1.

Claimants
2. Name of witness: Jayesh Tank
3. No. of statement: 1st
4. Date: 28 September 2018
THE POST OFFICE GROUP LITIGATION

Claim Numbers: HQ16X01238, HQ17X02637 & HQ17X04248

IN THE HIGH COURT OF JUSTICE

QUEEN’S BENCH DIVISION

BETWEEN:
ALAN BATES & OTHERS

Claimants
-and-

POST OFFICE LIMITED

Defendant

WITNESS STATEMENT OF JAYESH TANK

I, Jayesh Tank of 14 High Street, Fleckney, Leicester, LE8 8AJ, do say as follows:

1. I was the Subpostmaster at Fleckney Post Office, 14 High Street, Fleckney, Leicester, LE8
8AJ (the “Branch”) from 4 May 2006 to 15 March 2017, when it closed as part of the
Network Transformation Programme. I also operated a retail business from the premises
selling cards, gifts and stationery.

2. I am Claimant number 492 in these proceedings. I make this statement in relation to the
Horizon Issues as set out in Schedule 1 to the Third CMC Order (“the Schedule”).

3. The matters stated within this statement are true to the best of my knowledge and belief.
Unless otherwise stated, the facts contained in this statement are within my own knowledge
and are true. Where they are not within my own knowledge they are derived from the
sources to which I refer and are true to the best of my knowledge and belief.

Background

4. I understand that the Horizon Issues Trial in these proceedings concerns the technical
issues relating to “the Horizon System”, a term which is defined in the Schedule but which
I refer to as “Horizon” in this statement for brevity. I give this witness statement in respect
of these issues.

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5. With reference to the paragraph numbers set out in the Schedule, as will be clear from the
below, the issues I encountered show the difficulties I faced with bugs, errors and defects
in Horizon causing shortfalls in the accounts (1); errors arising in the course of the transfer
or processing of data (4(b) and (c)); issues with accessing transaction data and reporting
functions through Horizon to identify the occurrence and causes of shortfalls (9). This is not
an exhaustive list.

Power Failure

6. I cannot recall the specific date, but a power failure definitely occurred in or around 2010-
2011.

7. I recall that a member of staff was serving a customer when a total power failure occurred
in the Branch. This was a complete electrical failure to the entire building. The power failure
occurred mid-transaction and prevented the transaction from completing. After the power
failure, my staff member pressed the ‘enter’ button on Horizon to enter recovery mode. A
series of receipts were printed which she then gave to the customer. This particular
transaction involved a withdrawal from the customers’ Post Office Card Account.

8. We only noticed that there was a shortfall on Horizon when we printed off the report at the
end of the day and made a cash declaration. The shortfall totalled £600. We tried to
investigate by producing a transaction log for the day which showed the transaction
described above. The customer had made a withdrawal from their Post Office card account
of the maximum possible amount of £600.

9. In order to do my own investigations, I produced a transaction log and printed out the full
report which was very lengthy – around 15-18ft long. This was not an easy tool to use to
investigate discrepancies.

10. After we discovered the shortfall I called the Post Office Banking Team in Chesterfield. I
told them about the power failure and asked if they had recognised any errors or saw any
unresolved issues on Horizon. I gave them details of the date and the value of the
transaction but they said there were no unresolved issues from that day.

11. I spent approximately a week carrying out my own investigation, as part of this I even tried
to call the customer who made the withdrawal, but she had since passed away.

12. Generally, with power failures, we had to wait for the system to reboot and recover any
transactions. I believe this was an automatic process. Once Horizon was up and running,
we would get a session recovery receipt.
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13. I believe that, on this occasion, all paperwork including the recovery receipt went to the
customer.

14. I cannot be sure how the error occurred, but there appears to have been a bug or defect
with Horizon, or a more general limitation of the system in terms of its measures and
controls, which prevented it from detecting and correcting the error occurring during the
power outage. Investigating this issue from my end was made difficult by Horizon’s
limitations in terms of accessing data and reporting functions.

Label Transaction Issues

15. I cannot recall the exact dates, but in or around 2007, we had a recurring issue whereby
Horizon showed that the Branch had a shortfall as a result of the incorrect processing of
certain types of mail transaction.

16. Each night, Horizon is left switched on to allow for updates to take place. In the morning,
the paper in the printer had a series of characters printed on it which did not make any
sense.

17. If the first transaction was a mail transaction, you usually went through a series of steps.
Horizon printed a label which we then affixed to the item to be mailed. On the occasions we
had this particular issue, Horizon jumped ahead to the end of the transaction and therefore
no label could be printed. This led to a loss of around £2.50 on each occasion. This issue
did not happen with any other type of transaction.

18. I am aware of other Subpostmasters experiencing the same issue.

19. This issue appears to have arisen from a particular bug, error or defect within Horizon which
I could not remedy from my end.

I believe the contents of this statement to be true.

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