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Page 1


1

2 Monday, 10th June 2002

3 (9.50 a.m)

4 MR CLARKE: Sir, before we begin, I have to say that the

5 Inquiry has learnt, with great regret, of the death

6 earlier this month of Sir Edward Somers, a former member

7 of the Tribunal, which it has learnt with great sadness.

8 LORD SAVILLE: Indeed, thank you very much, Mr Clarke.

9 MR MURRAY SAYLE, affirmed

10

11 Questioned by MR CLARKE

12 LORD SAVILLE: Mr Sayle, if you look across to your right

13 you will be able to see who is talking to you. I say

14 this to all the witnesses: I am the Chairman. The

15 questions will come in the main from the barristers,

16 they are the people who are sitting in front of me.

17 Could I ask you to keep pretty close to that microphone

18 which is in front of you. You can pull the microphone

19 towards you if you like and then we will all be able to

20 hear what we have to say.

21 A. I am talking to Lord Saville, is that correct?

22 LORD SAVILLE: You are indeed, yes.

23 MR CLARKE: Do you have with you, Mr Sayle, firstly, your

24 statement to the Tribunal, the first page of which is

25 presently on the screen, which you signed


Page 2


1 in December 1999 and I think also a supplemental

2 statement which is M71.1.

3 A. There are two, because there is a third very short

4 supplementary statement, dealing with the map.

5 Q. Could we have M71.32. Are the contents of those three

6 statements true to the best of your knowledge and

7 belief?

8 A. Okay, now, number 2, the situation is this: I made an

9 original witness statement to Mr Lee and his colleague

10 Mark Davenport in London entirely from memory, refreshed

11 only by the unpublished article. So 30 years had gone

12 by.

13 My colleague Derek Humphry, I believe you will be

14 hearing from, was present at the time because he and

15 I wrote the article together. Okay, now, one or two

16 errors, as a result of time, were in my original,

17 I think they are flagged as I was not sure. For

18 instance, I had the barracks wrong, it was -- I said the

19 Paras, as I understood, had come from Hollywood Barracks

20 and therefore I thought that the conversation I had had

21 with an officer was in Hollywood; it turned out to be

22 Drumahoe Barracks. That comes from my contemporaneous

23 or near contemporaneous memo which is the subject of the

24 second statement.

25 The other one that I had wrong was Altnagelvin


Page 3


1 hospital, I think, I had the name wrong. Otherwise my

2 30-year memory, you will see, tallies pretty closely

3 with what is in the memo.

4 The importance of that is the memo describes the

5 working methods, how we arrived at this information. My

6 memo to Harry Evans, which was not intended for

7 publication, of course, describes the working methods

8 which I also describe in the original statement because

9 there is some duplication. Sir, that is --

10 Q. Thank you. Subject to those comments, are the contents

11 of your three statements true to the best of your

12 knowledge and belief?

13 A. The middle one, the second one amends the third one, the

14 totality of it is most certainly true to the best of my

15 knowledge and belief.

16 Q. Could we have M71.14 and could we have paragraph 2.

17 I should explain that everybody in this room has had the

18 opportunity to read the statement and its attachments so

19 I am not going to go through it in detail but there are

20 a fair few matters I would like to pick up on.

21 You describe in paragraph 2 how you were telephoned

22 on Sunday, 30th January --

23 A. Just a second. Just a moment, until we get comfortable

24 or I get comfortable, rather. I will have to keep

25 changing my glasses to read the screen, but I brought


Page 4


1 the document itself with me, so I will put my other

2 glasses on and read from that, if you do not mind.

3 Q. Certainly.

4 A. This set-up is perhaps for slightly younger eyes. Okay,

5 Mr Clarke, I have it in front of me now.

6 Q. You describe in paragraph 2 of your principal statement

7 how Harold Evans instructed you on Sunday, 30th January,

8 to go to Londonderry to research and write an article

9 for the paper in relation to the shootings that had

10 occurred on that date.

11 Do you recall when it was that you arrived in

12 Londonderry?

13 A. I am in some doubt. I was certainly there the next day

14 because we got started the next day and I am in some

15 doubt, because it is 30 years ago, whether I went that

16 night or whether I went first thing the following

17 morning.

18 Q. But it was one or the other?

19 A. It was one or the other. I cannot help you on which is

20 most likely.

21 Q. Could I ask you now to look at paragraph 5, which is on

22 the next page of your statement, because I would like,

23 if I may, to follow your train of thought.

24 You describe there how you read and heard statements

25 issued by Army public relations officers and you say in


Page 5


1 the sixth line that the statements that you heard were

2 to the effect that, "young men of military age wearing

3 combat jackets had been shot".

4 Can you tell us how you came to hear these

5 statements, did you attend press conferences?

6 A. No, no, no, I think they were on the radio. As

7 I explained in the piece, I had some experience of this

8 kind of thing and those statements would normally have

9 been written before a military operation, it is part of

10 the operation. Therefore, the phrase, "young men of

11 military age wearing combat jackets," kept recurring in

12 the radio statements, the statements I had heard.

13 Now, again where I heard them I am not certain.

14 I certainly did not attend a press conference to my

15 knowledge, I do not remember doing so.

16 Q. You describe in the second sentence how, in your

17 experience, statements issued during or immediately

18 after a military operation are often drafted before the

19 operation is launched?

20 A. Correct.

21 Q. And you say that they can be an indication of what was

22 meant to happen as much as what actually did. You say

23 in the last sentence but one, five lines up from the

24 bottom, that the statements that you heard:

25 "Sounded very like a restriction, not to fire at


Page 6


1 anyone not answering to the description 'a youth of

2 military age wearing a combat jacket.'"

3 And you say:

4 "In my experience, such restrictions can easily be

5 seen as permission to open fire if a soldier believes he

6 is, or is about to be, risking his life in combat."

7 I want to ask you some questions about that train of

8 thought?

9 A. Certainly.

10 Q. What was your experience of statements that were issued

11 after an operation being drafted before it began?

12 A. Okay, I had many, I have been in combat many, many

13 times, I will not take you through the list, but the

14 particular one I had in mind was the first day of the

15 Six Day War in Israel in 1967, 6th June 1967, in which

16 I dropped into, with other correspondents, of course,

17 the military headquarters, the briefing room in Tel Aviv

18 of the Israeli Army and they were playing on their

19 loudspeaker statements which were being issued in Egypt,

20 in English, by the Egyptian High Command of the supposed

21 triumphant progress towards Tel Aviv. This was what

22 supposedly was happening.

23 General Dyer, who happened to be present, was

24 talking to us. We asked him why, why are we listening

25 to this. He said, "because that is what is supposed to


Page 7


1 have happened, these were drafted beforehand".

2 I have been present in Vietnam and many other places

3 when orders were being drafted for an up-coming

4 operation and there was always some provision made: what

5 are we going to say about this? So it was based on that

6 idea.

7 Q. Does any of your experience in this regard relate to the

8 British Army?

9 A. No, because this -- I have not been in combat, unless

10 you regard this sort of thing as combat. The British

11 Army is one I have missed, but I have been with the

12 Australians and the Americans and the Israelis and very,

13 very many. And armies again have characteristic ways of

14 operating. There is a certainly fundamental level of

15 the military mind or military procedures that does

16 transfer to some extent. You do not have to learn every

17 new army every time you go to a new war, in other words.

18 There is a family resemblance, that was what I was

19 saying.

20 Q. You appear to have interpreted remarks you had heard on

21 the radio about young men of military age wearing combat

22 jackets being shot as meaning that there was

23 a restriction on firing only at people wearing combat

24 jackets; is that the train of thought?

25 A. That was the train of thought, because I recall, I think


Page 8


1 I explained this fairly clearly, that when we arrived,

2 and were briefed within half an hour of the basic

3 situation, questions arose. For instance: why are all

4 the people who are dead or wounded, with one exception,

5 a girl who was crushed, I think, by an Armoured

6 Personnel Carrier, why are they all males; why the

7 proportion of dead to wounded, 14 -- 13 to 13 at that

8 time, which would be most unusual in a firefight or even

9 in an accidental firing on a crowd. Why would they all,

10 what description -- now I fitted that together in my

11 mind with this repeated phrase, "youths wearing combat

12 jackets," now out of this -- this is a deduction, let me

13 stress, nobody is telling me this -- there is probably

14 a connection between the very strange nature in a normal

15 military situation of the dress, the sex, the

16 approximate appearance of the dead and wounded and only

17 young men of military age wearing combat jackets.

18 Now out of that there was -- do not forget, on the

19 first day of this job, myself and Humphry, we went

20 looking for some sort of explanation which we can test,

21 which we can say, "Now, if this is not the explanation,

22 what is?" It is a sort of -- almost a scientific

23 procedure: hypothesis -- try to disprove it. That was

24 the situation in that respect.

25 Q. Were you seriously supposing that the Army might have


Page 9


1 been told only to shoot of young men of military age

2 wearing combat jackets?

3 A. I was suggesting that as a restriction. You will recall

4 the Yellow Card restrictions. Okay, now, a plan would

5 have to fit within the purview of the military, or that

6 would be a consideration, fitting within the Yellow Card

7 restrictions.

8 Now, what I was trying to work out was: why this

9 peculiar structure, and I connect -- the phrase, "young

10 men wearing combat jackets," must have come from

11 somewhere, it was coming from the Army side, it must

12 relate to some of their thinking, so that was the

13 presumption.

14 Q. You were not seriously supposing, were you, that if

15 somebody wearing a tweed jacket threw a nail bomb the

16 soldiers were not to shoot him?

17 A. No, we were discussing a plan in which no throwing of

18 nail bombs at that point had come up. Underlying all of

19 this is the consideration of whether this was an armed

20 engagement or whether it was not.

21 Now, of course, the Yellow Card rules would provide

22 a soldier is entitled to shoot at someone who is holding

23 a weapon or who he believes is about to attack him, but

24 in those, in these circumstances, the aim -- presumed

25 aim of the operation, this is after all what the Inquiry


Page 10


1 is looking into, was not to engage people throwing nail

2 bombs, because the movements that are described, the

3 precise drilled pre-- presumably pre-rehearsed parts of

4 a military operation. Now, if somebody suddenly popped

5 up with a nail bomb, no doubt a soldier would have

6 been -- taken a snapshot at him, no doubt he would not

7 be forbidden to do that, I am not suggesting that for

8 a second. What I was looking for at the time was an

9 explanation of why people who were not carrying nail

10 bombs, who were distant from the -- some yards, et

11 cetera -- do I have to take that any further?

12 Q. No, you do not. As I understand it, you then inferred

13 that there was some restriction on firing at anybody

14 unless he was wearing a combat jacket and that was, or

15 could have been seen as permission to open fire on

16 somebody who was?

17 A. "Not seen as" would tend to turn into that. This is

18 what I was explaining.

19 Q. "Seen as" was the words you used in paragraph 5?

20 A. Well, maybe, but perhaps I have poorly put that and you

21 are asking me to expand it. The situation in combat, of

22 course, is that soldiers, even the bravest soldiers,

23 their principal emotion is fear, because they do not

24 want to die. Therefore, it is not a precise surgical

25 operation.


Page 11


1 A soldier's first duty is to protect himself, of

2 course, and his comrades. Therefore, in looking for an

3 explanation of the peculiar structure of the dead and

4 wounded -- I mean "peculiar" in the sense of most

5 unusual for an armed combat, a firefight, incredible in

6 fact for a firefight -- then somehow the explanation of

7 the fact that all roughly fitted into the classification

8 of youths wearing combat jackets and so on must have

9 somehow been involved in the order.

10 Now, it obviously, I could not imagine an order

11 which said, "shoot everybody who is wearing a combat

12 jacket," because that was almost universal wear in

13 Northern Ireland at the time, in cold weather, a combat

14 jacket, a zip-up jacket, Campari jackets I think they

15 were called at the time.

16 So I interpreted that as more likely to be

17 a restriction, "Do not fire at anybody who visibly could

18 not be an IRA suspect or sympathiser or member of a

19 possibly attacking force because they are not fitting

20 into the general description of what an IRA man would

21 look like".

22 Q. What is the hypothesis that you are suggesting in the

23 last sentence of paragraph 5, is it that the orders

24 could have been seen as permission to fire on anybody

25 with a combat jacket whether he was doing anything


Page 12


1 threatening or not, or is it some different hypothesis?

2 A. No, I think, you will forgive my saying so, a good

3 point.

4 What I am saying, is to seek a connection between

5 the phrase, "youths wearing combat jackets," which was

6 repeated so often that it could not have been an

7 accident, that was my opinion, and an explanation of

8 what had happened.

9 Now, it was, very early in the piece, discovered by

10 myself and Humphry that none of these people were armed

11 or -- could not have been members of the IRA, for

12 reasons we explain further down, that they had jobs and

13 so on.

14 Therefore, why were they selected to be shot at,

15 because it is not in dispute they were shot at. Okay,

16 as it could not have been what they were doing, it must

17 have been because of where they were and coupling that

18 with the youths wearing combat jackets, you see, as

19 I understood the situation -- and still understand it --

20 the military operation was an attempt at an ambush of

21 a group of IRA militant supporters and so on who would

22 presume to have been, under normal circumstances would

23 have been, among the demonstrators at the head of the

24 demonstration and that the plan had taken some care to

25 make sure that nobody would be shot indiscriminately.


Page 13


1 Therefore, the restriction, as I understood it, was

2 carefully drafted to make sure that the persons

3 concerned at least could have been, were not obviously

4 not members of the IRA or supporters, and therefore

5 the -- what had been a restriction could, in a soldier's

6 mind, readily be turned into permission.

7 Q. Permission to do what, to fire at somebody whether he

8 was threatening the soldier or not or to fire at

9 somebody who was threatening a soldier, what is the

10 hypothesis you were working on?

11 A. Nobody was threatening soldiers among the groups who

12 were shot, as far as I know, as we could discover,

13 because threatening them with what?

14 Q. Is the hypothesis upon which you started working that

15 soldiers were ordered or interpreted their orders as

16 allowing them to fire at anybody wearing a combat-style

17 jacket, whether he was posing any threat to the soldiers

18 or not?

19 A. No.

20 Q. What was the hypothesis?

21 A. Perhaps I am not explaining it very well.

22 Q. I am afraid I have not understood.

23 A. Okay, what I was trying to get at, or what we were

24 trying to get at, but I was largely responsible for the

25 military side of the article, was to try to work out in


Page 14


1 my own mind what the unknown order must have said.

2 Q. What did you assume or work out that it did say?

3 A. That it was, because the actions of the military made

4 this fairly clear, an ambush, that is that the Paras

5 were proposing to surround and defend themselves

6 against, if necessary, a presumed group of armed IRA

7 militants who would have been among the head of the

8 demonstration and, as I understood it subsequently, did

9 actually initially intend to be there.

10 Now, the -- again elementary military principles,

11 I will not give you a long lecture about it, but the

12 first requirement of a plan is protection, the usual

13 rule of thumb: protection, mobility, fire power, in that

14 order. The first person drawing up a military plan

15 thinks protection and the shooting was done, as I worked

16 it out, by the protective element of the snatch squad.

17 I understand there was a company, one section were armed

18 with helmets and defend rifles, not clubs, not -- they

19 were the protective element.

20 Now they would be under restrictions to who they

21 could fire at. We are in a crowded city and in the heat

22 of combat, of course, the soldier is inclined to shoot

23 at anybody, inclined to, who he thinks might be about to

24 shoot at him, might be.

25 So, I interpreted that as a restriction, "do not


Page 15


1 shoot at anybody who is not in the following

2 classification". Am I making sense to you?

3 Q. To a point. Is the hypothesis upon which you were

4 proceeding that if somebody was wearing a combat-style

5 jacket the soldiers were entitled to shoot them if

6 attacked or whether they were attacked or not?

7 A. No, because of, and we will develop this a little bit

8 later, because of where they were standing, because of

9 where they were.

10 You see, if --

11 Q. I do not understand what the answer "no" means, which

12 hypothesis was it?

13 A. You will have to repeat them again, pick up the second

14 one.

15 Q. One reading of what you appear to be saying in

16 paragraph 5 is that you assume, for various reasons,

17 that the soldiers had received orders to fire at anybody

18 wearing a combat jacket, whether they were fired on or

19 not?

20 A. I do not think that can be read from it. Sir, that was

21 certainly not my intention, far from it.

22 Q. If they were fired on.

23 A. Okay -- no, not if they were fired on, there was no

24 such -- because they were not fired on. No, okay, in

25 a normal military situation, right, you have enemies


Page 16


1 facing each other.

2 Now, you are, in military phrase, "in contact". You

3 know the enemy are over there. Now, if you see one of

4 them, you shoot at one of them. He does not have to be

5 shooting at you, his mere presence makes him a member of

6 the enemy and therefore a normal military --

7 Q. So That was your hypothesis, you assumed that the

8 soldiers had received orders to fire at anybody wearing

9 a combat jacket, whether that man fired on them or not?

10 A. I could see no, no explanation that would involve them

11 firing on them. For instance, the first two -- may

12 I continue? The first two, because I am looking at this

13 as we assemble information. The first two people who

14 were wounded were well back. Donaghy and -- you know

15 their names.

16 Q. Johnston.

17 A. Okay, they were shot at from some distance away, because

18 they were in the middle of a crowd. Okay, I have never

19 seen any suggestion that they were carrying weapons,

20 they were firing at anyone and why would they be firing

21 specifically well back from -- they must have been shot

22 at for some other reason.

23 Underneath -- forgive me, because this is something

24 that indeed came very much to our mind and it is clearly

25 troubling you and I think is largely what we are


Page 17


1 discussing here: was there or was there not an armed

2 engagement?

3 Now, whoever drew up the plan clearly assumed there

4 would be an armed engagement, because that is what an

5 ambush is. If you try to ambush people who are armed

6 they are very likely to shoot back, but there were

7 people who -- it has never been suggested that all of

8 the demonstrators were members of the IRA, therefore the

9 planners had a very difficult task, who is and who is

10 not in the IRA.

11 One of the suggestions, if you want to put it that

12 way, one of the orders, as I interpreted it, must have

13 restricted engagement, combat, to persons who could have

14 been in the IRA.

15 Q. When you say, "restrict combat," do you mean shooting at

16 people whether they were offering violence towards the

17 Army?

18 A. No, no, no, no. You see, in a normal military

19 situation, enemy versus enemy, then they do not have to

20 offer any violence to you, they are simply there.

21 Q. So the assumption on which you were proceeding or which

22 you deduced was that the order was to fire at people in

23 combat jackets, whatever they were doing?

24 A. No, because of where they were standing.

25 Q. Because of where they were standing?


Page 18


1 A. Correct, because the clearing of a barricade, for

2 instance, by shooting, is not the same operation as

3 having a combat with the people on the -- they were

4 shot, at least this was the presumption and I am

5 suggesting that the four -- where the bodies are,

6 falling in lines and all that, it is on the map, which

7 is very important to this, they could not possibly have

8 been standing in lines shooting at the Army, as far as

9 I know the IRA do not operate in lines. So the line

10 must be there for some other reason.

11 Now, the only other reason for the line must have

12 been that it constituted the closing of a box and that

13 the constant reiteration that this was an illegal march

14 and so on, which again was very prominent in the early

15 statements, suggested strongly to me and to my colleague

16 that the only explanation we could see for the clothing

17 they were wearing, the almost entirely male appearance,

18 et cetera, where they fell, that this constituted what

19 would, under normal circumstances, be quite an ingenious

20 military operation: closing a box.

21 Q. Can we leave aside for a moment the deductions you made

22 and see what were the facts which, or the evidence that

23 you had in front of you. Everything that you talk about

24 in this paragraph, paragraph 5, appears to be based upon

25 the fact that you heard statements on the radio that


Page 19


1 young men of military age wearing combat jackets had

2 been shot; is that right?

3 A. No, no, no. There is an earlier stage. I am sorry

4 I have to take you through this, but you -- right, we

5 arrived with initially certain problem questions to

6 answer: why they were all youths, why they were all

7 male, et cetera, we have been through that, right, why

8 no soldier has a scratch, why there is no photographic

9 evidence of other people -- of anybody carrying a weapon

10 other than people in the military, why the records that

11 we listened to, we could hear no sound other than

12 semi-automatic fire, right. All of this sounded like,

13 if you add it up together, a set of questions, whatever

14 had happened had to explain these facts, the explanation

15 had to explain these facts.

16 Now the first thing that seemed utterly impossible

17 was that there had been an engagement between people

18 armed with nail bombs, Thompson guns, pistols,

19 et cetera, an engagement, both sides shooting at each

20 other, because the end result was utterly incredible.

21 This would be the first action in history in which all

22 the wounded, all the wounded and dead were on one side,

23 I do not want to take you through them, you can see what

24 I am saying.

25 We were looking for an explanation that would answer


Page 20


1 these questions. Now, behind these questions lay the

2 unspoken problem, which of course is what we are all

3 discussing here: what was the military intention; what

4 were they trying to do that produced this result.

5 Now, as far as we could discover -- and I have seen

6 nothing to contradict it -- whatever they were trying to

7 do had nothing to do with what the response on the other

8 side was, because there was not any response on the

9 other side, are you with me?

10 Q. Yes, I follow that. Let us see the facts that you had

11 available: you mention them in paragraph 6 we have on

12 the screen: no soldiers had been wounded, no weapons

13 recovered, none of the arrested detained and many of the

14 injuries you say, could not credibly had been suffered

15 by a combatant in a firefight.

16 You then had the fact that you heard on the radio

17 that young men of military age wearing combat jackets

18 had been shot. Did you think that nearly all of the

19 dead and wounded were wearing combat-style jackets?

20 A. One of the questions we asked them, you remember that --

21 Q. It was what they were wearing, yes?

22 A. Where they were standing, what they were wearing and, if

23 they were still alive, where their injuries were. Three

24 neutral questions. The purpose of asking what they were

25 wearing was to check against exactly what we are


Page 21


1 discussing: whether they could -- colourably be

2 described as youths of military age wearing combat

3 jackets because the significance of that was not an

4 observation by someone that they all had been youths, of

5 course they had roughly in that classification, but that

6 this must have some part in the operational order.

7 Q. I wonder if you can answer my question: did you think

8 nearly all of the dead and wounded were wearing combat

9 style jackets?

10 A. Yes. We went over their clothes very carefully. There

11 is a list of it. In fact, the map that was subsequently

12 published in the Sunday Times I think lists what they

13 were wearing. I have seen many such lists. But we made

14 our own. At the Altnagelvin Hospital we asked the

15 wounded what they were wearing, one of the three

16 questions, and we could see from the photographs of the

17 dead what they were wearing and roughly speaking,

18 roughly speaking all of them fitted -- they were all

19 male to begin with, they all fitted within this

20 classification, roughly speaking.

21 Q. Well, we have details of their clothing and they do not

22 all fit within that classification.

23 A. That is a debatable matter. I said roughly fit within

24 that classification. None of them were wearing

25 three-piece suits, none of them were wearing clothing


Page 22


1 that would not -- at least that was what we made out of

2 it.

3 I am not saying, of course, that this clothing was

4 unusual in that part of the world at that time, I am not

5 saying that for a moment. What we were looking for, if

6 there had turned out to be a largely variegated outfits

7 wearing and they were in different sexes and so on, then

8 there goes the notion that some form of deliberate

9 selection of targets --

10 Q. You concluded they were all wearing combat clothing or

11 something similar; is that right?

12 A. Could be interpreted in the heat of what was thought to

13 be combat, because once a soldier hears a shot fired,

14 they thinks it is fired at them, that is normal, that

15 they could roughly fit within that classification, yes.

16 Q. Could we have a look at paragraph 7, please, which is at

17 the bottom of page M71.15, it is the bottom of the

18 second page. You described how Derek Humphry asked

19 Gilles Peress for prints of the photographs that he had

20 taken on that day and you say at the bottom of the page

21 that it was clear from eyewitness accounts and confirmed

22 by Peress's photographs and by the Army statements that

23 while most of the paratroopers were equipped with riot

24 gear, shields, visored helmets and clubs, one group of

25 two or three sections were equipped for combat with FN


Page 23


1 semi-automatic rifles.

2 When you say, "one group of two or three sections,"

3 what exactly do you mean by, "two or three sections"?

4 A. The section is, of course, the smallest military unit.

5 Q. You mean a platoon?

6 A. No, there are three sections to a platoon and then three

7 platoon to a company and so on.

8 Q. So how many people are you regarding as being a section?

9 A. That is pretty well universal; seven to ten. All armies

10 have about the same unit, the minimum unit. It is

11 commanded by a corporal or a sergeant. Then the platoon

12 is commanded by a lieutenant and so on.

