for the Monday, but my recollection of these dates could be a bit off.

Lead Inquiry: There was a meeting on 10 February.

Mr Dominic Cummings: Is that the Monday?

Lead Inquiry: Between 10.45 and 11.15. That could possibly be a Monday or maybe a Tuesday. So that would fit with what you’ve said.

There was another COBR meeting on 18 February.


Pages 1 to 3 give us the attendees, and page 5 gives us a sense of what was being discussed: repatriation of British nationals.

Then, over the page: legislation, a debate about the drawing up of a Bill to be employed in a reasonable worst-case scenario.

Then over the page, please, page 7: “Planning for a Reasonable Worst Case Scenario (RWCS) – next phase”, the Civil Contingencies Secretariat said there was work to be done to create a clear plan of activity from the moment of sustained transmission to its estimated peak.

Was there an understanding in Number 10 that a debate about repatriation and the drawing up of appropriate legislation and the drawing up of plans to deal with a reasonable worst-case scenario did not really reflect what needed to be done in response to the information that was then available?

Mr Dominic Cummings: Certainly by some of us in Number 10 at that time, there was, yes, but remember an awful lot of the senior people in the centre of Whitehall were off on holiday at this time.

Lead Inquiry: The Prime Minister, the evidence shows, received a note in his box on 30 January, around about the same time, about coronavirus. He expressed the view on 31 January that he wanted to spend more time discussing issues with ministers, and then he received an update on 3 February from the Civil Contingencies Secretariat.

There was then an email with an update on have referred.

We’ll just have a look at the diary for that, INQ000136739. This is the diary for the Prime Minister between 10 February and Friday 14 February. On 10 February, so you’re right, it’s a Monday, 10.45 to 11.15, “Coronavirus Update”.

Before he went to Chevening, which he did on 14 February, he received a note in his box, INQ000136743, page 4:

“Coronavirus/international response: containment of the virus in China is a key part of preventing the spread of the outbreak to the UK.”

If what you were told by the Chief Scientist was right, the Chief Scientific Adviser was right, Mr Cummings, that there was an inevitability or a probable inevitability to the virus sweeping the world, then any debate about whether or not

the virus could be contained in China was out of date.

Why was the Prime Minister not told, “Evidence is

now emerging that this virus is out of control and will

likely sweep the world, and debate about international

repatriation and drafting of legislation and doctrinal

identification of reasonable worst-case scenarios is

behind us, we need to deal with that loss of control”? February, and the meeting on 10 February to which you 8 A. Well, I think there was still – I think there was still

an awful lot of – so at the meeting that Patrick and

I asked for on the 10th, from memory these things were

discussed. But remember at that point it was still not

at all seen in Whitehall like this is going to be –

nobody really in Whitehall thought that a month from now

we’re going to be in – in – the biggest crisis

the country has seen in – since 1945. The view was

much more that if this is really going to happen, it’s

not going to happen for months. And you can see

repeated references in documents to Number 10 and

the Prime Minister that refer to, well, if there is

sustained community transmission in Britain, then

the crisis will come sort of two or three months after.

Which is repeated in various documents.

I remember at this point, although there was in

fact, we now know, sustained transmission in this

country at that time, that was not known then. So the whole system was at this point – and not just now, but three weeks after this point – still thinking of this as something that was going to land on people in May/June, not something that was going to overwhelm everybody in mid-March.

Lead Inquiry: You had sent a text to the Number 10 action WhatsApp group on 6 February saying the “chief scientist told me today it’s [probably] out of control now and will sweep [the] world”. You plainly told the other communicants to that WhatsApp group of what you had been told by the Chief Scientist?

Mr Dominic Cummings: Yeah.

Lead Inquiry: But during this next week, before the Prime Minister departed for Chevening, why was that message not being re-communicated to him in notes that were sent to him? Why was he not being told in this note, “Well, the Chief Scientist’s view is it’s probably going to sweep the world, it’s coming”?

Mr Dominic Cummings: Well, I think it was just part of the general, the general view from the Department of Health and the Cabinet Office that this was all still, you know, murky and in the future. They weren’t banging alarm bells at this point. Far from it, they were going skiing.

Lead Inquiry: Why weren’t you, though, Mr Cummings? You were the one who had spoken to the Chief Scientist or received a text from him?

Mr Dominic Cummings: Well, as you can see, I spoke to the Chief Scientist on multiple occasions and I organised a meeting for him and Whitty to come in and talk to the PM and as they requested.

Lead Inquiry: In the notes that went to the Prime Minister around the same time, why did you, as his adviser, perhaps chief adviser, not tell him, “My information is containment has failed, the virus is coming”?

Mr Dominic Cummings: Well, I did tell him that.

Lead Inquiry: It’s not here.

Mr Dominic Cummings: Well, the fact that things are not written down doesn’t mean that they weren’t communicated. Obviously, I was talking to the Prime Minister about all sorts of things all the time and things that I – as I said, I was having repeated conversations with Patrick, many of which were not actually recorded in diaries, from early January onwards. So lots of things like this, I passed on. But overall, as you can see, the system did not – was not in emergency mode at this time.

Lead Inquiry: Do you accept that there is no formal communication to the Prime Minister from anybody at this stage saying “The information from the Chief Scientist is to the effect that containment has likely failed”?

Mr Dominic Cummings: You have the documents, not me so, if you say so, I’m sure that’s right.

Lead Inquiry: Then the Prime Minister went to Chevening –

Lady Hallett: If you’re moving on, Mr Keith –

Mr Keith: Yes.

Lady Hallett: – I think it’s probably time for a break –

Mr Keith: My Lady, of course.

Lady Hallett: – sorry to interrupt.

3.15, please.

(3.02 pm)

(A short break)

(3.15 pm)

Lady Hallett: Mr Keith.

Mr Keith: So, Mr Cummings, by 17 February, some members of SPI-M-O and SAGE were reporting the belief that there was already sustained transmission in the United Kingdom. On 21 February news emerged of a cluster of locally transmitted cases in Lombardy in Italy, and a lockdown began there, you’ll recall, of a number of municipalities.

On 23 February, the DHSC reported 13 cases in the United Kingdom. The paperwork shows that the pace of the government tempo, the tempo of work in government declined notably between 14 February and 24 February, which coincidentally is half term.

Why was that?

Mr Dominic Cummings: I think it was a combination of, as I said earlier, the general perception of the senior people handling this in the Cabinet Office, DH, at the time was that if this proved to be a big problem, and it still was an “if”, then it was seen as really quite a distant problem, it was not seen as an emergency crisis.

Secondly, as you remark, I did not go on holiday, but many of the senior people were on holiday during that time, including the PM.

Lead Inquiry: There was no COBR between 18 February and 26 February, was there?

Mr Dominic Cummings: Don’t know.

Lead Inquiry: There were no Cabinets, there were no Cabinet meetings during that time, do you recall?

Mr Dominic Cummings: I don’t recall.

Lead Inquiry: There were no notes sent to the Prime Minister or emails between 14 February and 24 February?

Mr Dominic Cummings: I find that – I think that’s more likely to be a gap in the paperwork than reflecting reality.

Lead Inquiry: In relation to coronavirus?

Mr Dominic Cummings: I don’t know.

Lead Inquiry: He went to Chevening on 14 February, he returned to Downing Street three times, for work. His diary shows that there were a handful of meetings while he was in Chevening, but he received from his team in Downing Street absolutely nothing in relation to coronavirus between 14 February and 24 February.

You were part of that team. Why was he not kept in the loop in relation to the developing crisis?

Mr Dominic Cummings: Well, partly for the reasons I’ve already said, it wasn’t seen as an imminent crisis in the Cabinet Office and by the Cabinet – by the systems responsible for dealing with crises. When he did briefly reappear for meetings, for example, on the meltdown in the Home Office, Imran and I did talk to him about coronavirus, and we did try to get into his head that this was a growing problem and it had not gone away.

Lead Inquiry: You say there was a lack of understanding that there was a crisis. You had received text messages or information yourself that the virus was probably out of control. COBR had been reporting that there was now clear evidence of sustained transmission outside China. You knew and Number 10 knew that the virus had exploded in Italy, and you knew there were cases already in the United Kingdom. How can it possibly have been thought that there was no crisis?

Mr Dominic Cummings: Well, as I said, round about – when the Prime Minister went away on holiday, after the reshuffle, around about sort of 13th/14th, 13/14 February looked very, very different to 28 February, so things evolved a lot over that period of time. You are of course – I mean, your fundamental point is obviously correct, that there was indeed a massive crisis, it was indeed pretty insane that so many of the senior people were away on holiday at that time. But it’s also important to realise that it’s not like the Civil Contingencies Secretariat or the National Security Council, or any of the organisations in charge of this, were beating the drum and saying, “We’ve got to get the PM back, this is a massive crisis”. In fact, quite the opposite. As Patrick Vallance and others have pointed out, apart from me, the NSC and other things were treating it like the rest of Whitehall was, like maybe this will be a big problem but if it is it’s going to be in May or June.

Lead Inquiry: If it was insane, as you have described it, for them to be away, to be on holiday, or whatever everybody was doing, and for there to be a complete absence of administrative push in relation to coronavirus during that ten-day period, why weren’t you banging on the metaphorical door of Chevening saying, “You’ve got to come back, we have a crisis, this virus is about to overrun us”?

Mr Dominic Cummings: Well, I was talking to all sorts of people in that period, I was not on holiday and I was pushing and talking to Patrick and other people, but I did not regard, and neither did other people – we did not think that asking the PM to come back and talk to COBR or Whitehall in general at that point would have been productive. In fact, I thought it would have been counterproductive because I thought he would have said to everybody what he thought at the time, which was, “This is another swine flu, it’s all another rubbish media hoax, nothing will happen, blah, blah, blah, blah, blah, the real danger is the economy getting talked into a slump”. I thought that if he came back from Chevening and said that to COBR or any other part of government it would be counterproductive rather than helpful.

Lead Inquiry: So are you saying you did actively consider the possibility of asking him to come back and talk to COBR or Whitehall?

Mr Dominic Cummings: Yes, it was discussed while he was away.

Lead Inquiry: With who?

Mr Dominic Cummings: I discussed it with Imran and I discussed it with Martin and others in Number 10.

Lead Inquiry: Is there any record or any note whatsoever of that debate, Mr Cummings?

Mr Dominic Cummings: Don’t know.

Lead Inquiry: Are you surprised to hear that there is no note as far as we can tell of asking the Prime Minister to come back and take charge of the crisis?

Mr Dominic Cummings: No, not surprising, because they were conversations. You know, it was all people in the same – sitting next to each other at work.

Lead Inquiry: Well, you’re not averse to sending WhatsApps and texts 24 hours a day, Mr Cummings?

Mr Dominic Cummings: No, I’m not but, as I say, I was sitting right next to Martin and Imran, I didn’t have to – I didn’t have to – you know, this was conversations that we had around the office at that time.

Lead Inquiry: INQ000236371. WhatsApp messages, “NumberTen action”, page 47. On 27 February, after his return from Chevening, Mr Johnson said, in response to a suggestion from Lee Cain:

“I think a Monday coronavirus [COBR] meeting with the PM [as] chair [very] important to show grip. Suggested to Martin [Reynolds] earlier So think he is handling.”

Dominic Cummings:

“Yup. We shd pencil in an interview early next week on this too. We gotta sort stuff out over the next few days but Monday must be a new level …”

And Mr Johnson says at the end of this particular thread:

“Not sure if it can wait till Monday.”

There is no reference there to the possibility that he’d been asked to come back earlier or that there should be a COBR while he was in Chevening, is there?

Mr Dominic Cummings: No.

Lead Inquiry: And he asked or he said:

“I am not convinced we are showing grip on corona.

“We need to have a cobra.

“Not sure if can wait till Monday.”

There had been four COBRs already, had there not?

Mr Dominic Cummings: I don’t know how many there had been.

Lead Inquiry: Well, you know that there were four or five COBRs up to that point?

Mr Dominic Cummings: Yeah, something like that.

Lead Inquiry: But he had hitherto not shown any inclination to take a grip by chairing a COBR himself?

