Complaints and disciplinary investigations
2.6.257 Investigations into complaints made by bereaved families and others against SYP officers were undertaken by WMP investigators in conjunction with the criminal investigation. They informed decisions taken by SYP and the PCA regarding possible disciplinary action against SYP officers. The lead Investigating Officer was Leslie Sharp, Chief Constable of Cumbria Constabulary, who superseded the previous Investigating Officer, CC Dear. The investigations were overseen by the PCA.
2.6.258 The complaints against SYP Chief Constable Peter Wright focused on reported comments following an interview with the Sheffield Star headlined 'Coroner will reveal the true story'. In the press interview, he referred to 'a very strong feeling of resentment and injustice in the force as a result of Hillsborough'. LJ Taylor's conclusion that fans' drinking had had 'no effect on the events' was 'a little difficult to come to terms with'.
2.6.259 At the inquest he claimed there would 'be a lot of additional evidence presented to the coroner's inquiry that was not presented at Lord Justice Taylor's inquiry, which may put a different complexion on the end product'.
2.6.260 In response, bereaved families complained about the 'distressing innuendo, insinuation and veiled hints that additional evidence, not revealed to Lord Justice Taylor, will show alcohol played a major part in the tragedy'. They considered CC Wright's comments 'at best a breach of his privileged position and at worst a deliberate attempt to pervert the course of justice' by influencing the forthcoming inquests.
2.6.261 The South Yorkshire Police Authority decided that complaints made against the Chief Constable should be investigated by WMP. The Investigating Officer was CC Sharp. Statements were taken from the complainants and from the Sheffield Star journalist who had written the story. CC Wright provided written evidence and a full transcript of the newspaper interview was obtained. CC Wright was then formally interviewed.
2.6.262 CC Wright reiterated that evidence not heard by LJ Taylor would be presented at the inquests; the 'cause of the barrier collapse in pen three and the specific place where deaths occurred' were 'obvious instances of evidence not yet revealed'. He denied implying 'that the fresh evidence relates to drink', stating that he had 'no knowledge of what specific evidence will emerge'.
2.6.263 Given 'all the publicity given to Lord Justice Taylor's Inquiry, all that has been said by many people publicly during and since the Inquiry ... the suggestion that my statement would prejudice jurors is quite simply nonsense'.
2.6.264 CC Sharp reported on the complaints. He considered there had been 'nothing' said by CC Wright 'which suggests the additional evidence would or might relate to drink'. Yet, 'the manner in which the article is presented in The Sheffield Star could be interpreted that way' due to 'selectivity and juxtaposition in respect of the quotes'.
2.6.265 There was 'nothing to indicate that Mr WRIGHT was, or intended to be oppressive, abusive or uncivil to anyone, or to influence any juror or proceedings'. In conclusion, CC Sharp found that 'all of the complaints to be unsubstantiated' and that 'no disciplinary offences' had been committed. His report and conclusions were accepted by South Yorkshire Police Authority on 27 April.
2.6.266 CC Wright retired, as planned, three days later. He wrote to CC Sharp thanking him for processing the complaints quickly. He had 'dreaded the thought that I may have left the Service with them unresolved' but could now leave 'with a clear conscience'.
2.6.267 CC Sharp replied with gratitude, stating that the investigation had not been 'a job I relished or enjoyed doing'. He continued: 'That is not to say that I did not do it to the best of my ability - I did - but I would much rather have been able to sit with you over a pint, and yarn about the past, present and future'. Given that '[s]omeone had to do it' he was 'pleased that I was able to complete it in time to let you leave the service in peace'.
2.6.268 CC Sharp concluded that the 'balance sheet of service and dedication of Peter Wright will always be heavily in credit. More people than you will ever know, believe that. I, for one, know that to be true'.
2.6.269 CC Sharp also investigated complaints made against seven other SYP officers. The PCA confirmed it was content that the various complaints had been 'thoroughly investigated' and CC Sharp's reports had been forwarded to SYP and its Police Authority. In each case, CC Sharp presented the allegations, his analysis of the evidence and his recommendations regarding disciplinary action.
2.6.270 The complaints against Mr Duckenfield were:
- Failure 'to acquaint himself with the planning and problems related to the control of the semi-final'.