13 Anybody who is drawing up a military plan is

14 normally going to do it in terms of the military

15 structure, the hierarchy, the way armies are, in other

16 words the protective element of a company. It seemed to

17 us that all accounts suggested about 100 men, that is

18 a company and I think it has subsequently been confirmed

19 that this was Company A, was it not?

20 Q. No, it was Support Company?

21 A. Support Company, the name of the company is not

22 relevant, it was a company. Now, if I were drawing up

23 such a map, such a plan to put it, explain how our

24 thinking went, the first thing, who is the protective

25 element in this? Here we are going to have a mass lift


Page 24


1 in which we expect to be resisted, so some group have to

2 be armed for an armed conflict, for a firefight.

3 Therefore they will be wearing flak jackets, carrying

4 helmets, FN rifles and so on, but you could not snatch

5 anybody, you could not lift anybody wearing -- they were

6 the people wearing riot gear.

7 Q. The facts you had were that you had seen a photograph

8 which Mr Peress had taken, which had somebody with

9 a semi-automatic rifle, and you had been told by others

10 that some of the soldiers had such rifles; is that the

11 position?

12 A. Yes, and I worked out that it sounded to me, as we have

13 a company size and operation, that it would be most

14 likely that the protective element would be at most

15 a platoon, that is three sections, but more likely would

16 be one or two sections, so hence my confusion, one or

17 two sections.

18 Q. When you refer to there being one group of two or three

19 sections equipped for combat with FN semi-automatic

20 rifles, do you mean by FN semi-automatic rifles, the

21 standard self-loading rifle?

22 A. Standard Nato arm, yes.

23 Q. And you reckoned those were the protective element,

24 tasked with -- can we go to the top of the page, please:

25 "Saving their comrades' lives."


Page 25


1 You then describe in paragraph 8 how you decided to

2 speak to soldiers in the units that were regularly

3 stationed in Londonderry and you talked to officers and

4 NCOs of the Royal Green Jackets who thought that the

5 operation was ill conceived and totally unsuccessful.

6 I think you did not speak to, probably were not

7 able -- I do not know whether you were able to speak to

8 anybody from the Parachute Regiment?

9 A. They had left Derry by the time we arrived. My

10 understanding was that they arrived at 5.00 in the

11 morning, we were told, in buses, trucks, military

12 trucks, and that they had all left shortly after the

13 non-engagement, as I suppose I better say, to be

14 specific, had taken place, shooting had taken place and

15 they were all away in military trucks and gone.

16 Therefore, there were no Parachutists available to talk

17 to. Whether or not they would have talked to me, I have

18 no idea.

19 Q. I follow that entirely. I am slightly puzzled as to why

20 in those circumstances, where you had not, through no

21 fault of yours, been able to speak to anybody in the

22 Paratroop Regiment, you came to the conclusion you had

23 worked out to a high degree of accuracy what actually

24 happened?

25 A. Because no other explanation would fit the facts. This


Page 26


1 is the basis of -- it is the coherence of innumerable

2 pieces of information that had enabled us, again I say

3 a fair degree of accuracy, to work out what the plan

4 must have been, what they were trying to do, what was

5 the purpose of this operation.

6 Now, of course what was being put out at the time,

7 that this was crowd control, this could not conceivably

8 have been crowd control.

9 Q. When you say "crowd control," do you mean crowd control

10 or an arrest operation?

11 A. Well, they would be part of the same thing, one or the

12 other. It would be breaking up an illegal, as everybody

13 kept on insisting, an illegal march and arresting some

14 of the people, arrested, why, presumably because they

15 were taking part in an illegal march, I cannot think of

16 any other reason why they would be arrested.

17 Q. Or illegal riot, there is a difference?

18 A. Okay, but riot, marchers in Londonderry at that time, or

19 indeed in Northern Ireland at that time tended to wind

20 up with something called normal aggro, I am not telling

21 you anything you do not know and stones were thrown and

22 by and large everybody would go home, it would become

23 almost ritualised.

24 At what time this constitutes an offence, if the

25 whole march had been illegal it could have been broken


Page 27


1 up miles away, if the intention had been to prevent it.

2 So the intention cannot have been to prevent the march.

3 Q. Did you realise the whole march was illegal?

4 A. Everybody kept saying that.

5 Q. You sound surprised at that?

6 A. Surprised at what?

7 Q. That they kept saying it was illegal?

8 A. There were two reasons for that. One is, as everybody

9 knew it, why do they keep on insisting on it, that the

10 march was illegal. Of course the only presumption

11 I could make, and I think it a reasonable one at the

12 time, that the illegality of the march constituted part

13 of the reasoning behind the plan, that if people --

14 obviously if an arrest, an ambush operation, that is the

15 arrest of armed people, people who are armed and

16 expected to be shooting back, right, was contemplated

17 and clearly it seemed to me, and it still it seems to me

18 now, something like that was expected, and under the

19 normal circumstances would have been expected, because

20 I think, I say somewhere else, that we had been informed

21 that the IRA did indeed intend to take part on the

22 march, to show willing, as you might say, to the other

23 people in the Bogside. But to arrest them, to take them

24 in, you would normally expect gunfire.

25 Now, this, because it is in a crowded city and there


Page 28


1 are a lot of other people around and some of them are

2 likely to get hit by one side or the other, then what

3 would be the justification for doing this, and the

4 answer would be: the march was illegal. I agree with

5 you that the penalty for an illegal march in a British

6 city is not death, but the argument that because the

7 march was illegal, therefore the use of some force to

8 break it up, whatever you want to call it, to arrest the

9 leaders, whatever the Paras were intending to do, the

10 justification for using violence under the circumstances

11 would be covered by the fact that the march was illegal,

12 otherwise I could not understand why what everybody knew

13 already, that the march was illegal. I mean, there have

14 been many illegal marches, as you know, in

15 Northern Ireland, and they had not been followed by

16 consequences of this sort.

17 Therefore, in the thinking behind the plan -- that

18 is what I kept on, I had been sent there to discover,

19 not what happened, not what people said -- one said this

20 and the other one said that -- to try to work out how

21 this had come about or, as a journalist would say, to

22 get the story.

23 Getting the story is not just talking to a whole lot

24 of people and writing up what they said. Writing

25 a story has an interpretative element to it, of


Page 29


1 necessity --

2 Q. I wonder if we could move on, because you have got

3 rather far away from my original question. Could we

4 look at paragraph 9 on the screen. You say there that:

5 "Derek then spoke to members of both the Provisional

6 and Official IRA that he knew at that time. He was told

7 that most of the Londonderry Provisional IRA militants,

8 aware of the arrival of the paratroopers in Derry early

9 that morning, were not present on the march ..."

10 Were you present when he spoke to members of both

11 wings of the IRA?

12 A. Some.

13 Q. Some of them?

14 A. What happened, now, again, you have to ask Derek about

15 that, he is here, he will tell you about this. But my

16 recollection was that some people who were -- came up to

17 the City Hotel we were all staying, accompanied by Derek

18 because he wanted me to hear what they had to say too.

19 Now, I did not ask for their membership cards of the

20 IRA, of course, but nevertheless that is what they told

21 us together. Of course I did not write down their

22 names.

23 Understand what I was looking for was one key, one

24 key thing: why were the IRA not present, why was this

25 one unit action taking place.


Page 30


1 Q. You were present when some --

2 A. I was indeed. I cannot give you their names.

3 Q. You describe how he was told that most of the PIRA

4 militants were not present on the march and instead were

5 up in the Creggan Estate. Is the sense of that sentence

6 that you understood that although most were up in the

7 Creggan Estate, some were present on the march?

8 A. No. I was not prepared -- journalists are told to be

9 beware of the absolute; "all", "none" were present.

10 None were armed that were present, apart from the

11 exceptions we mentioned, the Official IRA man with the

12 pistol.

13 Q. That is that you were told, is it?

14 A. That is what they were told. Most of them were and

15 those who went there were not armed, as we understood

16 it. I am not prepared to say anybody said, "Oh, yes,

17 I have a long list here of who is in the IRA, none of

18 them ..." I am trying to avoid harsh absolutes.

19 Q. You say:

20 "The Officials also denied being on the march with

21 any weapons and said that, with one or possibly two

22 exceptions ... they never fired at anyone on that

23 afternoon. Their claim of around 80 IRA militants in

24 the Bogside area tallied with the intelligence the Green

25 Jackets told me they had been given ..."


Page 31


1 Can I understand, were the Officials, or people

2 calling themselves Officials, saying that there were

3 around 80 Official IRA militants in the Bogside?

4 A. No, no, no, that there were approximately 80 militants

5 in the Bogside altogether.

6 Q. When you say "altogether", is that Officials and

7 Provisionals?

8 A. As I understood it. I was not examining closely the

9 command structure of the IRA, but as I understood it,

10 the number, when I talked later with one of the Green

11 Jacket officers, I said to him, "By the way, how many do

12 you think there are," and he said, "Well, he understood

13 there was about 80".

14 Q. Both wings together?

15 A. He would have said that, yes.

16 Q. You then say:

17 "Derek's IRA contacts told both of us that both

18 wings of the IRA had originally intended to be present

19 at the civil rights march, but decided to stay away when

20 informed of the arrival in Derry early that morning of

21 the paratroopers."

22 Did you understand from these contacts what

23 originally they had intended to do?

24 A. Yes.

25 Q. What was that?


Page 32


1 A. Well, it is discussed in the article which we have all

2 read, I hope, in which we discussed the four strands of

3 reasoning that had led, in our version of events, to the

4 confrontation, the whatever happened in Derry. I put it

5 rather picturesquely, on the streets of Derry,

6 "bloodstained streets", something along those --

7 Now, as we understood it, my talking to some of the

8 IRA people, Derek talking to more of them, they

9 originally -- they were presented with a problem by the

10 civil rights movement. I will have to explain this to

11 you, it will only take a moment and you will see my line

12 of reasoning.

13 The civil rights movement was asking for civil

14 rights in Northern Ireland and the last thing the IRA

15 wanted was civil rights in Northern Ireland. What they

16 wanted was the elimination of the border, completely

17 contrary.

18 On the other hand, the civil rights movement had

19 attracted much, much support in the Catholic nationalist

20 community and had garnered support in the other side,

21 the Loyalist, respectable Loyalist people and people

22 like Reverend Donald Soper from London and so on.

23 The idea of civil rights presented a political

24 challenge to both wings of the IRA. Therefore they were

25 presented with a dilemma. If they do not go at all,


Page 33


1 everybody knows in the Bogside roughly who is in the IRA

2 and, you know, I am not telling you anything you do not

3 know. Therefore their absence from a popularly

4 supported movement would look a bit odd, to say the

5 least.

6 On the other hand, if they went armed, the chances

7 were that exactly what was supposed to happen would have

8 happened, they would have been involved in a gunfight.

9 Derry people would have been hurt, demonstrators who had

10 nothing to do with the IRA would have been injured and

11 they would have very rightly got the blame.

12 Therefore this dilemma, this is our understanding,

13 was solved by an early decision by them that some of

14 them would go so their faces could be seen among the

15 demonstrators but would not be armed. That decision, as

16 far as we could discover, had got back to Military

17 Intelligence because, as you know, the Bogside is full

18 of informers and I am not telling you anything you do

19 not know.

20 However, the second, the change of a plan when the

21 Paras arrived -- do not forget nobody knew the Paras

22 were going to turn up, certainly none of the organisers

23 of the march knew anything of that kind, they thought

24 just the regular police and regular military would be

25 involved. When they turned up they changed their plan,


Page 34


1 because they thought the Paras cannot be here for crowd

2 control, they must be here for some sort of military

3 operation and their guess was that it was going to be an

4 arms sweep through the Creggan -- this is what we were

5 told -- therefore they were all in the Creggan. I hope

6 I am -- I am being a bit wordy, but that is the

7 thinking.

8 Q. You say that the decision to be present but unarmed had,

9 so far as you could discover, got back to Military

10 Intelligence?

11 A. Yes.

12 Q. What is the basis for saying that you discovered that;

13 simply the fact that they were informers in the Bogside?

14 A. No, you see some of this comes out of, again long ago,

15 talks with people who were members of the regular

16 established military who had been there for some time,

17 who were still very much present in Derry.

18 Now, I had a lot of conversations with them on rainy

19 street corners in the next day or so, "what do you think

20 happened," on a non-attributable, no notebook in my hand

21 explanation, what do they think.

22 They said that their understanding was that some

23 Paras, some Provos or both wings of the IRA intended to

24 be present, that is what they had heard. Now, this is

25 not getting it, of course, from an Army Military


Page 35


1 Intelligence officer, that is simply, as the Americans

2 say, "on the grapevine," but it seemed reasonable, shall

3 we say.

4 Q. Can we have a look, please, at paragraph 10, the bottom

5 of the page. You describe speaking to a retired British

6 Army sergeant major, James Chapman and you say, about

7 five lines up from the bottom, that what he told you

8 convinced Derek and yourself that your theory of what

9 had happened was correct.

10 Could we have a look, please, at AC59.17. Can

11 I tell you what this is. We have some, but not all, of

12 the Sunday Times archive and this is described as

13 a statement of Mr James Chapman to Derek Humphry of the

14 Sunday Times. Do you recognise that statement?

15 A. No, I did not write it.

16 Q. That is not your handwriting?

17 A. Not my handwriting and you will have to ask Derek, who

18 is here, what that is. I talked to Chapman, to the best

19 of my recollection, in the company of Derek and I found

20 Chapman, as I said, most helpful, most helpful, because

21 here is a trained military observer. I could talk to

22 him about contact and squads and sections and all the

23 things I am talking to you about and nothing needed to

24 be explained to him and it was he who described to me

25 the speed and precision with which the operation that he


Page 36


1 witnessed had taken place, which demonstrated beyond the

2 question of possibility of doubt that this was

3 a carefully pre-planned operation, as indeed you would

4 expect it to be.

5 Q. Could we have a look, please, at S20. Can I tell you

6 what this is? This is a document also obtained from the

7 Sunday Times archive and I think it is your report to

8 the Sunday Times, telephoned in and typed. The reason

9 that I am asking you about it, is this: in this

10 paragraph your account begins by saying:

11 "Almost immediately the serious Army operation

12 began. Soldiers lifted the central section of the

13 knife-rest," et cetera:

14 "From Little James Street running into William

15 Street seven Saracens, lead by a Ferret scout car,

16 emerged and raced up Rossville Street, at a speed which

17 a trained military observer, ex-Sergeant Major James

18 Chapman, puts at 40 miles per hour."

19 Somebody has written in manuscript in the left-hand

20 side:

21 "Demolished at Widgery and agreed he must have been

22 mistaken in his main body of evidence."

23 A. Okay.

24 Q. Do you know whose handwriting that is?

25 A. Not the faintest idea, and I have something to explain


Page 37


1 to you. The statement you have in front of you is

2 a copy, a typed-up version of the copy Derek Humphry and

3 I telephoned in. I never found it in the Sunday Times

4 archive. The first I saw of it was 28 years later when

5 it was sent to me via a group here in Derry and it was

6 in the archives of Hull University, the National Civil

7 Liberties --

8 I am now delighted and interested to discover,

9 because nobody told me before, that someone in the

10 Sunday Times had taken this version somewhere and was

11 noting on it. When, you perhaps cannot tell me, when

12 did this reach the Inquiry?

13 Q. Very early on, some time in 1998.

14 A. Right, so it certainly -- nothing like that was in the

15 Sunday Times when I looked for it myself in 1972,

16 because on my return from Derry I searched, with the

17 help of my then girlfriend, who is now my wife, who was

18 working at the Sunday Times, we searched every

19 conceivable place we could find, "where is our copy"; we

20 could not find it, it had disappeared.

21 As far as I know, it was never sent to the

22 Widgery Inquiry. If so, I am told, you can confirm

23 this, that it was not in the Widgery papers which this

24 Inquiry received, it was not in the archive at Kew,

25 where the Widgery papers -- it had disappeared, I never


Page 38


1 thought I would see it again.

2 Somebody has been making a commentary on this. You

3 will have to find out who wrote that and on what it is

4 based.

5 Q. We know what it is based on. It is based on what

6 happened when Major Chapman gave evidence at Widgery.

7 A. Whatever -- who wrote it says it is based on that.

8 I can make no comment on handwriting I do not recognise.

9 I now learn at this moment from you, for the very first

10 time, that someone in the Sunday Times was annotating

11 it. I did not know that.

12 Q. Could we look at paragraph 11 on M71.17. You say:

13 "By this stage, we felt that we had worked out to

14 a high degree of accuracy what actually happened on the

15 day and we incorporated this into the article that they

16 wrote for the paper."

17 Would I be right in thinking "by this stage" means

18 the Thursday of the week after Bloody Sunday?

19 A. Yes, if I explain that, that may be necessary. Under

20 the normal circumstances, the way the newspaper worked

21 or way newspapers work, this would have had to have been

22 "lawyered", if you forgive the expression, because

23 anything of this kind would have to be looked over by

24 the company lawyer, the paper's lawyers. It would have

25 to be looked over by sub-editors, who might be on the


Page 39


1 phone with questions of the kind you are asking me, "how

2 do you know this, how do you know that," and so on.

3 In order to give the paper time to do this it would,

4 looked at from their deadline point of view, because

5 this we knew was going to be a very, very big piece and

6 therefore needed a lot of work in the paper, layout and

7 photographs and so on. To get it in on Thursday --

8 Q. I do not want to stop you, but we do know all this. We

9 have seen the whole Sunday Times archive, such as it

10 exists, and I think we have a fairly clear picture of

11 what had to be done.

12 Can I examine with you who you have been able to see

13 by this stage. Between you, you and Derek Humphry had

14 seen some of the wounded; is that right?

15 A. Well, I did not count them, but the wounded, I cannot

16 remember whether I saw them all. Derek, you can ask him

17 how many, because he originally and then I went down

18 with them and we talked to them again. We had seen all

19 of the wounded who we were able to talk to.

20 Q. Can we have on the screen M71.29. This is your article

21 plus some additional material in one of the forms in

22 which we have it. If we go to the bottom of the page,

23 it reads:

24 "Wounded: Code number: 1 ... Code number: 2",

25 et cetera.


Page 40


1 Over the page it goes down to "code number: 8";

2 would it be a fair assumption that the wounded whom you

3 would have seen by this stage are the eight people from

4 whom there appear to be quotes in this attachment to the

5 article?

6 A. It would be an assumption, but I cannot confirm it. By

7 the way, while we have this in front of us, would you

8 mind going back to the end of the text of the article?

9 Q. Could we have the previous page?

10 A. There is an omission I have to point out, to say, "we

11 have no choice," and the word "but" is missing. I know

12 it is missing because I would not write it without

13 a "but", it is ungrammatical the way it is.

14 Q. While we have the material on the page, each of these

15 wounded who are referred to has against his or her name

16 a statement in quotation marks. Can we assume that the

17 usual convention applies and that was a direct quote

18 from the wounded person in question?

19 A. Well, obviously compressed. It would have been

20 a version. It would have been, I have to say -- I do

21 not remember writing those and I think, because Derek

22 was largely in charge of that aspect -- we were working

23 together -- you can ask him exactly how those

24 statements -- but that is what I would certainly agree

25 with you, that that would be a fair compression,


Page 41


1 summary, in direct quotes, of what they said. We were

2 not using tape recorders or anything of that kind. The

3 direct quotes are the convention that you actually say,

4 "this is what they actually said".

5 Q. This is what they said, but it may be a compressed

6 version, is that it?

7 A. I should think it would likely be, because I would think

8 it highly unlikely that anybody would express these

9 grammatical clear, simple sentences and say nothing

10 more.

11 Q. You had seen some of the wounded; you had seen some

12 people from both wings of the IRA?

13 A. Correct.

14 Q. Do you have any idea how many people you saw?

15 A. Now, how many I saw or how many Derek saw?

16 Q. Perhaps you would like to answer both questions.

17 A. Okay, a small group, maybe half a dozen was my

18 recollection of the ones I talked to in Derek's company,

19 this was not because I mistrusted Derek, but I thought

20 it better we both hear what they have to say because of

21 its importance.

22 Q. Was that half a dozen people from the same wing?

23 A. I do not know, could not tell you. Too long ago, sorry.

24 Q. Do you know how many he may have seen?

25 A. I do not know, you will have to ask him.


Page 42


1 Q. You saw Mr Chapman, did you?

2 A. I did indeed talk to him at some length, yes.

3 Q. And anybody else, any other civilians at this stage?

4 A. Not that I can recollect talking to civilians. By

5 "civilians", I am wondering who we are talking about.

6 Derek talked --

7 Q. Anybody who is not a soldier.

8 A. Derek certainly talked to Dr McClean and I met him.

9 I do not remember how many he told -- what length

10 I talked to him, but I certainly met him.

11 Q. You cannot remember any others?

12 A. I cannot, but I am not prepared to say I did not. After

13 all, my memory is being refreshed very largely by this

14 piece. They are my notes, as you might say, that is

15 what we wrote at the time.

16 Q. Did I hear you a moment ago say that you listened to

17 some recordings, tape recordings?

18 A. Yes.

19 Q. What were they?

20 A. To the best of my recollection -- if I could digress,

21 because it will only take a second. We had a situation

22 at the City Hotel where just about every -- what Fleet

23 Street call a "heavy mob", were milling around, the

24 specials had been sent over to get onto this, right, and

25 not just from British newspapers, from Time and Newsweek


Page 43


1 and so on, in this small hotel. We are like journalists

2 normally under those circumstances, partly co-operating,

3 partly competing, that is the situation, a very

4 characteristic scene.

5 A lot of them were television and radio people. The

6 entire stage of the shooting, the entire phase of the

7 shots was something under half an hour. You will have

8 the timing better than I have, there are innumerable

9 other witnesses, but of that order of magnitude. Okay,

10 therefore it was very easy to listen to the sound

11 element of the television people, who were happy to play

12 it for us because they wanted to discuss with us what we

13 thought had happened. This is normal. I recollect

14 listening to tapes --

15 Q. This is tapes of news footage?

16 A. That were made at the time, yes, because there were

17 radio -- there were many, many press there, there were

18 radio people, I think a man from the BBC let me listen

19 to his tape for the relevant period.

20 Now, what I was listening for, of course, was the

21 sound of shots, which are very, very distinctive;

22 semi-automatic fire, full automatic, low velocity, high

23 velocity, these are all very distinctive sounds,

24 unmistakable, and the only firing I could hear in all of

25 these tapes was semi-automatic, high velocity FN.


Page 44


1 I have heard FNs fired many times and of course I have

2 heard other forms of low velocity automatic,

3 semi-automatic pistol, I have heard all of these things

4 fire, and the sound was irrefutable, it seemed to me,

5 because they were good records and they were very --

6 most valuable evidence.

7 Q. Can we come, please, to M71.21. This is the article

8 that you wrote in the form we most conveniently have it.

9 I do not want to go through all of it, but there are

10 some passages I would like your help on.

11 If we turn to the second page of the article,

12 M71.22, could we highlight the paragraph beginning:

13 "The IRA had never had much success in Londonderry

14 ..." down to paragraph 3. We have blanked off a name

15 which I ask you not to repeat, though you will have the

16 article in front of you. This paragraph says:

17 "The march, which was evidently going to be a great

18 success, posed a problem for both wings of the IRA in

19 the Bogside ..."

20 And you set out the problem that you were speaking

21 of earlier. In the next paragraph but one what has been

22 written is this:

23 "The quasi intellectual, diluted Marxist approach of

24 the Official IRA had little appeal for the Bogside

25 people and the movement barely existed in Derry until


Page 45


1 [and there is a name blanked out] Provisional IRA boss

2 of the New Lodge estate in Belfast and his lieutenant

3 [another name blanked out] arrived in the Bogside

4 in June last year to organise the movement."

5 There is a reference to the death of Cusack and

6 Beatty. Were you present at which either the person in

7 question, boss of the New Lodge estate in Belfast, spoke

8 to you or somebody else spoke of his arrival in Derry?

9 A. I cannot tell you. All I can tell you is that most of

10 the information that I had came from Derek. He was, as

11 we split the job up, he was the one who had the Bogside

12 contacts. Some of them he brought up for me to talk to

13 in the City Hotel, they were quite willing to come, but

14 exactly who was who, I personally did not ask their

15 names. I cannot help you own that, I am afraid, it was

16 a long time ago.

17 Q. I want to show you on that, although I think I know what

18 the answer might be in the light of what you have just

19 said, a document at M45.35. This is another document

20 that came from the Sunday Times archive. We think it is

21 the second page of a more than one page document. There

22 has been put in the top left-hand corner a cipher,

23 PIRA11. I do not want to go through it any detail, but

24 it records that he first came to Derry on a temporary

25 basis in May, "stayed there almost solidly until six


Page 46


1 weeks ago," and there is a discussion about the

2 Provisionals and how things really took off with Cusack

3 and Beatty on 8th July, et cetera; do you recognise this

4 document at all?

