Public Office (Accountability) Bill — Written evidence submitted by Deanna Matthews (POAB19)

Public Office (Accountability) Bill (3rd December 2025)

Primary navigation

Home

Parliamentary business

MPs, Lords & offices

About Parliament

Get involved

Visiting

Education

House of Commons

House of Lords

What's on

Bills & legislation

Committees

Publications & records

Parliament TV

News

Topics

You are hereParliament home page
>
Parliamentary business
>
Publications and Records
>
Hansard
>
Commons Debates
>
Public Bill Committee Debates
>
Public Bill Committee

Session 2024-25

Public Office (Accountability) Bill

Written evidence submitted by Deanna Matthews (POAB19)

1.

I am writing in response to the Public Office (Accountability) Billcall for evidence.

2.

May answer to the opening question "Do you have relevant expertise and experience or a special interest in the Public Office (Accountability) Bill, which is currently passing through Parliament?", is simply, yes.

3.

I am the niece of Brian Christopher Matthews, who was unlawfully killed at Hillsborough on 15 April 1989. Who’s name, along with the other victims, survivors , bereaved and people of Liverpool as a whole was besmirched through actions of the police, the press and successive governments. Actions which have resulted in an ongoing battle against falsities which endure to this day.

4.

My "relevant expertise" is an entire life that has been lived in the shadow of organisational corruption, orchestrated by the State. Having been born in 1993, I have never known anything but a life where trust in public bodies is not to be given, because I have never been given a reason to be.

5.

My special interest, trying to use this last opportunity to actually put protections in place which mean that the ongoing failings that we are still facing to this day are not suffered 
when
 the next disaster strikes, which it will. I want to ensure that those using my uncle do actually leave a legacy worth having. Not just something in name and no substance – which is unfortunately what the current draft is – toothless and ultimately worthless.

6.

I have waited to submit my views, in the hope that some reassurance would have been provided by the Justice Ministers. Unfortunately none has been forthcoming, so I am left with no other resort than to formally record my concerns. And hope that this Committee will have the courage to do what sponsoring departments aren’t willing to do.

7.

I believe the current Bill to be weak in its drafting, with various loopholes which could be exploited by those seeking to avoid accountability for their wrongdoings, a sample of these being:

a.

Lack of statutory framework for the duty of candour

·

The bill is claimed to "create a statutory "duty of candour and assistance" (a legal obligation to act transparently) for public authorities and officials when engaging with inquiries, inquests and similar investigations"

·

On the face of it this appears promising, but when assessing the detail, it’s clear that any attempt to implement it would be impossible.

·

Buy not having a statutory framework guiding what this statutory duty should contain creates a huge issue legally and practically.

·

The responsibility for deciding content, as drafted under clause 9(1), sits with individual organisations deciding what they believe that duty to be. This could result in employees of the same organisation being held to completely different standards depending on the branch they’re in.

·

This hardly seems just or right when the ultimate outcome could be losing your liberty.

·

If it’s going to be enforceable there needs to be a set standard in legislation for consistency and clarity. A basic principle of good law.

·

I note there is a reference in clause 10 that guidance will be available, but no mention that it will be made using force of law or have any statutory binding. Instead we will be plunged back to Covid scenarios where "the spirit" is what should be aimed for, but ultimately can be disregarded and ignored without any consequences. How can that be right?

·

Also, why at clause 9(10)(c) is there the potential for exclusion of provisions which the authority feels "the disclosure of…would be contrary to the public interest". Surely it is in the public interest to know exactly what standard they can expect of public bodies they may interact with, and what standards they are being bound to. What could possibly need to be withheld? Quite frankly, history has shown that public bodies think the truth is not in the public interest and withheld that, and this bill allows that to continue.

b.

Bar for inquiries is too high

·

Whilst I acknowledge that what was the Taylor Report would now come into scope of this Bill, and potentially avoid a similar situation as to what happened to us in Salford, with the cover up trial being thrown out on a technicality, it doesn’t remove the potential for the same type of thing to happen in practice.

·

As we saw with the Grenfell and Manchester Arena aftermath, there was a push from the establishment, including the public bodies, to outright push back on having an Inquest. And even a desire to have a non-statutory inquiry – always looking for the dilution to avoid culpability and responsibility when their known wrongdoing is found out.

·

The same is still possible under this bill as drafted. I.e. when the next Hillsborough does happen, any inquiry that’s set up will be one that doesn’t come into scope of this bill being triggered. And therefore not having the duty of candour bite.

