Malice in Wonderland

The Politics Behind Labour’s National Constitutional

Committee
Dr Peter Gates, Rushcliffe CLP

The following document provides a detailed account of the circumstances that led to my two-
year exclusion from the Labour Party after 25 years, at a two-day hearing that was reminiscent
of the kangaroo courts of Stalin’s purges. I provide an extensive account of what goes on under
the banner of the “National Constitutional Committee” (NCC) of the Labour Party, so that
members can see the length to which some in the Party apparatus will go in order to eliminate
one single supporter of the leadership. Because of the complexity of the issues, I provide here
a short summary; fuller details are on the attached document.
This whole process has so far taken up over two years and probably thousands of pounds of
Party money. It has had a very negative effect on me and my family, as well as calling into
question my integrity and my reputation. Most seriously it has damaged the standing of the local
party – something I do suspect has been intentional.
I am shocked that my party is so lacking in due process and natural justice that it allows such a
farce to continue to take place beyond the reach of Party democracy and decency, beyond any
questioning and appeal, in secret, hidden from the membership. One only has to refer to the
Chakrabarti report on this and Jennie Formby`s stated intention to overhaul the whole process,
to realise something is rotten in the heart of the Party. As Shami Chakrabarti says in her report:
“complaints and disciplinary procedures are wanting. They lack sufficient
transparency, uniformity and expertise in delivery.”
I go on to describe how I was forced to employ a solicitor to defend myself against the NEC of
my own Party. Yet contrary to all concepts of natural justice neither I nor my solicitor were
allowed to properly question the so-called evidence – some of which had been fabricated. The
NCC refused to hear all my witnesses; they refused to allow female witnesses in relation to
issues directly affecting women; the hearing was cancelled twice because it was not convenient
for the Party, but the NCC insisted on the final date even though it meant me having to cancel
my family holiday in order to attend.
The whole process to which I was forced to succumb was so very clearly contrary to Chapter 6
of the Labour Party Rules, yet the NCC appear to be beyond reach. Specifically, the process took
place behind the back of and without the knowledge of the Constituency Labour Party (CLP) –
absolutely contrary to Clause II of Chapter 6. Whilst CLPs can refer cases directly to the NCC
that was not the case here. Only after two years I discovered that 4 people had colluded to
secretly make a complaint to an official in the Regional Office. What happened then has never
been explained. Presumably, the case must have been referred firstly to the National Executive
Committee (NEC) and a summary of evidence plus recommendation put before the NEC Disputes
Panel in January 2017, yet there had been no investigation, there had been no collection of
evidence contrary to Clause I, Paragraph 1B of Chapter 6 of the Party Rule Book.
In such case it is the NEC who is taking action against its own members, and the Presenter and
witnesses are therefore acting on behalf of the NEC. The reason that is important is that the NEC
are effectively saying “following a full investigation according to our procedural guidelines there
is a prima facia case for expulsion”. Yet, the NEC Disputes Panel were misled in January 2017,
by whom I have never been told. They have consistently refused to provide me with the result
of the non-existent “investigation”; they have consistently refused to collect evidence from me.
I provide some background first. I had been Secretary of Rushcliffe Constituency Labour Party
(CLP) from September 2015 until November 2015, and West Bridgford Branch Secretary from
September 2015 until my suspension in March 2016. In March 2016 I was invited to a meeting
of “Rushcliffe CLP” to discuss “the situation in Rushcliffe”. I was not told what this was a meeting
of, nor what it was for. I went along with several other members, only to be told that none of
the other members could stay. I suggested we all ought to be working together but that I was
Malice in Wonderland