5 A. No, never seen it before.

6 Q. Could we then come, please, to M71.23. You deal in this

7 paragraph with the position of the Army. Could we

8 highlight, please, from where I am pointing on the

9 screen down to the end. What you wrote, was this:

10 "The Parachute Regiment staff planners believed they

11 had the answer in the last weeks of the old year --

12 a solution which in fact produced the massacre:

13 "The idea -- worked out, we believe, by Lieutenant

14 Colonel Derek Wilford on lines of thinking propounded by

15 Brigadier Frank Kitson, was based on the military

16 principle that the way to bring your enemy to battle is

17 to attack something that, for prestige reasons, he will

18 have to defend -- the Germans attacking Verdun in the

19 First World War or the same firm attacking Stalingrad in

20 the Second. Brought to battle he will then be

21 annihilated by superior strength.

22 "The civil rights march, the Parachute Regiment

23 planners believed, was just such an objective which the

24 IRA would have to defend or lose its popular support in

25 the Bogside -- and either way the IRA would be finished.


Page 47


1 "If the IRA gunmen could be induced to stand and

2 fight while other demonstrators fled, a snatch squad --

3 but it would have to be a large one -- would be able

4 either to kill them or take them in. So, for some

5 weeks, the Paras have been drilling and rehearsing

6 a company-size snatch squad -- at about 100 men, the

7 biggest one ever used in the present Ulster fighting."

8 Should we understand from that that your theory or

9 conclusion was that the Army planned to attack the civil

10 rights march in order to draw out the IRA whom a snatch

11 squad would then either kill or arrest, was that the

12 basic thesis?

13 A. Not attack the civil rights march as such, because they

14 did not do so. I mean, that was the proof of the

15 pudding, that whatever in the plan was -- whatever they

16 did must have been in the plan, at least until it began

17 to go wrong. No, that at the head of the demonstration,

18 when all of the other demonstrators had gone home and

19 the normal aggro had taken place, then among the normal

20 aggro, the people throwing nail bombs and stones and

21 shouting insults and so on. But if that group were

22 taken in they would, almost certainly, given experience

23 in Northern Ireland, contain members of the IRA who were

24 probably armed and that by taking them in, the people at

25 the head of the demonstration, this was bringing them to


Page 48


1 battle -- this is, you know, I am afraid I was giving

2 readers a bit of lecture in military theory, very

3 elementary military theory.

4 By attacking something your opponent has to defend,

5 that is the group at the head of the demonstration,

6 presumed to contain and under the circumstances would

7 have contained, normally speaking, armed IRA men, then

8 you could expect there would be a gun fight. You would

9 therefore have to have a protective element to make sure

10 that the Army won the gunfight, right. But that this

11 would decapitate not just the march, because most of the

12 march has already gone home or were off to a meeting,

13 but the militant group -- am I making myself clear?

14 Q. Yes, I think you are. What you are saying is that the

15 thing that was to be attacked, which for prestige

16 reasons would have to be defended, were the rioters at

17 the front of the march?

18 A. Exactly, exactly. The normal aggro, it was called at

19 the time. But not all the marchers by no means were

20 aggressive hooligans.

21 Q. Where it says:

22 "The civil rights march, the Parachute Regiment

23 planners believed, was just such an objective which the

24 IRA would have to defend ..."

25 We should interpret that as meaning the people at


Page 49


1 the head of the civil rights march?

2 A. Precisely, that is what I am saying, they would not go

3 unarmed under normal circumstances, that is exactly what

4 I am saying.

5 Q. That was based upon the evidence that you had gathered

6 and which we have just discussed between the Monday and

7 the Thursday; is that right?

8 A. Yes, what I am doing, of course, what they were doing in

9 this, is turning it into a narrative because of our

10 brief: what happened, and here we have our understanding

11 of what happened and we supply, I hope, the arguments on

12 which this line of reasoning is based and of course

13 hence our conclusion, "we have to choice but to

14 conclude ..."

15 Q. Could we have a look, please, at M71.18. Could we

16 highlight the middle of paragraph 13 from, "the civil

17 rights movement, non-violently calling," et cetera. You

18 describe there how the civil rights movement, you say,

19 presented the IRA with a difficult decision, a golden

20 opportunity for the Paras to lift, that is to say to

21 arrest the IRA leadership while they were outside the

22 Bogside proper:

23 "And were, according to intelligence reports,

24 temporarily without weapons."

25 What was your basis for saying that there were


Page 50


1 intelligence reports that the IRA were temporarily

2 without weapons?

3 A. We heard this from Bogside people, but Derek can help

4 you further on that. But the explanation that was

5 offered to us was that they did not want a gun fight,

6 they had a problem, whether to go or not, whether to

7 have their faces shown or not, but if they went with

8 weapons there was likely to be a gun fight in which

9 innocent Bogsiders, innocent Bogside rioters, if you

10 like, would have been killed or wounded and that would

11 further diminish their rather shaky hold on public

12 opinion in the Bogside.

13 So the decision, as we understood it, was that they

14 would indeed be present showing their faces but would

15 not be armed and that, presumably, would melt away at

16 the first sign of trouble.

17 Q. Is this the position: you learnt from conversations with

18 the Bogsiders that the IRA were short of weapons?

19 A. No, they had plenty of weapons, they just decided not to

20 take them. They had plenty of weapons, that was not

21 beyond dispute. They had plenty of weapons. They were

22 in the Creggan largely, that is what we were told and

23 they presumed there was going to be an armed sweep

24 through the Creggan.

25 Q. Temporarily without weapons because the weapons were in


Page 51


1 the Creggan?

2 A. Right.

3 Q. What I am concentrating on was your reference to,

4 "according to intelligence reports"?

5 A. You are asking me how I know there were intelligence

6 reports.

7 Q. How do you know there were intelligence reports that the

8 Army had that the weapons were all in the Creggan?

9 A. Not that they were all in the Creggan, I do not think

10 they had that information. I do not know, I simply do

11 not know. That -- because this was widely known in the

12 Bogside, that they intended to appear without weapons

13 and that the Bogside was pretty leaky from a Military

14 Intelligence point of view -- a lot of the permanently

15 stationed soldiers there had girlfriends, et cetera --

16 in other words, a great deal was known by the Military

17 Intelligence of what was going on in the Bogside, that

18 it was a fair presumption that this would have been

19 known because it explained something that was otherwise

20 puzzling about what actually happened, namely, the

21 activities of the execution of the presumed military

22 plan.

23 Now, when I say "presumed", I do not mean there is

24 any remote possibility there was no plan, because that

25 is not possible.


Page 52


1 Q. The reference to intelligence reports is the

2 intelligence you presumed the Army had?

3 A. It was around the Bogside, so it was highly likely the

4 Army had it, yes.

5 Q. Could we come, please, to M71.24. In this part of your

6 article you describe what happened on the march. May we

7 come to M71.26. Could we highlight, please, the third

8 paragraph. You describe in this part of the article the

9 wounding of Damien Donaghy and you describe in the

10 paragraph that is now on the screen how one Official IRA

11 man was nearby in a burned-out building opposite

12 Richardson's factory, he was posted there as an

13 observer, armed with a .38 pistol, although his orders

14 were that he was to be unarmed:

15 "After Damien Donaghy was shot, he says he fired

16 a single round at the soldiers on the GPO sorting office

17 roof. We make the range 50 yards."

18 Were you present when the Official IRA to whom this

19 paragraph refers gave this account?

20 A. The best of my recollection, he told both Derek and

21 myself, to the best of my recollection, but -- I beg

22 your pardon. To the best of my recollection.

23 Q. Did you learn who he was?

24 A. No, I asked none of the IRA people -- I did not ask them

25 what their names were. You will have to ask Derek if he


Page 53


1 did. I deliberately -- I was not interested in their

2 names, I asked no soldier his name either.

3 Q. If we go to the bottom of this page, the last two

4 paragraphs. Having described the shooting of Damien

5 Donaghy and John Johnston, you describe in the

6 penultimate paragraph how:

7 "No more shots were fired for between 10 and 15

8 minutes. This was the period when, according to the

9 Army plan, fire should have been returned by the IRA, or

10 they should have been seen running home for their

11 weapons."

12 What was the basis for saying that; that appears to

13 suggest that shooting Damien Donaghy or John Johnston

14 was part of a plan to draw out the IRA?

15 A. I do not say it was part of a plan because, because --

16 Q. "... according to the Army plan"?

17 A. Okay, now, may I explain, I have to get back into

18 military jargon, I am afraid. Nobody would have -- I do

19 not know who gave the "initiate" order. We were unable

20 to work that out. Initiate the plan, right, because

21 such a plan has to be -- somebody has to either say we

22 are starting at 12, noon, done by the clock, or somebody

23 has to say, "the plan is in action, everybody knows what

24 they have to do, initiate, do it."

25 I do not know who gave the "initiate" order because


Page 54


1 I do not know -- it should have been Wilford in the

2 normal hierarchy, he is the colonel of the battalion.

3 The order should have come either from him or through

4 him and I think that is why we said it did because that

5 would be normality. I understand a more superior

6 officer than Wilford was present, General Ford, but we

7 did not know that at the time.

8 This is all phrased by me very carefully, because

9 this covered an area that I could not understand.

10 I tried to work out why the two, Donaghy and the other

11 one, had been shot and there is some discussion of this

12 in the piece. They were not doing anything, they were

13 not carrying any weapons, they were not in any way

14 leaders of the march, why had they been shot?

15 The only possible explanation that seemed to us to

16 be remotely feasible was that this was an attempt to

17 draw fire. In a battle situation that is exactly what

18 you do, you put a tin helmet over the parapet and if

19 nobody fired back you would take a shot. In other

20 words, to determine whether they were, the Paras were in

21 contact or not, whether the enemy was present.

22 Now, I worded this -- and I remember hesitating,

23 I was very careful here, I went no further than iron

24 reasoning could have taken us in this particular matter.

25 I offer no explanation as to why these two were shot or


Page 55


1 even a guess or a hazard, but the single IRA shot -- and

2 I was very careful about the sequence of events here --

3 ten minutes later the Provisional IRA shot, might,

4 might, have been interpreted by someone as an indication

5 that the Paras were in contact, that the enemy was

6 present, that in other words the plan was to go ahead

7 and then 10 minutes later someone gave the "execute"

8 order and then everything else followed.

9 Of course they were not in contact except with this

10 one IRA man, that we know from the results, you know, we

11 have been through all that, the number of dead and

12 wounded and so on, that is a presumption on my part and

13 carefully worded it for that purpose.

14 Q. You say you gave no explanation for why they were shot,

15 but your reference to the Army plan appears to be

16 a plain suggestion that it was the plan of the Army to,

17 as you put it, draw fire by shooting at Damien Donaghy

18 and John Johnston?

19 A. Where do I say that?

20 Q. "This was the period when, according to the Army plan,

21 fire should have been returned by the IRA"?

22 A. And no fire was returned.

23 Q. What were you suggesting was the Army plan?

24 A. We have already described it, to ambush the presumed

25 armed IRA men or possibly unarmed, who run home and get


Page 56


1 weapons, at the head of the demonstration -- in other

2 words, to make sure that the IRA were in fact present.

3 I am well aware -- I discussed it in my memo by the way.

4 I am well aware of the implications of that, that that

5 could be way off the Yellow Card rules. I am well aware

6 of that and was well aware of it at the time, but I had

7 not called attention to it.

8 Q. So the Army plan you are referring to at this stage is

9 the Army plan, as you thought, to shoot people at the

10 head of the demonstration?

11 A. Not shoot people at the head of the demonstration,

12 ambush them, arrest them and if they resisted or ran

13 away, clear the barricade, as you would say in military

14 terms -- in more conventional terms, shoot people who

15 were on it, because indeed they were shot on the

16 barricade.

17 Q. At the bottom of the page you describe how a shot rang

18 out and Jack Duddy fell dying in Chamberlain Street and

19 you describe how Mrs Deery was hit in the back of the

20 leg and carried into a house at the top of Chamberlain

21 Street.

22 It is apparent from this, is it not, that at this

23 stage you thought both Jack Duddy and Peggy Deery had

24 been shot before the Saracens had driven into the

25 Bogside?


Page 57


1 A. I am not sure. I will re-read it again carefully.

2 I have no recollection from the time.

3 Q. It must be so, if you look at the third paragraph on the

4 page, what you went on to say was, "almost immediately"?

5 A. I agree with you that the presumption, the implication

6 that would be in the piece would be that, I agree with

7 you on that, but I have no recollection of that

8 particular train of thought at the time. But that

9 certainly could be read into that, yes, and I find it

10 difficult to read it any other way, yes.

11 Q. Then you describe, in the fourth paragraph, the seven

12 Saracens, led by a Ferret scout car, emerging and racing

13 up Rossville Street and you refer to Sergeant Major

14 James Chapman.

15 Then in the next paragraph you describe, in the

16 paragraph beginning, "within the next few minutes

17 a dozen more people were shot down," you refer to

18 soldiers jumping out and shooting apparently

19 indiscriminately, sergeant Major Chapman describing

20 exactly the same scene as in terms "equally shocked and

21 horrified"?

22 A. I am sorry, Mr Clarke, I have lost you.

23 Q. "Within the next few minutes"?

24 A. Okay, yes.

25 Q. "And the trained military observer, Sergeant Major


Page 58


1 Chapman, describes exactly the same scene ... Saracens

2 took up rehearsed blocking positions along

3 Rossville Street and next to Rossville Flats.

4 Paratroopers, wearing combat and not anti-riot gear,

5 jumped out and dropped into standard British Army firing

6 positions, in spots clearly selected in advance for the

7 purpose of the operation."

8 Would I be right in thinking this is largely derived

9 from Sergeant Major Chapman's statements?

10 A. Two things, what Chapman said and our map, because we

11 plotted all this on the map which I think will be shown

12 and on the map all of this makes a great deal of sense.

13 For instance, there was no reason for the three

14 soldiers to get behind the low wall we mention, and

15 their positions were indicated and people told us of

16 their firing from there.

17 Nobody was firing at them that we could determine,

18 therefore they must have therefore -- there is a lot of

19 therefores in this, of course -- therefore they must

20 have already known where they were going and, in the

21 absolute course of, you can say as an absolute certainty

22 and I was later able to confirm it, this must rehearsed

23 on a sand table or a model of some kind, because the

24 Paras had never been in Derry before.

25 As Chapman explained it to me, no orders were heard


Page 59


1 by anybody, they simply ran or arrived in their Saracens

2 and ran to positions, did not look around to see where

3 they were going, ran to exactly where they wound up,

4 fell on one knee, which is standard British Army firing

5 position, and I have seen a lot of British Army firing,

6 that this must have been, could only have been what

7 Chapman was describing to me, and he agreed with us, of

8 course, was a plan being put into effect and the map

9 shows what the result of the plan was.

10 Q. The facts upon which this is based are: the evidence of

11 Sergeant Major Chapman and the fact that people were

12 shot at the barricade and an assumption that there was

13 no firing from the barricade?

14 A. No, hang on. Yes, okay, but let me elaborate on that

15 a little. Do not forget, we set off to answer three

16 questions: what were you wearing, where were you and so

17 on, where are your injuries. That was in order to

18 prepare the map, because I could not see how you could

19 describe a military operation without the map.

20 Okay, if you put those together Chapman had not seen

21 our map, he was a completely independent witness, what

22 he described exactly matched what the map was.

23 Now, if there was any firing at the military, where

24 was it on the records? We could not hear it, unless the

25 IRA are also armed with FN semi-automatic weapons; where


Page 60


1 are the soldiers' wounds and then the whole, we are down

2 that whole long thing of how can you explain all this

3 and the only answer that is possible is that there was

4 no armed encounter, that is the one simple explanation

5 that jumps out of the map, the facts everybody told us.

6 Q. It is a cardinal support of the whole theory?

7 A. Yes, and by the way, "theory" is perhaps -- in a way,

8 all deductions of this kind, if you like, are theories;

9 the theory of relativity is, of course, a theory. It is

10 not a speculation, it is a series of logical steps which

11 I hope I have laid out in the article itself.

12 Q. I follow. Can we have the next two paragraphs. You

13 went on to say:

14 "This [that is taking up various positions] clearly

15 was to ambush the supposed concentration of IRA men in

16 the Harvey Street, High Street, Eden Street, Chamberlain

17 Street area, pinning them against the Army defences in

18 Waterloo Road."

19 Were you familiar with Derry at the time, had you

20 been here before?

21 A. Never, but I had been very familiar with that ground.

22 I had walked it ten times. The first thing I did when

23 we arrived on the Monday morning after the Sunday,

24 straight to the scene, had an artist there, I think he

25 arrived Tuesday morning, drew the whole map which is in


Page 61


1 evidence, his map and then, armed with the map, went

2 round and talked to everybody and said "show me across,

3 what is here, what is there". The whole thing was based

4 on an interpretation of where bodies were placed, people

5 were placed, what had happened, based on the map, the

6 map is absolutely crucial.

7 Q. You then described how another platoon ran through the

8 narrow allies and walkways of the Little Diamond area,

9 also a traditional battle ground.

10 And you go on to describe:

11 "Executing the normal fire and movement tactic,

12 taught to British Infantry, the paratrooper cleared the

13 barricade in Rossville streets by shooting everyone on

14 it or near it ..." and you describe the deaths of the

15 people at the barricade.

16 You went on to say:

17 "A section of paratroopers running through the

18 Little Diamond to link up with their comrades at the

19 barricade, got behind it -- there was no-one left alive

20 to stop them -- and began laying down a field of fire

21 behind Rossville Street Flats."

22 As I understand it, you had understood at this stage

23 that the soldiers who came in the end into Glenfada Park

24 had come from the Little Diamond; is that right?

25 A. Well, that is what the story says. I do not have that


Page 62


1 imprinted on my mind. Of course, this is now 30 years

2 later. But that is what the piece says and that would

3 have been based on what witnesses told us, pointing to

4 the map and showing me where this had happened and where

5 they had seen it.

6 Q. When you wrote, "a section of paratroopers running

7 through the Little Diamond to link up with their

8 comrades at the barricade, got behind it ..." were you

9 suggesting that soldiers had actually reached the

10 barricade?

11 A. That is how I would read it. I do not -- I would agree

12 with you that is how it reads. I have no recollection

13 of writing that, because it is a long time ago, but

14 I would have written that on the basis that that was

15 what we had been told and that it agreed with what

16 doctor -- all of this was done off our map, that it

17 agreed with what the map said.

18 Q. Can we have a look at your map. I hope it is at M71.33.

19 This is the map you were using; is that right?

20 A. Yes, let me explain. The artist, I think his name was

21 Butterworth, I got that wrong in my first statement, but

22 I corrected it when I saw the map.

23 That map was originally a simple plan, the drawing

24 of the streets and so on and Butterworth was present in

25 the Derry hotel, in the City of Derry for a couple of


Page 63


1 days. We went round -- we had more than one copy of the

2 map, the simplified version.

3 We then got people to mark it with arrows map, where

4 they fell, all that sort of thing. Then he drew it up

5 in the schematic form that you have in front of you.

6 Okay, everything we say, all the squares, the keys

7 you see and of course what we looked for, as soon as we

8 had plotted the line, what is the explanation of that

9 line that runs from top to bottom, you see it roughly,

10 okay, how could that be explained unless there was

11 another opposing group in a line shooting at them. Why

12 have they shot in a line? It cannot be an accident,

13 there is too many of them.

14 Okay, now everything was based on that. That map,

15 incidentally, was published, as you see, The Sunday

16 Times, "A sketch map for Widgery Tribunal". What was

17 published was the map but not the article, because the

18 map was sent with the article and without the article

19 the map does not make much sense. Conversely, without

20 the map the article is very hard to follow.

21 So they were intended to be, and I hope can now be,

22 read together and that explains what they were saying,

23 but the map is crucial, because that was our tool for

24 orientating ourselves in that. I walked at least,

25 I said in my memo, ten times, that would be about right,


Page 64


1 walked round and round and round all of these streets

2 with Butterworth, with witnesses who were prepared to

3 come with us and so on, saying, "where, show me where".

4 Q. Do I have the point: what it comes to is that because

5 you saw that there were a number of people who had been

6 shot at the barricade, that there must have been a plan

7 to shoot them there?

8 A. To clear the barricade, as we put in military terms.

9 Yes, because they had no weapons, there is no evidence,

10 they never fired back, they never hit anybody. They

11 could not have been defending the barricade, because

12 what are they defending it with and the line leads to

13 only one conclusion, which, as I said in the last piece

14 of the article, I rather reluctantly came to, we had no

15 choice to conclude -- if ours is not the explanation,

16 then what is the explanation, and I mention of course

17 the principle of economy of explanation, which I think

18 we are all familiar with. That one simple explanation

19 jumps out of that map at you, okay.

20 Q. And when you referred to:

21 "A section of paratroopers running through the

22 Little Diamond to link up with their comrades at the

23 barricade, getting behind it and beginning to lay down

24 a field of fire behind Rossville Street."

25 Was the suggestion that you were making that one lot


Page 65


1 of soldiers came up to the barricade and another lot had

2 come into Glenfada Park and were firing across there?

3 A. It would certainly read that way. Now, I have not

4 memorised this, of course, it is a long time ago. It

5 would certainly read that way and we were very careful

6 with, you know, synchronising the map and our -- it is

7 a pretty workmanlike job, if you will forgive my saying

8 so myself. If that is what the story says, that is what

9 we most certainly concluded at the time. I cannot say

10 any more than that.

11 Q. Could we come, please, to M71.28. In paragraph 2 on

12 this page, you wrote this:

13 "Meanwhile the attempted encirclement of the

14 Rossville Flats -- Chamberlain Street was continuing.

15 A Saracen raced into Rossville Flats parking area. The

16 crew saw that they were not in the spot allocated by the

17 operational plan, and the driver reversed the vehicle

18 against a low retaining wall (crushing Alana Burke) and

19 raced out to its allotted position. McElhinney was shot

20 dead about this instant in the centre of the same

21 parking lot."

22 Do you know where you got that from?

23 A. Which part of it, Mr Clarke?

24 Q. That the Saracen raced into the car park, the crew saw

25 they were not in the spot allocated by the plan and the


Page 66


1 driver reversed the vehicle against a low retaining

2 wall, crushing Alana Burke?

3 A. I can tell you. From a number of witnesses, and I think

4 one of them was Chapman. That would be my recollection.

5 Certainly from a number of witnesses, because we asked

6 them: did they remove to exactly the same place, were

7 they all, you know, to move a considerable number of men

8 and material all to the same place without any search,

9 without any points to pre-planning, but this one got

10 stuck in a somewhat narrow lane and it reversed. The

11 only time in the entire sequence of events that anybody

12 could tell us that the actions of the military had been

13 other than purposeful, i.e. pre-planned, because no

14 orders were being shouted and backing off they crushed

15 this unfortunate young lady -- clearly unintentionally,

16 that is a pretty big vehicle and it is a very narrow

17 street. That is where that comes from.

18 Q. I think you did speak to Alana Burke?

19 A. I cannot remember, but certainly I or Derek did, yes.

20 I cannot specifically remember speaking to her.

21 Q. Can we have on the screen AB101.9. She has given

22 evidence to this Tribunal. She was indeed hit by

23 a Saracen at approximately the apex of the arrow as

24 shown on this picture as it was entering into the car

25 park and not shot as the driver reversed against a low


Page 67


1 retaining wall and there does not seem to be a low

2 retaining wall anywhere near the arrow. Should we infer

3 that this description of what happened to Alana Burke is

4 unlikely to have come from her?

5 A. I do not know. I understand -- she was not shot, was

6 she, I thought she was crushed. Forgive me, I heard you

7 to say shot. She was, and my understanding, and what

8 sticks in my mind is that the Saracen backed on to her

9 and caught her between the wall and -- the exact

10 details, where it happened, I cannot now help you with,

11 it was a long time ago.

12 Q. Could we then come, please, to M71.29. In the first

13 full paragraph on this page, what you have written in

14 the article, is this:

15 "The IRA did, however, enter the picture after the

16 Army shooting ceased. IRA men on the march included the

17 head of the Bogside Provisional Organisation, name to

18 come, who was seen by a number of witnesses early on the

19 march."

20 Did you discover what was the name of the head of

21 the Bogside Provisional?

22 A. I mean, what my journalistic eye tells me is, we wrote

23 "name to come" because we could not find that or for

24 some reason, I do not remember what, had decided not to

25 use it, I do not remember. But at any rate, when we


Page 68


1 were writing the article, Derek and I, in the room in

2 the City Hotel, our notes and all the rest of it, did

3 not at that moment indicate the name. Probably London

4 would have been on the telephone saying what is his

5 name, so --

6 Q. You then went on to say:

7 "The IRA Provisional group had a hasty conference

8 when the shooting began and, according to a young woman

9 who was present, decided to do nothing."