Mr Dominic Cummings: Correct.

Lead Inquiry: On page 48 –

Mr Dominic Cummings: To be fair to him, nor was the system generally pushing him to.

Lead Inquiry: Well, your evidence is that you might not have wanted him to chair a COBR in any event because you were fearful for what he might say?

Mr Dominic Cummings: Correct, but I would say that’s unofficial conversations. My point was the official system wasn’t pushing him to try and do a COBR, as far as I recall, but we also weren’t trying to push the official system to do it because we were fearful that it would actually be counterproductive.

Lead Inquiry: So you were in part responsible for him not having chaired COBR hitherto?

Mr Dominic Cummings: That’s a funny interpretation to put on it, but …

Lead Inquiry: Well, you didn’t want him to, you were fearful of what he might do if he was allowed to chair COBR?

Mr Dominic Cummings: As I said, the system wasn’t pushing him to and I didn’t think it was wise to try to force the system to change its mind, I thought it would be counterproductive.

Lead Inquiry: On page 48, one further page on, please, you returned to your usual theme of Mr Hancock:

“[He’s] a know nothing on comms and he’s totally failed viz the Corona comms team … I am having to convene mtngs to sort shit out this afternoon.”

Mr Johnson asked for a conference call at 5.

Could you scroll back out, please.

At the bottom of the page, Lee Cain:

“Can we have a pm update call today …”

Mr Johnson:

“Frankly there is no limit to the stuff I am willing to do to show we are gripping this.”

By this time, Mr Cummings, it was becoming apparent that there was a complete absence of planning or of significant plans. There had been – well, it was evident that there was no means of controlling the spread of the virus once it had reached the United Kingdom. It was plain that there was sustained community transmission from the number of cases the DHSC were reporting by the end of February. Why was the Prime Minister left in a position in which only now he was saying, “There’s nothing I won’t do to try to get a grip on this crisis”?

Mr Dominic Cummings: Well, I think I’ve already explained the fundamentals of this. The system didn’t regard it as a crisis while he was on holiday. The system didn’t push him to come back from his holiday. However, in the last week of February everything started to move dramatically differently. As you referred to, everything kind of kicked off in northern Italy.

And crucial in terms of the PM, the media suddenly were all over this, and it was suddenly dominating, and that meant that Whitehall in general then shifted. We in Number 10 were starting to realise that all sorts of things were problematic, for example, PHE, the agency in charge of – nominally in charge of dealing with this had come to Number 10 and to me asking for help with the communications plan for coronavirus. That’s what that reference was to regarding Hancock and co. So we were starting to, and also as you know there’s an email from – then on 25 February I was saying: where are all of these red teams, where’s all this testing and whatnot that Hancock promised us existed? Where are these documents? And we at Number 10 were starting to get a feel for the absence of things and a feel for the fact that the first wave of all the communications plans was a nightmare, et cetera.

Lead Inquiry: Mr Cummings, you say the system didn’t push him to come back, the system didn’t regard it as a crisis, the system didn’t do that, but you were part of the system, why weren’t you pushing for these things?

Mr Dominic Cummings: Pushing for what?

Lead Inquiry: For him to come back and take a grip on the crisis?

Mr Dominic Cummings: I’ve already explained that, that I regarded him coming back at the time when the system – so the system was not pushing him to say, “This is a crisis”. If he had come back on 15 February he’d have said what he’d already been saying in the previous ten days, which is “This is all balls, it’s all swine flu, the real danger is the economy, blah, blah, blah, blah, blah”.

So that would have been, to me, highly counterproductive, given that me and Patrick and others were very worried about it. Of course, these things are a very fine balancing act. And you can see the problems we had on this with the handshaking, which happens, you know, roughly at this time, where I tried to push him on handshaking and then it completely boomeranged. So we had to be very careful with how we handled this nightmare problem.

Lead Inquiry: You say that there was a step change or rather the system changed direction in the first week in March, but the government published on 2 March a coronavirus action plan, “Contain, Delay, Mitigate”, which was described by Mr Warner in an email to you and others that it wasn’t a plan, it was a communication framework.

Mr Dominic Cummings: Yeah.

Lead Inquiry: You understood perfectly well that it wasn’t much of a plan, it was a comms plan if it was anything. Did you alert people to the fact that a plan for “Contain, Delay, Mitigate” was likely to be of little use given that containment had already failed?

Mr Dominic Cummings: There were certainly at this time growing conversations, this time ie when this plan was published, as you refer to. Ben Warner was immediately astonished when he saw this document. Other people in Number 10 similarly, Imran and others. And this contributed to our growing sense that: hang on a second, we’ve been told that we’re the best prepared in the world, we’ve been told that all of these things exist, this document is obviously pretty much a joke, like, what the hell is going on?

So yes, at that time, you know, there was a sort of – there was an exponential curve of the virus but there was also an exponential curve of alarm in the PM’s office and elsewhere in the system.

Lead Inquiry: Where are the emails from you saying, as the chief adviser to the Prime Minister, “Our sole and primary coronavirus action plan ‘Contain, Delay, Mitigate’ is a joke?

Mr Dominic Cummings: I don’t know if there were such emails.

Lead Inquiry: During the course of that week, more and more evidence came to light, both of the spread of the virus in Italy, which had increased five-fold, more measures were proposed to combat the spread of Covid in the Lombardy and other northern provinces, and as you’ve described in your statement, Marc Warner and you debate on 7 March your incipient concerns about plan A.

On 10 March, so a matter of days after your concern had started to emerge about the whole strategic direction that the government had embarked upon, the Civil Contingencies Secretariat prepared a note, INQ000049583, in which the director of the CCS stated in paragraph 1:

“Covid-19 looks increasingly likely to become a global pandemic, although this is not yet fully certain.”

The note sets out the views of the CCS as to the need to have fast-tracked legislation to effectively manage the outbreak. It deals with excess death management and the need for plans to be drawn up.

Did you or anybody else push back against this document and say, “It is absurd to believe that a Covid-19 global pandemic is not yet fully certain”, given the concerns that you were beginning to have?

Mr Dominic Cummings: Yes, throughout this – 9 March is the Monday, throughout this week, having – as you say, having spoken to Marc and others over the weekend, well, actually over the previous week, as you can see from multiple messages, from this day onwards I was very concerned. And this document also was, you know, one of many documents that appeared at that time that seemed to some of us in Number 10 to make clear that the system was miles off the pace.

Lead Inquiry: Because they simply didn’t reflect the change in thinking or the emerging understanding as to how far the virus had spread in the absence of means to control it.

Mr Dominic Cummings: Also I think a really crucial and underrated aspect is the speed. You know, one of the things that’s very striking, looking back, preparing for this, is how even in the week of – even when you go forward a week to the 16th, and indeed even if you go forward another week to the 23rd, the week of the lockdown, there were still documents repeatedly coming through from CCS and COBR and the Cabinet Office showing the crisis peaking in end of May, beginning of June. And I think this is really critical to understand. The fact that that was still on graphs in the week of the 26th is genuinely astonishing in retrospect, because of course it’s completely false.

What a critical thing at this point, on the 9th, was that partly because Marc Warner – at this point he had his data team embedded with the NHS and they were getting better and better data out of the NHS, this is the period when we in Number 10 to some extent started to short-circuit the Cabinet Office system and CCS, because we were getting information directly from the NHS. And we started to realise, hang on, there is a fundamental mismatch between the shape of the curve that’s coming out of these graphs coming from COBR and the Cabinet Office, peaking at the end of May/June, and the information that we’re getting from the NHS, which is showing that the crisis is almost upon us.

So this was all – this was increasingly alarming all the way through this.

On the 9th, I think it was, I asked Imran – again, you know, this was not supposed to be a job for SPADs and it was not supposed to be a job for Number 10. I said to Imran, “Please get in touch with Simon Stevens’ office and get data directly from Stevens’ office to here so that we can see what they’re talking about”. You can also see chatter between Warner and Patrick on this exact subject.

Lead Inquiry: Just pause there, that’s a very long answer. I’m going to ask you about Ben Warner.

He received an email from Professor Neil Ferguson on 10 March, in which Professor Ferguson asked him to show or to distribute to the Prime Minister and Cabinet documents relating to the surge demand and daily number of deaths that were likely. So that was another source of information coming into Number 10 at that time.

Mr Dominic Cummings: Yeah.

Lead Inquiry: On 10 March, the Cheltenham Festival commenced, and on the same day Public Health England data presented at SAGE suggested that the true number of cases in the United Kingdom was to be measured in the tens of thousands. Professor Ferguson challenged Number 10 officials at that SAGE meeting and asked them: do you know what an epidemic with 4,000 to 6,000 deaths per day would feel like?

What was the reaction in Number 10 when that information was relayed back to you?

Mr Dominic Cummings: Erm … well, it obviously, it contributed to our – to our growing sense that something had gone horrifically wrong in the communication between SAGE, DHSC and the Cabinet Office about not just the scale of the problem but the speed of the problem.

Lead Inquiry: Was there then a reconsideration of the wisdom of allowing mass gatherings to continue?

Mr Dominic Cummings: It was discussed in the context of the Cheltenham event, but again the PM was advised at the time that banning – banning mass events would – so what the PM was actually told at that time was: if you ban mass events, PM, then people will just go to pubs instead and that will be even worse.

Of course now the obvious question is: but why are they all going to pubs? But remember, there was no plan for lockdown on 9 and 10 March, there was no plan for stopping all of these things. So if you’re not going to close pubs, then you can see the kind of twisted logic of, “Well, don’t stop things like Cheltenham or football matches and everything else “.

Lead Inquiry: On 11 March, you sent a WhatsApp message, INQ000102697, page 17, where you say in the middle of the page:

“I think it is really important that senior people understand, and are able to discuss with [Prime Minister] this fundamental question: all sensible people can see the trajectory and how social distancing will be needed to flatten curve. very sensible people … are saying ‘the risks of delay are MUCH higher than the risks of going too soon’.”

Then you say in capital letters, a little further down the page:


Mr Dominic Cummings: Yeah.

Lead Inquiry: Was your appeal heard, Mr Cummings?

Mr Dominic Cummings: No.

Lead Inquiry: Why not?

Mr Dominic Cummings: It’s a very complex question, to which I don’t have a clear answer. I think – I think – well, obviously (a) at this point SAGE people were still going on TV saying, “Well, the plan is herd immunity and it makes sense”, so the fundamental plan A strategy was in place on the 11th. But they … there was also at this point this – this concept of “behavioural fatigue” that people kept referring to, and I think this is a really – a really critical question.

Lead Inquiry: Well, then, just pause there. On behavioural fatigue, what was the genesis of this notion that if you went too early people would struggle to sustain their commitment?

Mr Dominic Cummings: So we were told, the PM was told and I was told, in this week that it came from SAGE and SPI-B. However, obviously, since then, SAGE and SPI-B people have all rushed to try to claim that it was, “Not me, not me”. So I don’t think it’s actually been – I don’t know what the answer to this is. What I do know is that Patrick and Chris talked about this concept in this week, and this was another red flag for some of us in Number 10, because of course some of us had worked on political campaigns and we knew that an awful lot of stuff coming from so-called “behavioural scientists” turned out to be dodgy science and dodgy papers and dodgy concepts, so we were worried about this. But in that week the – a critical meme that kept being repeated was “This has to be done at the right time, this has to be done at the right time”.

Lead Inquiry: When you say “the PM was told and I was told”, so that we are clear, Mr Cummings, who told you that there was a problem with maintaining commitment?

Mr Dominic Cummings: This was referred to by Patrick and by Chris in their briefings in the PM’s office. Though they said that this had come from SAGE. And of course they referred to it publicly in various documents.

Lead Inquiry: This was all intimately bound up, of course, with the understanding of herd immunity, the one wave strategy, you’ve got to allow people to – you’ve got to allow parts of the population to become infected, that will reduce the risk of an uncoiled second wave and so on and so forth, and at the same time –

Mr Dominic Cummings: Exactly.

Lead Inquiry: – this idea took hold that you couldn’t go too soon because whatever measures were put in place were unsustainable?