prepared to leave. The meeting was abandoned for reasons that were unclear to me. A week
later all those who attended received letters of suspension.
For two years I remained suspended. The Party refused to say why or to provide any information.
I met with the Regional Director, who again refused to tell me why, and refused to provide me
with the minutes of our meeting. Over two years later, I received the “charges” against me. It
appeared that four people had colluded with the East Midlands Regional Office, to produce a
coordinated set of allegations over three days in January 2016. Every single allegation was false
which explains why they had to be kept secret from me, the CLP and Party members. Indeed,
many of the allegations were simply laughable. The Regional Office it appears had produced an
introduction which was totally false. The document was incomplete, internally inconsistent and
contained fabricated evidence. My legal representative, and many trades union officials told me
that it would not stand up to scrutiny in any tribunal. That matters not to the NCC.
I produced a 500-page response to the charges, providing detailed and forensic documentary
evidence rebutting every single allegation. I have no reason to believe the Panel ever read it,
for they took none of it into consideration. Eventually the NCC organised two hearings, at which
I had 15 witnesses from the officers of the CLP and beyond including four local Councillors and
an MP. The NCC cancelled both hearings at very short notice, then organised another without
consulting me on a weekend when I was to be away on a family holiday. I was told I had to
cancel my holiday or they would hold the hearing without me; I had no option but to cancel. The
NCC forced me to restrict my witnesses from 15 to 6 - a cynical strategy to weaken my case.
They also demanded that two men replace two women to talk about the exclusion of women.
They ignored the testimony of my witnesses – all local party officers or local councillors. The
NEC Presenter produced a fabricated email they claimed I sent – but which I had not. Much of
their case rested on this fabricated email, but they refused to divulge from where it had come.
The hearing was held in secret, took 20 hours over two days, no record was kept, and I was not
allowed to talk until the very end, when I was questioned. My solicitor was not allowed to cross-
examine the witnesses for the NEC in any sufficient detail and without being interrupted by the
Chair of the Panel, being told he had to accept their answers, in spite of us demonstrating they
were all lying. I was accused of being a misogynistic intimidating bully who discourages women
from involvement in the Party and who leads a cult of unthinking people to take over the Labour
Party. I was accused of:
● bullying and intimidation at meetings, though not one example could be produced;
● sending “excessive” emails, though only one email could be found;
● doctoring minutes, though all were approved as true and correct records;
● raiding the CLP funds, though not a penny was missing;
● organising attacks on the Labour Party, by organising a branch meeting on Austerity that
members had requested;
● refusing to advertise a social organised by a complainant, that I had advertised to all 800+
members;
● hiding in the kitchen making tea during branch meetings whilst suspended.
All of this comes from a fabricated Wonderland. I produced detailed evidence against these and
other fanciful and mendacious allegations. The NCC had no evidence against me because “the
Regional Office didn’t ask for any”. Of course they did not; there was none to be found. The NCC
found me guilty, excluded me from membership and required me to go on bullying training when
I was the victim of their bullying. I suspect that had this been held in Court, the Presenter and
witnesses would now be guilty of perverting the course of justice and contempt of court. In the
Wonderland of the NCC this is everyday practice. This has been a complete travesty of justice,
pure unadorned Malice in Wonderland. The Party should be ashamed of allowing this to go on
under the banner of democratic socialism.
Peter Gates
peter.gates3@btopenworld.com

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 Malice in Wonderland

Malice in Wonderland
The Politics Behind Labour’s National Constitutional
Committee
Dr Peter Gates, Rushcliffe CLP

Introduction
On 10th June 2018 I was “excluded from membership” of the Labour Party for two years after
being a member for 25 years. The events leading up to this are quite shocking and there are
people in the Party who should hang their heads in shame for bringing the Party into disrepute.
I am not one of them however; I am proud of what I have achieved, and proud of how I engage
with Party members. What you are about to read may shock you, parts of it may stretch
credibility, especially when you consider it all took place under the umbrella of a democratic
socialist party committed to social justice. I am publishing this account because people have a
right to know what goes on in their name, how their membership fees are spent, and how the
political changes taking place in the Labour Party are being resisted. Submitting myself to an
NCC hearing was, in retrospect, a mistake. The decision to exclude me appeared to have already
been made some time prior to the event.
I want to thank all the Labour Party members in Rushcliffe and West Bridgford in particular for
their unflinching support and encouragement over the past two and a half years. The letters,
emails and motions calling for my reinstatement have been really humbling. My exclusion has
had very negative repercussions for the Party. Some people have resigned, many others have
just stopped coming to meetings, because of the lack of any justice in a party they thought was
the party of social justice. It is tempting to conclude this might have been the purpose all along.

Background
This is a long and complicated story. As a teacher in disadvantaged communities for 15 years
from 1976, I consistently fought for equity. As a social researcher for over 30 years I have
believed in seeking the truth. As a member of the Labour Party for 25 years I have a deep-
seated passion for social justice. As a professional, a father and member of my community I
have valued integrity, honesty, transparency and collegiality. It was a complete revelation
therefore that my experience of the Labour Party’s “National Constitutional Committee”
represented a total negation of those seven basic socialist principles. I do have to say, I am
surprised that the Legal and Constitutional section of the Labour Party felt it necessary to spend
so much of the members’ fees on this matter. I am not a national figure; I have no political
ambitions other than the see Labour in government. Why I was targeted for what is so clearly a
political attack is irrational to say the very least. I will return to this at the end.
I need to explain a little of the background first. In May 2015 the Conservative Party won the
General Election. Like millions I was devastated and committed to re-engage with party politics
becoming very active in my local Labour Party. I quickly took on both CLP and Branch Secretary
positions because no one else would do it. I fully admit this was unwise and a little naïve given
my lack of experience in the Party. I was surprised to find some resentment from a very small
number of long-standing officers who spoke disparagingly of new members “who say a lot and
do nothing” and “those three pounders” – registered supporters, whom I thought were all
potential future Party activists. After repeated intimidation by the CLP Chair (one of the
complainants) I decided I would not continue in the post and resigned in November 2015, the
post being taken up by another of the complainants. I complained to the Regional Office over
this bullying and intimidation but was told to sort it out ourselves. I decided not to pursue it.
For 30 years I have been a senior academic, a professional with an international reputation for
research and teaching in the areas of equity and social justice. I have been contracted to
undertake social research in disadvantaged communities in Nottingham. I have been a Labour
Party member since 1994 when Tony Blair became leader. I believe I am well known and

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Malice in Wonderland

respected in my CLP and across Nottinghamshire. That is not the profile of a bullying misogynistic
cult leader determined to take over the Labour Party – which is what I was found “guilty” of.