10 Do you remember who the young woman was?

11 A. No, I do not and I would not have asked the name anyway.

12 Derek may be able to help you on that.

13 Q. "The Official group at the march, however, sent an

14 urgent call for gunmen and one active service unit

15 arrived some minutes after the last Army shots were

16 fired. This consisted, like all IRA active service

17 units, of four men armed with two .38 pistols, a .303

18 Army rifle and .22 hunting rifle with a telescopic site.

19 One of these men fired one pistol shot at long range

20 towards the Army but does not claim he hit any soldier."

21 Were you present when somebody from the Official

22 side gave that description?

23 A. I cannot remember. Perhaps Derek would be able to help

24 you better than that. It certainly came through his

25 investigations in the Bogside and it is a long time ago,


Page 69


1 but I have no doubt that was the situation -- the key

2 point, of course, to that being that this is after all

3 the shooting is finished so therefore could not have

4 led -- did not lead to a firefight, nor could it have

5 provoked the presumed and we say non-firefight that the

6 whole Inquiry is about.

7 Q. Could we have M71.30. Attached to this version of the

8 article are, as we have seen, these photographs from

9 various wounded. At the bottom of the page there is

10 a reference to Gilles Peress, the French photographer.

11 If we go over the page to M71.31, that appears to

12 contain quite a long statement in quotation marks.

13 Again, should we assume that that is probably taken

14 down directly from what he said?

15 A. Absolutely certainly. I had a long conversation with

16 Peress -- in French, I might mention, because his

17 English was very poor at that time.

18 Q. Could we now go, please, to M71.2. This is the

19 memorandum that you wrote, dated 19th February 1972, to

20 Harold Evans and others interested. In it, if we could

21 come to M71.11, you give a description of being invited

22 down to Drumahoe barracks just outside Derry "for drinks

23 with," and a name has been blanked out, but the relevant

24 cipher is O28?

25 A. Exactly, yes, I understand that.


Page 70


1 Q. You describe him as the, "PRO officer of the 41st Light

2 Anti Aircraft Regiment"; could that be a mistake for the

3 press officer of the 22nd Light Air Defence?

4 A. Of course it could be, a PRO, public relations officer,

5 is common, in common military use. He was the person in

6 charge of dealing with the media, that is what he told

7 me anyway. It could indeed -- it could have been

8 a mistake, it is a long time ago, but of course anything

9 could be.

10 Q. You record:

11 "The contact was through a local journalist, a very

12 naive Protestant, who said the Army wanted to talk to

13 me."

14 Do you recall who that journalist was?

15 A. No, I do not. There were many, many local journalists

16 around, many of them I never learnt their names. They

17 were fascinated by what the Fleet Street crowd were

18 doing, of course, and one of them -- why I describe him

19 as a naive Protestant, I do not now recall, but he did

20 not seem very clued in on military matters, to put it

21 mildly, and he said, "somebody in the Army would like to

22 talk to you," so I said, "Oh, what is his name." I was

23 given the name and the telephone number. I called and

24 the officer in question said, "Why don't they come down

25 for drinks to Drumahoe Barracks." No journalist is


Page 71


1 going to turn this suggestion down and I described the

2 consequences -- not, of course, for publication, but

3 that is abundantly clear.

4 Q. You went down to the barracks, can you recall how long

5 you stayed there, roughly?

6 A. We did some drinking, so that it was not ten minutes,

7 maybe a couple of hours, of that order. A lot of

8 talking. The officer concerned was palling up to me, as

9 you might say. He had something he wanted to persuade

10 me of. It was a social occasion, from his point of

11 view.

12 Q. You say "we", who else apart from you was there?

13 A. He and I. I went alone. Derek by this time -- my

14 partner in this enterprise -- had gone back to London

15 and I was in the City Hotel and if there were any other

16 Sunday Times people around, I did not see them and he

17 asked me to go down, yes.

18 Q. Can you still recall this occasion?

19 A. Oh, yes. I mean, not in the most vivid detail, but

20 I was well aware, it stuck in my mind that it had

21 happened, because it is a most unusual occurrence, to

22 put it mildly. But the memo, which is contemporaneous,

23 of course, reminds me pretty clearly what happened.

24 Q. What you wrote on 19th February, was this:

25 "He shot me an incredible line. He said he had been


Page 72


1 present at the demonstration himself, dressed in a plain

2 clothes and a wig and had seen the IRA open up with

3 Thompsons near the barricade site, thus killing their

4 own people."

5 Do you recall whether he gave you any idea as to

6 where he was when he saw this?

7 A. He was present. He did not mark my map, I did not take

8 my map with me. No, no, he was present and of course

9 the reason why I say the thing is incredible is that

10 there is no low velocity Thompson fire on the records.

11 If anybody fired at anybody it was not recorded and so

12 on.

13 Q. You say he was present?

14 A. That is what he told me.

15 Q. Did he indicate where he was present?

16 A. No, he did not, no. I did not ask him.

17 Q. You went on to record:

18 "One body, he said, had a .303 bullet in it,

19 proving that the IRA had shot because they have .303s

20 stolen from British Army barracks. So, I pointed out,

21 have the marksmen on the sniper posts around the

22 Bogside. He produced a boy of 14 who said he was from

23 the Bogside and said he had seen the IRA men open up

24 with Thompsons and nail bombs."

25 Can you help us about that, when your note records


Page 73


1 he produced a boy of 14, was he there when you arrived?

2 A. No, he was not present during the drinking session.

3 During the drinking session -- this is not a scene of

4 debauchery, it is a journalist talking to a military

5 man. A bottle was produced and we are having a quiet

6 chat. No, he said, "Oh, by the way, there is a boy here

7 was present, he has something to tell you". So I said,

8 "Okay." The boy then appeared. I do not know who

9 summoned him or how this -- I made him to be about 14.

10 I never asked him name. He certainly had a very strong

11 Northern Irish accent.

12 Q. Do you know what he was doing in a military barracks?

13 A. That is precisely what I asked. I very much wondered.

14 I seem to remember asking the officer in question what

15 he was doing there, but I go no -- oh, he had "come from

16 conscience", as I remember he said to me, because he

17 badly wanted to tell me the story, the boy did, and the

18 story was absurd.

19 Q. What you recorded was this:

20 "He produced a boy of 14 who said he was from the

21 Bogside who said he had seen the IRA men open up with

22 Thompsons and nail bombs. I asked the boy was he sure

23 about the nail bombs; he said yes.

24 "Ten minutes before [that is the cipher name] said

25 he heard no nail bombs and not one witness heard any


Page 74


1 nail bombs. I suspect this boy is lying, either for

2 money or because he is in some way related to one of the

3 numerous Bogsiders serving in the British Army. 'What,'

4 I asked 028, 'is this boy doing alone in a British Army

5 barracks near midnight?' 028 then asked me if I would

6 drive the boy home myself, only later changing his mind

7 about this."

8 You do not recall, do you, whereabouts the boy was

9 said to live?

10 A. I do not. I remember the incident, however, because

11 I then farewelled the officer in question. I was driven

12 in a British Army car with a Army driver sitting in the

13 front seat and the boy and I got into the back seat.

14 The boy continued his conversation. I was intended to

15 drop him off, it was dark at night. I did not know the

16 geography of that part of the world very well and he

17 said "here we are", the door opened and off he went.

18 That is all I remember and then the driver continued to

19 take me back to the City Hotel.

20 Q. The boy is produced and says what you describe. Then at

21 the top of the next page, if we may have that, your note

22 recorded that:

23 "O28 then launched on a wild --"

24 A. "Rambling tour d'horizon".

25 Q. Was the boy there at this stage?


Page 75


1 A. I do not think so -- I left with the boy. My

2 recollection is shaky. I think the boy, having spoken

3 his piece, either made himself absent, or -- I cannot

4 remember his continued presence, but I certainly

5 remember the tour d'horizon because the officer became

6 almost maudlin, I thought, and again what he was saying

7 was absurd, you know, this stuff about Communists, but

8 he talked that way.

9 I was in the presence of, I thought, an ignorant

10 bigot, but I did not write that in the memo because --

11 the purpose of the memo I am sure is plain to you, it is

12 to warn Evans that we are in a difficult position for

13 the reasons -- and that something very fishy is going on

14 about the evidence. That is what I wanted to tell him.

15 Q. I do not think we need go through the tour d'horizon.

16 We can see it on the page. Your note then went on to

17 record:

18 "O28 then showed me the model the regiment have made

19 of Derry. They made it in Germany. It is about the

20 size of a billiard table, very detailed."

21 Did he simply, do you recall, volunteer the

22 existence of a model or did you ask if there was a

23 model; how did this all come about?

24 A. My recollection is -- but again it is a long time ago --

25 do not forget we were talking as a soldier to an


Page 76


1 extremely experienced war correspondent, and I said,

2 "Well, where did you plan this, where is the exam

3 table," fishing, if you like, and he said, "it is in the

4 next room". What I do vividly remember is being taken

5 into the room and seeing it.

6 Now, I presumed there had to be one because that is

7 how these operations are planned, but it was most

8 interesting, indeed, to have it confirmed there was one

9 and I remember thinking how detailed it was and I said,

10 "did you make this here," he showed me round it and he

11 said, "No, we made it in Germany". He is the source of

12 that information.

13 I still have a vivid recollection of seeing, on

14 something that looked like about the size of a billiard

15 table, so it was maybe 6 feet long, 4 feet wide and

16 it vividly sticks in my mind and is mentioned in the

17 memo, the detailed nature of this, this model.

18 It did not surprise me, as I say in the memo, that

19 it existed. I would have been sure, I had been present,

20 I mean to say, at a lot of military planning sessions --

21 something like that is always made, if there is time.

22 Q. When you talk about "a sand model", was it literally --

23 A. No, these are collectively called "sand tables" and the

24 process is called "sand tabling it". No doubt -- it is

25 an ordinary military term -- no doubt they were once


Page 77


1 made of sand, but they are usually called a sand table.

2 Q. Did you discover what it had been used for?

3 A. No, I did not ask. But I suppose it was an uneducated

4 guess that it must have had something to do with the

5 operation, it would be -- why was he showing it to me.

6 Q. Could we have a look, please, at photograph P562. This

7 is a model of the Bogside, did it look anything like

8 that?

9 A. Very much like that, very much like that. I cannot at

10 this distance in time identify it and I certainly do not

11 identify what is round it, the chairs and tables, but

12 what it looked like -- this is a 30-year-old

13 recollection, that is either it or something very like

14 it. It is exactly something of that kind, it is either

15 it -- I do not know where it comes from, yes, that is

16 something very like it.

17 Q. I can tell you where it comes from. It is the model

18 that was used at the Widgery Tribunal and the circular

19 wood behind is the seating of the council chamber in

20 Coleraine where the Widgery Tribunal was held. It could

21 have been that one -- you think it was?

22 A. No, because you would have to ask what is the provenance

23 of this particular -- was it made for Widgery, if so it

24 could not be that one. But it looks very like it, is

25 what I am prepared to say. It was a model that looked


Page 78


1 very like that. This is a fairly typical Army sand

2 table model. It might also be a model used in judicial

3 inquiries, I should think they are similar.

4 Q. You were told the model had been made in Germany?

5 A. Yes, that is why I mentioned it in the memo.

6 Q. If we go back to M71.12, you expressed the view at the

7 bottom of the page that you were sure that the officer

8 in question was lying; how clear is this recollection in

9 your mind?

10 A. Extremely clear.

11 Q. It does not feature in your principal statement; is

12 there any reason for that?

13 A. No, because when I made the principal statement I had

14 forgotten that this memo existed, much less had I read

15 it.

16 Q. Had you forgotten the incident as well?

17 A. No, no, but it was not relevant at the time. Nobody

18 asked me about it. The principal statement had to do

19 with the unpublished article and this, as you see, is

20 written 10 days later and it is -- it does not add

21 anything much to what was in the original article

22 because my intention in reporting it to Harry Evans was

23 to, as it says itself, to urge great caution in the

24 paper in view of this experience.

25 This would be normal, you would warn your colleagues


Page 79


1 "be careful" and that is what it was all about. No, it

2 does not figure because I, to tell you the truth, only

3 reading it, of course, 30 years and so on, does

4 vividly -- the circumstances came back, but I most

5 certainly remembered -- it did not seem a propo of much

6 when I made the first statement, the visit to the

7 barracks, seeing the sand table, the officer shooting me

8 this line, et cetera, certainly I remember that.

9 Q. I think I should show you, may we have on the screen,

10 document B1583. This is a supplemental statement to

11 this Inquiry from Soldier 028?

12 A. This is from 028?

13 Q. This is from 028. What he says in it, so far as

14 immediately material, is this:

15 "I do not dispute that I may have met Mr Sayle in

16 Londonderry in 1972."

17 Then he deals with his correct title:

18 "I have no recollection of meeting Mr Sayle and I am

19 therefore unable to comment specifically on what he

20 says. Some of the information attributed to me, such as

21 my presence in the Bogside in plain clothes and having

22 seen civilians with weapons is consistent with the

23 evidence I gave to Lord Widgery and is true.

24 "I did not, however, wear a wig. I have never worn

25 a wig and would not have told Mr Sayle that I had.


Page 80


1 Furthermore, I would not have held or expressed some of

2 the views and comments attributed to me and there are

3 words that I would not have used.

4 "As to the suggestion that I produced a boy of 14

5 who was from the Bogside, this is simply not true.

6 I cannot provide any explanation as to why Mr Sayle

7 should have written this if he really is intending to

8 refer to me as the source of that introduction. All

9 I can say is that no such an event occurred in my

10 presence, nor have I ever heard of such an incident,

11 then or subsequently. My reaction on reading the notes

12 is that the story is incredible, like something out of

13 Alice in Wonderland."

14 That is his account to this Tribunal; in the light

15 of that, are you sure this took place?

16 A. Certain.

17 Q. Could we please go back to M71.6. This is part of your

18 memorandum to Harold Evans of February 1972 in which you

19 describe the plan as you had satisfied yourself that it

20 was and the way in which you described it to the editor

21 was this:

22 "The ambush was therefore ordered in -- we see the

23 three APCs which charged from Little James Street down

24 Rossville Street. The seizure of the 'key point'

25 involving clearing the barricade just in front of it and


Page 81


1 in the courtyard behind it going towards Glenfada Park."

2 You explain what "clear" means:

3 "The barricade and the courtyard both offered risks

4 to the Paras (four men, by all the eyewitness accounts)

5 at the key point; the barricade because it offered cover

6 to any hypothetical IRA men who were about, who could

7 have got behind it and thrown nail bombs or opened up

8 with Thompsons, the courtyard because the four Paras

9 could be shot from behind by anyone in the courtyard."

10 You appear to have been referring there to what you

11 thought was a key point that was to be seized. Do you

12 recollect what you were referring to?

13 A. No, I must -- when I read the memo after all these

14 years, I wondered what, because it is a long time ago,

15 what I meant by the key point. I must have been working

16 off a map and what I suspect I had done was to take --

17 now suspect, the explanation I found for myself, was to

18 take the map, which you know is very large and is

19 published in the Sunday Times by Harold Evans as your

20 guide to understand and mark on it the key point, that

21 is the best -- I have, of course, no copy of the key

22 point and I cannot tell you at this distance of time

23 exactly what I meant by the key point, but the general

24 observations I make there, namely that if I had been

25 a Para and had got behind a wall, the low wall I had


Page 82


1 mentioned, I would have been very worried about the

2 blocks of the flats behind me and their windows and had

3 I been a Para I would have been very worried about the

4 rubble barricade which was not far away, that somebody

5 behind it was going to shoot at me. I would be worried.

6 A lot of this consists of trying to understand, see

7 things through a military eye.

8 Q. And you also appear to have referred to the barricade

9 offering cover to any hypothetical IRA men who were

10 about and the courtyard being a source of risk because

11 the four Paras could be shot from behind by anyone in

12 the courtyard. Do you have any idea where you were

13 thinking of those four paratroopers as being?

14 A. I have been -- as you know, virtually nothing is there

15 now. Derek and I made a kind of a recce of the area.

16 So I am dependent on a 30-year-old recollection of the

17 exact geography. But I cannot -- I see now, of course,

18 and no doubt should have seen then, perhaps -- that it

19 does appear to be a bit repetitive, does it not, the

20 courtyard from behind me.

21 I take it this was in reference to a map which

22 I must have shown Evans or discussed with Evans.

23 I cannot help you at this late stage on the exact

24 movement. What I can help you with is a vivid

25 recollection, which is with me still, of seeing the low


Page 83


1 stone wall and of seeing that that would be a perfect

2 position to put a protective fire unit, in other words

3 people whose job is charged with protecting the lives of

4 their comrades. It was a good place to hold, in other

5 words. But it was exposed and, therefore, I would be

6 very worried, and I am sure they would be very worried

7 about where a shot could come at them from. Do not

8 forget -- we know this -- they believed there were lots

9 of armed IRA men around.

10 Q. Could we have a look at M71.10. This is again part of

11 your memorandum to Harold Evans. You said there:

12 "On military confirmation I have two things to

13 report. One: I checked over the map and plan with

14 a captain of the Light Anti Aircraft Defence Regiment,

15 I chatted up for two hours on a very rainy street

16 corner. He agreed I had got the plan right, agreed that

17 it was a very pretty one if used to capture Rommel's

18 headquarters or a Rhine bridgehead but inappropriate to

19 use against a demonstrations, added 'but the Army cannot

20 admit we were in the wrong, can we.' This captain,

21 I deliberately did not ask his name, as no doubt he has

22 reported our conversation to Army intelligence like

23 a good soldier."

24 I just understand the flavour of the piece. You

25 describe yourself as chatting up this captain for two


Page 84


1 hours on a rainy street corner, is this while you were

2 in this city in the week after Bloody Sunday?

3 A. It must have been, because I had the map in my hand and

4 do not know how otherwise I would have had it. I did

5 not know what was going to happen. I knew the piece had

6 been pulled, but whether or not -- do not forget at this

7 time people are burning down British embassies and so on

8 and nobody knows exactly whether it would be the end of

9 the story or not.

10 So I was busy, as a journalist would, looking for

11 post confirmation, any more information I could get and

12 I do remember talking to this officer. In my line of

13 work at that time, talking to soldiers was pretty easy.

14 I have done an awful lot of it. We were having a kind of

15 general chat about what he made out of it and I produced

16 my map and then the rest followed.

17 Q. Was he somebody who was in a position to know what the

18 plan was, if there was one?

19 A. I do not know. I should think that more information

20 about the nature of the plan -- it was not confined only

21 to Paras because my understanding was, my understanding

22 was, I was not certain that the only shots fired had

23 been fired by Paras and I am still not certain. Do not

24 forget, it is rather difficult to find out who fired

25 a shot. You cannot see where it comes from.


Page 85


1 So I to this day do not know what the other military

2 posted in Derry, who had been there for some time, knew.

3 What I do know is that everyone I spoke to was most

4 indignant, they were saying, "these idiots have risked

5 our lives," they were not very happy about the outcome

6 and because they were not very happy about the outcome,

7 they could equally not have been very happy about the

8 idea behind it. That was my recollection.

9 Q. What he appears to have been saying was: if that was the

10 plan it was not a very sensible one, was that the

11 flavour of it?

12 A. Given how it worked out, yes, given the risks that were

13 involved, yes, that would be the flavour of it, yes.

14 Q. Do you know who I mean by Vincent Brown?

15 A. I do indeed. Now, I cannot put a face to Brown. The

16 name rings a bell, of course. He is a well-known Irish

17 journalist. He was one, I do not think it certain, but

18 I think it possible, I have of course seen -- I got it

19 off your website, I have seen his statement to the

20 Inquiry.

21 He was one of the local -- by that I mean Irish --

22 journalists who were present in this crowd milling

23 around the bar in the City Hotel and I was certainly

24 talking to a lot of them because, again, I mentioned

25 this earlier, the sort of guarded exchange of


Page 86


1 information that takes place among a group of

2 journalists all working on the same story. I cannot put

3 a face to Vincent Brown but I am pretty sure if he

4 walked into the room, the recognition would be made.

5 Q. His evidence to the Inquiry is to the effect that he

6 used material that the Sunday Times Insight team had

7 obtained for a story that he wrote for the Sunday Press

8 on 6th February. I know you were not in the Insight

9 team, but do you think you and Derek Humphry may have

10 been the source of his material?

11 A. It is highly likely that we were the source of it in the

12 sense that we talked to him. It would not surprise me

13 in the least that we talked to him because I had

14 discussed various aspects of this with many other

15 journalists who were present.

16 Again, I say it is this ambivalent situation, very

17 well-known to journalists, in which you want to exchange

18 information but not too much because they are

19 competitors. In a sense he was not a competitor at all,

20 he is an Irish paper, we are a London national paper, he

21 is an Irish -- confined to Ireland so in a sense, and

22 he, of course, being Irish, from the south, but had

23 worked in Derry many times before.

24 But I have no recollection of actually handing him

25 our article, I have not recollection of it. I am not


Page 87


1 prepared to put my hand on my heart and say it never had

2 happened, I have no recollection of it. He has our map,

3 I notice. How he got that, I have not the faintest

4 idea, I cannot help you.

5 Q. He got it from the Sunday Times, or based it on the

6 Sunday Times map?

7 A. Excuse me, Mr Clarke, for a second, what is the date of

8 his article?

9 Q. 6th February 1972?

10 A. That is the Sunday.

11 Q. That is the Sunday following the Sunday of --

12 A. That is the date on which our article would have

13 appeared, it was going to appear and that is the date

14 the map was published. Now, I am uncertain whether it

15 is not a photograph taken of an earlier copy of the

16 Sunday Times which would have arrived in Dublin some

17 time Saturday night and technically it would have been

18 possible for them to photograph it and use it. I was

19 not present, of course. I certainly did not give him

20 the map because I did not have a copy of it at that

21 time. That is the drawn-up finished version.

22 What we were working on was a plan Butterworth had

23 given to us, which had crosses and arrows, the basic

24 material on which Butterworth --

25 I certainly did not give him the map. As far as


Page 88


1 what he wrote, now he has put a catchy headline, "Killer

2 plan of Paras," and so on that I would not have dreamed

3 of doing --

4 Q. Could you slow down a little, what you are saying has to

5 be taken down and it is quite difficult if you speak

6 very fast.

7 A. I myself have puzzled over, of course, where Mr Browne

8 got this stuff from, and in particular where he got the

9 map from. His article -- there is no mention of the

10 Sunday Times in his article.

11 Q. There is.

12 A. What does it say?

13 Q. If we could have L171, and could we highlight -- what he

14 records is this, it is described as:

15 "The scene of Bloody Sunday, a sketch map drawn by

16 John Butterworth."

17 The next paragraph but one, he says:

18 "The map is based on interviews by Sunday Times

19 reporters which began on Monday" and then there is a key

20 and at the bottom it says "copyright the Sunday Times".

21 A. Okay, he has the map somehow from the Sunday Times.

22 Q. Quite. If we could have on the screen, please, L279,

23 this is an article --

24 A. I know it well.

25 Q. You know it well?


Page 89


1 A. I know it well.

2 Q. It has details about you and Derek Humphry and in the

3 passage dealing with Derek Humphry there is included

4 this paragraph:

5 "Their story [that is you and he] came to the

6 attention of the Sunday Press in Dublin which published

7 details on 6th February 1972: Derek Humphry says that he

8 for one expected managerial repercussions but curiously

9 there was none."

10 That appears to suggest that what they were in

11 effect publishing on 6th February 1972, was, as stated,

12 your story?

13 A. That is not how I read it. The story came to their

14 attention, it does not say it was given to them.

15 "Coming to their attention" could mean anything from an

16 exposition in a bar to a re-written hard copy and

17 I cannot help you on that -- I discussed it with various

18 Irish journalists and undoubtedly Browne and at some

19 length, I have no problem with that. I do not

20 specifically remember Browne. I have no problem with

21 that, and if you read his article it looks like

22 a crudely re-written version of ours.

23 Q. It does, does it not?

24 A. Or a man with a retentive memory putting together what

25 he has heard from us or even made notes while he was


Page 90


1 talking to us. But I have no recollection of saying

2 "Here, Vincent, here is our article".

3 Now, nothing would have prevented me doing so. If

4 the Sunday Times was not going to publish it, then

5 nothing stopped me because at the time, I regarded this,

6 and who did not, as a matter of extraordinary public and

7 national interest, and you remember people thought

8 something like a civil war was imminent, so it was

9 important.

10 About what Derek means about "managerial

11 repercussions", you will have to ask him.