Mr Dominic Cummings: So (a) that they might be unsustainable but (b) remember the fundamental distinction, that if you’re going for a single peak strategy then they didn’t want to go too soon because that would actually suppress things and then the thing would just pop back up straightaway.

Lead Inquiry: Indeed.

Mr Dominic Cummings: And that’s why when you asked, you know, was my question properly answered, in the all caps here, “WHY NOT MOVE NOW AND FLATTEN CURVE EARLIER ?”, that logic is the logic of Gowers and Hassabis and the Warners. That logic is logic of, if you are actually not going to do a single peak, if you are actually going to control it and suppress it now, then the simple logic of exponential curves means that, of course, the sooner you do it the better. But that was not what the planning assumption was on the 11th.

Lead Inquiry: Were you readily persuaded that the herd immunity approach or rather the one wave strategy was the wrong way to go?

Mr Dominic Cummings: It’s obviously really hard to reconstruct psychology exactly but I would say that by this time of – certainly in the week of the 9th, 10th, 11th, I had growing doubts on an hourly basis. By the 11th I was pretty much in – so by the 11th my view was I’ve got an appalling feeling that I’m being one of those like historic catastrophes like July 1914.

I’m not completely sure of it, but I’ve got some very smart people coming to me saying this is a – (a) fundamentally the strategy is wrong, misconceived, but also at a practical level at this point, remember I was sitting in an office and suddenly overhearing people having phone calls about whether local authorities could book out ice rinks and get trucks to carry massive numbers of bodies and store them in ice rinks. These conversations suddenly exploded in the week of the 9th in Number 10. So we had on the one hand a kind of – a fundamental argument: is the strategy misconceived or not? But we also had this sort of growing cascade of nightmare conversations going on around us when we realised that the system was just completely out of control in terms of coping with its original plan A.

Lead Inquiry: Could we have INQ000173144, please, on the screen, page 1.

Mr Hancock, in a WhatsApp message with Damon Poole, dated 23 May, says:

“Herd immunity was never the Government strategy, but it was what Dom was pushing until he was finally persuaded to drop it in early March.”

Is that a fair assessment?

Mr Dominic Cummings: Well, it’s obviously laughable.

Lead Inquiry: When did it become apparent that modelling may not have been necessary in order to drive home the point that with the number of deaths and hospital cases that were the inevitable result of the infection fatality rate and the hospitalisation rate, the healthcare system would be likely to be overwhelmed?

Mr Dominic Cummings: So Marc and Ben Warner raised this with me from a kind of week before this point, of the 10/11 March, but when it really came home very starkly was after I asked, I think on the Monday, Imran – somehow between us anyway, Imran and I asked the NHS to provide their data, which for some odd reason hadn’t come through, and there is references to that between Warner and Vallance as well. That data arrived and I asked to get Simon Stevens in to present it, which I think happened on the 12th. Everyone – all the records are a bit iffy on that day, for reasons that you’re aware of. But when we saw these NHS documents, and Marc Warner explained the background of it, that’s what really made things incredibly stark, because you suddenly had these two completely divergent sets of graphs, one from the NHS and one from the COBR system.

Lead Inquiry: On the 12th, there was a – on 11 March there was a Cabinet meeting, INQ000056132.

At page 4 the Secretary of State for Health and Social Care said this to Cabinet, you can see about two-thirds of the way down the page:

“Without these symptoms [the symptoms of a dry cough and a temperature], it was highly unlikely that someone was suffering from coronavirus.”

By 11 March was it generally well understood in Downing Street that a large percentage, a large proportion of this disease for the viral spread in fact was transmitted asymptomatically?

Mr Dominic Cummings: It was, and Mr Hancock had made this point in multiple ways, and sowed chaos by saying this. He was repeatedly told by Patrick Vallance that what he was saying was wrong but he kept saying it. He said it here. And, if you notice, it makes its way into statements that have been provided to this Inquiry.

So this false meme lodged itself in crucial people’s minds. I don’t understand – never understood why Hancock said this, but Patrick Vallance made extremely clear to me and to others in Number 10 that what Hancock was saying was factually wrong.

Lead Inquiry: On 12 March you messaged the Prime Minister raising concerns. Part of the message was put to Mr Cain earlier in the course of evidence, but I’d like it back, please, on the screen, INQ000048313, page 22.

You see there at the 12 March date, this is the reference to the need to chair daily meetings in the Cabinet Room.

If you then go over the page, please, to page 23:

“The overwhelming danger here is being late and the nhs implodes like zombie apocalypse film – not being a week early.”

What did you mean by that?

Mr Dominic Cummings: So you mean the last message?

Lead Inquiry: Yes.

Mr Dominic Cummings: Well, at this point we’d got the data that I’d asked for from the NHS and we’d seen these graphs, and it was clear – it made starker not only the scale of the problem but also – but also two things, (a), that the whole crisis was coming much, much, much faster than we had been told and that the Cabinet Office understood and that was on all of these official graphs. And secondly, to me almost worse than this was, like, what on earth is going on? Like, how can we be in a situation where the NHS has these graphs showing that we are days away from having to make a decision on what to do to stop this nightmare but the official system in the Cabinet Office for dealing with this crisis doesn’t seem to understand this.

So it wasn’t just the sort of the kind of first order level of how bad it was, it was also the second order level of what on earth is going on in the system that this could be possible.

Lead Inquiry: On page 69 of INQ000048313, there is a WhatsApp message from you saying:

“Sedwill babbling about chickenpox god fucking help us.”

What was being said about chickenpox, Mr Cummings?

Mr Dominic Cummings: So there was a meeting in the PM’s study at roughly noon on this day and there was a conversation and in the conversation the Cabinet Secretary said to the PM, “PM, you should go on TV and you should explain that, you know, this is like the old days with chickenpox, and people are going to have chickenpox parties and the sooner a lot of people get this and get it over with the better, sort of thing”, and this had been mentioned before, this analogy, and I said, “Mark, you should stop using this analogy of chickenpox parties”, and the Cabinet Secretary said “Why?” And Ben Warner said, “Because chickenpox doesn’t spread exponentially and kill thousands and thousands of people.”

And the look on people’s faces when Ben said this, that was quite a crystallising moment because it made us (a) think who on earth is briefing the most important official in the country along these lines? This is terrifying. But also other officials obviously heard this exchange and some of them came to us and said essentially, like, something has gone terribly wrong in the Cabinet Office.

Lead Inquiry: All right.

On Friday 13 March the Inquiry understands that of course there was the meeting in the evening involving yourself and others at which a plan B, to use your wording, was sketched out on a whiteboard.

It’s at INQ000048313, page 3. If you could just scroll in, please, we can re-acquaint ourselves with this whiteboard.

Essentially, Mr Cummings, and if you would just simply confirm yes or no, this whiteboard was the first emanation of plan B which recognised that to stop the NHS collapsing there would have to be consideration probably of a lockdown, and of course it deals with the number of deaths that would occur in a reasonable worst-case scenario, it deals with issues as to how you’d deal with contact, what the differences are between plan A and B, who not to save, ie who is at risk, and full lockdown before collapse.

Mr Dominic Cummings: Yeah.

Lead Inquiry: And this whiteboard is moved around Downing Street I think like Theseus’s ship, it’s brought into meetings and it’s further explained to the Prime Minister and individuals there?

Mr Dominic Cummings: Yeah.

Lead Inquiry: During the course of that meeting, though, the Prime Minister texted you and Mr Hancock, Sir Patrick Vallance and Sir Chris Whitty, saying “How do we win the herd immunity argument”?

Mr Dominic Cummings: Mm-hm.

Lead Inquiry: Was that because, notwithstanding the information which had been received from the scientists, from Professor Ferguson, from the NHS, your incipient understanding of the wave of death that was to ensue, it was still thought in Number 10 Downing Street that herd immunity was the way forward?

Mr Dominic Cummings: Yes, but at this point on the Friday evening, 13 March, plan A remained plan A. And also, of course, what the PM is specifically referring to is at that point in that week multiple scientists, including the CSA and John Edmunds, had been on TV explaining the herd immunity problem – sorry, the herd immunity basic plan A, but there had been a lot of push-back from it. The PM was nervy and was saying, essentially, “How are we going to explain this better and how are we going to get this argument out?”

Lead Inquiry: All right. The next day, on the Saturday, there were a number of meetings. There were also, there was also a long debate on WhatsApp between the Chief Scientific Adviser, the Chief Medical Officer, Mr Hancock, the Prime Minister and yourself.

Could we have INQ000048399.

I don’t want to spend too much time on this WhatsApp thread, but it shows on pages 3, 4 and 6 a fairly extensive debate about how herd immunity as an argument can still be advanced if it is to be advanced at all, but also how concentration now needs to be focused on measures to be taken to avoid transmission and save lives. And I think on page 3, 14.03 – 14 March at 7.39, Mr Johnson says:

“Agree totally [with] above. That’s why I was concerned when some on team were suggesting last week that we actively need a proportion of [population] to be infected.”

If you could just scroll back out:

“Civil Service need to grasp.”

So the Prime Minister understood that there was a problem here with whether or not the system, as you would describe it, or the civil service, as he would describe it, understood the danger, understood the need for a change in strategy, the need to understand that there was no time to be lost?

Mr Dominic Cummings: I think that’s oversimplifying things, if I may say so, respectfully. If you look at the chronology, some of these messages start early in the morning and some of these messages are in the evening and an awful lot happened that day. You know, in the morning the PM is still essentially in plan A mode, then there is the – a meeting that I organised – an official meeting and then there’s a second meeting and the situation, I think what the PM’s mind and other people’s minds, including Patrick, were very different even in this, between morning and evening on this day. It was a day of kind of psychological transition for a lot of people.

Lead Inquiry: The whole thread shows that evolution in thinking.

If we could go to page 6, we can see at 10.49 am Mr Johnson says “NO TIME”, although I now can’t see it.


Lead Inquiry: Yes, thank you very much. 10.49.15:

“Johnson Boris: Seeing what happened in Italy we simple have [in capital letters] NO TIME.”

Over that weekend of the 14th and 15th there are, as I said, a number of meetings. SAGE is asked to model lockdown. You’re in touch with Timothy Gowers to ask him for his help and he says you’ve got to move urgently to extreme containment measures; correct?

Mr Dominic Cummings: Yeah.

Lead Inquiry: INQ000253942, page 3.

You asked him for his views and he says you’ve got to move urgently to extreme containment measures – there we are, about a third of the way down the page:

“… I now think that we should move urgently to extreme containment measures.”

Then on that Saturday 14 March, at the officials’ meeting in the morning, Number 10 was informed that matters – the outbreak was further along the curve than had been thought, and there was a private meeting, was there not, between 9.01 and 9.10 with the Prime Minister, yourself, Cleo Watson, Lee Cain, Imran Shafi and Stuart Glassborow where you wheeled in your whiteboard and you took the Prime Minister through the problem?

Mr Dominic Cummings: Yeah.

Lead Inquiry: In light of what Mr Cain said earlier, can you make plain, please, though, that it doesn’t appear as if any decision was made during the course of the weekend for a lockdown, it is that there was a change in the strategic approach of the government, there was a realisation that there had to be a change of approach and much more stringent measures were likely to be required but no actual decision was made to impose a national lockdown?

Mr Dominic Cummings: Correct. The way I would describe it is that we had the conversation with the PM on the Saturday morning, we told him our concerns that plan A was heading for a catastrophe. I then, after that, spoke to Patrick Vallance and articulated and my concerns and my ideas about a plan B that was sketched on the whiteboard.

Patrick Vallance had clearly changed his mind in various ways as well, as I referred to in my text with the PM. And I agreed with Patrick that we would organise a meeting on the Sunday at which he and I jointly would try to articulate a different way forward. But I was very keen for him to do this rather than me, for obvious reasons.

Lead Inquiry: And to be clear, at the morning meeting on the 14th, on the Saturday, you said “Need to do in the next 72 hours to avoid NHS lockdown”, and there was a debate including Michael Gove MP in which he said “Go now!” We know that from the notes of that meeting kept by Mr Shafi.

Mr Dominic Cummings: Yes, I remember him saying it. I remember Gove saying that, sorry.