- Failure 'to prevent a dangerous build up of supporters outside the Leppings Lane gates'.
- Failure 'to monitor the crowd numbers packing into pens 3 and 4'.
- Failure 'to act when it became obvious that pens 3 and 4 were overfull when he had an excellent view point from the police box above the pens'.
- 'He should not have opened the gates under any circumstances giving unlimited and uncontrolled access into the football ground by supporters'.
- Failure 'to control the movement of supporters subsequent to the opening of Gate C'.
- Failure 'to make provision for fans coming through Gate C after he had given the order for the gate to be opened'.
- Failure 'to respond to the developing tragedy and that he was slow to effect a rescue operation'.
- Failure 'to act when it was obvious that people were in distress'.
- Deceit and intentionally misleading 'senior police officers and members of the public regarding his command and control of police officers on the day'.
- Attempting 'to mislead the Assistant Chief Constable at the ground and others, namely, representatives of the Club, the FA, and the fans themselves regarding the origin of the order for gate 'C' to be opened. That is by inferring [sic] supporters had forced open the gate when he had, in fact, given the order to open the gate'.
- Collusion 'with Mr JACKSON, the Assistant Chief Constable, to mislead the public over the opening of Gate C'.
2.6.271 CC Sharp's analysis reflected the WMP report to the DPP. His advice was that allegations 1, 5, 10, 11 and 12 (above) were 'unsubstantiated' while allegations 2, 3, 4, 6, 7, 8 and 9 were 'identical to those currently under consideration by the Director of Public Prosecutions'.
2.6.272 Consequently, should it be decided that there was 'insufficient evidence to prosecute these criminal offences, then the same must be said in respect of the disciplinary offence'.
2.6.273 CC Sharp also considered that allegations made against one junior officer were unsubstantiated, while in the remaining six cases (including C/Supt Duckenfield), all complaints would be unsubstantiated if the DPP decided not to prosecute. The DPP announced his decision not to proceed with criminal prosecutions on 30 August 1990.
2.6.274 The SYP decision regarding disciplinary proceedings was not made immediately as 'the Coroner and the Police Complaints Authority are of the view that no discipline decisions should be arrived at in advance of the Inquest findings'.
2.6.275 Following the conclusion of the inquests, SYP's Assistant Chief Constable Stuart Anderson wrote to the PCA. He had decided 'that no disciplinary action is appropriate in respect of any of the complaints'. His decision was 'based solely upon the evidence presented to me in the report of the supervised investigation undertaken by Mr Leslie Sharp'.
2.6.276 Brigadier John Pownall replied that the PCA was 'disappointed' with the lack of detail in ACC Anderson's letter and requested 'a more fully reasoned explanation'. ACC Anderson responded immediately. He explained it had been his wish that 'the events of that afternoon be looked at externally and quite independently without any suggestion of influence by the management of the force'. The recommendation submitted was 'unbiased' and he 'would not seek to influence the decision of the PCA'.
2.6.277 Brigadier Pownall wrote to ACC Anderson's successor, Assistant Chief Constable Moore, presenting the PCA's position on possible disciplinary action. For four officers, the PCA agreed that the evidence did not justify disciplinary proceedings. The complaints against C/Supt Duckenfield and Supt Murray, however, raised 'difficult issues'.
2.6.278 The PCA did not accept that the disciplinary charge of 'neglect of duty' was identical to any possible criminal offence. Even had it been, 'we would not be bound (as far as discipline is concerned) by the decision of the Director not to bring criminal prosecutions'.
2.6.279 For the PCA, the Hillsborough disaster 'would not have occurred had sensible and simple steps been taken to secure the safety of spectators in Pens 3 and 4'. The 'responsibility for the safety of those in Pens 3 and 4 and blame for overcrowding in those pens should rest with those in the Police Control Box from which the pens could be observed, the deployment of police manpower could be directed and the decision to open Gate "C" was made with its attendant responsibility for controlling those who entered through it'.
2.6.280 Thus the PCA recommended that disciplinary charges of 'neglect of duty' be brought against C/Supt Duckenfield and Supt Murray, as well as an additional charge of 'discreditable conduct' against C/Supt Duckenfield in line with LJ Taylor's finding that he had misled others into believing that Liverpool supporters had forced entry through Gate C.