12 Q. I do not want to go through their article and the

13 differences between their article and your article, save

14 in one respect: if we have on the screen L171, could we

15 highlight, please, the bottom left-hand corner under the

16 heading "Unprepared".

17 This article has an account of the position of the

18 IRA which is different in some respects from the account

19 that appears in your article. Let me explain. What

20 they say, under the heading "Unprepared," is this:

21 "At this stage the IRA became aware of what was

22 going on. The Provisionals were utterly unprepared and

23 had very few arms in the area at the time.

24 "The Officials had an active service unit of four

25 men on duty. They were all either to be armed during


Page 91


1 the parade or to have immediate access to arms should

2 they become necessary. In addition, a number of other

3 volunteers in the parade were armed for their personal

4 protection."

5 They say:

6 "It is important to emphasise that at no stage

7 during the initial part of the parade did any IRA men

8 open fire."

9 At the bottom of the paragraph they refer to

10 a substantial amount of arms being moved from the

11 Bogside to the Creggan earlier that morning. If we go

12 to the top of the next column, if we may, the first two

13 paragraphs down to "Revolvers," what they describe is:

14 "When the second volley of British gunfire

15 occurred," and by that they mean after Jack Duddy was

16 shot, "the four members of the active service unit were

17 immediately alerted. Two of them had, in fact, to

18 return to a maisonette to collect a couple of rifles --

19 there is some dissension in the Official IRA on this

20 point, for the local northwest command is annoyed that

21 arms were not to hand."

22 Could we have the next heading, "Revolvers," down to

23 the end:

24 "Meanwhile, the two other members of the unit moved

25 into what they described as sniping positions, but what


Page 92


1 in fact were only street corners. Both of them were

2 armed only with short arms, .38 revolvers."

3 Missing a paragraph:

4 "After the second burst of Army gunfire, the

5 Officials took up positions and one shot was fired by

6 one of the men with the short arms at a soldier in

7 William Street, but it missed. No other shot was fired

8 then by anybody until the actual murderous assault ..."

9 They have an account of an active service unit, two

10 of whom moved into sniping positions and both of them

11 were armed with revolvers and one of them fired at

12 a soldier in William Street.

13 If we go over the page to L172, if we could have the

14 column, "No shots fired," the account goes on to say:

15 "The two volunteers, who had returned to the

16 maisonettes to get a rifle, fired instead at the Army

17 post on the top of Stevenson's bakery. One of them had

18 a pair of binoculars and surveyed the scene beforehand."

19 A. Forgive me, are we still reading Browne, is it still

20 Browne's article?

21 Q. Yes, it is:

22 "The two volunteers, who had returned to the

23 maisonette to get a rifle, fired instead at the army

24 post on the top of Stevenson's bakery. One of them had

25 a pair of binoculars and surveyed the scene beforehand.


Page 93


1 The sniper, with the aid of a telescopic sight, fired

2 one shot at the post. He believes he hit a soldier."

3 A. I do not know how he would believe that, but go on.

4 Q. Pausing there --

5 A. It is new to me. That did not come from me, the first

6 I have ever heard of it. If you want me to speculate --

7 Q. No.

8 A. -- Browne had his own contacts of course, and he is

9 responsible for what he has written. I have never heard

10 any of that before, although it does vaguely resemble,

11 you can see a vague outline of our version, the key

12 point being, of course, that apart from the wounded

13 soldier who turned out not to have been wounded, a key

14 point is that there was not an armed engagement and that

15 is what he says. There was not a firefight, in other

16 words.

17 Q. He goes on to deal with:

18 "Another member of the active service unit firing at

19 a soldier on a road block at Bishop Street and a sniper

20 fired a few shots from the vicinity of Long Tower

21 Street."

22 That is news to you as well?

23 A. All news to me. The Bogside and the IRA and so on was

24 not my primary interest in the piece, that was Derek's.

25 Q. Lastly, he deals with:


Page 94


1 "... the Provisionals loosing off a few rounds from

2 a Thompson just as the Paras were withdrawing."

3 A. No Thompson fire is to be heard on the records is all

4 I can say and I know the sound of low velocity

5 semi-automatic fire very well.

6 Q. Wherever he got all that from --

7 A. -- was not from me.

8 Q. Was not your sources?

9 A. Was not from me.

10 Q. Thank you very much. Those are my questions.

11 LORD SAVILLE: We have some other questions, no doubt.

12 I think we will stop for lunch at this point. It is now

13 12.10.

14 Mr Sayle, could I ask you -- it is the Chairman

15 talking to you: we will stop for lunch now. Can you

16 come back at 1.00.

17 A. Most certainly.

18 LORD SAVILLE: As I say to all the witnesses: I would be

19 grateful if you did not discuss the evidence you are

20 giving until you finish giving it.

21 A. May I lunch, without talking to him, with my colleague

22 Humphry?

23 LORD SAVILLE: You can certainly have lunch with

24 Mr Humphry, but not discuss the evidence you are giving.

25 (12.12 pm)


Page 95


1 (The Short Adjournment)

2 (1.10 pm)

3 Questioned by MR MANSFIELD

4 MR MANSFIELD: My name is Mansfield and I represent in

5 particular the Nash family, one of whom you interviewed.

6 Perhaps I could deal with that straightaway.

7 M71.30, please. At the top of this page is

8 Alex Nash, he is the father. There is a quotation

9 there. The question I have is, since you were

10 present: do these quotations -- there are several on

11 this page -- represent an edited version of what was

12 said?

13 A. Well, in a journalistic way, the convention is of course

14 that we have, if -- normally speaking I would run that

15 back if I had time, run back what I say somebody said

16 past them and say; is that a fair account of what you

17 said? It is obviously -- nobody speaks five literate

18 sentences one after another, so in that sense it is

19 a condensed, it is -- I put in direct speech -- is my

20 interpretation, that is what he said.

21 It is not edited in the conventional sense that

22 I wrote it all down and cut bits out here and there.

23 Q. That is all I want to know.

24 A. I have no doubt that it accurately represents what he

25 said.


Page 96


1 Q. A rather bigger topic, please, M71.9: this is a page of

2 a memorandum that you wrote on 19th February 1972.

3 There is a passage here you have not been asked about,

4 but I want your assistance with it. In the top half of

5 the page there is a sentence:

6 "We cannot get to the bottom of this ..."; do you

7 see that?

8 A. Yes.

9 Q. "... without looking into the command structure of the

10 whole Army operation in Northern Ireland, with, let us

11 make no mistake, a strong possibility that when we find

12 out how the command set-up works and who authorises

13 these operations, criminal charges may be appropriate."

14 Getting to the bottom of this, to put it in context

15 without going back, is the plan which you had formulated

16 and inferred must have occurred --

17 A. Or reasoned must have occurred.

18 Q. The theory of ambushing the supposed presence or

19 supposed IRA men presence --

20 A. Expected, yes, okay.

21 Q. The question is this: did you in fact investigate the

22 command structure in order to discover who submitted and

23 who authorised a plan, which involved sending in

24 Paratroopers armed with SLRs, and in some cases Sterling

25 machine-guns?


Page 97


1 A. This will be slightly longer than perhaps a yes or no.

2 This is the situation: we were asked to explain for our

3 readers and the public burning to know what had

4 happened, as our brief was, find out to the best of your

5 ability what happened. Now that is what we did to the

6 best of our ability.

7 What I am doing here, and this is a memo that I sent

8 to Harry Evans, it was never intended for publication,

9 of course, saying where we should go -- "we" meaning the

10 Sunday Times -- where we should go from here, where is

11 the next element of the story that needs to be

12 investigated, that could well profitably be

13 investigated, because who drew up the plan and who

14 considered the dangers that were involved in it would be

15 step one, these people, that is what you want to know --

16 Q. May I just cut you short very briefly? The question is:

17 did you investigate it?

18 A. But after -- I had left Ulster on -- 10 days later and

19 was in no position to find out how the command structure

20 worked because nobody would tell me.

21 Q. The answer is no?

22 A. No, not me personally.

23 Q. I have one final question, it is this: it appears from

24 your statement in at least two places that you were

25 present in Northern Ireland the previous


Page 98


1 year, August 1971?

2 A. I was.

3 Q. And you witnessed violence on that occasion and

4 bloodshed, not in Derry, but in Belfast?

5 A. I covered internment in Belfast. Now, "covered" it

6 means that I reported it. I do not have a vivid

7 recollection of seeing somebody shot, I do not, and

8 I could not now off-hand -- that is not being discussed,

9 but --

10 Q. The question I have, again just to cut it short: did you

11 or were you aware of the involvement of the Parachute

12 Regiment in 1971 in Belfast?

13 A. I cannot tell you, I cannot remember, I cannot remember.

14 I knew of their presence in Northern Ireland, I cannot

15 remember.

16 Questioned by LORD GIFFORD

17 LORD GIFFORD: Sir, my name is Anthony Gifford and

18 I represent the family of James Wray. First, you said

19 in answer to Mr Clarke, you were asked by him about who

20 you had spoken to by the time you wrote the article?

21 A. Yes.

22 Q. And you mentioned a number of wounded; you mentioned

23 Mr Chapman?

24 A. Yes.

25 Q. And indicated that Derek Humphry had spoken to people


Page 99


1 including McClean, but it sounded like a rather small

2 list that you gave.

3 Might I, in light of your answer, ask you to look at

4 a passage from Derek Humphry's statement at M43.1? Can

5 we highlight paragraphs 5 and 6? You will see that he

6 talks about going to Altnagelvin Hospital. In

7 paragraph 6 he says:

8 "Once this was done, I interviewed other local

9 eyewitnesses who were able to point out on the map

10 exactly where the paratroopers' vehicles had parked and

11 where the soldiers had been when they opened fire. When

12 this was coupled with the results of what the wounded

13 had told me, Murray and I were able to build up what we

14 believe was an accurate picture of what actually had

15 happened."

16 Does it follow from that passage that collectively,

17 whether it was he doing the work or you, you had in fact

18 interviewed a number of eyewitnesses in addition to the

19 wounded?

20 A. Oh, yes, most certainly, yes. The one that stuck in my

21 mind was Warrant Officer Chapman because I had had

22 a long talk with him because he was a military man, and

23 thus we could talk military --

24 Q. He was not the only --

25 A. No, I have not a list of names in my head, but, yes, he


Page 100


1 was not the only one.

2 Q. In addition to the ones Derek Humphry can tell us about

3 you yourself talked --

4 A. Many, many, many.

5 Q. Next, I want to see if you can help us any more about

6 the sand table at Drumahoe. What you say in M71.12, in

7 a memo, the second half of the page -- this was a memo

8 which was written on 19th February referring to a visit,

9 which is noted at the top of the page, as being on

10 14th February?

11 A. Yes.

12 Q. So it is fresh in your mind. What you said was, going

13 back to M71.12:

14 "[Blank] then showed me the model, the regiment have

15 made of Derry. They made it in Germany, it is about the

16 size of a billiard table, very detailed."

17 That would suggest to me that it was a model which

18 was of an area wider than the immediate battle ground of

19 Bloody Sunday?

20 A. My recollection -- now I have a 30-year old image in

21 front of my mind of how big it was, I mean of how much

22 of an area it covered. It certainly covered the entire

23 area of the march, you know, which had come 2 and a half

24 miles and so on, so it was much bigger the actual area

25 under discussion, but how far it extended beyond the --


Page 101


1 that area of interest to both of us, I cannot now

2 remember.

3 Q. Did it take in the Creggan, for instance?

4 A. I would think it did, yes, yes, I would think it did.

5 Again, you are asking me -- my recollection, if only

6 I was back in February 14th, I could have answered this

7 in a flash because I had just seen it. What I now have

8 is a memory picture that has been gone over and over in

9 my mind.

10 Q. Going back to the photograph you were shown, P562: this,

11 as you were told, was a model used in the

12 Widgery Inquiry?

13 A. Yes.

14 Q. You will see indeed that it shows at various places,

15 here and here (indicating), at least two of the

16 barricades which were in place in the Bloody Sunday

17 operation?

18 A. Yes.

19 Q. And would appear, although we may in due course hear

20 more about it, a model prepared for Widgery; that, of

21 course, only takes in the area of the Bloody Sunday

22 events and some surrounding streets. It would appear

23 from what you were saying about the memory you have,

24 that this probably was not the model you saw?

25 A. Well, I am not sure. This does not look like the one


Page 102


1 that I remember, but I am comparing something that I see

2 in front of me with something I saw 30 years ago.

3 I mentioned in the memo that the key fact for me, the

4 absolute key fact of this, there was a sand table, yes,

5 sure enough there was one and, as I had expected, there

6 must be somewhere, and there we are.

7 Q. Was it drawn up on the basis of a street plan like this

8 one is?

9 A. I do not know. I can see buildings, you could look down

10 on it, it was a plan in the sense that they were, you

11 know -- it was a little model and that is all

12 I remember.

13 Q. And you had no specific information as to whether it had

14 been used, either by the local regiment or by the

15 paratroopers?

16 A. No. Well, would you like to see -- I recall Officer 028

17 saying, "would you like to see it?", because he

18 volunteered it. I would not have said to him, "show me

19 the sand table", it was not on that basis, but he

20 volunteered for me to see it. So I looked at it and

21 said, "Ah yes," and looked it over. I did not then

22 discuss him, "you came in here and went in there,"

23 nothing of that kind happened, because he was not one of

24 the planners, that had never been suggested and I did

25 not spend more than maybe three or four minutes looking


Page 103


1 at it, and my impression from now, which is in the memo,

2 is how detailed, how well it had been made, the labour

3 that had gone into making it, that was my basic

4 impression.

5 Q. Finally, Mr Sayle, do you have any visual memory of

6 Officer 028?

7 A. What he looked like, I could not put a face on him, no.

8 Q. You could not at all?

9 A. He was in plain clothes, he was not in a uniform; he was

10 what you would expect a captain to be in his age group,

11 maybe late 20s, early 30s, otherwise unremarkable. He

12 was an Englishman by the way he spoke, but I did not get

13 into that, he certainly was not Irish. I could not put

14 a face on him, no, I could not.

15 Q. I am going to ask you to look at a bit of video. I do

16 so because -- it may be for other interested parties

17 useful to know -- to be able to verify whether this idea

18 is right. We think we may have this officer on video.

19 Video 3, it is at segment 36. We are going to be

20 looking for a rather distinctive individual crossing

21 from left to right on the screen.

22 (Video Played)

23 That man there. I do not know whether we can

24 freeze-frame it. Any help you can give us --

25 A. I do not recognise -- I do not even see which of them


Page 104


1 you are discussing. Where is he, from left to right?

2 I see a lady on the left, I see what I take to be

3 a soldier in what appears to be a flak jacket with his

4 back to us?

5 Q. The one I am referring to is a rather tall person with

6 dark hair who is, at present, to the left of the group,

7 to the right of the white window, and who crosses to the

8 right. Can we play it on once more?

9 (Video Played)

10 That one. It may be that others will help in due

11 course. You cannot help at all?

12 A. I cannot help because the circumstances were completely

13 different in which I met this gentleman.

14 Questioned by MR GLASGOW

15 MR GLASGOW: Mr Chapman, on your left. My name is Glasgow

16 and I represent many of the individual soldiers.

17 Could I just ask you to help the Tribunal a little

18 more with the division of work between yourself and

19 Mr Humphry?

20 A. Certainly.

21 Q. We have your statement at M71.14, and if we look at

22 paragraph 2. You said in the middle of that paragraph

23 that the idea was that you would concentrate on

24 investigating the military background to the shootings

25 and Derek would concentrate on interviewing the local


Page 105


1 people?

2 A. Right.

3 Q. You reported on that, explained it in some detail to

4 Harold Evans when you sent in your report, which we have

5 at M71.4. I wonder if you can look at that with us,

6 sir. If we take it from the bottom of the page, just

7 the last few paragraphs. You are telling Mr Evans here

8 what you were doing.

9 "My own work since has been in two directions. One

10 is sifting eyewitness accounts to see if they fitted the

11 scenario -- not, let me stress, asking them if they

12 agreed with me, but asking apparently aimless questions

13 and working on military sources for confirmation."

14 While we have it in front of us, can we look at your

15 recollection at that time when events must have been

16 clearer in your mind, as we all appreciate, that on the

17 first line of attack, you are looking at the --

18 A. By "attack" of course I do not mean military attack,

19 attacking the problem.

20 Q. You have now studied 200 different accounts either in

21 person, and "in person" we have in brackets:

22 "(eight wounded, six priests, ten journalists and

23 about a score of Catholic Bogsiders present.)"

24 Totalling up some 60 to 70 people who you had

25 actually spoken to in addition to the 200 statements;


Page 106


1 does that accord with your recollection?

2 A. Something, of course I do not know the number, but that

3 would be not a bad sample of the people I personally

4 spoke to, yes.

5 Q. Going on you say:

6 "I have not so far found any discrepancies of

7 weight, and an enormous number of details ...". Then we

8 come to your "military confirmation", those were your

9 words.

10 Could we flip on in the pages until we get to 71.10,

11 because that is where you pick up the "military

12 confirmation"? If we go to 71.10, the bottom half, the

13 words picked up again there:

14 "On military confirmation I have two things to

15 report:

16 "1. I checked over the map and plan with a captain

17 of the Light Anti-aircraft Defence Regiment. I chatted

18 up for two hours on a very rainy street corner."

19 That accords with your recollection today, that is

20 the first specific military check you made before

21 writing to Mr Evans. And over the page, the top of the

22 page:

23 "2. Last Monday night [that is where you are able

24 to check the date from, sir, February 14th] I was

25 invited down to Drumahoe ...", and there you saw the man


Page 107


1 you described as a PRO, with the 41st Light

2 Anti-aircraft Regiment?

3 A. Right.

4 Q. Do you think it is possible --

5 A. They are the same officer?

6 Q. Yes?

7 A. No.

8 Q. The reason why I put it to you to consider, sir, because

9 I suggest to you it is a possibility -- the description

10 you gave to the man you met on the street corner, unless

11 it is by extraordinary coincidence, is precisely

12 accurate for 028, who I should say I represent?

13 A. You mean what he looked like or his rank?

14 Q. He was indeed a captain in the 22nd Light Air Defence?

15 A. Okay, well, not the only captain, I presume, in the 22 -

16 On that, what I relied on in writing to Evans, the

17 soldier I talked to on the street corner was in duty and

18 in uniform, of course.

19 Q. You recall talking to him for two hours in the rain?

20 A. We had a long talk. I did not clock it of course, but

21 we had a long talk.

22 Q. I wanted you to have the opportunity of seeing it?

23 A. I understand that and people in my line of business are

24 very accustomed to talking to soldiers, as you imagine,

25 and I did not recognise 028. He was wearing civilian


Page 108


1 clothes, of course, plain clothes, when I saw him, that

2 I distinctly remember. He was not wearing uniform when

3 I met him at the barracks on his invitation, but I did

4 not say, "Ah, here we are again," I had no recollection

5 it was the same man and I am prepared to say it was not,

6 because the man I spoke to on the street corner said

7 nothing like what 028 said.

8 Q. We will come back to it, I promise. Could we look at

9 the second page of your current statement at M71.15, the

10 top half first? Your recollection is it, sir, that

11 Derek Humphry had autopsy reports -- preliminary autopsy

12 reports were made available?

13 A. My understanding was that Derek -- I cannot recall that

14 I actually read any of the autopsy reports --

15 Q. That with respect, is not what I asked. I keep it as

16 short as I can, otherwise we are going to keep everybody

17 here all afternoon. Your recollection is that somebody

18 made available preliminary autopsy reports to your team

19 within days of Bloody Sunday?

20 A. Not my team, to Derek. They were not made available to

21 me, I discussed the matter with Derek.

22 Q. Do you think it is possible that you got the

23 descriptions of what the dead young men had been wearing

24 from those reports, because in fairness to you I can

25 tell you that the documents that were submitted, quite


Page 109


1 naturally, after the autopsies recorded carefully what

2 they had been wearing?

3 A. Of course, yes. Now my recollection is that there were

4 two sources for what they were wearing: the dead from

5 photographs, the wounded because we asked them. Now

6 I talked to some people in the hospital but not all of

7 them, do not forget Derek and I asked together on this,

8 and he had the same list of questions, and he asked them

9 what they were wearing, that is my recollection.

10 Q. I promise I will not go over the ground at length you

11 tried to assist my learned friend Mr Clarke with, who

12 asked you questions this morning, but I want to make

13 sure there is not a linguistic difference between two

14 people separated by the same language, if you will

15 forgive me.

16 A. Willingly.

17 Q. We do have a collection of all the reports on the dead,

18 as Mr Clarke very accurately and fairly told you.

19 I will not go through them in detail. In order to save

20 time, we have collected them all onto one sheet of

21 paper, OS7.58. This is simply taken from the records,

22 and if anybody needs to check the reference for the

23 document, it is on the right-hand side, and the

24 description of the jacket or the outer garment is

25 precisely typed out, including unique spelling in the


Page 110


1 central column.

2 All I wanted to ask you, sir, looking down that

3 list, of the pin -- it is obviously meant to be

4 a pin-striped jacket, light blue jacket, the green

5 checked sports jacket, the brown corduroy jacket, the

6 blue zip-up jacket, the brown anorak, the brown suit

7 jacket, the brown corduroy jacket, the dark grey

8 three-quarter length coat, the brown tweed car coat, the

9 blue denim jacket, the grey and black tweed car coat,

10 and blue zipped up anorak; is any of those descriptions

11 what you, in your use of our language, would describe as

12 a combat jacket?

13 A. No, I would not describe -- looked like a combat jacket.

14 Nobody was actually wearing a combat jacket, that is

15 a piece of military equipment. But they were wearing,

16 and going through the list seems to be fairly accurate,

17 the kind of zip-up jacket which was very common wear --

18 and still is -- in Northern Ireland at that time. It

19 was not a very useful discriminator, of course, as to

20 who is who, but nobody was wearing, that we could

21 discover, anything that would be grotesquely outside

22 that description. I think the word "approximately" you

23 will find in what I have to say.

24 I noticed the word "jacket, jacket, jacket, jacket",

25 going up and down. We are not talking about -- somebody


Page 111


1 was wearing a full-length coat, I notice.

2 Q. We have your answer, because your answer, if you wanted

3 to correct it that you gave to the Tribunal in answer to

4 Mr Clarke this morning, was, he asked you after a very

5 long exchange:

6 "I wonder if I can ask you my question once

7 again: do you think that nearly all the dead and wounded

8 were wearing combat-style jackets", and you said "yes,

9 we went over their clothes very carefully", and this is

10 what you had in mind?

11 A. But I did not say combat jackets, I said combat-style

12 jackets, and there we get into what does that mean,

13 exactly. I certainly did not say they were all wearing

14 combat jackets, certainly not.

15 Q. While we are on this page, there are two other matters.

16 Paragraph 6, if we could look at that together,

17 M71.15: your own experience as a war correspondent of

18 other firefights would have been you would have

19 expected, if I make take it very shortly, a very much

20 larger number of people killed to wounded?

21 A. No, wounded to killed. The normal proportion is a third

22 killed to two-thirds wounded, or in that order. It is

23 most unusual to -- in a firefight -- the wounded

24 out-numbered the dead. I would have expected -- one of

25 the first things I said is: why are there an equal


Page 112


1 number of wounded to dead, what does that point to? It

2 points to extremely accurate close range shooting, with

3 design to kill.

4 Q. The last three lines, if we remind ourselves: despite

5 the matters that have been gone through with you

6 carefully today, it is still your belief, the evidence

7 you wish to give that you scrupulously checked any piece

8 of evidence that could have disproved your preliminary

9 hypothesis?

10 A. In the time we had available, never forget that, we had

11 a deadline. But I never found anything that -- for

12 instance, recorded automatic low-velocity fire would

13 have blown the whole thing to pieces. But I could not

14 find that.

15 Q. The last paragraph, if we look at one point in

16 paragraph 7, please; again, Mr Clarke asked you, may

17 I ask you to confirm, if you can, where it came

18 from: your recollection is that from Mr Peress's

19 photographs and by Army statements most of the

20 paratroopers were equipped with riot gear and shields

21 and visored helmets?

22 A. Yes, that is my recollection.

23 Q. It really is your recollection, the majority of the

24 paratroopers were carrying shields?

25 A. Yes. Now, of course I had not counted them, but of the


Page 113


1 photographs I could see and what people spoke to, most

2 of them were engaged in what would be called a snatch

3 operation at the time.