The 7th March 2016 “Meeting”

In February 2016 I was invited out of the blue by an East Midlands Regional Official to “a meeting
of Rushcliffe CLP to discuss complaints and the situation in Rushcliffe” to be held at 8pm on 7th
March 2016. No one at the East Midlands Regional Office would tell me what this meeting was
for, who would be there, who had made these “complaints”, whom these “complaints” were
about, what “the situation in Rushcliffe” was, why we were discussing it and why I was invited.
No one amongst the eight CLP officers I asked had any idea either. Against my better judgement
I was persuaded to attend and turned up at 8pm along with several other members who were
about to take up positions as CLP General Committee delegates from their branch. I had made
it clear to the Regional Office that I would not take part in any discussion about “complaints” as
this would be highly improper and contrary to Labour Party rules. Indeed, it would be contrary
to any sense of propriety and justice I had ever encountered. I subsequently found out this was
a meeting of the CLP Executive Committee – a body so improperly constituted such that no one
outside of that small group even knew it existed.
It appears that between 7pm and 8pm the “Executive Committee” met, as noted, unbeknown to
the CLP General Committee, who had not even been told of the re-establishment of an Executive
Committee that had been dispensed with a year previously, let alone that it was meeting. No
agenda for the 8pm meeting was circulated in advance. When we arrived at the meeting, the
Chair of the East Midlands Regional Board was present, who I felt became very aggressive telling
everybody who had not been specifically invited to leave. Since all Party meetings in Rushcliffe
had always been open meetings, and we had been specifically encouraged to attend all meetings
by Branch and CLP Chairs, this seemed quite odd if not a little suspicious. I raised my hand to
speak. The full text of what I said can be found in the minutes of that meeting that were provided
to me by the NEC (I can provide copies of these minutes), and included:
“What is crucial for our CLP is that we move together, move forward, unite and work
together. The choice is whether to throw people out or do you try to be more united
and if those people didn’t stay, I would not stay.”
At that point the Chair of the East Midlands Regional Board appeared to get very agitated and
instructed the Chair of the CLP to close the meeting. Since he was there as a guest, this appeared
highly improper. It is also worth noting that this only lasted 14 minutes. On 11th March 2016,
along with all the other members who went, including two who merely waited outside the room,
I received notification of administrative suspension from the Labour Party but I was not informed
why I was suspended. In June 2016. I was invited to meet with Gordon Pattison, the then East
Midlands Regional Director. This was amicable, and there was no mention of any complaints, yet
he refused to tell me why I had been suspended. Notes of the meeting were taken on a laptop
by George Carr-Williamson. In spite of several requests, I have been refused access to those
notes.
For over two years a lie has been circulated by Party officials that I led an unruly mob who broke
up a meeting and refused to leave. The minutes of the meeting contained in the Charges Pack
however tell a very different story. The CLP Secretary at the time – one of the main complainants
– is currently under investigation by the CLP for what appears to be falsification of the minutes
of that meeting. The real question is, what is behind this incident and subsequent falsification?

The “Charges Pack”

I was unaware of why I was suspended until 16 months later, July 27th 2017 when the “Charges
Pack” arrived. The documentation was shockingly bad. It failed to set out in any detail the
allegations against me, and in formal legal proceedings would have been totally inadmissible. It
was incomplete, contained wholly inaccurate information, documents totally unrelated to me,
internally inconsistent documentation, assertions and unsubstantiated allegations. No claim or
allegation was supported by any evidence of wrongdoing whatsoever. It is quite obvious to
anyone reading it that the so called “Charges Pack” was all assertion and no evidence.