Lead Inquiry: On the Sunday, and in fact throughout the weekend and then onwards on the Monday, there was a considerable debate also on a WhatsApp group titled CSA-CMO-Matt-PM-Dom concerning the need to accelerate the social distancing plans, in essence do you agree?

Mr Dominic Cummings: Yes.

Lead Inquiry: And there was a debate including Mr Hancock about the need to ramp up testing, not stop testing, and need to continue contact tracing and introduce self-contact tracing, and I think he assured you at 7.30 on 14 March that both of those were in hand; do you recall?

Mr Dominic Cummings: Vaguely, yes.

Lead Inquiry: On the Sunday, there were further meetings, and the Prime Minister held a meeting with his closest advisers in which you’d summarised the discussion from the day before and about the need to move to plan B. Was a decision about the government’s approach able to be taken at that meeting or did the Prime Minister want to confer further with the Chief Medical Officer and the Governmental Chief Scientific Adviser?

Mr Dominic Cummings: Sorry, I’m not sure exactly which meeting you’re referring to. You said Sunday.

Lead Inquiry: On the Sunday?

Mr Dominic Cummings: Yeah, on the Sunday they were – so on the Sunday I met with Patrick and Chris, certainly with Patrick, possibly with Chris, before the meeting with the PM. Then at the 5 o’clock, I think it was, that meeting was with Patrick and with the PM.

Lead Inquiry: At that meeting, it anybody express anger or irritation or annoyance at the view then being expressed by Sir Patrick Vallance as to the need to change course?

Mr Dominic Cummings: I would say there was a great deal of confusion at that meeting, because – in terms of the reactions to it, because of course Patrick and I were essentially suggesting that the original herd immunity plan had to be – had to be ditched.

There was anger after that meeting expressed by people in the Cabinet Office and at DHSC reflecting the fact that they were essentially blindsided. Of course, as far as they knew, as far as the people in the Cabinet Office and DHSC knew, plan A was still in place – plan A was still in place. As you can see from the record, Matt Hancock said on the Saturday morning, on the 14th, to the official meeting “We’ve got to ‘stick with the plan’”. So when Patrick and I wheeled in white boards and said essentially we’ve got to go down a different route on the Sunday evening, I was told after that that Patrick Vallance was reprimanded by various people and that there was a very angry reaction in the Cabinet Office and DH.

Lead Inquiry: In particular, was he reprimanded by the permanent secretary at the DHSC for having, as the permanent secretary appeared to think, promoted, advocated a change of direction without the permanent secretary’s knowledge?

Mr Dominic Cummings: That is my understanding. And you can see from messages on the 18th that the permanent secretary at DH still was behind the curve on this whole discussion.

Lead Inquiry: Because he was still talking about one wave strategy, talking about why the NHS would be overtopped, to use his word?

Mr Dominic Cummings: Correct, on the afternoon of the 18th. So I think, just for complete clarity, it’s a very – it’s a big mistake to think that there was a kind of clear moment, right? This was all complete chaos.

There was informal meetings on the Friday, there was formal and informal meetings on the Saturday, there was formal and informal meetings on the Sunday, there was Patrick and I basically articulating a plan B, there’s the PM thinking about it, there’s the Cabinet secretary and other people in the system suddenly going, “What the hell’s going on, are we ditching plan A, what the hell?”

So it’s important not to think that there was a sort of – you know, that this was all very clear and then suddenly everyone left the meeting and everyone was aligned. It was a very chaotic process, that transition.

Lead Inquiry: So chaotic was it that data and whiteboards and information that you were using to make your point were themselves out of date.

So if we could have INQ000048313, your letter to the Inquiry, at page 39. This is a screenshot that you’ve provided of charts from the NHS showing how beds – the bed capacity of the NHS would be overwhelmed.

Mr Dominic Cummings: Yeah.

Lead Inquiry: That information, it will be page 40 then, please, I think I must have got the wrong reference.

There are NHS graphs which were shown to you and which you deployed in order to show the crisis facing the NHS that weekend in which the peak on those graphs was still being shown as being in June of 2020?

Mr Dominic Cummings: So, no. That’s slightly confused. There’s two different sets of graphs. There is a set of graphs that came from COBR and CCS which were showing a peak in June at this time. The NHS graphs, which we’d been provided by either NHS or possible – well, essentially from Stevens’ office, the ones I referred to earlier, which was shown to us on Thursday the 12th, if you look at the photo of me in the room with the PM on Saturday the 14th, you can see those NHS graphs are the ones that are in front of him.

So part of what that meeting was about was showing him: here’s what the Cabinet Office and the CCS are all planning on the basis of – and DHSC, but here is the actual NHS graphs which Stevens has provided and which the Warners are saying is much more accurate. These completely mismatch.

Lead Inquiry: Because the first set of graphs showed and continue to show that the peak would be in June and of course information had already by then been received in Downing Street that we were way off the trajectory, it was coming sooner than expected?

Mr Dominic Cummings: Correct. It was a measure of how bad that was, even after this was realised and we had these conversations and we were saying to people, “These are the graphs from the NHS, these CCS graphs are completely wrong from COBR”, these graphs kept appearing in the briefing pack for two more weeks after this.

Lead Inquiry: All right.

Now, during the course of that week commencing on Monday 16 March, there were urgent debates and there was rapid consideration of the need to shut schools which you called for in a number of texts and messages, you called for London to be locked down to stop the NHS collapse in London in 15 days. There was obviously an extensive debate about whether or not practically a lockdown could be put into place, as well as whether it should be national or London first and then the rest of the country behind that.

What was the Prime Minister’s general position in relation to whether or not this was a course that would have to be contemplated and pursued?

Mr Dominic Cummings: He – he … he oscillated through the course of the week. I think that he, like me, in the week of the 9th his bat sense was telling him that something had gone wrong, I think he’d been very alarmed by the chickenpox parties when he heard the most senior official in the country use this. It wasn’t a blame about Mark but it was some signal that who the hell was briefing Mark ideas like this. So he was concerned.

When we talked him through on Saturday and said we’ve got to ditch plan A and shift to plan B and try and build our way out of it, he was certainly open but, you know, like me and like the Warners and others he was somewhat dumbstruck that we were in this situation.

And, of course, there was no plan for lockdown, so he was also perfectly reasonably saying, “How the hell do we lock down when there isn’t a plan for lockdown and I’ve been told for the last eight weeks that (a) lockdown was impossible, (b) lockdown was mad because it just means an even worse second wave, now suddenly you and others are saying we’re going to have to lock down, what the hell’s going on?”

Lead Inquiry: In your statement you referred to a number of difficult discussions with the Prime Minister because of the way in which he swung, he backed and veered from taking the view that there had to be a lockdown to taking the view that there should not. Were those careful and measured considerations of the options or were they, to use your language, wild oscillations and trolleying?

Mr Dominic Cummings: Well, I think, you know, to be fair to the PM, you know, it’s hard to overstate – you know, the last time anyone had been in that building in a situation like that was literally Churchill. It was an extraordinary situation. And the PM had repeatedly, you know, extraordinary meetings. So he suddenly had the Cabinet Secretary coming in saying, “Are you absolutely sure about this? The Cabinet are going to revolt. This is all going to kick off”. He had the Chancellor coming in to say the bond markets might puke and we might have a massive 2008-style financial crisis, with the perm sec from the Treasury –

Lead Inquiry: Slow down, Mr Cummings, please.

Mr Dominic Cummings: There were a lot of crazy things of people suddenly just coming into his study saying wildly different things.

Lead Inquiry: All right.

Mr Dominic Cummings: So although I have been very critical of him, I think it’s important to understand in this context that he was being buffeted very strongly by different forces. There was a million and one set of people making one argument that we’d basically been kiboshed by disastrous groupthink and we had to change path. He had people in the Cabinet Office saying that, he had people in the Cabinet saying the other, and he had the Treasury people warning him that, if we went down this path, then we might provoke another parallel disaster.

Lead Inquiry: And as the days unfolded, he backed and veered from supporting a lockdown to being incredibly concerned about the prospect of ordering a lockdown.

On 19 March a bilateral meeting with the Chancellor of the Exchequer took place and the Inquiry’s received evidence that somebody said at that meeting, “We’re killing the patient to tackle the tumour, large numbers of people who will die, why are we destroying everything for people who will die anyway soon?”

Who said that, Mr Cummings?

Mr Dominic Cummings: I think it was the PM.

Lead Inquiry: Was that a reflection of the agonising debate which was going on in Downing Street?

Mr Dominic Cummings: Yes, and a reflection of the fact that the Treasury were pushing back against – the Treasury were kind of baffled as to what’s going on: we had a plan why are we not sticking to it?

Lead Inquiry: But the Chancellor wasn’t trying to stop serious action being taken, from your own statement, that’s what you say, but you sent emails or WhatsApps to Mr Cain, we saw those earlier this morning, saying, “Get in here he’s melting down … He’s back to Jaws mode … I’ve … said [the] same thing [to him] ten fucking times”, and there’s references to stopping the trolley.

So it does appear, Mr Cummings, that there was a very real problem in getting the Prime Minister to agree to a course of action and to stick to it; is that the nub of it?

Mr Dominic Cummings: It is the nub of it. Also I think by the 19th it’s important to realise that there had been a huge swing in the kind of institutional weight. So if you go back a week prior to the 19th the whole weight of the machine was behind plan A, by the time you get to the 19th the whole weight of the machine had shifted, and this was sort of cascading through the system of, “Hang on, we cannot do plan A, obviously, when you look at what plan A means and also how fast it’s all going to unfold, we’ve got to shift”. So there was a sort of huge institutional shift over the course of that week.

And part of what I was referring to in that message was by the 19th it was totally obvious that there was going to be a lockdown, and my fear then was that if the PM suddenly trolleyed back then all it would do was cause more, you know, needless confusion. If you imagine how hard it was to ditch plan A and shift to plan B, if the PM had then started saying to key people “Oh, hang on, we might move back to plan A again”, you know, we were all holding our heads –

Lead Inquiry: And it would cause more delay?

Mr Dominic Cummings: Yes.

Lead Inquiry: There was a debate about whether or not London should be locked down. The Prime Minister met with the Mayor of London and they agreed to jointly announce that entertainment, hospitality and retail must close in London from that Friday?

Mr Dominic Cummings: Yeah.

Lead Inquiry: But the Prime Minister changed his mind again and that announcement did not take place and London was, of course, not shut down early.

The position then by the following weekend, the weekend of 21 and 22 March, was that time was allowed to see whether or not the measures which had been put in place that week would work, whether or not there would be sufficient compliance, and it became apparent, didn’t it, over the weekend that from continued social mixing up and down the land those measures were simply not going to work, and that is why the lockdown decision was made on the Monday?

Mr Dominic Cummings: Yes, I mean, if I recall correctly, again I would say that it might have been formally made on the Monday but I think it was pretty clear over that weekend that it was going to happen before.

Lead Inquiry: There were meetings on the Sunday and the matter obviously formally had to be debated by Cabinet?

Mr Dominic Cummings: Yeah.

Lead Inquiry: And the Cabinet meeting took place on the Monday.

For all those reasons, Mr Cummings, is that why you say in your statement, in effect, that had proper preparations been made, had a proper border and test and trace system been in place, there may never have been a need for a lockdown, but that it became necessary, as the weeks in March moved on, to stop the NHS collapsing; is that the nub of it?

Mr Dominic Cummings: It is the nub of it.

Lead Inquiry: If there had been a scaled-up test and trace system from January or February, then control over the virus would not have been lost, yes?

Mr Dominic Cummings: Ah, possibly, but I think it would – to do it properly you would also need industrial manufacturing and scaling up rapid test as well.

Lead Inquiry: Yes, when I say scaled-up test and trace I mean a sophisticated scaled-up rapid TTI contact system.

And control having been lost, Mr Cummings, there is obviously an argument that that lockdown, which became necessary to avoid the collapse in the NHS and to prevent death, could have been decided upon earlier than it was?

Mr Dominic Cummings: For sure.