2.6.281 In preparing a response to the PCA's recommendations, SYP took advice from CC Sharp and Counsel, Richard Payne. CC Sharp wrote to SYP Deputy Chief Constable Peter Hayes, stating it was 'quite wrong ... to pursue disciplinary charges of "neglect of duty", particularly as the Inquest jury brought in a verdict of "Accidental Death" '.
2.6.282 In CC Sharp's opinion, the inquest verdict, together with the DPP's decision not to prosecute, was a 'powerful argument' against disciplinary charges. He advised that 'the problems of proving the disciplinary offences proposed by the PCA are formidable'.
2.6.283 On 31 May 1991, Stephen Walker, solicitor for South Yorkshire Police Authority, wrote to Mr Payne, requesting further advice. Directing Mr Payne towards relevant parts of the inquest transcripts, Mr Walker noted that 'much of what happened at the inquests helped in no small way to redeem a balance which had hitherto weighed heavily in criticism of the actions of some officers at Hillsborough, not least being Chief Superintendent Duckenfield and Superintendent Murray'.
2.6.284 Should Mr Payne advise 'that the PCA's views are supportable disciplinary proceedings will be taken as recommended'. Mr Walker stated that ACC Moore had 'no principle objection to taking disciplinary action' but there was 'clear concern that the PCA's recommendations fly so dramatically in the face of the Investigating Officer's views'.
2.6.285 Should Mr Payne consider that disciplinary proceedings were 'not supportable', written opinion would be sought by SYP and submitted to the PCA. Subsequently, Mr Payne advised that, with the exception of LJ Taylor, 'the conclusions of those who have made an independent study of the primary evidence do not attribute blame to any Police Officer'. He cited the DPP's decision not to prosecute, the inquest jury's finding of accidental death and CC Sharp's report to the PCA.
2.6.286 In conclusion, Mr Payne's view was that disciplinary charges would be 'oppressive and unnecessary and fruitless' with none having a 'realistic chance to succeed'. ACC Moore forwarded Mr Payne's and CC Sharp's submissions to Brigadier Pownall at the PCA.
2.6.287 Brigadier Pownall forcefully rejected both submissions. He questioned the propriety of CC Sharp's letter, writing that 'we did not feel it was altogether appropriate for the investigating officer to set out so fully his views on the disciplinary action to be taken'. He also criticised the lack of thoroughness underpinning Mr Payne's opinion, stating that it was 'selective' and had failed to reflect 'some important points'.
2.6.288 As SYP had not acted on the PCA's recommendations, the PCA had 'decided in accordance with Section 93(3) of the Police and Criminal Evidence Act 1984 to direct that disciplinary charges be preferred against Chief Superintendent Duckenfield and Superintendent Murray as set out in our letter of 7 May, 1991 and for the reasons explained in that letter'. This placed a legal duty on the SYP to bring disciplinary charges.
2.6.289 Arrangements for a Tribunal to hear the charges followed. Charges were drafted by SYP and forwarded to the PCA for approval. Following discussion with ACC Moore, Brigadier Pownall agreed with the draft charges, but 'wondered if counsel should have the opportunity to comment upon them before they were served'.
2.6.290 This caused a significant delay. The South Yorkshire Police Authority solicitor provided initial instructions to Counsel, John Sleightholme, who visited the PCA. Superintendent Alan Fell at SYP estimated the 'anticipated date for the Tribunal' as 2 July 1992, a nine-month delay. Brigadier Pownall 'was concerned about the delay' and suggested setting a date for the Tribunal without charges being served.
2.6.291 According to ACC Moore, however, this 'would amount to oppressive conduct as Chief Superintendent Duckenfield was sick with stress and had been told not to deal with any issue at all relating to Hillsborough'. ACC Moore stated that Bridgadier Pownall 'went on at length as to how the public was fed up with police officers using this method of "getting away with it" '.
2.6.292 Ahead of a further conversation between ACC Moore and Brigadier Pownall, Supt Fell wrote to ACC Moore informing him of several problems. These centred on the status of evidence gathered by WMP. Statements could not be 'conveniently used' for disciplinary proceedings as many were 'unsigned or undated recollections of answers to questionnaires'.
