Covid-19 Inquiry: Module 2 Preliminary Hearing

1 March 2023

Anna Morris today addressed the Covid-19 Inquiry at a Module 2 preliminary hearing on behalf of the Covid 19 Bereaved Families for Justice group.

During her submissions Anna highlighted key issues.


Anna invited the inquiry to look at the impact of 10 years of austerity and public sector cuts on the core political and administrative decision making in relation to the pandemic. Anna said that these decisions “cannot be properly examined without understanding the economic and political context in which they were made”.

Adding that public institutions and some households were left in a weak and vulnerable financial position and struggled to mitigate the “immediate and devastating consequences” of the pandemic.

Anna also highlighted the impact of structural racism, saying the inquiry should include an understanding of structural racism and discrimination in its examination of the key issues of Module 2.

“How can the inquiry understand inequalities without understanding the underlying social conditions that are likely to have led to those inequalities?”

Rule 9 requests and disclosure

Anna renewed the request for disclosure of the Rule 9 requests. And with reference to leaked WhatsApp messages from former health secretary Matt Hancock said: “The families deserve to be in the inquiries circle of trust, they do not deserve to be left reeling from media revelations regarding documentation that I’m sure your team will agree is clearly within the inquiry’s scope.”

Full understanding of what’s been requested from whom and therefore have the ability to contribute our assistance in identifying gaps in disclosure.

Anna called for disclosure of rule 9 requests in good time so that core participants can identify gaps well in advance of hearings.


Anna voiced concerns about the broad approach to redaction taken by inquiry’s legal team which will impede the bereaved families’ team rapidly scrutinising the material. Anna continued to explain that any delay in discloser would hinder her team’s ability to identify legitimate lines of inquiry and therefore adversely affect the effective participation of families in the inquiry. Ann instead suggested that the redaction process be applied if and when the material needs to enter the public domain.


Anna said that “without proper funding being made available to all non-state core participants, the already daunting task of preparing for the module 2 hearings becomes an impossible task, and the inquiry risks losing the voices of key bodies which represents millions of people affected by the pandemic”.

Questioning witnesses

Ann said that the only meaningful way to provide for the effective participation of the bereaved is to allow for core participants to ask their own questions of witnesses, and that it is “essential for the bereaved families confidence in the inquiry”.

Anna continued to point out that there is a “significant benefit to having a diversity of questioners, with diverse areas of expertise, representing a diverse range of real individuals, with diverse lived experiences”.

“In order for the bereaved to be at the heart of this inquiry their voices must be heard not just in the evidence that they give but in the questions that they ask.”

Watch Anna’s submissions from 1:08:10.

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