Lead Inquiry: And it was the way in which the government system, the structure, attempted to change direction from 9 March onwards, and the lack of any planning or preparation for shielding or any of the other parts of the system that would be required to accommodate a lockdown, that a lockdown could not be imposed earlier?

Mr Dominic Cummings: Yes, there wasn’t an operational plan for it or a legal plan for it or all the sort of thinking through of what it would actually mean.

Lead Inquiry: With hindsight, Mr Johnson’s view varied between – particularly before he became ill – concern that the government had overreacted, he was concerned because, he said, “I’ve no idea whether Covid is killing people, I don’t know how many Covid deaths are truly additional, did we really have to take those steps”, but after he fell very gravely ill and recovered, he told you, “This thing is no joke, thank god we changed course, it would have been a catastrophe”?

Mr Dominic Cummings: Correct.

Lead Inquiry: Over the course of the months after the lockdown, the government backed and veered, in no small part due to the Prime Minister himself, as to the extent to which the system should be allowed to open up and the extent to which it should be kept controlled, and that debate raged, did it not, throughout the summer months?

Mr Dominic Cummings: Yeah.

Lead Inquiry: Is that the time at which you and other members of Number 10 engaged with Mr Hancock, particularly on the issue of the way in which the testing system was then becoming designed and put into place, the way in which the care home sector was being protected adequately or not, and the way in which steps were being taken to try to get in sufficient quantities of PPE?

Mr Dominic Cummings: Yes. After I came back from having the disease myself, from roughly 13 April we’d discussed extensively in the Cabinet Room all of those things: how to build test and trace, how to build the infrastructure, PPE and everything else. Also of how to create the Vaccine Taskforce. I mean, many dozens of such things.

Lead Inquiry: The detail of test and trace and of the care home sector and of PPE are for later exploration in later modules, so I don’t want to go into it in detail, but was it around that time that you sent multiple emails and WhatsApps and messages to Mr Johnson and others stating that your belief was that you were being misled by Mr Hancock, misled by the DHSC in relation to assertions as to what was being done to protect the care home sector, what was being done to ramp up testing and what was being done to get in adequate supplies of PPE?

Mr Dominic Cummings: Yes, multiple officials, including Mr Shinner and an excellent private secretary, Alexandra Burns, raised issues with me that they thought that what was being said in the morning meetings about those issues was not accurate, and I tried to convey this to the PM, as – to be fair to him, also as Mark Sedwill, the Cabinet Secretary, did.

Lead Inquiry: Could we have INQ000048313, page 16, this is an extract from your letter to the Inquiry dated 7 May, you say that:

“Mr Hancock is unfit for this job. The incompetence, the constant lies, the obsession with media bullshit over doing his job. Still no fucking serious testing in care homes his uselessness is still killing god knows how many. This morning you …”

Are you addressing this to Mr Johnson?

Mr Dominic Cummings: Yes.

Lead Inquiry: “… must ask him when we will get to 500k …”

Is that tests?

Mr Dominic Cummings: Correct.

Lead Inquiry: “… per day and where is your plan for testing all care home workers weekly.”

Mr Dominic Cummings: Yes.

Lead Inquiry: If you could go, please, scroll out, and go to the bottom of that page and then scroll in on the last entry:

“You need to think through timing of binning hancock. There’s no way the guy can stay. He’s lied his way through this and killed people and dozens and dozens of people have seen it.”

Was it around this time, in fact on 15 May, that Mr Hancock said, “We’ve tried to throw a protective ring around our care homes”?

Mr Dominic Cummings: I believe so. You have the date. I’m sure you’re right.

Lead Inquiry: Was it around this time, therefore, that in Number 10 there was repeated consideration to the issue of sacking Mr Hancock?

Mr Dominic Cummings: Yes, and I also had complaints from officials to me, entirely rightly, the Cabinet Secretary said to me himself, “The British system does not work if ministers lie at the Cabinet table, and you have to convey this to the PM”.

I think the Cabinet Secretary was completely right, there was only so much that he could do, this was fundamentally a political matter, and I did what I could.

Lead Inquiry: Lord Sedwill said in a WhatsApp on 18 April:

“Hancock is quite slippery on all this.”

That was in the context of PPE.

And on 20 April Mark Sedwill referred to:

“I’m fast losing confidence in Hancock’s candour as well as grip.”

We’ll have that on the screen, please, INQ000048313, page 26.

Mr Dominic Cummings: Yes, that’s the sort of conversations that I was referring to – but we had – I mean, it wasn’t just on WhatsApp, we had face-to-face discussions along those lines.

Lead Inquiry: If you could scroll in, please, it’s quite hard to read but you can see, in the top third of the page:

“That exchange really worries me and reinforces the need to get a grip on DHSC who should have been kicking my door down over this for weeks to get it resolved.”

Mr Dominic Cummings: Yeah.

Lead Inquiry: “I’m fast losing confidence in [his] candour …”

But Mr Hancock was not sacked, but there was a significant change in Downing Street because on 14 May the Prime Minister called Mark Sedwill, the Cabinet Secretary, into his study and, at a meeting attended only by Mark Sedwill and Boris Johnson, Mr Sedwill was effectively told that his time was up. He ended up staying till September, but that his role as Cabinet Secretary was effectively over?

Mr Dominic Cummings: Yes. This was one of the most disastrous moments of the entire 2020 because it set off a kind of bomb across the whole system. I begged the PM not to do it. I knew what would happen. The same as every single HR conversation he ever had with anybody, it was a total disaster. And it was also – I mean, from a personal level it was very unfair on Mark, but from a government level it kind of kicked off week after week after week of debilitating argument across the system, instead of actually rebuilding the system, which is what needed to happen.

Lead Inquiry: But you had, of course, put poison into your master’s ear because you had described Mr Sedwill as – well, you had insulted him, you had told the Prime Minister he was off the pace, he was not up to the job. In a WhatsApp on 14 March you said to Mr Johnson “That fucker [Mr Sedwill] should be in the office”. You played your part in the loss of confidence, did you not?

Mr Dominic Cummings: Yes. I did, but – so I think you have to separate out two fundamental questions. It was my job to convey to the PM that the Cabinet Office structure, which was the engine room for dealing with a crisis like this, had blown up and could not cope. And I think I was right in pointing out to him multiple problems. That’s completely different from the way in which the PM then tried to handle the whole situation, which obviously should have been handled in a completely different way.

The way he handled things with Mark and then almost immediately afterwards he did practically identically the same thing with Helen, just caused absolute chaos.

Lead Inquiry: Are you implying that Mr Johnson treated Helen MacNamara in a way that you would not have done?

Mr Dominic Cummings: Well, I mean, so there’s a huge –

Lead Inquiry: Yes or no, Mr Cummings?

Mr Dominic Cummings: Yes.

Lead Inquiry: Helen MacNamara –

Mr Dominic Cummings: In fundamental way –

Lead Inquiry: Excuse me.

Mr Dominic Cummings: Do you want me to explain why or not?

Lead Inquiry: No, I’d like you to listen to the question, please.

Helen MacNamara and Martin Reynolds produced a report which identified toxic cultural problems in Number 10: people talking over junior women, sexist, macho culture, and they describe a pretty unpleasant working atmosphere in Number 10. Had you contributed to that toxic atmosphere, Mr Cummings?

Mr Dominic Cummings: Erm, I contributed to – so certainly the atmosphere was toxic in all sorts of ways. I contributed to it in the sense of I’d said that the system’s broken, a lot of the people need to be removed and it needs to be rebuilt. This was extremely unpopular with – this was very popular with some officials, it was extremely unpopular with other officials, in particular Martin.

There was, though, I would stress, a lot of support. You know, a lot of very good officials had seen the collapse of the Cabinet Office up close. There was a lot of support for my view, which was that it needed fundamental root and branch change.

Lead Inquiry: My question was: had you contributed to that toxic atmosphere? Is your answer yes?

Mr Dominic Cummings: No, my answer’s not yes. If you’re trying to suggest that an overall – the way that you characterise it, no. I think that explaining to the PM and others directly, “These are the problems, we can’t carry on like this, crucial people need to be removed, here’s what’s wrong with it, here’s how we rebuild it”, did that contribute to bad relations, undoubtedly, yes, with some people. But it was necessary and justified.

Lead Inquiry: Did you treat individuals in Downing Street with offence and misogyny, Mr Cummings?

Mr Dominic Cummings: Certainly not.

Lead Inquiry: Could we have INQ000283369, please, an extract from Mr Johnson’s “Fightback” WhatsApp group, page 37. Just to pick up the thread of the chronology, if you could scroll in on the top of the page, we can see that the first WhatsApp is 21 August 2020, Mr Johnson says:

“Mail has fucked up remnants of my Scottish break so back in chequers and in a thoroughly homicidal mood.

“We need a plan for the dept of education … perm sec … better ministers … reform.”

There is then some communication between him and Mr Cain and you at the bottom of the page.

Then over the page, please, to page 38, you say this at 12.20:

“If I have to come back to Helen’s bullshit with PET …”

What’s that, propriety and ethics –

Mr Dominic Cummings: Yes.

Lead Inquiry: – part of the Cabinet Office or Number 10:

“… designed to waste huge amounts of my time so I can’t spend it on other stuff – I will personally handcuff her and escort her from the building.”

Had you got form, Mr Cummings, for arranging for people to be escorted from Number 10 before?

Mr Dominic Cummings: You shouldn’t believe everything you read in the newspapers. That story was not accurate.

Lead Inquiry: “I don’t care how it is done but that woman must be out of our hair – we cannot keep dealing with this horrific meltdown of the british state while dodging stilettos from that cunt.”

Page 10 of INQ000283282:

“We gotta get Helen out of CabOff. She’s fucking up frosty. She’s fucking up me and case. She’s trying to get spads fired and cause trouble on multiple fronts.

“Can we get her in Monday for chat re her moving to [community local government] or dft [Department for Trade] … we need her out ASAP. Building millions of lovely houses.”

If you go back one page to page 7, please, three pages in the same document, we will see a way in which you speak of a professional scientist who gave his time and considerable amounts of energy to SAGE, Professor Neil Ferguson, a third of the way down:

“We should get someone to hammer Ferguson.”

Mr Cummings, was that aggressive and foul-mouthed and misogynistic approach the correct way to manage fellow professionals?

Mr Dominic Cummings: I don’t know what the Ferguson thing is referring to but, in terms of Helen and the situation at the Cabinet Office, you need to understand that the Prime Minister had first of all tried to sack the Cabinet Secretary and then botched it and he was still there, then he’d said to everyone that he wanted Helen to be removed as well and that he’d lost confidence in Helen. The new Cabinet Secretary had said that he wanted to have the authority to change both the PPS and choose his deputy, ie Helen. The Prime Minister had then trolleyed back on this as well. So we were in this absolutely nightmare situation where the PM had destroyed – had made clear that he didn’t have confidence in either of the two senior officials, had said to people he was going to remove them, then he didn’t remove them for week after week. This led to an absolutely nightmare situation.

Now, my language about Helen is – the language is obviously appalling, and actually I got on well with Helen at a personal level, but a thousand times worse than my bad language is the underlying issue at stake, that we had a Cabinet Office system that had completely melted and the Prime Minister had half begun the process of changing the senior management and then stopped. So me and other people were desperately trying to build a new system with a new Cabinet Secretary over this period in order to get ready for September, and then suddenly we were getting dragged out of meetings on things like test and trace and vaccines to be told that we had to deal with Cabinet Office HR issues and legal questions regarding judicial reviews and Jolyon Maugham. This is – I mean, Kafkaesque nightmare doesn’t begin to explain it.

So I apologise for my language towards Helen but a thousand times worse than my language was the underlying insanity of the situation at Number 10.

Lead Inquiry: When this morning –

Lady Hallett: Mr Keith, I’m sorry to interrupt, but I think we have to take a five-minute break.

Mr Keith: Yes, of course.

Lady Hallett: I’ll be back at 4.35. So it’s not five minutes.

(4.32 pm)

(A short break)

(4.35 pm)

Lady Hallett: Mr Keith.