2.6.293 Further, relevant witnesses had 'not been asked for their evidence'. Many statements 'did not contain material that the witnesses gave to the Lord Justice Taylor enquiry and the Inquest'. Without proper statements, charges could not be formulated, witnesses could not be chosen and it was not possible to meet the legal duty to disclose evidence against the accused.
2.6.294 On 25 September, ACC Moore had a telephone conversation with Brigadier Pownall, apparently recorded verbatim. Brigadier Pownall's advice, from the Chairman of the PCA, was that the problems raised by Mr Sleightholme were inconsequential. ACC Moore stated he had 'the impression' that Mr Pownall thought the SYP was 'not doing our job properly' and 'might be trying to delay the matters, which I don't think is fair'.
2.6.295 Brigadier Pownall replied that 'the issues are really comparatively simple'. ACC Moore disagreed. Brigadier Pownall, however, stated that he had 'seen this in many cases that we [the PCA] deal with, and you know even much much lesser things than this - it's a sort of tactic. I mean, I don't mean it offensively or rudely, but I can see no other reason'.
2.6.296 ACC Moore disclosed that he was in a difficult position given Counsel's advice and suggested that the Chairman of the PCA, Judge Francis Petre, should meet with Mr Sleightholme and they could 'talk law together'.
2.6.297 Brigadier Pownall then wrote to ACC Moore expressing concern that such a meeting might 'be imposing too great an influence from the Authority [PCA] on matters which are strictly the responsibility of the South Yorkshire Police'. He enclosed a note written by Judge Petre intended to 'provide some helpful guidance'.
2.6.298 According to Judge Petre's note, the disciplinary charges were 'simple and easy to understand' and although 'the overall enquiry gave rise to a vast amount of paper-work ... the charges are specified so as to keep the issues within manageable limits'.
2.6.299 Mr Sleightholme, however, considered that the note appeared to miss the point. He stated: 'Whilst I am grateful for the Chairman's notes, these do not, with respect to him, represent the problems which presently give cause for concern'. Mr Sleightholme was concerned about the status of witness statements.
2.6.300 Further, his intention had been to rely on C/Supt Duckenfield's evidence at the inquests, but he 'had not anticipated that he [C/Supt Duckenfield] would have given some answers which were against his interests but were untrue'. Apparently, he 'had "wilted" under cross-examination' and it 'would be entirely wrong to seek to rely on answers we genuinely believe to be untrue'.
2.6.301 Mr Sleightholme required more time to consolidate the charges and prepare the evidence thoroughly. While he wanted to establish a timetable for the Tribunal as soon as possible, it was not 'proper' to do so without agreeing charges.
2.6.302 Concern about C/Supt Duckenfield's health was also significant, particularly the impact of serving charges on someone who had been 'off sick for a lengthy period'.
2.6.303 A further note from Supt Fell presented the problems. The Tribunal could not 'proceed until charges accompanied by supporting statements of evidence have been served on the accused officers'. Yet the evidence did not 'exist in an appropriate form'. It would require a 'team of police officers conversant with the circumstances ... to obtain such statements'. Given that the PCA had already 'certified ... that it was satisfied with the investigation' setting up a team was 'difficult to countenance'.
2.6.304 Supt Fell reiterated the issue concerning officers' recollections, some of which 'were supplemented by further recollections'. He considered that 'some' recollections 'were perhaps influenced by advice as to what was required for the purpose of the Taylor Inquiry and civil litigation'.
2.6.305 Other statements, made by non-police witnesses, were also unsigned and witnesses had given additional evidence to LJ Taylor or the inquests, making their statements 'incomplete'. Supt Fell continued: 'Unpalatable though it might prove, the Regulations must be followed and the solution to the problem of obtaining suitable statements appears to be that West Midlands police should complete the investigation under the continuing supervision of the Police Complaints Authority'. Otherwise, 'the Tribunal probably cannot begin its work'.
2.6.306 According to Supt Fell, there appeared to be 'no alternative to obtaining appropriate and suitable statements'. Yet there were risks. When it became 'widely realised that there is a need to take further statements to be satisfactory for the purpose of the discipline hearing, questions may be asked whether (as the investigating officer indicated) they were unsatisfactory for the purpose of a criminal prosecution'.