·

Instead, if the bill is claiming the duty extends to all actions by all persons who are considered in scope of it, when performing duties associated with their public role, then it should equally apply to all inquiries into that act, be they low level internal investigations or a statutory inquiry.

·

It shouldn’t be the case that you only need to be honest and truthful when most serious degree of harm has been caused which require a Ministerial investigation. It’s not a deterrent or a safeguard.

·

And so the definition of "UK inquiry" in clause 18(2) needs to be broadened.

c.

Exemptions

·

I am extremely perplexed by the exemption in clause 11(4)(b) – that nothing in the section around "misleading the public" applies where it has been done "for the purposes of journalism". And the explanatory note is as equally as unhelpful. So I ask simply what does this mean?

·

My reading is that, under the bill as drafted, the police officer who provided The S*n with the material to produce "The Truth", would be exempted from action on the basis that the spreading of lies and creating decades of devastation and irreparable harm, was done for the purposes of journalism.

·

Also I do not understand why there is a sweeping exemption at clause 3(7)(a) and (6)(2)which disapplies the duty of candour to any public authority or public official where it would cause a breach of "any prohibition or restriction imposed by or under an enactment or a rule of law". On my reading this would exempt almost all of the Civil Service, Armed Forces, Ministers etc etc, as they all have to sign an undertaking under the National Secrets Act. Again another gaping loophole.

·

And I presume this would also be the case where there is a (super)injunction, similar to what we have recently seen with the Afghan Relocation debacle, and a method of suppression which I note the government didn't rule out using again.

·

It feels like overreach, or using a sledgehammer on a nut to have such a sweeping provision. And I appreciate there are instances where national security may be at play, but there are established processes already in place, which work well, to provide special measures for this. So why is the same not afforded to the truth?

d.

Part 4 -

Participation of persons at inquiries and investigations

·

I would also argue that Part 4 does not go far enough. In my experience the participation of impacted persons should go beyond just inquiries and investigations and allow for people to be granted interested person status at subsequent/resulting criminal trials, where the wrong doing established through the inquiries/investigations is to be prosecuted.

·

As I can attest to through my own treatment in both Preston and Salford, families get completely shut out by the CPS at this stage and at no point are they sure that the best interests of those at the heart of the case are being represented.

·

The CPS are "independent" and act on instructions of the State. There is no confidence in families who, through failures of that same State, find themselves in inquests, inquiries, criminal courts. With State appointed advocated prosecuting their own boss. It works as well as having the Police investigate the police. And for the avoidance of doubt, I’m saying it doesn’t work.

·

A system should be created where families/interested persons can be involved. It exists in civil to be added as a 3rd party, and should be the same for criminal trials, at least in these distinct circumstances.

e.

Punishment not sever enough

·

This bill is advertised as creating "two new statutory offences to replace the common law offence of misconduct in public office". The reality is, it’s removing an offence that could have actually been a deterrent and had a sentence which reflected the grave harm actions could have, and has been replaces with two weak offences whose sentences are below that which was recommended by the Law Commission. Why?

·

How is this a deterrent? How is it just?

f.

Devolution issues

·

I note at clause 11(4)(a) the provisions of that part do not extend to matters where competence has been devolved. Is there any intention to have equivalent measures in place across the UK, by the Devolved Administrations bringing these in? Or is this yet another divergence in standards the bill is encouraging?

g.

Lack of definitions

·

Throughout there are references to terms but no definitions or explanations setting out what they actually mean. I would provide a list of examples, but I have already breached the guidance of evidence being short. But I am sure during a line by line assessment you’ll spot one soon enough.

·

This needs correcting so the full impact of the provisions can be known from the outset and not become the

8. As I say, I could provide you with my own line by line analysis, but I shan’t bore you and try to do your job for you. But hopefully this is an insight as to why in its current form I cannot provide my support for this bill. I cannot in good faith say that it will deliver the outcome that we need to prevent similar harms being done to others as have been done to us.

9. I cannot justify my uncle being used yet again if this is all Parliament says he is worth. Because he deserves better. We all do.

10. Many thanks for providing this opportunity and for reading my response.

Deanna Matthews

November 2025

Prepared 3rd December 2025

Footer links

A-Z index

Glossary

Contact us

Freedom of Information

Jobs

Using this website

Copyright

Privacy notice
Cookie policy
Cookie Manager