1.

Claimants
2. Name of witness: Jayesh Tank
3. No. of statement: 2nd
4. No. of exhibits: JT1
5. Date: 27 February 2019
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

SUPPLEMENTAL WITNESS STATEMENT OF JAYESH TANK

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

1. This witness statement is supplemental to my first witness statement (“First Witness

Statement”) made on 28 September 2018.

2. As stated in my First Witness Statement 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”). Exhibited to this witness statement is a paginated bundle of
documents marked JT1. References in this witness statement in the form {JT1/number}
are to pages of that exhibit.

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.

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4. After providing my First Witness Statement and in preparation for giving oral evidence at
trial I have been shown a copy of Mrs Van Den Bogerd’s Second Witness Statement dated
16 November 2018 {E2/5}.

5. At paragraphs 75 to 84 she responds to my First Witness Statement. At paragraph 77 she

refers to a loss of £195.04 that my branch suffered in or around the 13 December 2011. I
had not remembered this incident prior to providing my First Witness Statement. Having
seen Mrs Van Den Bogerd’s evidence this prompted my memory that a loss probably did
occur in or around December 2011.

6. In order to assist with remembering the £195.04 loss I decided to try and access a Yahoo
forum group for Subpostmasters that I used to use. This forum group was known to
Subpostmasters as “The List”. I still had my old laptop that I had used to access the forum
group. I had not looked at this previously as I did not think I would be able to access the
forum group and it did not seem relevant. As a result of Mrs Van Den Bogerd’s evidence
mentioning the £195.04 loss I decided to look for any contemporaneous documents or
correspondence as I had no real recollection of this event.

7. In order to obtain these forum posts I signed into the forum on Yahoo and accessed the
archive of the group. I then copied and pasted the relevant posts into a word document. I
found two relevant forum posts that I had made: one regarding the £195.04 loss and another
regarding the £600 loss.

£195.04 issue

8. On 13 December 2011 I posted in the forum group regarding the £195.04 loss {JT1/1-2}. It
is clear from this forum post that the loss occurred on 12 December 2011 and that I called
the NBSC helpline on 13 December 2011. I have now seen the NBSC call logs for my
branch {POL-0511346} and can see my call on 13 December 2011 regarding the £195.04
loss is there (at row 120 on the ‘Remedy’ sheet). I therefore agree with the first part of Mrs
Van Den Bogerd’s evidence at paragraph 77 of her witness statement {E2/5/20}.

9. At the time I did not know that this issue became the subject of a Peak. However, I can see
from my forum post that after speaking to the NBSC helpline I then managed to speak to
someone at Chesterfield (banking), who told me that she would speak to Fujitsu.

10. My recollection of the £195.04 loss is as I have described it in the forum post, dated 13
December 2011.

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£600 issue

11. I have also found a forum post I made on 29 September 2014 in relation to the £600 loss
issue {JT1/5-6}. In my First Witness Statement at paragraph 6 I refer to the shortfall of
£600 as having occurred in or around 2010-2011. Now that I have been able to look at a
contemporaneous record is it clear that I was mistaken. As can be seen from my forum post
this loss actually occurred on 16 September 2014.

12. Seeing this contemporaneous document has assisted my memory. There was a power cut
at the entire building, but this only lasted a few minutes. I would like to clarify that where at
paragraph 7 of my First Witness Statement I describe what my assistant, Louise, did in
regards to the transaction and pressing the enter button on Horizon to enter recovery mode,
this is information I obtained from her the following morning.

13. To the best of my recollection I did find the £600 transaction in the transaction log and
therefore I could not understand why I had a loss of approximately £600. When I called
Chesterfield they said they could not see any problems. As can be seen from my forum post
I settled this loss centrally on 17 September 2014.

14. As I stated in the 29 September 2014 forum post I called Chesterfield again that morning. I
cannot recall this telephone conversation, but I recorded in the forum post that Chesterfield
said they were going to send me a letter. I did in fact receive this letter dated 29 September
2014 {JT1/8-10} which stated that I owed £660 to Post Office for a branch discrepancy and
asked me to contact Post Office regarding payment, which I did. I then received a further
letter from Post Office dated 13 October 2014 {JT1/11} which confirmed that I would pay
for the debt by one deduction of £660 from my remuneration/fees in October 2014.

Label transaction issues

15. At paragraph 15 of my First Witness Statement where I say the label transaction issue
happened in or around 2007, I now recall that this issue began in or around 2011.

STATEMENT OF TRUTH

I believe the contents of this statement to be true.

Dated: 27 February 2019

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