4 Q. You do now recall and you recalled when you made your

5 statement, speaking to officers and NCOs of the Royal

6 Green Jackets?

7 A. Yes.

8 Q. Was there any reason, sir, why you picked on them -- so

9 that the question does not in any way trap you, the

10 Royal Green Jackets --

11 A. You mean that regiment?

12 Q. Yes.

13 A. Because they were present and roughly around in that

14 area. There were no doubt other soldiers present, what

15 stuck in my recollection --

16 Q. Just to stop you, if I may, Mr Sayle, were you not aware

17 the Royal Green Jackets were the only resident battalion

18 who did not deploy on Bloody Sunday, the one unit that

19 was put under the command of the Light Air Defence?

20 A. I was not aware of exact military dispositions, no,

21 I was not. I might also record, this was made 30 years

22 later, at that stage.

23 Q. That is why I wondered if you remembered that --

24 A. It may be the name of the regiment stuck in my mind.

25 I certainly talked to somebody from the Royal Green


Page 114


1 Jackets.

2 Q. Did you understand that one of the complaints and one of

3 the criticisms, which is fair to say has been repeated

4 even today, of the use of the Paras, was that they would

5 not have had an intimate knowledge of the geography on

6 the streets, and therefore they were unsuitable for use;

7 did you hear that?

8 A. No, I did not because that is not what paratroopers do.

9 If you ask me a question, may I continue it answer?

10 There is a characteristic style of Parachute operations

11 and I have seen many of them. They are trained to rush

12 in, minimum fuss, go exactly where they are doing and

13 start shooting. This is a Parachute operation and they

14 have -- they are specially trained for snatch-shooting

15 all sorts of things of this kind. They are not trained

16 to walk around to look for trouble. Parachute

17 operations are decisive, quick, in and out, that is the

18 characteristic.

19 Q. It follows from that, does it, if anybody in the Royal

20 Green Jackets or otherwise had told you that they

21 thought the Parachute Regiment was unsuitable because

22 they did not know the local geography, you would have

23 been able to put them right from your own experience?

24 A. Put them right about what?

25 Q. Correct them and say: no, that does not matter?


Page 115


1 A. What does not matter?

2 Q. The fact they did not know the local geography?

3 A. For conducting an operation of that kind, of course they

4 would not know, you mean individual soldiers knew the

5 local geography? Unnecessary, would not be the point.

6 No, I do not think the geography had anything to do with

7 it. It was an attitude of speed, shoot first, because

8 this is what paratroopers do.

9 Q. Your understanding, I am still not quite sure where you

10 got it from, but indeed your evidence has been that the

11 paratroopers had trained for this operation for weeks?

12 A. Absolutely, rehearsed.

13 Q. Rehearsed it, knowing in detail what the lay of the land

14 was?

15 A. They had a sand table and I would assume, it would be

16 extraordinary if it had not happened, that they had

17 rehearsed with tapes somewhere on the ground, and know

18 exactly where they are running to.

19 Q. Whatever may have been said and whatever evidence may be

20 given to this Tribunal, you are satisfied on oath

21 saying, you are quite confident that the paratroopers

22 had rehearsed, must have rehearsed this operation for

23 weeks before it happened?

24 A. Right, must have, must have, because --

25 Q. Could you have a look at paragraph 9, and your


Page 116


1 understanding from your own military experience was that

2 the plan carried into effect would have been a Parachute

3 Regiment plan?

4 A. Absolutely, very characteristic of them, of paratroopers

5 generally, I do not say that regiment.

6 Q. You thought that would have been done, what, behind the

7 back of the Brigade Commander?

8 A. Oh, no, no, no, I would not go that far. No, I had no

9 idea about where the ramifications, who had authorised

10 it, I had no idea. All that I did know, that what

11 happened was described to me was an operation very

12 characteristic of Parachutists of any armies I had had

13 to deal with and very different from that of ordinary

14 infantrymen.

15 Q. As is clear from the end of this paragraph, your belief

16 was that the officer commanding the Parachute Regiment,

17 named as Colonel Wilford, would actually have had the

18 authority himself to abandon the plan?

19 A. No, to give the execute order or not to give the execute

20 order, certainly not to abandon the plan. I mean, he

21 was, in the normal military hierarchy, he was the

22 colonel in charge of the --

23 Q. The words you use in the last two lines, that if they

24 had had better intelligence he could have modified or

25 cancelled the planned operation; is that what you meant


Page 117


1 to say?

2 A. Yes, perhaps poorly put by me. What I am saying is he

3 would not, had he been informed there was no IRA

4 presence, that he was not in contact, to use the

5 military term, I would find it astonishing that he would

6 give the execute order, because the order would clearly

7 call for, first of all, the establishing of contact; it

8 is the first thing you have to do in a military

9 operation.

10 Q. Did you have any evidence at all for that or was that

11 simply based on your own experience and knowledge?

12 A. Evidence of what?

13 Q. The conclusion you reached as to the authority that the

14 Officer commanding the Parachute Regiment would have in

15 this situation?

16 A. I had two sources for knowing he was in command: one was

17 that he said he was; and two, that in the normal

18 military hierarchy the order would come through him --

19 he is the Colonel of the battalion -- the orders could

20 not come from anywhere else, therefore the execute

21 order, which is what we are talking about, or failing to

22 ever execute, must have, in the normal course of

23 military chain of command, come from him or through him.

24 Whether he had the personal, individual authority

25 not to give the order, that I do not know, but if he


Page 118


1 certainly would not give it unless he thought he was in

2 contact.

3 Q. May we go over the page, please, to M71.17? Three small

4 matters: first of all, paragraph 11. You concluded with

5 a high degree of accuracy as to what had actually

6 happened before you had had the opportunity of speaking

7 to any military personnel; is that right?

8 A. No, I had spoken to some military personnel, I mentioned

9 talking to them in the streets and so on.

10 Q. Slightly slower.

11 A. I beg your pardon, I clearly was not going to ring up

12 the high command in --

13 Q. I can stop you sir, save your breath and everybody

14 else's time, if I may, it is a simple question: had you

15 reached, were you satisfied, with a high degree of

16 accuracy, before you spoke to the military personnel you

17 had spoken about, or did you speak to them first?

18 A. No, it was all part of the process of coming to this

19 conclusion. I could not tell you which came first or

20 which came second, that was adding parts to a mosaic and

21 they were part of it.

22 Q. Could we look at paragraph 12 in its entirety, please,

23 because you say it was not until the Saturday afternoon

24 deadline had passed that you did certain things, and you

25 then decided to put your version to the Army; does that


Page 119


1 help you at all?

2 A. Where is that?

3 Q. The deadline is right at the top; you said:

4 "I therefore decided to put our version of events to

5 the Army for their comments."

6 I thought that this following paragraph 11 --

7 A. I was in error. I thought I had telephoned the Drumahoe

8 and asked for somebody to brief me, that was my

9 recollection. But the memo tells me it was the other

10 way round: they asked for me and I was out in the date,

11 you noticed that also, but that is a 30-year-old

12 recollection as against a contemporary document.

13 Q. Did you not think that, having reached even your

14 preliminary conclusion, it would have been your style to

15 have asked for some account on the other side in order

16 to give some sort of balance, even to something that you

17 wrote?

18 A. No, because I was not there to adjudicate between two

19 parties. I was there to try -- I was not accusing

20 anybody of anything -- I was there to try to find out

21 what happened, in other words to get the story. Now the

22 implications of it, of course, I was not ignorant of,

23 they are in the memo.

24 We had a deadline and when a journalist is not in

25 a position to say "I do not know, give me another week"


Page 120


1 because unfortunately, or fortunately, I did know, I had

2 to answer it to the best of my belief and supported

3 by -- we have been around my motives, that was the

4 answer I had been sent to give, sent to get, and so

5 I sent it off to the paper.

6 Q. You then in paragraph 12 give the account that you have

7 given in some detail to the Tribunal already, and I will

8 not rehearse it again: your recollection is of going in

9 the evening and speaking to a captain in the Light Air

10 Defence?

11 A. Yes.

12 Q. You are fairly sure it was not the man you had met

13 before?

14 A. I am reasonably sure, yes, by the way he was a captain

15 because he said he was, he was in plain clothes.

16 Q. Out of all the things he told you, two were fairly

17 remarkable: one was he produced a 14-year-old boy as

18 a sort of stooge witness; that was an unforgettable

19 extraordinary event?

20 A. I was unconvinced, shall we say.

21 Q. And secondly, he had actually been present on the day

22 and had witnessed IRA shooting civilians with Thompsons?

23 A. That is what he told me, that is to the best of my

24 recollection; that is what I said in the contemporary

25 memo, that is what he told me.


Page 121


1 Q. I would agree with you, with respect. Can you explain

2 those two -- and I would agree with you, with respect --

3 unforgettable accounts; why is it neither of them

4 appears in your statement?

5 A. Which statement?

6 Q. What we are looking at at paragraph 12?

7 A. You mean my initial witness statement, the first one?

8 Q. I hope it was clear, sir, what we are looking at on the

9 screen in front of us, the statement made to assist this

10 Tribunal?

11 A. But which one, I made several?

12 Q. The full statement, the only full-length statement you

13 made in December 1999, which gave what I think we

14 thought, until we heard you today, was a full and

15 accurate account of this meeting?

16 A. You mean the first statement that I made before I knew

17 of the existence of the memo, that is the one we are

18 talking about.

19 Q. The one that is on the screen in front of you, sir, yes.

20 A. Could I see the top of it I will soon know which one it

21 is.

22 Q. It is the full statement.

23 A. No, no, no could I possibly see -- I know how it starts,

24 could somebody --

25 Q. You want to see the first page or the last?


Page 122


1 A. The first, please.

2 Q. The first page we have is at M71.14.

3 A. That is the memo.

4 Q. No, M71.14.

5 A. Okay. Now, that was my first statement. I did not then

6 know of the existence of the memo. When I had made this

7 statement, what the captain said to me or did not say to

8 me ten days later -- and I thought it was after the

9 deadline had passed, at any rate -- no longer seemed to

10 me relevant to what I have been asked about, namely the

11 published article which makes no reference to my visit

12 to Drumahoe and so on, it makes no reference to it, you

13 follow me, am I making myself clear?

14 Therefore, I was not going to volunteer it because

15 I could not at that point see what it had to do with the

16 article that we had published -- did not publish, but

17 our first article, written before I had any recollection

18 of having seen -- only then, three months later, did the

19 Inquiry send me the memo, whose existence I had

20 forgotten, and then they said "tell us more about the

21 memo; what were the circumstances", and that is my

22 second witness statement.

23 In a couple of details on the first statement I was

24 wrong, names of barracks and so on, that is the sequence

25 of events.


Page 123


1 Now what are you asking me, Mr Glasgow, I beg your

2 pardon?

3 Q. What I asked you was, why you did not think it was

4 relevant when you made this statement we are looking at

5 now on the screen, to tell the Tribunal the

6 unforgettable event of having a 14-year-old boy produced

7 to make a false story?

8 A. Because this had happened after the end of the

9 shooting --

10 Q. It was a conscious decision that you did not think --

11 A. No, no, I had only the vaguest of recollections of this

12 Drumahoe situation. I knew I had been there; I knew

13 I had seen the sand table.

14 Q. Had you also, in your vague recollection, forgotten that

15 an Army officer had told you but a few days after

16 Bloody Sunday, that he had witnessed the IRA shooting

17 civilians with a Thompson sub-machine gun; had you

18 forgotten that when you made your statement as well,

19 sir?

20 A. No, it was not a few days after; it was, as you say,

21 more than a week after.

22 Q. Ten days.

23 A. It was not relevant to the statement, because the

24 statement concerned the published article, that was what

25 my statement was about.


Page 124


1 Q. Did you not think this Tribunal might need to know that

2 an Army officer had told you, within 2 weeks of

3 Bloody Sunday, that he had witnessed the IRA shooting

4 civilians with a Thompson sub-machine gun?

5 A. Now, I must add, sir, in general terms: it was

6 abundantly clear --

7 Q. Why do you need to answer in general terms; why can you

8 not for once give us a straight answer to a question?

9 A. I am giving straight answers, as far as I know. Many

10 people -- it was clear that everybody could not be

11 telling the truth in the week in which we worked on this

12 story, the stories were not matchable, they were not

13 right.

14 Therefore, running -- it did not strike me that an

15 Army officer speaking under these circumstances in

16 Drumahoe and so on, had any particular relevance to what

17 had happened. If you want to be blunt about it, I did

18 not, when I talked to him, or recollect him as having

19 been a witness of truth when he talked to me, I think he

20 had another purpose in mind; I make that very clear in

21 my second statement.

22 Am I making myself clear now?

23 Q. Please give whatever answer you feel is right, I will

24 not stop you.

25 A. The question you are asking me, why did I not take it


Page 125


1 aboard when I made my witness -- I obviously could not

2 have taken it aboard when we were writing our article,

3 I had not then spoken to him.

4 When he later talked to me, what he told me, so

5 ill-consorted with everything else that I knew, that

6 I could not see any point in drinking it up from

7 a 30-year old recollection in my first statement.

8 In my second statement, when I was asked about the

9 memo, which is suddenly put in front of me, I have not

10 seen it for nearly 30 years, then of course, my memory

11 was confirmed, a 30-year old memory, nobody has

12 a photographic 30-year old memory, I suppose, by

13 contemporary document.

14 If I am understanding what you are saying is why did

15 I not believe it.

16 Q. Go we go back now to M71.17, please, which was the

17 paragraph I asked you about, paragraph 12? You will

18 there recall what you said. There is one particular

19 matter can I put to you: you say in this statement in

20 relation to the sand table that you asked to see the

21 sand table. You told the Tribunal just half an hour ago

22 in answer to my friend that you did not ask to see it,

23 he showed you?

24 A. He showed it to me, yes.

25 Q. That is just a mistake.


Page 126


1 A. Just a mistake, yes. The first one --

2 Q. Are you sure you did see it here, sir?

3 A. Absolutely sure, absolutely sure.

4 Q. You have a recollection of seeing it at that place?

5 A. Absolutely sure, I was very surprised that he showed it

6 to me.

7 Q. Could we, without rudeness, clarify what you want to say

8 about the photograph you were shown: do you now think it

9 was the model, as you agreed with Mr Clarke --

10 A. I cannot be certain if somebody --

11 Q. No. Forgive me, I did not ask you to "be certain", my

12 words were careful, I said: it may be important for the

13 Tribunal to know, do you think, doing the best you can

14 on a wholly neutral point, that the model you saw is the

15 one that Mr Clarke showed you a photograph of, which,

16 doubtless honestly, you reacted by saying you thought it

17 was it, or very like it?

18 A. Very like it. I could not say with certainty it is the

19 same one, no.

20 Q. Having seen a model, wherever you saw it and for

21 whatever purpose it had been built, you came to the

22 conclusion that this was a model that had been made for

23 training the paratroopers for the operation in Derry;

24 that is what it boils down?

25 A. Not necessarily for training. Such plans are normally


Page 127


1 drawn up on sand tables. There was the sand table in

2 front of you. It did not occur to me that they had made

3 two sand tables.

4 Q. You did draw the conclusion that the model which you

5 saw, whether or not it be the one that we showed you the

6 photograph of, but the model you saw in this city

7 shortly after Bloody Sunday, must have been a model

8 prepared and used by the Paratroop Regiment in Belfast

9 for training for this operation?

10 A. That I saw in Drumahoe?

11 Q. Yes.

12 A. I cannot answer that it was used, I do not know, that

13 there existed a sand table I was most interested to see.

14 Q. Because your information all precisely corroborated, as

15 you have told us, was that every witness had told you

16 that the Parachutists had deployed swiftly and silently,

17 you concluded they must have had detailed orders as to

18 precisely where they were going?

19 A. Absolutely.

20 Q. Everybody told you that the Parachutists deployed

21 swiftly and silently?

22 A. And the "silently" means nobody heard any orders given,

23 therefore people who ran here there, drove personnel

24 carriers here and there must, must have been following

25 a pre-arranged plan because there is no other


Page 128


1 possibility.

2 Q. The other matter, which again I respectfully repeat,

3 must have been unforgettable about the use of the

4 Thompson sub-machine guns; you discounted that and

5 rejected the officer's account of what you thought he

6 told you he had seen because you knew there had not been

7 any automatic fire?

8 A. I had heard none on the records, from the tape

9 recordings made at the time.

10 Q. It was because you had decided, in the light of the

11 evidence you had carefully collected, that there had

12 been no automatic fire, that the officer could not be

13 telling the truth?

14 A. One of the reasons certainly, there were other reasons,

15 but that was certainly one of them because --

16 Q. Had you not at an earlier stage been troubled by

17 evidence about automatic fire that you could not make

18 sense of; was that not one of the discrepancies that did

19 initially trouble you?

20 A. No, what I said was -- you are talking about the memo in

21 which I make reference to having seen the soldier with a

22 photograph with a Sterling sub-machine gun, pistol

23 ammunition sub-machine gun.

24 Now, that demonstrated that somebody physically had

25 an automatic --


Page 129


1 Q. Did you, sir, come to the conclusion, at any stage

2 during your investigation, that the evidence you had

3 collected supported the theory that there had been

4 automatic fire or that it supported the firm

5 conclusion --

6 A. Firm conclusion that there had not been. If you forgive

7 me, it will take a second: no photograph showed anybody

8 carrying a suitable weapon for automatic fire, the FN

9 rifle is very difficult to put on full automatic and

10 would never be used under such circumstances on full

11 automatic, it uses too much ammunition.

12 So no record, no photograph, no credible --

13 credible, I underline -- eyewitness statement that

14 anybody had seen someone carrying, on particularly what

15 we are discussing, using, a low velocity automatic --

16 a Thompson gun or evidence of that.

17 Q. Could we look, please, at the way in which you disposed

18 of the evidence that might have contradicted that, at

19 M71.7, so that I can ask you whether you think it is as

20 scrupulously careful as your conclusion was. In the

21 middle of your memo to Harold Evans, you say:

22 "I will not begin in this memo to list the endless

23 fitting together of bits that has gone into this.

24 A couple of examples. I studied the statement of the

25 Scottish Chief Constable that he heard automatic fire


Page 130


1 and, as the Army had only self-loading rifles, automatic

2 fire must have been opened by the IRA. Sound, and

3 a serious difficulty -- until I found on one of Peress's

4 pictures a shot of a Para in a jump helmet carrying a

5 Sterling slung over his shoulder, end of Scottish

6 copper's theory."

7 Why do you describe it in those terms, in the

8 perhaps rather derisory, "the Scottish copper's theory"?

9 A. Because I am talking -- it is slang -- to an editor who

10 I knew very well. This was never intended for

11 publication or being seen by anybody and journalists

12 tend to be a bit, you know --

13 Q. You believed that because you had found a photograph of

14 a paratrooper apparently carrying a Sterling sub-machine

15 gun, this, to your satisfaction and scrupulously fair

16 examination of the evidence, disposed of what you

17 contemptuously described as "the Scottish copper's

18 theory"?

19 A. It was not contemptuous, affectionate, if you like.

20 I have had a lot to do with the police in my time.

21 I perhaps do not make it very clear in my memo, may

22 I now make the line of thinking clear?

23 Q. I am sure the memo is admirably clear to anybody who

24 reads it with an open mind, sir, do not worry.

25 A. If I may worry and just illuminate it because it will


Page 131


1 not take a second.

2 What I am saying here is that if anybody said he had

3 heard an automatic weapon, anybody -- and of course

4 people can be mistaken about such things -- then the

5 line of reasoning that therefore the IRA must have fired

6 it because the Paras did not have any automatic weapons,

7 that particular line of reasoning, that particular

8 syllogism is destroyed by finding a photograph of

9 somebody else who had an automatic weapon. That I do

10 not say he fired it, I am simply saying that that line

11 of exclusion in all SB and all that chronological

12 structure is destroyed. The proposition that all swans

13 are black is destroyed by finding one white swan, it is

14 simply a logical matter of that kind.

15 Q. The last page I want to trouble you with is M71.19, the

16 last but one page of your statement, if we look first at

17 paragraph 17 together. One of the shootings you looked

18 into was the shooting of Johnston and Donaghy, the very

19 first?

20 A. Yes, the very first.

21 Q. And those two men, they also fitted your description of

22 people who had probably been singled out because they

23 were young --

24 A. No, no, no. I could not work out why they had been

25 singled out. Neither of them were obviously women or


Page 132


1 elderly clergy men, in other words, anybody taking

2 a quick look at them --

3 Q. They did not quite fit the picture?

4 A. No, no, no, they were not excluded immediately from the

5 picture, I am saying something different.

6 Q. Can you remember, sir, why you came to the conclusion

7 that Mr Johnston had been shot as he went to help

8 Donaghy, or was that just adding a bit of journalistic

9 colour?

10 A. I was not adding journalistic colour, we were told this

11 had happened.

12 Q. Did you not read his statement?

13 A. Whose statement?

14 Q. Mr Johnston's; was he not one of the statements you

15 read?

16 A. You mean, at the time?

17 Q. Yes.

18 A. You will have to put it up in front of me.

19 Q. Very well, AJ5.1, I will do exactly as you asked,

20 because this, we are told, is the statement he made to

21 the Sunday Times. Do you think you saw it:

22 "Mr John Johnston, wounded, manager of clothing

23 store"?

24 A. I personally have never seen it before. Hang on, this

25 statement is made on 22nd of the 2nd, long after I had


Page 133


1 left Derry.

2 Q. Do you think you ever saw it?

3 A. This statement?

4 Q. Yes.

5 A. No, I saw nothing. When I left Derry to return to

6 London, I never studied any documents because I was, in

7 journalistic terms, taken off the story.

8 Q. Do you think that the statement, whether by him or about

9 him, that you had -- contrary to what he says in his own

10 statement -- had said that he was going to help

11 Mr Donaghy when he was shot, is that your recollection

12 or can you not help?

13 A. I cannot help because I have not memorised what the

14 statement said 30 years ago. However, if they are on

15 our list of the ones appended to our unpublished

16 article, then either myself or Derek Humphry must have

17 got that from him, now I cannot recollect which of us --

18 Q. The reason why I thought it fair you should see it, sir,

19 because somebody, perhaps even more scrupulous than

20 yourself, regarded this statement as scotching the

21 romantic rumour that Johnston had been going to help

22 Donaghy, and I was going to suggest to you that you were

23 the author of the rumour?

24 A. I am not the rumour certainly.

25 Q. If we go over the page that appears to be your own


Page 134


1 newspaper's conclusion.

2 A. My own newspaper?

3 Q. The Sunday Times that you were working for.

4 A. I am not responsible for conclusions of the newspaper

5 other than those that I made; I did not write this other

6 stuff, I did not conduct this other interview.

7 Q. Did anybody ever tell you that the romantic rumour that

8 Johnston had rushed to the aid of Donaghy had been

9 scotched by his own statement?

10 A. You are putting the word "romantic" in, I am not and

11 I would never dream of using such a word, but (b), by

12 the time this material was being circulated in the

13 Sunday Times, if it was circulated, I was far away in

14 Pakistan covering yet another war in that part of the

15 world.

16 I dropped the story, was taken off it. After my

17 return from Derry -- by the time I wrote the memo, which

18 is, what, the 18th, I was back in London and in the last

19 few days it is the next time I have been back in Derry

20 or have done any work on the story.

21 Q. So you can deal with it, sir: we are told the reason why

22 the story was dropped was because it could not have been

23 published as a piece of responsible journalism?

24 A. Who told you that?

25 Q. Mr Bruce Page?


Page 135


1 A. Oh, did he. Okay, well that is his opinion.

2 Q. Was it not given to you, sir, at the time?

3 A. Most certainly not, read my memo. The memo says nothing

4 about responsible journalism. My memo is addressed to

5 an editor -- may I finish -- addressed to an editor by

6 a helpful reporter who is saying: what do we do next?

7 Q. So you can see the words, if it is new to you, you

8 should see it. It is Mr Bruce Page's statement to this

9 Tribunal, it is at M63.1.

10 A. I am not responsible for what Mr Page says and I do not

11 wish to get into a debate 30 years on with Mr Page.

12 That was not -- by the way, may I say, what was

13 published at the time minus our article, has the map on

14 it which evidently was thought responsible, it certainly

15 was published and the reason given in the paper, by

16 Evans presumably, is not irresponsible journalism or

17 whatever you are accusing me of, it was the problem of

18 sub judice.

19 Q. Mr Sayle, it is not my accusation, the only reason

20 I thought you ought to look at it is, if you have not

21 seen it before, it would be wrong and rude of me not to

22 give you the opportunity of commenting on it.

23 A. Thank you for your courtesy.

24 Q. Look at paragraph 5 together; I am sure you remember who

25 Mr Page was?


Page 136


1 A. I met him.

2 Q. What it says is:

3 "I, along with some other members of the editorial

4 team, felt that the article was not substantiated by the

5 evidence Sayle and Humphry had produced and that it did

6 not stand up to close scrutiny. It made far too many

7 assumptions and could not have been published as

8 a responsible piece of journalism."