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 Malice in Wonderland

It thus became clear that the “complaints” referred to in the 7th March 2016 meeting were a
coordinated and secretive set of emails from four individuals to the East Midlands Regional Officer
over four days in January 2016. An analysis of these shows that just two people – a married
couple - were largely responsible for a substantial set of allegations. These allegations contain
not one statement of truth and it became clear why they had to be secreted away from the
membership; they were fanciful, laughable, ludicrous, mendacious, slanderous and all totally
unsubstantiated. That is not merely an assertion; I have demonstrated this in my Response. I
remain unclear what motivated these individuals to secretly construct these demonstrably false
allegations. I guess we will never really know, since most have now moved on and away.
What was clear however, was that these four individuals had been communicating with an official
in the East Midlands Regional Office – the same individual who invited me to the CLP Meeting.
Indeed, the coordination of these four emails, over successive days, appears to have been
organised, I presumed, by the Regional Official. What ought to have happened - if these
allegations had been genuine - was first to discuss with me, then raise with CLP Officers, then
the CLP General Committee, then the Regional Office. This is all described in the Labour Party
Bullying and Harassment Policy Statement and Procedural Guidelines, under “Informal
Procedure”. But also, this is what any reasonable person would do – to make contact with the
“alleged harasser”. However, “if informal action fails” there is an alternative procedure of
escalation. There was no such communication. On the contrary, the East Midlands Regional Office
and the individuals concerned went out of their way to keep all the allegations secret. I believe
the evidence points to this being due to the fact that the allegations were totally vexatious,
without any substance. Why people would do that, is open to conjecture. I believe this
commenced in October 2015, when they became consumed with anger over a vendetta against
another member which I became embroiled in due to my responsibilities as CLP Secretary at the
time. Quite why others become involved, I put down to changes happening within the Party, and
my support for the Leadership. This argument was supported by two long serving Party member
who acted as my witnesses at the hearing.
My legal representative and I were confident the charges would be rejected by the Party as they
would have been in any court or tribunal. Keen to clear my name and reputation however, I
produced a robust and detailed response (the Response) to the allegations in a document
stretching to almost 500 pages. In that Response I refuted every single allegation with very
detailed and indisputable documentary evidence. I provided this to the NCC; whether they ever
read it is questionable; it very clearly demonstrated the fabrication of the allegations.
In the Charges Pack, I am simultaneously described as hostile and criticised for being too
friendly; for sending excessive emails and for not replying to emails. I am accused of shoe-
horning members into positions and of excluding members. My reputation has been slandered
as “disgusting”, described as “disruptive”, and I was excluded for twenty-seven months at a time
when the Labour Party so desperately needed to campaign for more Labour Councillors, a Labour
PPC, a Remain vote and a Labour Government. The first “charge” made against me was:
Charge 1
In the period leading up to January 2017, you are alleged to have acted in a bullying, intimidating
and otherwise hostile manner towards a number of other members of the CLP including, but not
limited to excessive correspondence in breach of the Labour Party's Bullying & Harassment
policy. This behaviour continued after the expectations of the Party with regard to the conduct
of individual members were raised with you
I can state categorically that I have never bullied, harassed or intimidated anyone in my life. If
you know me at all, you will already know this. Indeed, no evidence has been provided in the
Charges Pack which demonstrates this – and with good reason - there is none. I invite anyone
to come to a Rushcliffe CLP or West Bridgford Branch meeting and ask members their opinion of
me. In my Response I provided extensive evidence of my considered, professional and polite
approach to members. That is the sort of person I am. This is not to say that the meeting on 7th
March 2016 was not intimidating; it was. I was certainly intimidated as I think were all those
officers who turned up hoping to observe a discussion on the development of Rushcliffe CLP -
particularly the women members. I think the setup of the 7th March 2016 event was unfortunate

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Malice in Wonderland

and short-sighted, even ham-fisted. Information has been concealed and surreptitious collusion
has gone on in the shadows. There was incompetent communication and deceit.
I have been informed by more than one person that someone – I presumed the East Midlands
Regional Director at the time – deceived the NEC Disputes Panel by presenting a false account
of events, which I had been given no opportunity to either know to or to rebut. I do not
understand how or why the NEC Disputes Panel would have approved an NCC hearing had they
known there had been no investigation, no evidence sought, and collusion between complainants
and Regional Officials. All of which is very improper and contrary to both the NEC and Labour
Party Rule Book Guidelines on undertaking an investigation.

The Evidence
As to the charge of “acting in a bullying, intimidating and otherwise hostile manner …including
excessive correspondence” one might expect to subsequently read: “for example…” followed by
a catalogue of incidents that have documentary evidence. One might expect minutes of
meetings. One would expect to see this “excessive correspondence” consisting of harassing and
intimidating emails. Now, I was intrigued because I knew this did not exist, so we asked for all
the evidence in order to build our case. We were told that the NCC was under no obligation to
provide documentary material – evidence in other words. The NCC consistently refused to
provide any evidence. I am very happy to provide relevant people in the Party with my full
Response and all documentation; I have absolutely nothing to hide.
During the hearing we asked various complainants to substantiate their allegations with proof or
at least some evidence. “Oh, I didn’t think we needed to bring anything along”, “I don’t have
that email any more”, and more shockingly from the NEC Presenter and member of the East
Midlands Regional Board, Richard Oliver: “The Regional Office never asked for evidence”. A very
telling comment which contradicts the NEC Notes on undertaking an investigation which I discuss
later.
Here then for transparency, is the full collection of evidence that was provided in the Charges
Pack supporting the allegation that I intimidate, harass and send excessive correspondence.

That is it; there is no more. The NEC Presenter considered this sufficient to “prove” intimidation
through excessive correspondence – and it is rather disturbing that the Panel agreed.