Mr Keith: This morning, Mr Cummings, I asked you what your view was of the private office within Downing Street and you said this:

“… there was a core problem, which is that private secretaries in the Prime Minister’s office … quite a few of them are young women … and on other occasions, some of the young women in the private office said to me … there was a serious problem with senior people in the Cabinet Office not paying attention to what they were saying, talking over them, generally just a bad culture of a lot of the senior male leadership in the Cabinet Office, which was something I agreed with.”

You, Mr Cummings, were the person who denigrated women, you denigrated Helen MacNamara, and you sent that misogynistic message about her, did you not?

Mr Dominic Cummings: No, that’s not correct, I was not misogynistic, I was much ruder about men than I was about Helen. I agree that my language is deplorable, but, as you can see for yourself, I deployed the same or worse language about the Prime Minister, Secretary of State and other people. If you want to look at how we actually ran things, unlike Whitehall, I had two young women as my deputies, I hired young women into the data science team. In the Vote Leave campaign I actually put a young woman in her 30s in charge of it, much to the rage of a lot of MPs.

So if you look at the reality of how I actually ran teams and how I got on with the private secretaries in Number 10, you will see the truth of the matter.

Lead Inquiry: Moving through to the late summer, your statement shows that the Prime Minister kept changing his mind several times a day, questioning what had been done, “I should be the mayor of Jaws”, and you refer to pressure from the press, and I just want to ask you a single question about the impact of the press on Mr Johnson.

It is obvious there is a symbiotic relationship between the press and politicians, not at least the Prime Minister, and he plainly paid a great deal of regard to what the newspapers were saying and to what their owners were saying to him.

It is obvious that he found himself unable to ignore their entreaties about what should be done and about opening up the economy.

In Downing Street, what was thought about that degree of influence of the press on the Prime Minister and, in particular, the impact on him in deciding what was essentially a public health emergency?

Mr Dominic Cummings: Well, obviously there was a general feeling in Number 10 that the way in which the Prime Minister responded constantly to the media was extremely bad and extremely damaging to the Covid response. There were specific concerns about his relationship with the Barclays, and The Telegraph, and there were specific concerns, and also suspicions of possible corruption in terms of his relationship with Osborne and funnelling money to the Evening Standard.

Lead Inquiry: Just pause there. I am going to ask you another question then about the press. Is it the Evening Standard that is owned by Lord Lebedev?

Mr Dominic Cummings: Yes.

Lead Inquiry: And is it Lord Lebedev he met – spoke to on the phone and met, in fact, in the evening of Thursday 12 or 19 March?

Mr Dominic Cummings: I think I remember seeing a reference to the 19th.

Lead Inquiry: The 19th. All right.

The text messages that you sent the new Director General in Downing Street, or permanent secretary, Simon Case, in July and August show that you and he were gravely concerned about Mr Johnson changing position as to the merits or the need for a lockdown, the lockdown which had occurred in March, and throughout September/October Mr Johnson backed and veered again, did he not, about whether or not the undoubted evidence of an increase in the incidence of the virus could only be met by a circuit breaker or ultimately a national lockdown?

Mr Dominic Cummings: Yes.

Lead Inquiry: It’s in that period that there are multiple references to him being a trolley, to being incapable of making a decision, to also the influence, if any, that his then girlfriend exercised on his decision-making.

Mr Dominic Cummings: Yes.

Lead Inquiry: But the stage was reached, was it not, that everybody else in Downing Street took the view that a national lockdown was inevitable, and so it came to be. Were you in favour of a national lockdown in September and October, when the scientific evidence and the position of SAGE showed that the disease was spreading again and was spreading irrevocably towards a further collapse in the NHS or a collapse in the NHS?

Mr Dominic Cummings: Yes, as the evidence shows I basically agreed with Patrick and Chris and I think also … I also thought that, as a kind of psychological or political judgement, that if we did not do what Patrick and Chris were suggesting, I had a lot of confidence – remember at this point the data was extremely good, unlike the first wave, so at this point I had a lot of confidence in what the data people were saying, and I thought if they’re roughly right then I absolutely know that this guy is not going to be the mayor of Jaws, he will definitely bottle and U-turn and again it’ll be the worst of all worlds.

Lead Inquiry: All right.

On 15 October, could we have INQ000267902, at page 68, in a WhatsApp message between Mr Johnson, Mr Cain and yourself. (Pause)

All right, we don’t appear to have that or we don’t seem to be able to put it on the screen. You say this –

Mr Dominic Cummings: I think I know the one you’re referring to.

Lead Inquiry: Is it the one in which you say:

“We must NOT do national lockdown. Must preserve ‘local approach’.”

Mr Dominic Cummings: Oh, no, sorry, it’s a different one then.

Lead Inquiry: Why did you say to Mr Johnson and Mr Cain “We must NOT [in capital letters] do a national lockdown”, on 15 October 2020, in light of what you’ve just said about being a proponent of the national lockdown?

Mr Dominic Cummings: Well, without having the message up its hard to see what the context is, but there’s a couple of things. There is the argument between 17 and 21 September, where you can see there’s lots of documentation about what I thought and Patrick and Chris and other people. At this point, though, that ship had sailed to some extent and the PM had already decided to go down the local approach, so there was a debate inside Number 10 then when suddenly people were saying, “We’ve got to do a national lockdown now”.

Lead Inquiry: All right.

Mr Dominic Cummings: There was an argument for, having started the local thing, you couldn’t then just suddenly trolley again immediately and say, “Well, now it’s going to be national”, if you see what I mean, even though two weeks later it ended up being obviously – obvious that we had to go to national again.

Lead Inquiry: Did you trolley, Mr Cummings?

Mr Dominic Cummings: Well, if you show me, what is it that – oh, it’s now up, let me just read this.


Mr Dominic Cummings: Sorry, this doesn’t have what you were referring to on.

Lead Inquiry: This isn’t the one. Never mind, I see some heads being shaken.

Mr Dominic Cummings: I think essentially, as I said, that there’s the debate 17 to 21 September about a lockdown where the views of me and others were all in writing and very clear about what we ought to do. There is then the chaos between then and the end of October discussing possible local approaches which didn’t work. There was a stage where I was trying to get the PM to stick to what they’d already announced on local stuff and not career off again, but unless you get the documents up it’s hard to go into it in detail.

Lead Inquiry: In your statement you express the opinion that the second lockdown could have been avoided if, as you were saying earlier in the course of your evidence, a proper sophisticated scaled-up test, trace, contact, isolate system had been put into place from the spring, correct?

Mr Dominic Cummings: Correct, with mass testing as well.

Lead Inquiry: With mass testing, and you also attribute the fact that a lockdown could have been avoided if there had not been what you describe as failures in the Prime Minister’s character?

Mr Dominic Cummings: Yes. Also, to be fair to the PM, remember that, for reasons still unexplained, DH basically trashed the idea of mass testing from March and, therefore, the months of March to July were wasted, to a large extent, in building that whole infrastructure up, until we were alerted about that in July.

So I think you can’t hold the Prime Minister responsible for that – for that.

Lead Inquiry: You left Number 10 Downing Street on 13 November 2020, did you not?

Mr Dominic Cummings: Yes.

Lead Inquiry: And your last messages with the Prime Minister, Mr Johnson, were on 15 November, two days later.

Could we have INQ000283282, page 26. If you could scroll in, please.

We can see Mr Johnson said:

“You speak of briefings from team Carrie.”

Is that a reference to the allegation that she had briefed against you, colleagues of hers had been briefing against you, and may have been involved in leaks:

“She hasn’t briefed anyone and my instructions to all were to shut the fuck up. How is any of us supposed to know where these briefings come from? Look at the claims made on behalf of allies of Lee and Dom. That I am out in 6 months. That I can’t take decisions. That Carrie is secretly forging lockdown policy!! And about a billion equally demented claims. Are you responsible for all that crap? No? Then look at it from my point of view. This is a totally disgusting orgy of narcissism by a government that should be solving a national crisis. We must end this. That’s why I wanted to talk and see what we could jointly do to sterilise the whole thing. But if you really refuse then that’s up to you.”

You left the WhatsApp group, as we can see, because you blocked the contact, shortly thereafter.

He has a good turn of phrase, Mr Johnson. Would you agree that there was in the government of which you played a major part an orgy of narcissism?

Mr Dominic Cummings: Certainly there was.

Lead Inquiry: You run a blog, do you not?

Mr Dominic Cummings: Yes.

Lead Inquiry: On 5 July 2021, INQ000273905, so about five or six months later, you said:

“I and my team worked with Boris in the referendum. Some of us worked with him, officially or unofficially, between the referendum and summer 2019. We knew his skills and his weaknesses. We knew he was, in any objective sense, unfit to be [Prime Minister]. We also knew that he knew too, since he’d told us.”

Is that your blog?

Mr Dominic Cummings: It is.

Lead Inquiry: Elsewhere in your blog, do you say things like “Self-aware Boris knows that Normal Boris cannot manage, cannot focus …”, “[he] won’t read the papers … he cannot chair meetings to save his life”.

Mr Dominic Cummings: Yes. Is that a question, sorry?

Lead Inquiry: Did you say that in your blog?

Mr Dominic Cummings: Sounds familiar.

Lead Inquiry: In your statement, did you say that he couldn’t chair meetings, stick to a plan or build a high-performance team?

Mr Dominic Cummings: For sure.

Lead Inquiry: Whether right or wrong, Mr Cummings, and the Inquiry will of course hear from Mr Johnson and will make its own mind up, you helped to put him there, did you not?

Mr Dominic Cummings: Sure.

Lead Inquiry: You contributed to his election campaign in December of 2019, you were his chief, perhaps, adviser, but even after that general election, in the early days of the administration in January 2020, as you subsequently told journalists, you said, “we were having meetings in Number 10 … by the summer either we’ll all have gone from here or we’ll be in the process of trying to get rid of him and get someone else in as prime minister”. Did you say that?

Mr Dominic Cummings: Yeah.

Lead Inquiry: So you helped to put into power and to sustain someone, who was, in your view, and I emphasise it’s your view, the Inquiry has reached no view, somebody who was unfit to respond to the extraordinarily difficult demands of a pandemic?

Mr Dominic Cummings: Correct.

Lead Inquiry: Are you sorry?

Mr Dominic Cummings: No, because I think that you have to – politics is about choices and the choice that we had in summer 2019 was: do we allow the whole situation, this once in a century constitutional crisis to continue, melt down and possibly see Jeremy Corbyn as PM and a second referendum on Brexit – which we thought could be catastrophic for the country and for democracy, for faith and democracy – or to roll the dice on Boris and to try to control him and build a team around him that could control him? And that was the – we didn’t take that choice lightly. We considered in summer 2019 an alternative of staying out of it, but we thought the combination of the second referendum and Corbyn was so bad that we should roll the dice.

Lead Inquiry: Perhaps in deference to your support, he supported you when the Barnard Castle affair exploded in Easter 2020, did he not?

Mr Dominic Cummings: Yes.

Lead Inquiry: For health and security reasons, you drove from London to Durham over the weekend of 27 to 29 March at the height of the lockdown with your wife and child, correct?

Mr Dominic Cummings: Ah, is the 27th the Friday? Yes.

Lead Inquiry: I don’t know when you drove, but it was over the weekend of the 27th to the 29th.

Mr Dominic Cummings: It was the night of that Friday, the day that the PM got Covid.

Lead Inquiry: In your statement, you say that the Prime Minister knew that you had moved your family out of London, but his WhatsApp messages – INQ000226225, page 22 – are adamant that you never told him that you had gone to Durham during the lockdown and he only discovered when the stories started to come in.


Lead Inquiry: Whether or not you told him, on 12 April you drove 25 miles to Barnard Castle to test your eyesight, yes?

Mr Dominic Cummings: Er, so –

Lead Inquiry: Did you drive to Barnard Castle?

Mr Dominic Cummings: Are you asking me about the whole thing or just about the 12th?

Lead Inquiry: I want to ask you about Barnard Castle on 12 April.

Mr Dominic Cummings: Yes.

Lead Inquiry: Did you drive there?

Mr Dominic Cummings: Yes.

Lead Inquiry: Did you take your wife and child in that car?

Mr Dominic Cummings: Yes.