9 My only question, sir: because we have been given

10 that I wanted to know whether you had ever been told

11 that?

12 A. Never.

13 Q. I will not press it any further. Let us go back to

14 M71.19 and look at the last paragraph, paragraph 18.

15 Maybe it is just the use of English, but you quote from

16 the article, where you say:

17 "The Saracens pulled up, apparently at random.

18 Soldiers jumped out and began shooting, apparently

19 indiscriminately at the panic-stricken crowd."

20 You go on to explain that the use of the word

21 "apparently" twice "indicates our view that there was

22 nothing random or indiscriminate about these actions".

23 That is what you mean, is it? The article saying

24 that the shooting was apparently indiscriminate meant

25 that it was not indiscriminate at all?


Page 137


1 A. Not apparently to me. Apparently many people, as you

2 will discover from -- as I am sure you know --

3 eyewitness statements, could not work out who or why

4 they were shooting at them and hence the word

5 "apparently".

6 Q. You understood the evidence was that it was not

7 indiscriminate but deliberate and selective?

8 A. I believe that it was in following a plan drawn up in

9 advance and the nature of the plan is in our unpublished

10 article.

11 Q. And specifically your own words are "especially the

12 witness James Chapman", you understood to be sharing

13 that view?

14 A. Yes, absolutely. He described to me a planned military

15 operation.

16 Q. And nothing indiscriminate --

17 A. I would find it hard to brief that British paratroopers

18 would fire at anybody indiscriminately, as I say in the

19 memo.

20 Q. Could we see the statement he made, which I think we

21 have accurately been told must have been the one you

22 were working on because it is labelled as having been

23 made to Mr Derek Humphry and we see it at AC59.17. You

24 will remember you were shown it this morning because it

25 was said to have been made to Derek Humphry.


Page 138


1 A. It is made to Derek Humphry, yes, I see.

2 Q. If I put the last half anyway, the account he gave you

3 was of a crowd of between 5,000 and 6,000 had got past

4 the barricades, leaving about 3,000 to 4,000 still on

5 the open ground. In the last paragraph, which I wanted

6 to look at because of your belief that he supported you

7 that the fire was not indiscriminate:

8 "Then I saw a fleet of seven Saracens preceded by

9 a Ferret scout car tear into the Bogside at about

10 40 miles per hour and fan out to a prescribed plan in

11 the obvious intention of arresting some of the crowd.

12 "Between 50 and 100 Paras dismounted from the

13 armoured cars or ran up behind and changed from berets

14 into helmets. Some went flat on the ground, others on

15 their knees into firing positions and fired wilfully and

16 indiscriminately into the crowds at the barricade."

17 Did you not from that understand that your specially

18 prized witness who you depended so heavily upon, was

19 actually saying in terms that the fire had been

20 indiscriminate?

21 A. How would he know they were indiscriminate? No, I have

22 no recollection of reading this statement. What

23 I said -- Chapman had, my reliance on Chapman, was

24 talking to him, and I cannot conceive how a soldier

25 could say that another soldier was firing


Page 139


1 indiscriminately; I do not know what the word means; how

2 does he know what they are firing at?

3 Q. I only asked you because it was a word that you have

4 used quite a lot both in your writing and in your

5 evidence.

6 A. Indiscriminately, never.

7 Q. Never?

8 A. Never, I could not imagine a British paratrooper firing

9 at anybody indiscriminately, that would be a riot by the

10 army, I do not believe that this has happened, these are

11 highly trained, professional people.

12 Q. The evidence Mr Chapman gave you appeared to you to be

13 consistent with what everybody else was saying?

14 A. Everybody else? Who is everybody --

15 Q. The other witnesses you had collected?

16 A. No, we are talking about different things. He was

17 a military man; they were civilians looking at

18 something, the nature of which, inevitably when

19 civilians look at military operations, they did not

20 fully understand.

21 Q. You preferred his evidence --

22 A. Because of his training as a military man I was able to

23 use military language with him, yes.

24 Q. Do you recall anybody else telling you that a fleet of

25 seven Saracens had come into the Bogside, had torn in at


Page 140


1 40 miles an hour?

2 A. I remember Chapman talking about the speed with which

3 they moved.

4 Q. Could I have an answer to the question? I do not mean

5 to be rude, but could we do want to get on: do you

6 remember anybody else telling you that a fleet of seven

7 Saracens had torn into the Bogside at 40 miles an hour?

8 A. I remember Chapman -- the word "tore" is what I objected

9 to, I am sorry, I am hoping to try to make myself

10 clear -- Chapman told me they had moved at a

11 considerable speed, 40 miles an hour. That pointed out

12 to me that this could not have been an exploratory

13 probe, they knew where they were going.

14 Q. I will give it one last shot: do you remember any other

15 witness telling you that they had seen a fleet of seven

16 Saracens "tear", to use his word, into the Bogside at

17 40 miles an hour?

18 A. I did not, and I am not responsible --

19 Q. Do you remember any other witness telling you that 50 to

20 100 Paras had dismounted and changed from berets into

21 helmets?

22 A. That would be far too high. My understanding was that

23 a protective section or at most two sections -- 50 is

24 half a company, two platoons -- too many.

25 Q. Did you understand from the evidence that you collected


Page 141


1 that there was a considerable weight of civilian

2 evidence which supported the suggestion that there had

3 been firing, whether indiscriminate or not, into

4 thousands of people fleeing over the barricade?

5 A. You are going to have to ask me that question again, it

6 was a bit complicated; what am I being asked?

7 Q. Mr Chapman told you, as he told Lord Widgery, that there

8 were about 3,000 to 4,000 people still when the Paras

9 came in, that they were fleeing over the barricade and

10 that the paratroopers simply opened fire with whatever

11 word -- perhaps we do not need an advert -- but they

12 opened fire at them, shooting at them while they were

13 fleeing over the barricade?

14 A. That was not my recollection of what I said to Chapman

15 --

16 Q. You formed the view, did you, irrespective of his

17 military background, Mr Chapman was one of the most

18 reliable witnesses to whom you spoke?

19 A. He was -- not witness for the newspaper, the newspaper

20 is not on trial as far as I know -- he was the most

21 useful person I talked to at some length among all the

22 eye-witnesses because we could use military language.

23 Q. Did any of the civilians to whom you spoke give you any

24 account of civilian fire, civilian gunmen with guns or

25 shooting, other than the man with the pistol, the .38


Page 142


1 pistol, who had responded to the Donaghy and Johnston

2 shot, or those who had fired after the Army firing had

3 effectively ceased?

4 A. None of the eyewitnesses told me about the pistol shot,

5 it came from the person himself indirectly, (inaudible)

6 I forget. As far as the subsequent -- that did not come

7 from eyewitnesses either.

8 Q. You were given no account --

9 A. No eye-witness -- I found no-one, and if I had I would

10 have been very shaken, but I found no-one who was

11 present, a civilian, who was able to they will me that

12 he was certain that an automatic weapon, low velocity,

13 something like a Thompson gun, had been seen. Nobody

14 could remember that.

15 LORD SAVILLE: That is not quite Mr Glasgow's question.

16 Could you ask it again?

17 MR GLASGOW: Mr Sayle, I know it is a long day: did any

18 civilian give you any account of seeing any other

19 civilian with a weapon or shooting on that day other

20 than the account you had of the .38 pistol at William

21 Street, or the firing that took place late in the day

22 after the Army had effectively ceased --

23 A. I do not recollect anybody saying that, I do not

24 recollect it.

25 Q. If they had, presumably as an honest journalist, you


Page 143


1 would have recorded it?

2 A. (Witness laughs) Yes --

3 Q. You shrug and laugh, but did you take it that seriously?

4 A. I am flattered that I am described as an honest

5 journalist, I expect you are not wholly sincere about

6 that, but never mind. No, of course, but we are

7 discussing here, what I was trying to do, looking for

8 serious -- people can be mistaken about what they see,

9 right, particularly civilians when there is shooting

10 going on, and so on. I have no recollection because

11 otherwise it would have occurred in our piece.

12 Q. Do you think it is possible, then, in view of that

13 answer that you came to the conclusion that such

14 accounts as you were given of civilians with guns might

15 simply be mistaken, and in such a minority that you need

16 not bother about them?

17 A. Too long ago and I have no idea whether that -- if

18 somebody did say that to me, I have no recollection of

19 it.

20 Q. It is a possibility?

21 A. What is a possibility.

22 Q. That civilians, one or more, did give you accounts of

23 civilians about guns, but because they were in the

24 minority and because you believed they were mistaken you

25 did not take them seriously?


Page 144


1 A. Possible, yes, of course it is possible.

2 MR TOOHEY: Mr Glasgow, just before you sit down, please,

3 I wonder if you could help us in regard to the

4 photograph P562 that was produced by Mr Clarke? In

5 particular, can you tell us either now or after inquiry

6 where and when the model shown in that photograph was

7 produced and, secondly, in what location or locations

8 the model was shown in that photograph was

9 during January and February 1972?

10 MR GLASGOW: The answer, sir, I have tried and I think it

11 would be better if I did take further instructions.

12 I can say straightaway it is the recollection of some

13 clients in 22LAD that a model was made, but until I have

14 investigated that further and to where it would have

15 finished up, and when and where it was made, I do not

16 think I can take it further.

17 That this model was, we believe, produced by the

18 Army within this city, one of the resident battalions,

19 I think is not in doubt, but I cannot put a date and

20 I cannot put a place, and I know my learned friend

21 Mr Clarke and I are both looking, and I am sorry, I did

22 not get the information in time to put to this witness.

23 MR CLARKE: I do not think it was produced by one of the

24 relevant battalions, it was produced by a model-making

25 agency of the Armed Forces. I cannot remember for the


Page 145


1 moment which one it was, but it is in Donny Scott's

2 statement relating to the provenance of various

3 photographs. I will find the reference in due course.

4 I think we may be able to work out from some subsequent

5 material what was the date it was produced, I have not

6 got it in my mind.

7 MR TOOHEY: Would that help also to identify the location in

8 which the model is shown in that photograph?

9 MR CLARKE: I have really very little doubt that this is the

10 model in situ in the Council chamber in Coleraine in

11 which Lord Widgery sat.

12 MR TOOHEY: That does not tell us where it was before it

13 arrived at Coleraine.

14 MR CLARKE: No, it does not, and all I think we will be able

15 to find is the entity that made it, and possibly the

16 date when they made it; where it went in between is,

17 I think, at present unknown and will probably remain

18 unknown.

19 MR TOOHEY: Thank you, Mr Glasgow. Thank you, Mr Clarke.

20 MR GLASGOW: I can help my learned friend by saying there is

21 a bill -- lawyers tend to remember bills -- there is

22 a bill in bundle G for making it, I do not think we got

23 any further than that.

24 MR CLARKE: I think there is a document that is not in any

25 of the bundles at the moment which has surfaced, which


Page 146


1 is the date it was made, but I have only got that at the

2 back of my head.

3 LORD GIFFORD: I rise on other point: Mr Glasgow put that

4 Mr Chapman had said both to Mr Humphry and Lord Widgery

5 that some 3 or 4,000 people were fired on; he certainly

6 did not say that to Lord Widgery. He said he had said

7 to Humphry 3 or 400 and that there had been

8 a correction. That may be something we can explore with

9 Mr Humphry, but certainly what was put was not correct.

10 Questioned by MR ELIAS

11 MR ELIAS: Mr Sayle, my name is Elias and I act for a number

12 of former military personnel. You have partly answered

13 the only issue I briefly wanted to raise with you with

14 Mr Glasgow a moment or two ago. Could I ask you to look

15 at M71.19, paragraph 17 of your first statement?

16 A. Very first statement, yes.

17 Q. Paragraph 17: this is the paragraph in which you refer

18 to the Official returning a pistol shot. I wanted to

19 ask you whether, as you say three or four lines up from

20 the bottom:

21 "The fact that the Official IRA man admitted firing

22 a shot would have been recounted to Derek and me in his

23 conversations with the IRA".

24 Do you recall now whether you or Derek Humphry spoke

25 directly with the man who was admitting firing the shot?


Page 147


1 A. Of course I cannot answer for Humphry. People who, from

2 the Bogside, were visiting the City Hotel to talk to us,

3 and some of them we asked to come up. Now, I do not

4 remember, because it is a long distance, whether I heard

5 about the Official shot from the shooter himself or from

6 Humphry, or from someone else.

7 What I had satisfied myself was, that the IRA, the

8 Official IRA, acknowledged having fired one pistol shot,

9 that is all I remember, because what was important to me

10 was that one shot had been fired.

11 Q. What you said to the Tribunal a moment or so ago in

12 answer to Mr Glasgow's question was:

13 "No eyewitness told me about the pistol shot, it

14 came from the person himself indirectly"; what did you

15 mean by that?

16 A. No eyewitness reported having seen it fired; do you

17 follow me? Nobody saw this man firing the pistol shot;

18 no eyewitness reported that he had fired. We could not

19 find any trace of anybody who had seen it fired, heard

20 it fired, what had happened to it, nobody saw it. The

21 information that it had been fired came directly or

22 indirectly from the person with the gun himself.

23 Q. You cannot remember whether you spoke with him and you

24 do not know whether Derek Humphry did?

25 A. You will have to ask Humphry about whether Humphry spoke


Page 148


1 to him. Certainly, one of us did and I cannot remember

2 whether I was with Humphry or that he said it

3 independently, I cannot remember.

4 Q. One of you did?

5 A. One of us must certainly have done so.

6 Questioned by MR CLARKE

7 MR CLARKE: Could I have on the screen M71.29? This is the

8 end of your article. Could we highlight, please, the

9 passage which begins underneath the line?

10 That reads:

11 "This copy filed and agreed by Sayle, Humphry and

12 Pringle, who are all prepared to stake their

13 professional representations on total accuracy. We

14 understand, confirmed by Moynahan paratroop officer

15 interview which completely independent of us and so

16 valuable confirmation."

17 Do you know of whom that was an interview?

18 A. No, I have not the faintest idea. It came second-hand,

19 I mean, maybe from someone in the office, that

20 Moynihan -- you understand how Sunday Times people

21 fanned out, but Derek and I were the people in Derry

22 where the thing was, you know, where it was -- action

23 had happened. Someone told us, I cannot tell you who,

24 that Brian Moynahan, another colleague, had secured an

25 interview with the paratrooper officer. We had not


Page 149


1 spoken to any paratroopers, officers or otherwise.

2 I never saw the statement; if it ever was made, I never

3 saw it.

4 Q. Can we have on the screen S14? We have in fact attained

5 from the Sunday Times archive what looks very much as if

6 it is the interview in question, because this is

7 something that has been sent over from Moynahan in

8 Belfast for Bruce Page in London. It is dated 4th

9 February. It is described as "notes of an interview

10 with Captain Mike Jackson, the Adjutant of the First

11 Parachute Battalion".

12 As I understand from your last answer --

13 A. I have never seen it before.

14 Q. -- you have never seen it before. What I wanted your

15 help on, to see if there is some link, is this: could we

16 have on the screen L171?

17 This is the --

18 A. Vincent Browne's piece.

19 Q. -- Vincent Browne's piece. If we go to the opening

20 paragraphs, it talks about the plan as conceived and the

21 fact that the plan misfired, but it includes in it

22 a paragraph which reads:

23 "This information is based not only on an

24 interpretation of what actually happened, but also on an

25 unattributable interview with an officer of the


Page 150


1 Parachute Regiment which was the spearhead of the

2 operation."

3 Then it goes on to refer to the operation being

4 prompted by political pressures. This may be guesswork,

5 but one possibility is that as well as getting

6 information from the Sunday Times including yourself,

7 and as well as getting the Sunday Times map, Vincent

8 Browne got a copy of or was told the contents of an

9 interview with an officer of the Parachute Regiment,

10 which looks like Captain -- as he then was -- Michael

11 Jackson, which had been carried out by Brian Moynahan;

12 is that possible?

13 A. You are asking me whether it is possible that Vincent

14 Browne got a copy? I have no way of answering that. It

15 is possible in the sense that, while I can physically

16 imagine it happening, but I had no knowledge of that.

17 I have no knowledge of where Browne got his information

18 from, I hope I have made that clear.

19 Q. Unfortunately, to some extent, neither does he. Are you

20 aware of any other interview with an officer of the

21 Parachute Regiment which the Sunday Times carried out at

22 this stage, apart from whatever interview Brian Moynahan

23 carried out?

24

25 A. No, not told me.


Page 151


1 Q. Thank you very much.

2 LORD SAVILLE: Mr Sayle, the Chairman again, thank you very

3 much indeed for coming here to help us.

4 A. And thank you everybody for being so courteous.

5 (The witness withdrew)

6 MR Derek Humphry, affirmed

7 Questioned by MR CLARKE

8 LORD SAVILLE: Mr Humphry, over to your right. You

9 probably heard me introduce myself to your colleague.

10 The important thing to remember is to keep pretty close

11 to that microphone so we can all hear what you have to

12 say. You can pull it towards you if you like to make it

13 more comfortable.

14 MR CLARKE: Do you have with you, Mr Humphry, your statement

15 to this Tribunal which you signed on 6th May 1999, and

16 the first page of which is presently on the screen?

17 A. Yes, I have it in my bag and I see it on the screen.

18 Q. Are the contents of that statement true to the best of

19 your knowledge and belief?

20 A. They are.

21 Q. You describe, if we may have paragraphs 2 and 3 on the

22 screen, how you were asked on the evening of the Sunday

23 to travel to Derry and to research and write an article

24 on the shootings that had occurred. You had yourself

25 been here on the Saturday before the march but you


Page 152


1 returned from Derry to London, I presume; is that right?

2 A. Yes.

3 Q. Because the planned demonstration was not considered to

4 be of any particular significance beforehand, and then

5 came back again here on the Sunday evening?

6 A. That is correct.

7 Q. You describe, if we may look at paragraphs 5 to 7, how

8 you started to interview some of the marchers who had

9 been wounded that afternoon, went to Altnagelvin and

10 asked the wounded to show you where they had been

11 standing, what they were wearing at the time and where

12 on their body they were hit.

13 Have you been present this morning when Mr Sayle was

14 giving evidence?

15 A. Yes, I heard it all.

16 Q. I may be able to take matters a little more shortly in

17 that case. You will recall that attached to the version

18 of the unpublished article that we have there is a list

19 of quotes from eight witnesses, of the wounded.

20 Would I be right to infer those were the totality of

21 the wounded whom you saw at that stage, the eight that

22 are referred to subsequent to the article?

23 A. I would expect so, yes. I cannot remember name for

24 name.

25 Q. You describe in paragraph 6 that once you had done the


Page 153


1 interviewing of wounded people in the hospital, you

2 interviewed other local eyewitnesses who pointed out to

3 you where the paratroopers' vehicles had parked and

4 where the soldiers had been when they opened fire.

5 Do you have any idea of the sort of number of

6 eyewitnesses whom you talked to?

7 A. Well, I worked from sharp Monday morning afternoon and

8 evening, the Tuesday, the Wednesday, the Thursday --

9 dozens -- I do not recall, but I worked flat out for

10 four days on it.

11 Q. Was this at the City Hotel or was it touring round the

12 Bogside, or what?

13 A. Oh, no, touring round the Bogside, all over the place.

14 Q. You do not, I suppose, have any notes that have survived

15 today?

16 A. No.

17 Q. Could we have on the screen AC59.17? This is

18 a statement of Mr Chapman, which is described as being

19 given to yourself. If we look at the next page,

20 AC59.19, the last page, it is signed by him.

21 Do you recollect this statement being taken?

22 A. I probably interviewed him. I expect I did, I cannot

23 remember, but that does not look like my interview

24 because the corrections on it are not my handwriting and

25 my style. It is Insight style to take signed


Page 154


1 statements, it is not the style of a fast reporter,

2 unless you get rid of really dangerous -- I -- it is

3 similar, but I do not think that is actually my

4 interview.

5 Q. Could it have been Peter Pringle?

6 A. Quite possibly, yes. Well, the Insight team were moving

7 in when we were moving out.

8 Q. Could we go back to the first page of the statement,

9 AC59.17? You tell us that is not your handwriting; do

10 you know whose handwriting it is?

11 A. No, I do not, no.

12 Q. If we look at the third paragraph, there is a sentence

13 which reads as follows:

14 "The crowd started to come back into the Bogside.

15 About 5 to 6,000 had got past the barricades leaving

16 about 3 to 4,000 still on the open ground. They thought

17 they were safe. I was still watching and I could see

18 from my window that CS gas and rubber bullets were being

19 used to get them out of the William Street entrance."

20 Could we have a look now, please, at AC59.15? This

21 is a passage in the evidence of Mr Chapman to the

22 Widgery Inquiry and he was being asked questions by

23 Mr Stocker, who was then the Counsel to the Inquiry.

24 He asked these questions:

25 "When you appeared on television [that is referring


Page 155


1 to, I think, appearing on This Week] do you remember

2 having an interview with Mr Derek Humphry of the Sunday

3 Times?

4 "Answer: That is right, sir."

5 If I skip two questions, he was next asked

6 this:

7 "Question: Did you say this to Mr Derek Humphry:

8 'about 5,000 to 6,000 people had got past the barricade,

9 leaving about 3,000 to 4,000 still in the open ground'?

10 "Answer: Leaving 300 to 400, I initialled any

11 alterations. He came up to my house after getting it

12 typed out and I have a copy initialled at my home and he

13 has a copy of my initials on his. I said 300 to 400."

14 Does that bring back any recollection?

15 A. No, that is not my statement. If my name is at the top

16 of it, somebody has made a mistake. It is -- never in

17 any of those interviews did I take them back and ask

18 them to be signed, it was not my style, so, Mr Chapman

19 has mistaken me for another Sunday Times reporter --

20 Q. If we --

21 A. In relation to this particular statement.

22 Q. Let us follow this to its conclusion. If we look at

23 AC59.20, this is another version of the same statement

24 which we have obtained from the Sunday Times archive,

25 and again it is expressed as being a statement to you.


Page 156


1 We can see Mr Chapman was right in what he told

2 Lord Widgery, because the figure which appeared

3 previously as 3 to 4,000 has in fact been corrected in

4 manuscript to 3 to 400?

5 A. Yes, I see that.

6 Q. You still think, do you, in the light of this document

7 and Mr Chapman's evidence and the provenance from which

8 this document comes that this was not a statement taken

9 by you?

10 A. No, no.

11 Q. Do you remember speaking to Mr Chapman?

12 A. No. I probably did, but I do not recall it. I cannot

13 say.

14 Q. Is it possible it has simply faded from your memory with

15 the passage of time?

16 A. Quite, but I do know that this is not my work that has

17 my name on it, there has been a misunderstanding.

18 Q. May we come, please, to M43.2, and to look at

19 paragraph 8? You tell us there that you were able to

20 establish, through interviewing members of both wings of

21 the IRA in Derry at the time, that they were not present

22 when the shooting started:

23 "I had no reason to doubt that what they were saying

24 was true. All such interviews were however conducted on

25 a no names basis, otherwise the interviews would not


Page 157


1 have taken place."

2 Had you reported from Derry before Sunday,

3 30th January?

4 A. For some four or five years, and four or five years

5 afterwards.

6 Q. Should I assume that you had quite a large number of

7 contacts in this city?

8 A. On both sides of the political fence.

9 Q. How were you able to interview members of both wings of

10 the IRA about what had or had not happened on the

11 Sunday; how did you set about it?

12 A. By going to the homes of some of them that I had visited

13 before; by meeting them in pubs; the usual, you know,

14 rounds of my contacts in Derry.

15 Q. Can you recall how many, approximately, members of both

16 wings of the IRA you interviewed in connection with the

17 events of the day?

18 A. I cannot remember, it is too far back to remember

19 a figure like this. It would be in the range of 15 to

20 20, I would think, but I cannot say with certainty at

21 this distance.

22 Q. When you say that all such interviews were conducted on

23 a no names basis, otherwise the interviews would not

24 have taken place, do you mean to say by that that you

25 did not know the names of the people you interviewed, or


Page 158


1 that you knew them but agreed not to divulge them?

2 A. Half and half; I knew their names and addresses, I would

3 call in, knock on the door and go in for a cup of tea.

4 Some of the more -- different characters, no, I did not

5 know their names in some cases. It was too dangerous to

6 ask their names.

7 Q. But some you knew and some you did not?

8 A. Quite.

9 Q. Can you remember now the names of the persons whom you

10 knew at the time?

11 A. I know, but I decline to tell you.

12 Q. Is that because you regard them as sources?

13 A. Yes.

14 Q. We know because they have both told us that

15 Martin McGuinness was, if not the leader, in a senior

16 position in the Provisionals, and we know that

17 Reg Tester occupied a position with the Officials. And

18 we have heard from Messrs Pringle and Jacobson on the

19 Insight team that they interviewed both of them.

20 I do not think there is any great secret in relation

21 to that; did you interview either of those two?