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 Malice in Wonderland

One particularly chilling event was the circulation by the NEC Presenter of a PDF of an email I
was supposed to have sent to another member. It was claimed that I wrote:
The anti new member is a solid position we have to counter - and it will go on .. it is
the defining issue in labour. which is why we have to keep pushing .Look we have
ousted XXXX and XXXX! We are getting people on GC etc. and making life difficult.
WE are ploughing on in only a few months.
But I never said anything of the sort. I keep all my emails! It also contains at least 6 amateurish
typographical and grammatical errors. We pointed out to the NCC and to the Labour Party
Solicitors that we believed we were being presented with fabricated evidence and requested the
original so that we could trace its provenance; they refused. The NCC and NEC Presenter would
also not inform us how they claim to have come into possession of a private email between two
individuals. Having made this point through my Solicitor, I was quite astonished when the
Presenter asked each of the 11 witnesses “whether it was acceptable to make life difficult for
people” reading out the email as if there was no dispute over its origin. Given how difficult the
NCC had made my life over the past two years, I suspect the irony was lost on them.
The Charge that “This behaviour continued after the expectations of the Party with regard to the
conduct of individual members were raised with you”, is a total fabrication. To be blunt, it is
a lie – but not the only one in the Charges Pack. The NEC Presenter would not, because he could
not, produce evidence to substantiate that.
Charge 2
On or around 7th March 2016, you are alleged to have attended a meeting arranged by the CLP
EC and regional board to resolve historical complaints and arranged for a number of uninvited
members to also attend who refused to leave the meeting which was subsequently abandoned.
This second charge, was quite easy to refute, as the minutes of the meeting had been included
in the Charges Pack. These minutes quite clearly contradict this allegation, as did the testimony
of three of our witnesses who were Rushcliffe CLP EC members and were in attendance at the
7th March meeting. The Panel were not interested; their minds had already been made up.
The third charge is pure Walter Mitty meets Joseph K.

Charge 3
Since the matter was last considered by the NEC Disputes Panel on the 17 th January 2017, you
are alleged to have acted in a bullying, intimidating and otherwise hostile manner towards a
number of other members of the CLP including, but not limited to excessive correspondence in
breach of the Labour Party's Bullying & Harassment policy.

Not one single piece of evidence was produced for this charge. One particular allegation was of
misogyny and discouraging women’s engagement in the Party – ironically made by a woman I
had specifically encouraged. Indeed, when the complainant who raised this was pressed to be
specific, she named one particular woman who I had allegedly discouraged. In fact, that person
was one of my witnesses – and she subsequently told the Panel that she found that allegation
laughable. However, the NCC panel believed the complainant, rather than the woman herself,
who is now CLP Secretary. This complainant at one point said “I don’t know why these people
follow Peter”. Not only is this a shockingly patronising thing to say about Party members implied
to be between 25-30 people, but suggests someone who has a fragile grasp on reality –
specifically that I am a cult leader lording over an unthinking band of automatons in order to
take over the Labour Party. That is pure fantasy, the stuff of science fiction.
This NEC witness claimed I was hiding in the kitchen making tea and coffee during Branch
meetings during my suspension; I will admit I did laugh at that point. Are we to believe I lurk
secretly in kitchens passing cups of tea through a hole in the wall? This was one of many such
laughable, demonstrably false, allegations that demeaned the whole disciplinary process and
brings the Party’s procedures into disrepute. It suggests a “Walter Mitty” approach to evidence.

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Malice in Wonderland

The Witnesses
The treatment of my witnesses was something I found deeply troubling. I initially had 20 witness
statements, and 15 witnesses had arranged to attend the first hearing - one even cut short a
family holiday in Spain to attend the then subsequently cancelled hearing. The NCC forced me,
contrary to the Rules of the Labour Party (Appendix 6, 5, B, iii.d), to arbitrarily restrict my
witnesses to 6. They even suggested that the two women (one of whom is the Woman’s Officer)
could be replaced by two of the male witnesses to talk about the exclusion of women, a pointed
irony. These two women have lodged a formal complaint over this gender discrimination with
the General Secretary, but never even received an acknowledgment, let alone an apology. The
NCC went out of their way to restrict the possibility of a fair hearing by denying 14 people the
opportunity to provide evidence. Again, this only makes sense if the NCC had already made up
their mind and were thus uninterested in evidence.