2.3.307 Should this be the case, it could be suggested that they were not 'ideally appropriate for making decisions as to criminal culpability'. His conclusion was unambiguous: 'Far fetched though such speculation is, it would be better if it never could surface'.
2.6.308 Supt Fell's report was forwarded to the PCA. Following a request for more information, a schedule of statements given by the proposed disciplinary witnesses, along with details of whether they had been signed, dated and witnessed, was provided soon after.
2.6.309 Meanwhile, because of C/Supt Duckenfield's continuing ill-health, doubts were raised publicly about the likelihood of disciplinary charges. An open letter from Trevor Hicks of the Hillsborough Family Support Group stated that delays in bringing charges were 'totally unacceptable'.
2.6.310 He wrote that considerable time had passed since the decision on criminal prosecution had been taken and, '[n]othing has, so far, happened - allegedly due to Mr Duckenfield's incapacity on undisclosed sickness grounds'. He noted that it was '90 days since ... Mr Duckenfield commenced sick leave' allowing him 'to apply for early retirement on ill health grounds and the disciplinary matters relating to him would automatically lapse'.
2.6.311 SYP Chief Constable Richard Wells replied that he understood 'the [bereaved] families' sense of impatience'. He continued: 'The 96 deaths resulting from the Hillsborough tragedy are constantly on our minds and we share the grief of those bereaved. Strong feelings like this have still to submit themselves to the processes of the world of legal detail'.
2.6.312 He reassured Mr Hicks that SYP had 'let no grass grow under our feet' and had instructed Counsel to draw up disciplinary charges. It was, however, 'very difficult for anyone to finalise arrangements for the hearing while the details of charges have yet to be agreed between the South Yorkshire Police and the Police Complaints Authority'. C/Supt Duckenfield's illness was a 'further complication'. The assessment of his illness was 'not a matter for police officers, it is a matter of medical advice'. A report from 'a police staff surgeon' was awaited.
2.6.313 Soon after, the report was received by SYP and CC Wells issued a statement. He had taken 'the decision to retire Chief Superintendent David Duckenfield from the South Yorkshire Police on medical grounds'. The police surgeon's 'unequivocal report left ... no doubt that Mr Duckenfield is too ill to continue service as a police officer'. His medical condition could not be disclosed due to 'the rules of patient and doctor confidentiality'. More generally, however, he was 'described as suffering from severe depression and post traumatic stress disorder'.
2.6.314 CC Wells stated that he understood that bereaved families and others would 'be angry at my decision since it rules out Mr Duckenfield's involvement in the planned disciplinary tribunal for which South Yorkshire Police have been preparing for some months'. He continued: 'David Duckenfield has become the symbolic focus of much of the anguish felt by those who were so hurt by the tragedy but I must deal with the man, not the symbol. The fact is, David Duckenfield is now too ill to serve'.
2.6.315 The decision had not been taken 'lightly ... more especially in a case of such complexity and public interest'. He concluded: 'The fact that David Duckenfield is so unwell has simplified that decision. There has been enough suffering already and I can only hope that time will help to soften the terrible pain felt by the families of the Hillsborough victims, and will help to heal David Duckenfield as well'.
2.6.316 The sole remaining charge was against Supt Murray. Mr Sleightholme accepted 'the charge against Supt Murray has some prospects of success' but he was 'concerned as to whether having regard to all the circumstances that now obtain it is just and fair that Supt Murray should as it were be seen to face the music alone'.
2.6.317 A detailed charge was drafted. WMP were approached to take additional evidence. SYP, however, requested the PCA to allow proceedings to be dropped. Crucially, it was questionable 'whether a fair hearing can occur when such an important witness [C/Supt Duckenfield] is absent' leaving 'the tribunal as a means of casting Mr Murray as scapegoat for the Hillsborough Disaster'.
2.6.318 On 13 January 1992, the PCA published its decision. Following 'very careful consideration' it had decided that in the wake of C/Supt Duckenfield's retirement 'what is, in effect, a joint allegation of neglect of duty cannot be fairly heard in the absence of the more senior officer'. To continue with disciplinary proceedings would be 'unjust and inappropriate'. Thus SYP were granted leave not to proceed.