Lead Inquiry: Why did you need them in the car to be able to drive to test your eyesight?

Mr Dominic Cummings: Because, well, as I explained to MPs a couple of years ago –

Lead Inquiry: Just tell us, please.

Mr Dominic Cummings: Oh. I am. So in the days up until the 12th, of course, the PM was increasingly sick, I was getting messages from Lee Cain and others about the diabolical situation –

Lead Inquiry: Mr Cummings, why did you –

Mr Dominic Cummings: I –

Lead Inquiry: Excuse me.

Mr Dominic Cummings: Sorry, you asked me to answer the question, so I’m answering the question.

Lead Inquiry: Why did you take your wife and child in that car to enable you to test your eyesight?

Mr Dominic Cummings: As I was saying, I was asked to go down, to drive back down to London because of the terrible situation with the government. I had intended to go the day before on Saturday but I was too ill to do so. On the 12th I thought: right, I’ll drive down the road, drive back, see how I feel, and if I feel okay then I’ll drive back the next day. Back to London, I mean.

Lead Inquiry: Why did you have to have your wife and child in the car to assist you to drive down the road?

Mr Dominic Cummings: Well, obviously I didn’t have to have them in the car.

Lead Inquiry: That day, 12 April, was it your wife’s birthday?

Mr Dominic Cummings: It was.

Lead Inquiry: Was it Easter Sunday?

Mr Dominic Cummings: I think so.

Lead Inquiry: You recognise, of course, that confidence in the United Kingdom Government’s handling of the epidemic collapsed after that matter came to light and after your press conference in the rose garden?

Mr Dominic Cummings: I think – so it was certainly a disaster, the whole handling of the situation, but there were other factors involved with it all as well. Testing and PPE and many other things were all going haywire at the time.

Lead Inquiry: Do you accept that your behaviour, whether a breach of the rules or not, caused immeasurable offence and additional pain to the bereaved?

Mr Dominic Cummings: Well, I’d had to move my family out of the house, I’d had to call on police because of incidents at my house, which I discussed with the police and with the Prime Minister and with the Deputy Cabinet Secretary. So, in terms of moving my family out of the house for security reasons, no, it was completely reasonable and agreed by everybody at the time to be reasonable.

However, the –

Lead Inquiry: The day of 12 April and the drive to Barnard Castle, about which you spoke at great length in that press conference, do you acknowledge it caused immeasurable offence and additional pain to the bereaved, who were unable to see their own loved ones die?

Mr Dominic Cummings: Yes, I think the way that we handled it was an absolute car crash and a disaster and did cause a lot of people pain. I think that –

Lead Inquiry: I’m not concerned with the handling, the aftermath of that event. I’m asking you: do you accept that that apparent breach of the rules caused enormous offence and pain to the people in this country whose loved ones were dying?

Mr Dominic Cummings: No, I think we’re talking about two different things. I think the handling of it was a disaster and caused huge trouble and huge pain to a lot of people, and I very much regret and have already apologised for how badly Number 10 handled the whole thing. But in terms of my actual actions in going north and then coming back down, I – I did – I acted entirely reasonably and legally and did not break any rules.

Lead Inquiry: In July 2020, you had agreed to leave on Friday 18 December, correct?

Mr Dominic Cummings: Of what, sorry?

Lead Inquiry: In July of 2020, you agreed with Mr Johnson that you would leave government in December?

Mr Dominic Cummings: I wouldn’t say exactly agreed, but I told him at the end of July that that was my intention, yes.

Lead Inquiry: By September, you describe your relations with him as “knackered”?

Mr Dominic Cummings: Yes.

Lead Inquiry: On 13 November, with the country on the cusp of a devastating second wave, you left work for the weekend; you never returned, did you?

Mr Dominic Cummings: Sorry, on 13 October?

Lead Inquiry: On 13 November 2020 –

Mr Dominic Cummings: Oh, 13 November.

Lead Inquiry: – did you leave Downing Street and never return?

Mr Dominic Cummings: Correct.

Lead Inquiry: And you left Downing Street under the control of a man whom you described yourself as unfit for office?

Mr Dominic Cummings: (Witness nods).

Mr Keith: Thank you.

Lady Hallett: Mr Weatherby.

Questions From Mr Weatherby KC

Mr Weatherby: Thank you, my Lady.

Mr Cummings, I’m going to ask you a very short number of questions on behalf of members of the Covid Bereaved Families for Justice UK. I have permission on two points.

I’m just going to pick up really where Mr Keith left off, and could we have INQ000226258 at page 6, please. This is a WhatsApp, the Number 10 WhatsApp group. I’m sure you’re familiar with it. It’s 15 October 2020, and it reads:

“We should start an enforcement dashboard of Covid reporting. I’ve harped on but it’s killing us. How do you justify ever more Potemkin laws that aren’t obeyed? At what point do people reasonably say fuck this I’m the idiot for taking the rules seriously? Like with surveillance and data, the truth is we’ve ducked out of facing these questions at a political level. We shouldn’t. We [should] look at enforcement metrics like hospital metrics. And change the laws on policing. Or else admit to ourselves we genuinely aren’t serious!”

Now, first of all, the point that you were making that, there should be a public-facing dashboard for compliance with Covid regulations, was that connected to public confidence in the regulations?

Mr Dominic Cummings: Er, no, actually I think it – I think that this was a reference not to a public dashboard but to a kind of – but to a sort of internal government dashboard. So at that point we had a kind of health dashboard which would be presented to the PM and obviously –

Mr Weatherby KC: Yes.

Mr Dominic Cummings: – more people. What I was suggesting was that added to that dashboard should be information on enforcement so that we could get a much clearer picture of the true situation.

Mr Weatherby KC: Okay, so you could present data which would enhance public confidence in the regulations?

Mr Dominic Cummings: No, so that we could actually understand honestly what was really happening on the subject of enforcement round the Cabinet Room table and get a grip of this situation, which frankly was just being very badly handled.

Mr Weatherby KC: Okay, so you then go on to refer to Potemkin laws, a word you’ve used a number of times.

Mr Dominic Cummings: Yeah.

Mr Weatherby KC: Just to make it clear, Potemkin laws, you’re there saying that they’re effectively deceptive regulations? They’re there to convey something, but they don’t actually do anything; that’s what you’re trying to convey, isn’t it?

Mr Dominic Cummings: Sort of. So the reason for this was that at this time there was a really fundamental problem which was that on the one hand we were being told that compliance to various rules was not being followed at the level that we needed it to be. This was then generating in Whitehall a constant sort of ratchet to say: well, let’s tighten up these rules in various ways to try and get compliance higher. But this was fundamentally misconceived in lots of ways, because the new rules which were constantly being suggested were aiming at – would have no effect on the people that were complying. Do you see what I mean? So there was a sort of – there was a sort of Potemkin process of people saying: well, compliance is bad, let’s impose more laws, but these laws are not actually being enforced.

Mr Weatherby KC: Let me try and short-circuit this. By this point, you were putting forward the view that the regulations that were in place were not being obeyed or they were unenforceable or they were deceptive?

Mr Dominic Cummings: Correct, and it was a bad combination –

Mr Weatherby KC: Yes.

Mr Dominic Cummings: – to have this mix of rules that were not being enforced, and not face that problem squarely, but then keep demanding more rules and more rules and more rules.

Mr Weatherby KC: Just finally on this point, when did you reach that view? Was that before or after your trip to Durham?

Mr Dominic Cummings: Oh, long bef – oh. Well … I mean, we were discussing these enforcement issues I think from April, and it was a constant problem in Number 10 to try and figure out what was actually being enforced and what the police were doing, and this central question of how the police would interpret their role in enforcing things. Because obviously sometimes they massively overreacted on certain things and arrested people when they shouldn’t have done, et cetera, et cetera, which was bad –

Mr Weatherby KC: I’m not going to take this point any further. It’s just if that’s so, you’d known that from the outset? That’s a period of about six months where you’re chief adviser to the PM.

Mr Dominic Cummings: Yes, certainly for many months this problem was debated and there were multiple meetings with the Home Secretary and the Home Office about this question about enforcement compliance and this problem of constantly increasing the number of laws but people not complying and this actually undermining the whole regime.

Mr Weatherby KC: The second point – well, INQ000093325, please. This is another WhatsApp, it’s a short point and going back to 14 April. And this raises a point about transmission in hospitals. Just the first page just sets out who is on the WhatsApp group, and it seems to be people in your office and from the Department of Health.

Mr Dominic Cummings: Yeah.

Mr Weatherby KC: And I think that the owner of the cellphone, so described, is Matt Hancock.

Mr Dominic Cummings: Okay.

Mr Weatherby KC: Perhaps you can help us with that as we go along. The message at page 2, short message, and it’s from you:

“Surely we should be segregating hospitals between [Covid-19 and non-Covid-19]?? Are there any good arguments against this? How else will we stop the spread in hospitals?”

Then the reply is:

“Welcome back. We are doing this within hospitals and with the Nightingale. Worth asking whether it’s enough.”

First of all, am I right that’s Mr Hancock?

Mr Dominic Cummings: I mean, the Inquiry has these WhatsApps from somewhere. I’m afraid –

Mr Weatherby KC: That’s my understanding, and we’ll be corrected if I’m wrong about that.

Can you help us: what caused you to send this message at what was really quite a late stage by this point, three weeks after lockdown?

Mr Dominic Cummings: This was actually the day after I returned to work on the 13th and I’d had a lot of people say to me that they were obviously extremely worried about the situation in hospitals and in care homes, that there wasn’t – there still weren’t enough tests obviously to go around at this point. I think some officials had pointed out to me that in some countries they were segregating their patients to try and keep – to try and keep them separate and protect people who didn’t have Covid –

Mr Weatherby KC: Okay.

Mr Dominic Cummings: – and I think I was basically just suggesting: why aren’t we doing this? Particularly given how few tests we had.

Mr Weatherby KC: Okay. I don’t want to close down your answer, but perhaps we could do it a bit shorter –

Mr Dominic Cummings: Sure.

Mr Weatherby KC: – in the answers.

You had been to Durham and Barnard Castle, and this is your first day back at work?

Mr Dominic Cummings: Second day, yeah.

Mr Weatherby KC: Second day back at work, and you are raising the fact that there doesn’t seem to be segregation in hospitals. Why was that actually, on that day, something that occurred to you?

Mr Dominic Cummings: I mean, I can’t remember now, to be honest. I mean, on any day around this time I would have literally like a hundred issues like this that I would deal with.

Mr Weatherby KC: Were you reassured by the answer, “Welcome back. We are doing this within hospitals and with the Nightingale”, or did you think that, given this was such a major issue, that you should investigate further?

Mr Dominic Cummings: I did investigate further. I spoke to Chris Whitty and Patrick about it at some point in the next few days.

Mr Weatherby KC: Yes.

Mr Dominic Cummings: They reiterated their concerns about this, and testing in care homes too.

Mr Weatherby KC: Were you satisfied with that response? Did you think that Mr Hancock and team were actually doing what they should be doing in terms of segregation in hospitals?

Mr Dominic Cummings: So, no. I mean, as you can see from the whole stream of messages, in general I wasn’t. At this time in April, everyone round the Cabinet table knew that we had to probe and keep asking repeated questions.

Mr Weatherby KC: Final point on this is that the context of this really is 19 March, isn’t it? That you would know at 19 March the decision was taken to move 30,000 patients out of hospitals, many of them into care homes?

Mr Dominic Cummings: Yes.

Mr Weatherby KC: And here we are three or four weeks later, and you’re still raising points about segregation in hospital and isolation?

Mr Dominic Cummings: Correct.

Mr Weatherby KC: Does that tell us something about the response?

Mr Dominic Cummings: Yes, I mean, I think that and all – and lots of the other messages which the counsel has been showing regarding messages between me and other people in Number 10 in April, officials were like literally shouting at me about this subject, private office officials were rightly raising concerns about care homes, and I think I said earlier on an excellent official, Alexandra Burns, raised this issue repeatedly –

Mr Weatherby: Thank you.

Mr Dominic Cummings: – and rightly.