Procedural Irregularities
The whole process I was forced to succumb to was so very clearly contrary to Chapter 6 of the
Labour Party Rules, yet the NCC appear to be beyond reach. Specifically, the process took place
behind the back of and without the knowledge of the Constituency Labour Party (CLP) –
absolutely contrary to Clause II of Chapter 6. Whilst CLPs can refer cases directly to the NCC
that was not the case here. Only after two years I discovered that 4 people had colluded to
secretly make a complaint to an official in the Regional Office. What happened then has never
been explained. Presumably, the case must have been referred firstly to the National Executive
Committee (NEC) and a summary of evidence plus recommendation put before the NEC Disputes
Panel in January 2017, yet there had been no investigation, there had been no collection of
evidence contrary to Clause I, Paragraph 1B of Chapter 6 of the Party Rule Book.
In such case it is the NEC who is taking action against its own members, and the Presenter and
witnesses are therefore acting on behalf of the NEC. The reason that is important is that the NEC
are effectively saying “following a full investigation according to our procedural guidelines there
is a prima facia case for expulsion”. Yet, the NEC Disputes Panel were misled in January 2017,
by whom I have never been told. They have consistently refused to provide me with the result
of the “investigation”; they have consistently refused to collect evidence from me. The NEC
appears to have effectively acted contrary to the Party Rules.
The NEC have produced a document titled: “NEC Advice Note. How to carry out an investigation
into a breach of rule by a member”. Paragraph 2 of this document states:
Investigations may be carried out at many levels within the party. However,
allegations and complaints that a member is in breach of a Labour Party rule, which
may require disciplinary action, can only be progressed to the NCC by the NEC
(Labour Party Rules Chapter 6.I.) or a CLP (Chapter 6.II.). The rules for CLP
investigations, outlined in section 6.II. of the Rule Book must be strictly adhered to
at each stage.
Rushcliffe CLP were not consulted about an investigation or complaints. Instead four emails were
sent to an East Midlands Regional Officer over four days in January 2016.
The NEC Advice Note Paragraph 3, is clear:
If at the end of the investigation it is decided that there is a case for the respondent
to answer and charges are presented to the NCC, the respondent will at that stage
be entitled to see all of the evidence being submitted in support of the charges.
This was not done. The Investigator refused to tell me what the allegations were. I received
these 12 months after the interview, rather than “at that stage”.
The NEC Advice Note stipulates, in Paragraph 4:
When complainants or other witnesses to the alleged breach of rule are interviewed
a statement of their evidence should be written, agreed with and signed by them.
I was not asked to sign a statement and have been denied access to the notes of the meeting.
The NEC Advice Note in Paragraph 4 goes on to say:

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 Malice in Wonderland

Investigators should ask the respondent whether there are any particular members
that they would like the investigators to interview. The investigators may request
written statements in advance from such witnesses, to determine whether they have
relevant evidence to offer before arranging to interview them
That was never done; the NCC must have known this never happened but chose to ignore it.
The NEC Advice Note in paragraph 5 states:
Comprehensive notes should be taken of the interview with the respondent giving
details of the questions asked and the answers provided.
I have consistently been denied sight of these notes.
The NEC Advice Note adds in Paragraph 7:
Once it has been agreed by the CLP that charges should be presented against the
respondent to the NCC, the investigators will have to decide which of them is to be
the presenter of the case before the NCC. The presenter, with the help of the other
investigators, will prepare the written case to go before the NCC.
It is not clear how the NEC Presenter was selected. It was a previous Vice Chair of the CLP, but
this was not referred to nor approved by the CLP. This has now been changed to an individual –
Richard Oliver - who had absolutely nothing to do with the investigation.
The NEC Advice Note further adds in Paragraph 7:
It should be noted that in normal circumstances the NCC will give greater weight to
the evidence of a witness who appears before the panel at the hearing and has their
evidence tested by questioning.
Yet the NCC restricted attendance at the hearing for several of my key witnesses – at least nine
- who were not allowed to provide material evidence through questioning.
The Model Charges Sheet in the Advice Note includes in each example charge direct concrete
evidence of allegations in the form of emails. No such evidence has been included in my Charges
Pack.
The NEC Advice Note stipulates in Paragraph 3
The investigators have a duty to act fairly and without bias.
It is highly questionable whether it was either of these. Not only did the NCC breach data
protection regulations, and principles of natural justice, they even breached the NEC Guidelines.

Harassment
The NEC Advice Note stipulates: “The investigators have a duty to act fairly and without bias”.
Gordon Pattison did not, to my knowledge, carry out a fair or unbiased investigation, and
furthermore neither did he adhere to NEC advice on conducting that investigation. The NCC panel
insisted they had not had sight of Gordon Pattison’s report or the notes of my meeting with him,
difficult to believe though that is. Whilst being expect to attend a hearing and present my case,
I have been consistently denied sight of both the report and the notes.
Yet after all this, I get suspended, cut off from all Party communication by one of the
complainants as CLP Secretary, and denied any form of justice, or voice for 18 months. I was
publicly denigrated by the Regional Director at a Branch meeting and lies were told about my
behaviour. When eventually after persistent requests for 12 months I get to a possible hearing
I get treated as if I am the guilty party, rather than the victim. I get threatened that the NCC
will hear the case in my absence or refuse all my witnesses if I did not agree to dispense with
nine of them. All this when I have totally complied with all requests, and after the NCC cancelled
the first hearing at short notice when, as we indicated in an email to the NCC, my case had been
quite transparent for weeks before that. The second hearing date which I fully complied with
also got cancelled by the NCC.