2.6.319 CC Wells expressed SYP's 'deep and sincere sorrow' towards the bereaved families and noted the impact of the disaster on police officers who 'faced with the tragedy, attempted to deal with the horror of the moment'. He recalled 'the sentiments of Dr Hapgood who, at the Memorial Service, said that no disaster was the fault of one organisation or of just one human being, but rather a combination of factors and shared responsibilities'.
2.6.320 Consequently, CC Wells had 'never been convinced of the appropriateness of the disciplinary tribunal'. This opinion had been 'strengthened by the Director of Public Prosecution's [sic] decision on criminal matters, by the findings of the independent investigating team, the conclusions of the inquest and advice given by leading counsel'.
2.6.321 CC Wells had 'never thought that the police alone should be blamed, although we firmly acknowledged our own responsibilities by the settlement of the civil actions against us'. He concluded by stating that SYP were 'anxious not to forget Hillsborough, but to draw strength from its lessons and to move forward, particularly in the area of ground improvements for crowd safety, which are the real ways in which we can give some meaning to the awful loss of life on that afternoon'.
2.6.322 On behalf of the Hillsborough Family Support Group, Mr Hicks criticised the decision as the 'final coat of whitewash'.
 Sheffield Star, 'Coroner will reveal the true story', 5 February 1990, SYP000123600001, p126.
 Letter from Mr Devonside to South Yorkshire Police Authority, 3 March 1990, SYP000123600001, p131.
 Letter from Mr and Mrs Hicks to South Yorkshire Police Authority, 7 February 1990, SYP000123600001, p129.
 Letter from South Yorkshire Police Officer to West Midlands Police, 22 March 1990, SYP000123600001, p133.
 Statement of CC Leslie Sharp, 10 April 1990, SYP000123600001, p106.
 Statements in document SYP000123600001, pp74-113.
 Letter from CC Peter Wright to South Yorkshire Police Authority, 23 February 1990, SYP000123600001, p143.
 Transcript of 'Peter Wright 5.2.90' tape, 5 February 1990, SYP000123600001, p147.
 Interview with CC Peter Wright, 10 April 1990, SYP000123600001, p180.
 These quotes are from the letter from CC Peter Wright to South Yorkshire Police Authority, 23 February 1990, SYP000123600001, pp143-144.
 Complaint against Peter Wright, Investigating Officer's Report, 23 April 1990, SYP000123600001, p213. Quotes from pages 230, 257 and 258.
 Minutes of special meeting of South Yorkshire Police Authority, 27 April 1990, SPA000000430001.
 Letter from CC Peter Wright to CC Leslie Sharp, 30 April 1990, SYP000123600001, p212.
 Letter from CC Leslie Sharp to Peter Wright, 8 May 1990, SYP000123600001, p211.
 Example statement by the Police Complaints Authority, SPA000000390001.
 The complaint and discipline report files are available as follows:
Chief Superintendent David Duckenfield, South Yorkshire Police, SYP000038960001; Assistant Chief Constable Walter Jackson, South Yorkshire Police, SYP000038970001; Superintendent Roger Marshall, South Yorkshire Police, SYP000038980001; Superintendent Roger Greenwood, South Yorkshire Police, SYP000038990001; Superintendent Bernard Murray, South Yorkshire Police, SYP000131490001; A South Yorkshire Police Constable, SYP000038940001; A South Yorkshire Police Constable, SYP000038950001.
 Complaint and discipline report file for Chief Superintendent David Duckenfield, South Yorkshire Police, SYP000038960001.
 File note 'Hillsborough - Legal/Inquest Proceedings - Progress Report' written by DCC Peter Hayes, 18 September 1990, SYP000118480001, p23.
 ACC Anderson's letter did not cover the complaints made against Assistant Chief Constable Walter Jackson. Though CC Sharp had also concluded that complaints against ACC Jackson were unsubstantiated, this case was dealt with separately. South Yorkshire Police Authority were advised to dismiss the complaints made against ACC Jackson on 9 August 1991, SPA000000600001.
