Page:Formal Complaints about the Conduct of The Right Honourable Dominic Raab MP, Deputy Prime Minister, Lord Chancellor, and Secretary of State for Justice.pdf/40

 169. The significance of the MoJ Group Complaint is that it led to the making of all of the other Complaints. The participants in the MoJ Group Complaint deserve credit for their courage in coming forward. It cannot have been easy for them to do so and their motivation was to stand up for more senior colleagues whose experiences they had observed at one remove. Having interviewed almost all of the individuals closely involved, I find that they are sincere and committed civil servants, with no ulterior agenda.

170. However, the composition and content of the MoJ Group Complaint make it unsuitable as a basis for any findings about the DPM's conduct. In particular:


 * (1) It was the product of discussions, involving a large number of individuals, over an extended period in February and March 2022.


 * (2) It was drafted by 'committee', with multiple contributors.


 * (3) It is focused only to a limited extent on the DPM himself, with references also to Ministers (plural) and other civil servants.


 * (4) It uses the language of a "perverse culture of fear" without a clear explanation of what it is said to mean. I received different explanations from different individuals.


 * (5) It refers to a significant extent to material in relation to effects on colleagues about which none of the interviewees in respect of the MoJ Group Complaint knew anything specific.


 * (6) It made allegations about unreasonable work deadlines which were not persuasively instantiated by any witness.

171. In relation to the MoJ Additional Complaints, I have considered those allegations which are included in the MoJ Additional Complaints themselves separately from those allegations which were raised by witnesses but which do not form part of the MoJ Additional Complaints. Where the latter type of allegation was closely linked to one of the MoJ Additional Complaints, I have considered, and taken into account in my findings below, whether it sheds any light on the presence or absence of a relevant pattern of conduct. If it raised a separate allegation, which was not the subject of an MoJ Additional Complaint, it was not appropriate or necessary to find any facts about it.