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I informed the Secretary of the NCC that I felt bullied, intimidated and harassed by the NCC,
and pointeds out the Labour Party Bullying and Harassment Guidelines which provides a set of
procedures for such circumstances the first of which is:
Informal Procedure
Where instances of harassment or bullying occur the member or volunteer who has experienced
the harassment or bullying can, either on their own or with assistance from or provided by the
RDGS, pursue the following informal procedure;
(i) He/she may wish to speak or write to the alleged harasser and explain that his/her conduct
is unwelcome, offensive and interfering with activity. He/she should be polite but firm and advise
the person that his/her conduct is unacceptable, unwanted, and is also in breach of the
harassment policy, which the Party considers to be a serious matter.
(ii) A record of the discussion, and copies of any correspondence, should be kept by the member
or volunteer in the event that follow-up action becomes necessary.
I tried that and it failed. The NCC merely denied the suggestion. It appears that the Party Bullying
and Harassment Guidelines applies to everyone but members of the NCC.

I therefore felt I had no option but to resort to the next stage:

Alternative Procedure
If informal action fails, or if the member or volunteer feels unable themselves to take such action
as set out in Chapter 6 of the rule book, or if the harassment is of a very serious nature, members
or volunteers are advised to raise a complaint using this procedure which shall be treated as a
formal investigation under Chapter 6 Clause I of the rule book.
I will be considering now the submission of a formal complaint to the Party. This procedure is no
way to treat loyal party members and is not fit for purpose.

Subject Access Request

In order to try to find the reasons for my suspension, I submitted a Subject Access Request in
accordance with the Data Protection Act 1998 (“DPA 1998”) and followed procedures outlined
by the Office of the Information Commissioner. After forty-one days, I received forty-seven
pages — which can be found in my Response. What is especially worrying is that in the material
supplied by the Labour Party, there is no record of any communication with me, particularly over
issues I have fully documented in my Response. Specifically, there is no record of:
• communication with Regional Office over my organising a workshop in October 2015;
• communication over my resignation as a CLP Secretary on 16th November 2015;
• my complaint over the 16th November 2015 GC meeting at which I resigned;
• correspondence with Finbar Bowie over the 7 th March 2016 meeting;
• my meeting with Regional Director Gordon Pattison in June 2016.
The provided material contains no complaint made against me other than an obscure reference
to a complaint in one email dated 19th January 2016. All of this suggests a failure by the Labour
Party to comply with the provisions of the DPA 1998 by telling me they were providing all
information the Party held on me but removing material that contradicted the allegations made
against me. What is very worrying is it is as if the material had been carefully selected to give a
one-sided and negative impression of me by omitting significant material the Party holds on me
including that which documents the hostile treatment I received, and the advice I received in
response to my own complaint in November 2015, to deal with disputes locally. I have asked
the Party three times now to explain this and each time been ignored.

Confidentiality
The Panel Chair consistently claimed I had breached confidentiality by providing my witnesses
with extracts from the Charges Pack which I did in order for them to have the background
information necessary in order to prepare their witness statement and evidence – something
that is routine in legal cases. The Chair and NEC Presenter harassed each of our witnesses,

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alleging they had somehow acted contrary to Party rules in receiving and retaining copies of
parts of the Charges Pack. The Chair of the Panel repeatedly referred to these – erroneously –
as “confidential documents”. We were however, able to successfully demonstrate that there is
no Party Rule or Procedural Guidance that prevents a respondent in disciplinary proceedings
disclosing documentation that has been served on him/her by the NEC to third parties. The lack
of clarity on this point was demonstrable when the Panel Chair searched, in vain, through the
Labour Party Rule Book.
There was no mention of confidentiality in the Charges Pack nor in any other communication
with me. This disclosure by myself was only made to those I wished to call as witnesses with a
proviso that they keep them confidential – as I was aware there was sensitive information
contained within them. This was necessary for them to respond to the evidence advanced by the
NEC, and in many instances, allegations against them also. Indeed, at a Party Branch Meeting
in October 2016 the Regional Director, Gordon Pattison, had assured Party members that they
would be able to read the documentation relating to the charges against me. Even if these
documents should have been classed as confidential, as the Panel members seemed to believe,
by not informing me of any confidentiality condition, it follows that the Party appears to have
breached this confidentiality assurance allegedly given to the complainants. To then try to argue
it was my fault is rather disingenuous.