 Letter from ACC Anderson, South Yorkshire Police, to Brigadier Pownall, Police Complaints Authority, 28 March 1991, SYP000123570001, p98.
 Letter from Brigadier Pownall, Police Complaints Authority, to ACC Anderson, South Yorkshire Police, 10 April 1991, SYP000123570001, pp91-92.
 Letter from ACC Anderson, South Yorkshire Police, to Brigadier Pownall, Police Complaints Authority, 10 April 1991, SYP000123570001, p95.
 Letter from Brigadier Pownall, Police Complaints Authority, to ACC Moore, South Yorkshire Police, 7 May 1991, SYP000123570001, pp75-78.
 Letter from CC Sharp, Cumbria Constabulary, to DCC Hayes, South Yorkshire Police, 16 May 1991, SYP000123570001, pp58-63.
 Letter from Stephen Walker to Richard Payne, 31 May 1991, SYP000123570001, pp37-48.
 Counsel's advice from Richard Payne, undated, SYP000094930001, pp91-125.
 Letter from ACC Moore, South Yorkshire Police, to Brigadier Pownall, Police Complaints Authority, 26 July 1991, SYP000123570001, p17.
 Letter from Brigadier Pownall, Police Complaints Authority, to ACC Moore, South Yorkshire Police, SYP000123570001, p9.
 South Yorkshire Police press release, 12 July 1991, SYP000123580001, p319.
 Letter from South Yorkshire Police to Brigadier Pownall, Police Complaints Authority, 18 July 1991, with draft charges, SYP000123580001, p301 and pp306-311.
 Note for file of discussion with Brigadier Pownall, Police Complaints Authority, 22 July 1991, SYP000123580001, p289.
 Instructions to Counsel, 25 July 1991, SYP000110390001.
 Counsel's advice, 9 October 1991, SYP000123580001, pp180-188.
 Memorandum from Superintendent Fell to Chief Superintendent Mole, 5 September 1991, SYP000123580001, p257.
 Note of telephone conversation between ACC Moore, South Yorkshire Police, and Brigadier Pownall, Police Complaints Authority, 29 August 1991, SYP000123580001, p262.
 Memorandum from Superintendent Fell to Assistant Chief Constable Moore, 23 September 1991, SYP000123580001, p255.
 Note of telephone conversation between ACC Moore, South Yorkshire Police, and Brigadier Pownall, Police Complaints Authority, 25 September 1991, SYP000123580001, p251.
 Letter from Brigadier Pownall, Police Complaints Authority, to ACC Moore, South Yorkshire Police, 30 September 1991, SYP000123580001, pp219-230.
 Advice from Counsel, 9 October 1991, SYP000123580001, pp180-188.
 The evidence considered 'untrue' is not specified.
 'Problem preventing progress of the Hillsborough tribunal' by Superintendent Fell, 21 October 1991, SYP000123580001, pp172-179.
 Letter from ACC Moore, South Yorkshire Police, to Brigadier Pownall, Police Complaints Authority, 24 October 1991, SYP000123580001, p161.
 Letter from ACC Moore, South Yorkshire Police, to Judge Petre, Police Complaints Authority, 29 October 1991, SYP000123580001, pp124-156.
 Letter from Trevor Hicks to Chief Constable Richard Wells, South Yorkshire Police, 23 October 1991, SYP000123580001, p167.
 Statement by CC Wells, South Yorkshire Police, undated, SYP000123580001, pp163-164.
 South Yorkshire Police press release, 29 October 1991, SYP000123580001, p123.
 Advice from Counsel, SYP000123580001, p88.
 Draft disciplinary charge, 26 November 1991, SYP000123580001, p39.
 Letter from ACC Roche, West Midlands Police, to ACC Moore, South Yorkshire Police, 20 December 1991, SYP000123580001, p14.
 Letter from ACC Moore, South Yorkshire Police, to Judge Petre, Police Complaints Authority, 12 December 1991, SYP000123580001, p27.
 Statement by the Police Complaints Authority, 13 January 1992, SYP000123580001, pp9-13.
 South Yorkshire Police press release, 13 January 1992, SYP000123580001, pp7-8.
 Press clipping from unidentified newspaper, undated, SYP000123580001, p3.