22 A. No, I have seen Mr McGuinness on television many times

23 over the years and I have looked at him, I do not think

24 I ever met him. His face does not ring a bell to me.

25 Q. You would not have interviewed him in January 1972?


Page 159


1 A. I doubt it, because I have no memory of it. And the

2 other name you mentioned is foreign to me.

3 Q. Tester? Never heard of it?

4 A. No.

5 Q. I may come back to that in a moment. Did you interview

6 an equal number, as it were, approximately, of people in

7 each wing or did you interview more people in one wing,

8 more people in the other?

9 A. I certainly would have tried to interview as many as

10 possible in the time.

11 Q. Could we come, please, to paragraph 10? You describe in

12 that paragraph how you felt that the evidence you had

13 gathered conclusively proved that the Army were not

14 ambushed by the IRA that day and that the civilian

15 fatalities and casualties were shot when they were

16 trying to get away.

17 You say you did, however, find evidence of one IRA

18 shot having been fired at the Army because an Official

19 IRA man told you that he had fired a pistol shot at

20 soldiers stationed in a derelict building on the north

21 of William Street near the GPO, fired in response to the

22 Army shooting of Damien Donaghy.

23 You spoke to this man yourself, did you?

24 A. Yes.

25 Q. Not through an intermediary, you actually saw him?


Page 160


1 A. No.

2 Q. Did he describe where he was at the time when he fired

3 this shot?

4 A. I cannot recall, sir.

5 Q. What was described as a pistol shot, was it?

6 A. Definitely, yes.

7 Q. One only or more than one?

8 A. One, one shot from one pistol.

9 Q. You describe it in this paragraph as:

10 "A shot at soldiers stationed in a derelict building

11 on the northern side of William Street".

12 Could we have a look, please, at M71.26? In the

13 article that was filed what is written is this:

14 "One Official IRA man was, however, nearby in

15 a burned-out building opposite Richardson's factory. He

16 had been posted there as an observer and was armed with

17 a .38 pistol ... after Damien Donaghy was shot he says

18 he fired a single round at the soldiers on the GPO

19 sorting office roof."

20 There is a slight difference between what appears in

21 the article, which is a reference to shooting at

22 soldiers on the GPO sorting office roof and what appears

23 in paragraph 10 of your statement, which is shooting at

24 soldiers stationed in a derelict building on the

25 northern side of William Street near the GPO building.


Page 161


1 Are you able to explain what has happened?

2 A. No, I cannot. I -- with the passage of time I cannot

3 recall why there is a difference there.

4 Q. Should we assume that what was entered in the article is

5 more likely to be correct?

6 A. I think so.

7 Q. Apart from that episode, somebody firing a pistol

8 towards either the GPO sorting office roof or possibly

9 soldiers in a derelict building nearby, did you become

10 aware of any other incident in which fire had been

11 directed at the soldiers other than at the very end of

12 the whole business?

13 A. The only evidence I picked up was the one shot.

14 Q. Could we have a look, please, at M71.29? This is

15 towards the very end of the article that you wrote.

16 What was written was this:

17 "The IRA did, however, enter the picture after the

18 Army shooting ceased. IRA men on the march included the

19 head of the Bogside Provisional Organisation, name to

20 come, who was seen by a number of witnesses early on the

21 march."

22 Would you have written this portion of the article?

23 A. Well, the way we did it, the way we operated, every

24 evening I came back, typed-up my notes of each interview

25 on a separate sheet of paper and then we would go over


Page 162


1 them.

2 When we wrote this article on the Thursday after the

3 Sunday, Murray more or less dictated it. I typed --

4 I typed it -- this is not my typing, by the way,

5 somebody else has retyped it -- and fed into each other,

6 he would say "now Derek, you explain what happened at

7 the hospital" or something like that, so it was done,

8 this is Sunday Times and other policies, you know, hand

9 in hand.

10 Q. Would you have been the person who fed in the

11 information about the IRA?

12 A. I expect so, yes.

13 Q. As drafted, this indicates that the name of the head of

14 the Bogside Provisional Organisation is to come, but did

15 you discover what the correct name was?

16 A. I do not remember saying that or, I just do not recall.

17 Q. Whether you were responsible for this form of words, did

18 you learn or did you already know the identity of the

19 head of the Bogside Provisional Organisation who was one

20 of the people on the march?

21 A. Yes, I think I must have done, yes.

22 Q. Do you still know who it was?

23 A. No, I cannot remember, it is just 30 years -- you also

24 understand, sir, I have not kept up with the story,

25 I have lived the other side of the world. I have not


Page 163


1 written books on this, I have not been involved -- I was

2 not involved in Widgery, so my detachment is more than

3 30 years from this subject. I do my best, mind you.

4 Q. I do not suggest for a moment to the contrary. So we

5 are clear: you do not now know who was the head of the

6 Bogside Provisional Organisation on 30th January 1972,

7 who is referred to in this paragraph?

8 A. I knew, I knew then who was the IRA person, but whether

9 he was on the march or not, that has slipped me.

10 Q. Do you, as we speak now, know who was the head of the

11 Bogside Provisional Organisation on 30th January 1972?

12 A. Yes.

13 Q. Are you prepared to tell the Tribunal in private who

14 that was?

15 A. No.

16 Q. Because?

17 A. It was a valuable source and I would not wish to get

18 that person into trouble or destroy my reputation as an

19 investigative journalist.

20 LORD SAVILLE: Why did you put "name to come" in this

21 article we have on the screen?

22 A. I do not recall doing that, sir, I cannot -- it has gone

23 from my mind. I cannot answer your question, I am

24 sorry.

25 MR CLARKE: The article goes on to say:


Page 164


1 "The IRA Provisional group had a hasty conference

2 when the shooting began and, according to a young woman

3 who was present, decided to do nothing."

4 Do you know who the young woman was?

5 A. I do.

6 Q. You do?

7 A. Yes.

8 Q. And you know her name now, do you?

9 A. Yes.

10 Q. Are you prepared to tell us who she was?

11 A. I am not.

12 Q. It goes on to record the following:

13 "The Official group at the march, however, sent an

14 urgent call for gunmen and one 'active service unit'

15 arrived some minutes after the last Army shots were

16 fired", and you describe what that group consisted of.

17 This information, did you get it from members of the

18 group or from some other Official, or what exactly?

19 A. I cannot remember. I would tell you if I knew, but

20 I cannot remember.

21 Q. In the next paragraph what was written is this:

22 "One of those men fired one pistol shot at long

23 range towards the Army but does not claim he hit any

24 soldier."

25 Do you know now who that man was?


Page 165


1 A. No.

2 Q. "This shot was the last one fired in the engagement

3 ...".

4 So we can work out where we have got to: so far as

5 your present knowledge is concerned, you know who was

6 the head of the Bogside Provisional Organisation and who

7 is the young woman referred to in this paragraph; how

8 many others of the IRA do you know the names of now but

9 do not wish to tell us?

10 A. Probably eight or ten, and I did not necessarily know

11 their names, they went by Johnny or Sammie, or -- and

12 one was not indiscreet enough to ask their -- but if

13 they were having tea in the house, then you -- and

14 talked in a certain way, then you knew who you were

15 talking to, but --

16 Q. Are there some of those who you know the proper name of

17 rather than a mere Christian name?

18 A. No.

19 Q. The ones you know the proper name of are the head of the

20 Provisional group and the young woman who is referred

21 to?

22 A. Yes.

23 Q. The young woman who is referred to in this article, was

24 she herself a member of the IRA Provisional group?

25 A. I think almost certainly, yes.


Page 166


1 Q. You were present here this morning and you will remember

2 that I asked Murray Sayle about the references in the

3 Vincent Browne article to IRA activity, and pointed out

4 that they differ from the accounts that appear in the

5 article that the two of you wrote.

6 Were you familiar with any of the information in the

7 Vincent Browne article?

8 A. I never read the Vincent Browne article until lunchtime

9 today. I knew that there had been such an article;

10 I had never seen it, I had never read it. I read it

11 over lunch. What was your precise question in relation

12 to --

13 Q. My question is whether you were aware of any of the

14 information about what the IRA did, which is contained

15 in the Vincent Browne article, but is not contained in

16 the article that you and Murray Sayle wrote?

17 A. It looks to me as a journalist that he has written his

18 article with access to our article. Some of the

19 information seems to be ours; a great deal is his own

20 independent information.

21 Q. We have seen in your article two pieces of information

22 about what the IRA did: one is the man who fires at

23 soldiers on the GPO sorting office roof, and the other

24 is the arrival of an "active service unit" late in the

25 day and one man firing a pistol shot.


Page 167


1 Apart from what is contained in your article, is

2 there anything else you learnt about the activities of

3 either wing of the IRA which is not reflected in it?

4 A. No.

5 Q. Could we have a look, please, at M43.2, the bottom of

6 the page, paragraph 12? You describe in that paragraph

7 how the article was telephoned into the Sunday Times on

8 the Thursday. You flew back to London and found out

9 that it had not been printed, which made you angry.

10 Sorry, you found on the Sunday that it had not been

11 printed. You then flew back to London and went to see

12 Harold Evans the following Tuesday and you recount, over

13 the top of the page, how he told you that he was not

14 going to risk prison to print the article, and you say:

15 "This was a reference to the fact that he had been

16 warned by the Home Secretary to not print anything on

17 the subject as a Government Inquiry had been ordered to

18 be chaired by the Lord Chief Justice."

19 Is that something that he told you?

20 A. Well, we had learned on the Friday, the previous Friday,

21 that the article would not be printed because

22 Mr Maudling, the Home Secretary, had called a commission

23 of inquiry, so we knew at that point on the Friday.

24 Q. What you have put in this sentence is that he, that is

25 the editor, had been warned by the Home Secretary not to


Page 168


1 print anything on the subject as a government inquiry

2 had been ordered. I wanted to know how you knew that.

3 A. I believe Harold Evans told me, I do not know how else

4 I would have known.

5 Q. Is it possible that you may be somewhat mistaken on

6 that, in this sense: we have a statement from Harold

7 Evans in which he indicates -- I can show you the

8 paragraph if you would like -- that Lord Widgery himself

9 had made it clear that he would regard publication as

10 a serious handicap to the Inquiry and, indeed, as

11 a contempt of court?

12 A. Yes, I am obviously mistaken in that; Mr Evans is right

13 and I am wrong.

14 Q. Those are all the questions I want to ask. We may need

15 to revert in due course to the position in relation to

16 the information that we have been discussing a moment

17 ago. For the moment those are my questions.

18 LORD SAVILLE: Mr Glasgow, it is probably time to take

19 a break at this moment. We will come back at 3.10. If

20 you would like to take a break, Mr Humphry. As I said

21 to Mr Sayle, please do not discuss the evidence you are

22 giving until you have finished giving it.

23 (3.00 pm)

24 (A short break)

25 (3.20 pm)


Page 169


1 LORD SAVILLE: Mr Clarke, before we get on to the

2 questioning, I understand from an e-mail we have some

3 further information, at least about the Widgery model?

4 MR CLARKE: The information appears to be this: we

5 understand that the model which was used at the

6 Widgery Tribunal was made by the modelling section of

7 the Joint Air Reconnaissance Intelligence Centre (whose

8 acronym is JARIC); that modelling section was based at

9 RAF Wyton in Huntingdonshire, and we have been provided

10 with a copy of the modelling branch ledger which

11 indicates that the model was ordered by and delivered to

12 the headquarters of the 8th Infantry Brigade,

13 Londonderry, though where exactly it was physically

14 delivered is not, I think, apparent, and was completed

15 on 7th February 1972, and it appears from the ledger,

16 which we will circulate in due course, that only one

17 model was created and that both photographs and slides

18 were produced of the finished model and, apart from the

19 ledger, no additional documents appear to have survived,

20 so it is not presently possible and may never be

21 possible to identify who exactly requested the model to

22 be constructed or who at the modelling section actually

23 made it.

24 LORD SAVILLE: Thank you very much. Who is next for asking

25 questions of Mr Humphry?


Page 170


1 Questioned by MR GLASGOW

2 MR GLASGOW: Mr Humphry , as you know, my name is Glasgow

3 and I represent many of the soldiers.

4 Mr Sayle helped the Tribunal by telling them the

5 division of labour between you and he; I think you heard

6 him say that?

7 A. Yes.

8 Q. That is broadly right; you concentrated on the civilians

9 and he on the military?

10 A. Correct.

11 Q. You particularly interviewed as many of the wounded as

12 it was fair and reasonable for you to talk to in

13 Altnagelvin, I think?

14 A. As I recall.

15 Q. And you had help from Dr McClean, as you recall, telling

16 you about the nature of the injuries they had sustained?

17 A. Yes.

18 Q. Mr Sayle also told us he believed that you had, you as

19 a team had, some preliminary autopsy reports; do you

20 have any recollection of that?

21 A. Well, they were from Dr McClean. He was asked by a high

22 clergyman -- head of the Catholic Church in this area,

23 as I recall, to do autopsies independently, and Ray

24 McClean showed me the autopsy reports.

25 Q. You think he showed you the preliminary or draft


Page 171


1 reports, or the completed thing, can you remember?

2 A. Well, he had the papers in front of him and he described

3 it to me.

4 Q. He was able to tell you at least the nature of the

5 wounds?

6 A. Yes, the entrance and exit wounds, things like that.

7 Q. As you say in your statement, that he told you that some

8 people had been shot twice?

9 A. Yes.

10 Q. Some people, he believed, had been shot while crawling

11 away?

12 A. Yes, he said that.

13 Q. Did he give you any indication of the number of people

14 who had been shot in that way, either twice or while

15 crawling away?

16 A. I have forgotten. He did tell me, but I have forgotten.

17 Q. I entirely accept you were dependent on him.

18 If we go to M43.2, the second page of your

19 statement, the very top three lines: you are here coming

20 to the conclusion that you came to at a fairly early

21 stage, because of what the wounded had told you about

22 what they had been doing when they were shot, if you

23 remember; that appeared to you to be inconsistent with

24 the Army story that they had been shot effectively from

25 the front?


Page 172


1 A. Yes.

2 Q. The view --

3 A. The outstanding fact where the bullet --

4 Q. They had been shot while running away or --

5 A. That was the troubling feature.

6 Q. That was what troubled you?

7 A. Yes.

8 Q. You helpfully included at the end of the draft article

9 a very brief account of the interviews you had had with

10 the wounded at M43.11; a very brief account of a digest

11 of what it said they had been doing?

12 A. Yes.

13 Q. I think I am right in saying that all the people we have

14 on these two pages -- we will go over the page in just

15 a moment -- would have been in hospital; does it follow

16 your recollection is you would have spoken to most of

17 them?

18 A. I would think I did. It looks like my style and I would

19 have progressed -- digested it, then Murray and I would

20 marry it into the article.

21 Q. Let me go through because I wonder whether or not you

22 are right in your recollection in the statement that the

23 consistent story you had got either from them or

24 Dr McClean was they had been shot while running away?

25 A. Not all of them, sir.


Page 173


1 Q. Not all; can we look at the account you did have. You

2 say you formed the view that you did because of what

3 they told you they had been doing. If we look at the

4 previous page, M43.11, the first two, Joseph Friel. He

5 appears to have said he was just standing. He thought

6 it was safe, he does not particularly say any more than

7 that, does he; is that right, whereas Mr Campbell says

8 he was running away when he was hit in the back?

9 A. Yes.

10 Q. That is one?

11 A. That is one.

12 Q. Going over the page: Alex Nash -- we know that is

13 Mr Nash Senior -- he was on the barricade, of course,

14 and raised his arm and they shot him in the arm.

15 Michael Bridge ran away as fast as he could, lost

16 his head, and was then shouting "you murdering

17 bastards", as indeed he has told us, and waving his arms

18 at the soldiers.

19 Then Michael Bradley, who says, very honestly, that

20 he was throwing stones, his blood was up and he saw

21 a soldier aiming at him.

22 The sixth is Paddy O'Donnell: he says that he was

23 sheltering an old lady on the ground when shot in the

24 shoulder.

25 Patrick McDaid, as we know from your map number 7,


Page 174


1 says he saw a Saracen coming, ran in front of the flats,

2 they were shooting everybody and he felt a pain in his

3 shoulder, and Alana Burke, as we know, was hit by

4 a Saracen. I think you had also spoken to Mr Johnston,

5 the older of the men who was hit, do you remember, the

6 mature man and Mr Donaghy, the first two people?

7 A. I cannot put a name to any of them at this distance.

8 But you seem to be confusing -- you asked me about the

9 autopsy report and then we switch to these. The

10 autopsies reports show evidence of being shot in the

11 back or while down on the ground.

12 Q. If we go back to the question I was asking you about,

13 sir, I wanted you to see what you wrote at the time. If

14 we go back to M43.2, right at the top of the page, you

15 were concentrating on having mapped out where the

16 wounded were and what they were doing when they were

17 shot, and with one exception does actually appear, with

18 respect, that not one person told you he was running

19 away when he was shot?

20 A. You are correct.

21 Q. I am correct. Thank you. The only other matter

22 I wanted you to help the Tribunal with, if you could,

23 other than the identities of the people concerned is

24 that you said very candidly in your paragraph 10 on this

25 page, M43.2, that an Official IRA man had given you an


Page 175


1 account of shooting his pistol; do you remember?

2 A. Yes.

3 Q. That was, sir, the only account that any civilian gave

4 of shooting, or of seeing or of hearing any civilian

5 firing any shot?

6 A. Yes.

7 Q. So far as all the other -- we are told something like

8 200 -- accounts that you went through and however many

9 people it were you spoke to, not one single person gave

10 you an account of any other civilian shot being fired

11 until the shooting was effectively over from the Army

12 side?

13 A. Particularly no mention of machine-gun fire.

14 Q. Indeed, when you spoke to this Official IRA man who told

15 you what he had done, he was also telling you that that

16 was the only Official IRA shot which he knew?

17 A. I expect so, yes, I cannot recall the conversation

18 exactly.

19 Q. Did you understand -- can you cast your mind back now,

20 was he a responsible officer in the Officials, was he

21 a senior man?

22 A. I do not recall, sir.

23 Q. Did you or would you have asked him: are you the only

24 IRA man who has fired a shot on that day?

25 A. I expect I would, yes.


Page 176


1 Q. You would have done?

2 A. Yes.

3 Q. So far as you know he did not say "there were four or

4 five of us" or --

5 A. No, he did not and there were, I mean, I would not take

6 his word alone, I corroborated it with talking to other

7 people, other of his associates, and so forth.

8 Q. You did talk to others?

9 A. Yes.

10 Q. And nobody admitted at all?

11 A. No.

12 Q. Mr Clarke very typically fairly showed you the passage

13 in the article at M71.26, if we glance at that again,

14 and you very honestly, I am sure, said that this would

15 be more likely to be accurate if it was closer in your

16 mind at the time. We have the passage, just the top

17 half:

18 "One Official IRA man ..."

19 You understood from what he told you that he had

20 actually been posted with a firearm, he had been posted

21 in a position overlooking the march in William Street;

22 no question of him being summoned thereafter something

23 shocking had happened --

24 A. Not that I heard, although he disobeyed orders by taking

25 the gun.


Page 177


1 Q. The word you used in the article was "posted there"?

2 A. Yes, an observer, yes.

3 Q. Did you subsequently learn, sir, because you remained as

4 a reporter in the city for some years?

5 A. Yes, until 1978.

6 Q. Did you subsequently learn of the account that gradually

7 filtered out of IRA activity on the day?

8 A. No, I kept right away from the subject of Bloody Sunday,

9 I was -- following the row with the Sunday Times over

10 the sub judice matter, I never touched it again from

11 that day. I refused --

12 Q. Did any of the other people on the Sunday Times ever

13 tell you of the information that they had unearthed

14 about IRA activity?

15 A. Well, I remember reading the Insight article.

16 Q. Did you see, for example, we have -- one of the few

17 documents we have which originated at this time is AOIRA

18 1.1, which is one of Mr Barry's documents -- you knew

19 Mr Barry, sir?

20 A. Yes.

21 Q. AOIRA 1.1. Leaving it in its entirety for the moment,

22 does that ring any bells; did you ever see that account?

23 It has been redacted so as to take everybody's names

24 out, and you can see they are referred to as AOIRA 1 and

25 2?


Page 178


1 A. I only ever saw the printed version of the Insight

2 article, I never saw their notes or statement.

3 Q. I realise it would be unfair to ask you to help the

4 Tribunal with the detail of things you were not told

5 yourself, but did you not hear the story that quite

6 a large number of IRA men, a handful, had been handling

7 guns from a car in Glenfada Park?

8 A. I never --

9 Q. That never came to your ears?

10 A. I never.

11 Q. Did you ever learn that anybody other than the

12 officially acknowledged wounded and dead had been shot

13 on Bloody Sunday?

14 A. I never heard that.

15 Q. You remained in this city with contacts on both sides?

16 A. I went back to the homes of the leaders of the Provos --

17 Q. Did anybody tell you that an Official IRA man had been

18 shot on Bloody Sunday but that his identity --

19 A. I never heard that, sir.

20 Q. Never heard it?

21 A. No.

22 Q. Can you think of any reason why, with all your contacts

23 and all the people you knew and, in your own terms --

24 A. I would expect I would have heard of them --

25 Q. And went to have tea with them?


Page 179


1 A. Yes. You know, I am not a know-all, but I would expect

2 I would have picked it up following --

3 Q. You would have done?

4 A. Yes.

5 Q. It surprises you that that information was kept even

6 from you?

7 A. Yes.

8 Q. It does?

9 A. It should have drifted out in a conversation over the

10 next few years, it did not.

11 Q. Thank you very much, sir.

12 LORD SAVILLE: Mr Clarke, do you have any further

13 questions?

14 MR CLARKE: Just two. I have forgotten whether I asked

15 you: the Official who fired a pistol, did you know his

16 name?

17 A. I knew it at the time, I do not --

18 Q. Do you know it now?

19 A. I do not.

20 Q. We have had a lot of evidence in this Tribunal about

21 a man who has come to be named "Father Daly's gunman"

22 because he was seen by Father Daly shooting from a gable

23 wall at the end of Chamberlain Street in the direction

24 of the soldiers towards the entrance to the car park;

25 did you hear of that shooting in the weeks and years


Page 180


1 after you remained here in this city?

2 A. No, I did not.

3 Q. Those are all the questions I have.

4 LORD SAVILLE: Mr Humphry , there are two people who, as

5 I understand your evidence -- it is the Chairman again,

6 I should have said who I was.

7 The head of the Bogside Provisional IRA and a young

8 woman who you also were fairly clear was also a member

9 of the Provisional IRA. You say you know the names of

10 those people but you are not prepared to disclose them

11 to this Tribunal?

12 A. Correct.

13 Q. Am I right in thinking the reason for that is because

14 you regard them as confidential sources?

15 A. Yes.

16 Q. Is there any other reason?

17 A. No.

18 Q. I know you have been away for a very long time, but do

19 you have any idea of the whereabouts of those two

20 people?

21 A. No, I have not been in touch with them, no.

22 Q. You will appreciate that we as a Tribunal have a duty to

23 try and seek the truth, and indeed the whole truth,

24 about Bloody Sunday and it may, therefore, be necessary

25 to ask you to come back at some stage and to see whether


Page 181


1 it is necessary for us to require you to answer the

2 question as to the identity of those two people.

3 Were that to take place, of course you would be

4 entitled, at Government expense, to legal advice and

5 representation. I hope you understand that we may have

6 to ask you to come back to deal with that problem with

7 legal representation if, of course, you want it?

8 A. I hear you, sir.

9 Q. Meanwhile, thank you very much for the assistance you

10 have been able to give us so far.

11 Are there any changes to tomorrow's list?

12 MR CLARKE: Mr Taylor is, as I still understand, to be here.

13 LORD SAVILLE: We will start tomorrow at 9.30.

14 (3.40 pm)

15 (Proceedings adjourned until 9.30 am on

16 Tuesday, 11th June 2002)

17

18

19 MR MURRAY SAYLE, affirmed .................... 2

20 Questioned by MR CLARKE ...................... 2

21 Questioned by MR MANSFIELD ................... 96

22 Questioned by LORD GIFFORD ................... 99

23 Questioned by MR GLASGOW ..................... 105

24 Questioned by MR ELIAS ....................... 147

25 Questioned by MR CLARKE ...................... 149


Page 182


1 MR DEREK HUMPHRY, affirmed ................... 151

2 Questioned by MR CLARKE ...................... 151

3 Questioned by MR GLASGOW ..................... 171

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