Mr Weatherby: Thank you, my Lady.

Lady Hallett: Thank you, Mr Weatherby.

Mr Friedman, I think you’re going next.

Questions From Mr Friedman KC

Mr Friedman: Thank you, my Lady.

Mr Cummings, I act for four national disabled people’s organisations and I want to ask you about two documents, both of which were copied in to your letter that you wrote to the Inquiry.

So if we go back, please, to INQ000048313, and the first document is at the bottom of page 3 and it’s the screen of the whiteboard that you were asked about. And this is Number 10, isn’t it, on the evening of Friday 13 March 2020?

Mr Dominic Cummings: Yes.

Mr Friedman KC: Just under point 4 on the whiteboard and the lockdown, the word “Lockdown” on the left-hand side as you look at it, it says “[Equals] e/o [everyone] stays home”?

Mr Dominic Cummings: Yes.

Mr Friedman KC: Do you see that? Then there are words in brackets just under that:

“Who looks after the people who can’t survive alone??”

Mr Dominic Cummings: Yes.

Mr Friedman KC: Do you see that?

Mr Dominic Cummings: Yes.

Mr Friedman KC: So we’ve heard what you said to Mr Keith about the vulnerable and at-risk groups, that there were effectively no plans or any plans even to get a plan; but can you explain what conclusions were reached at the meeting on 13 March and, as the whiteboard was used in meetings across the weekend, as to who was going to look after those people or simply how they were going to be supported?

Mr Dominic Cummings: So I wrote – you know, this was obviously a kind of, you know, sort of stream of consciousness scribbling on the Friday night late-ish, 8-ish or something. I wrote that down because it just seemed like such an obvious question and we had not had a satisfactory answer in Number 10, and this whiteboard was partly intended – like partly obviously to help develop the idea of what plan B looked like, but also as a kind of aide memoire to remind me and other people in subsequent meetings to look through a lot of the issues on this whiteboard, to go like, “Who’s in charge of this, who’s doing that, who’s doing that”, so we could check it off.

So this was also partly so I could say to private secretaries, “Imran, can you check on this? So-and-so, can you check on that?” and make sure that someone was covering all of these things. And, in fact, that did happen regarding that and there was a meeting on the 19th about it, an extremely bad meeting.

Mr Friedman KC: Can we just then follow that through with the second document I wanted to take you through, and that’s pasted in the same letter, same reference, and it’s at page 24, and it’s part of the email correspondence that you had with the mathematician – I’m going to call him Professor Sir Timothy Gowers, you have called him Tim Gowers.

Mr Dominic Cummings: Yeah.

Mr Friedman KC: I want to just ask you about the email dated 15 March 2020.

Mr Dominic Cummings: Yeah.

Mr Friedman KC: Page 24 at the top, just under the words “Me/Gowers 15/3”, and to get your bearings on it:

“Thanks Tim, I basically agree. We cannot do herd immunity in the crude way media discussing without NHS collapse. We must avoid NHS collapse at all costs. We’ll have to move rapidly to extreme measures to buy time to increase NHS capacity, work on drugs, etc. The only question is how fast to move through levels of extreme caution.”

Then this, Mr Cummings, which is what I wanted to ask you about:

“Proper social isolation for vulnerable groups will kill many of them – our advice is starting this now would kill more than it would save – but of course we must review constantly and try to time for when it will save more of these groups than it kills.”

Then there is a follow-on email where Professor Gowers asks you to send the details of that advice.

Mr Dominic Cummings: Yeah.

Mr Friedman KC: And you tell him – I need not go into it – they’re overtaken by events, you say, new measures are going to come in.

Mr Dominic Cummings: Yeah.

Mr Friedman KC: Can you explain now for the Chair what advice you were referring to when you said in the email on 15 March, “Our advice is starting this now would kill more than it would save but review consistently and try to time for when it will save more of these groups than it kills”? What was that advice?

Mr Dominic Cummings: So Chris Whitty and others from the Department of Health had addressed this question, and essentially what they were saying was that, you know, if you’ve got a load of people, some of whom are very seriously disabled or have health problems of all different kinds, vulnerable in different ways, then if you tell them to go into sort of like a severe isolation, then that itself – of course that’s going to help protect them against Covid, but that itself is going to be extremely damaging for some fraction of that vulnerable population, and this was part of the whole question which we kind of sort of alluded to earlier on about the question of timing.

So in terms of plan A, the original plan A, the logic was: well, we’re going to time it like that so there’s herd immunity by September, and also timing it is relevant for these relevant groups. If you do it now, say, you know, say 1 March hypothetically, then you would be saving very few of them from Covid because Covid was not, as the people thought it, then very prevalent. Do you see what I mean?

Whereas if you nominally timed it for sort of eight weeks later, say, as people were thinking about at the time, then they would be much more protected from Covid. So it was like what Chris Whitty’s point was and other people’s points was: there was this question of balancing the trade-off in time. If you go earlier, you save fewer people from Covid by definition because there’s less Covid around, but you kill more people by putting them into isolation in various ways. If you go later, you save more people from Covid but also they suffer from being isolated. Do you see what I mean? Does that make sense?

Mr Friedman KC: Yes. Well, in the chronology, as we can see in the email below, matters then get overtaken and you worked towards plan B, I think. You can see it on the page there.

Mr Dominic Cummings: Yes. Also it’s crucial to bear in mind that one of the nightmare things we discovered at this time was that there wasn’t – not only was there not an actual plan for shielding, but that many people in the Cabinet Office didn’t want to have a plan for shielding.

Now, fortunately, a brilliant official called Jen Allen, a young woman in the digital side, worked with a guy called Oliver Lewis and they essentially said to the Cabinet Office, “This is all total bullshit, we are going to build a system for shielding”, and they hacked together a bunch of databases, they called up local authorities and they figured out a way to do it. But it was literally basically cobbled together in 72 hours or something.

Mr Friedman KC: And from scratch?

Mr Dominic Cummings: From scratch.

Mr Friedman: Thank you, my Lady.

Lady Hallett: Thank you, Mr Friedman.

Mr Jacobs.

If you could keep your answers a bit shorter, Mr Cummings, I’m afraid it’s been a very long day.

Mr Dominic Cummings: Sorry, I will certainly try.

Lady Hallett: Don’t worry about looking at Mr Jacobs, he won’t consider you’re being insulting if you don’t –

Mr Dominic Cummings: Sorry, don’t look at him?

Lady Hallett: – because we don’t want you turning away from the microphone.

Mr Dominic Cummings: I apologise, sorry.

Lady Hallett: It’s okay.

Questions From Mr Jacobs

Mr Jacobs: I apologise for asking questions over your shoulder, Mr Cummings. On behalf of the TUC, I have a few questions in relation to a passage on page 85 of your statement, and in particular paragraph 412.

You say:

“A lot of richer people had a happy time in Spring/Summer 2020 staying at home with family, working via Zoom. Lots of poorer people had to go to work or lose money. There was resistance to thinking about how to compensate people for staying at home when they were told they had to.”

In relation to your observation that lots of poorer people had to go to work or lose money, are you referring, Mr Cummings, to the many in lower paid occupations who continued to attend work throughout 2020: transport workers, those working in supermarkets and food processing plants, and so on?

Mr Dominic Cummings: Exactly, yes.

Mr Jacobs: And are you referring to the problem that many attending work on low income, if they had to self-isolate, may be in a financially precarious position?

Mr Dominic Cummings: Exactly.

Mr Jacobs: You make the observation that there was resistance to thinking about how to compensate people for staying home when they were told they had to.

Mr Dominic Cummings: Yeah.

Mr Jacobs: First, perhaps a simple point, but why was it important to compensate people for staying home when they had to?

Mr Dominic Cummings: Well, (a) I thought there was a reasonable argument, just in moral terms, that we should compensate people for staying home. (b) there was a practical question that, you know, obviously – you know, if I think of my own position, if I had very little money and my – and I was told: well, you’ve got to stay at home, but in doing that I wouldn’t have the cash to actually look after my own family, then obviously I’m going to ignore a lot of rules and I’m going to go off and I’m going to work and try and keep getting paid. And that was a fundamental problem that that refers to.

If you look around the world –

Mr Jacobs: Sorry, Mr Cummings, I’m just conscious of time.

Mr Dominic Cummings: Sure.

Mr Jacobs: It’s a fairly simple logic, isn’t it, that if self-isolation isn’t effective in low income groups, then that’s going to put an upward pressure on the R rate?

Mr Dominic Cummings: Correct.

Mr Jacobs: So why was there a resistance to providing financial support for those needing to self-isolate?

Mr Dominic Cummings: I think it was just normal Treasury official short-term thinking, was my impression at the time.

Mr Jacobs: Do you recall Sir Patrick Vallance and others trying to impress upon ministers in meeting that this issue of financial support for self-isolation was an important one?

Mr Dominic Cummings: I do, and I think Patrick also raised it with me directly.

Mr Jacobs: Could we have on screen INQ000273901 and page 164, and this is an entry, Mr Cummings, from Sir Patrick Vallance’s diary or daily note which you may have seen put to Mr Cain this morning.

He says, and this is on 7 September 2020:

“[Chancellor] blocking all notion of paying to get people to isolate despite all the evidence that this will be needed.”

Is it consistent with your recollection that the Chancellor was blocking all notion of paying to get people to isolate?

Mr Dominic Cummings: It’s certainly consistent with my recollection that the Treasury institutionally was opposed. I don’t now remember exactly what the Chancellor’s personal view on it was, but there were certainly Treasury officials who were blocking, who were very hostile to the idea.

Mr Jacobs: Did you share the view that it sort of flew in the face of the evidence that it was needed?

Mr Dominic Cummings: I did. I didn’t have an extremely strong position about it, but I also note – you know, one of the things I tried to do at that time was look at countries that were doing much better than us, and it seemed to me that, in places like Singapore and Korea and other places who’d got their act together better, they had systems like this to – for example, they had kind of food drops for people who had to stay at home under isolation, they had all kinds of like infrastructure to actually support people who had to stay at home, and I thought that at the very least that that should be seriously thought about.

Mr Jacobs: Was it understood or reflected upon that the difficulty for those on low incomes of self-isolating also intersected with issues of disproportionate impact of the pandemic on a number of minority ethnic groups?

Mr Dominic Cummings: I think it was discussed, but I think this issue – like many issues sort of similar to the nightmare of child abuse and things like that, and care homes – I think this issue was generally neglected in the chaos.

Mr Jacobs: Does it fall into the same category that you describe earlier, then, as an issue appallingly neglected?

Mr Dominic Cummings: Yes.

Mr Jacobs: Were ministers advised, to your recollection, that financial support for self-isolation would not only assist generally those on lower income workers, but it would also help lessen the disproportionate impact on some minority ethnic groups?

Mr Dominic Cummings: Yes, different people made versions of that argument and sort of similar arguments.

Mr Jacobs: So help us, Mr Cummings, with your impression as to why it is, then, that there seems to have been simply no interest in actually addressing it?

Mr Dominic Cummings: Well, sorry, there was interest in addressing it, different parts of the system addressed it, there were people in private office who addressed it and other parts of the system, including Patrick, including SPADs, including officials from elsewhere. Also there was resistance from the Treasury –

Mr Jacobs: Sorry, Mr Cummings, I’ll rephrase my question slightly, if I can. Clearly people were raising it.

Mr Dominic Cummings: Yeah.

Mr Jacobs: Why was there apparently no interest on the part of ministers to addressing it?

Mr Dominic Cummings: I don’t know what ministers thought about it at the time. If I did know, I’ve forgotten.

Mr Jacobs: My Lady, I can leave it there, thank you.

Lady Hallett: Thank you very much, Mr Jacobs.

Does that complete the questioning?

Mr Keith: My Lady, that does indeed.

Lady Hallett: Thank you very much, Mr Cummings. I’m sorry it’s been such a long day.

We shall resume at 10 o’clock tomorrow morning.

Mr Keith: Thank you.

The Witness: Thank you. I apologise again for my terrible language.

Lady Hallett: Thank you.

(The witness withdrew)


(The hearing adjourned until 10 am on Wednesday, 1 November 2023)