The Hearing
After more than two years of extensive correspondence over interminable delays by the Party, I
was eventually informed that a hearing would need to take place in December 2017. However,
after organising for 15 witnesses to support me (I had 20 supportive witness statements in my
Response, all CLP and Branch Officers including a Shadow Minister) the NCC cancelled the
hearing at short notice because of unavailability of one or two of the NEC witnesses. It was
rearranged for February but was yet again cancelled at short notice by the NCC because it was
alleged the Presenter of the NEC was ill. At this stage my Solicitor was in correspondence with
William Sturges (the Labour Party’s solicitors) over a Letter of Claim he had served on the Party
alleging extensive and serious procedural irregularities with the way the Party had dealt with
this case and, more seriously, falsification of evidence, indicating our intention to pursue the
matter through the civil courts – something I was reluctant to do; I still had some confidence in
the integrity of my Party. My solicitor advised the Secretary of the NCC that we would enter into
no further discussions on a hearing until the legal process was complete. Shortly after however,
we received with no consultation Notification of a Hearing from the NCC on a weekend I was due
to go on a family holiday with my partner and daughters. I was first asked to provide evidence
of my holiday, which I did, and was then told if I did not attend the hearing on that date, it would
proceed without me. I felt I had no choice but to disappoint my family and cancel our holiday. I
was not aware that the NEC presenter was asked for a doctor’s note for his alleged illness in
January which required the February hearing to be cancelled. In retrospect, I should have
realised at this point that I was facing a “stitch up”; that I was guilty regardless of the truth.
My solicitor (a long-standing member of the Labour Party) and I had been working together for
a long time challenging the whole process communicating with the administration at the NCC,
the Legal and Compliance Unit, the General Secretary (both Iain McNicol and Jennie Formby)
and the Party’s lawyers. All to no avail. The hearing eventually took place on the weekend of 9th
and 10th June -over 20 hours and the charges against me were upheld. We do not feel we lost
because of poor preparation or argument, and especially not because of a lack of evidence. My
preparation was thorough and extensive. My solicitor too spent many hours on preparing the
case on my behalf. He had been a practising litigation solicitor for over 30 years, a very
experienced County Court trial advocate and over the years has appeared before all sorts of
judicial and quasi-judicial bodies; social security tribunals, immigration courts, employment
tribunals, licensing panels, planning committees, homelessness panels, as well as the
Magistrates’ Court and the County Court. In all that time he advises me that he has not appeared
before any tribunal as incompetent, biased and disrespectful as the NCC Panel that met to hear
my case. It was a pretence of a tribunal, unable or unwilling to meet the rigours of rational fact-
finding expected after having read the written statements of evidence and heard the oral
evidence from the witnesses on both sides.

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Malice in Wonderland

The identity of the panel up until that point had been secret, but turned out to be Peter Mason,
Maggie Cosin and Dave Clements. It is my impression that the outcome of the hearing was a
forgone conclusion, the Panel having already made up their mind before hearing any evidence
or argument; they gave us the impression they were uninterested in any evidence.
Our expectations of getting a fair hearing were not high given our experiences of intimidation
and harassment by the NCC. Indeed, I had already indicated to the Secretary of the NCC that I
was evoking the first stage of the Party Guidelines on Bullying and Harassment against the NCC
itself. This was ignored.
As a Labour Party internal tribunal, Panel members obviously bring with them their own political
beliefs and attitudes. It is not clear to me how members of the Panel are selected, though it has
been suggested to me this is a political act. Any members of a judicial or quasi-judicial body
should leave their own political prejudices at the door of the tribunal, but that is a lot to expect.
The potential damage of political bias of individuals could be lessened if members of a tribunal
are capable of analysing evidence objectively, taking account of only relevant facts and rejecting
irrelevant evidence. This should have been a fact-finding exercise, with the Panel members
listening to the evidence, allowing that evidence to be challenged by cross examination,
assessing the credibility of the witnesses and noting the inconsistencies of individuals’ accounts
under questioning. That sort of discipline is a real skill, requiring intellectual honesty and critical
analysis. It is what judges in the legal system are trained to do and acquire through experience.
The greatest disappointment for me was, what I felt, was the very obvious lack of the required
skills amongst the Panel. It was as if those members suspended any critical faculties they might
have and failed to question or interrogate the fantastical propositions put forward by the NEC
and their witnesses. Much of the NEC evidence from their witnesses was just fantasy and we
were able to demonstrate this. Through questioning and referencing the documents that were
in the Charges Pack produced by the NEC and in my comprehensive Response Pack we felt we
had countered every single allegation all witnesses made. This was coupled with the very strong
evidence from our witnesses most of which contradicted that of the NEC. It seems this all counted
for nothing with the Panel, hence our belief that the outcome was a foregone conclusion. I was
criticised by the NEC presenter for claiming the allegations were “mendacious and vexations”. I
did so because, I had thoroughly demonstrated they were both mendacious and vexatious; As
Winston Churchill might say, they were “terminological inexactitudes”.
My feeling was that the behaviour and mannerism of the Chair, Peter Mason, was both hostile
and oppressive in preventing my solicitor from running lines of cross-examination of their
witnesses and was epitomised with his conduct towards the Rushcliffe CLP Chair, Cllr Keir
Chewings, when he gave evidence on my behalf. We understand Keir (who is a very well-
respected and long-standing Party member and local Councillor) is preparing a formal complaint
of intimidation against the Panel Chair. It is an easy tactic when someone is unable or unwilling
to do the hard work of analysing evidence to use their position of authority to cut off the
exploratory process of challenging that evidence. It is why we have a Bullying and Harassment
Policy in place. This was one of the more disappointing aspects of the whole episode.
Although I have a solicitor/client relationship with my legal representative, he was also a member
of the Labour Party and has been continually since 1981. He is currently a CLP Chair and a
former Leader of the Labour Group on a District Council. He is also a member of Unite having
joined the MSF in the mid-1990s. In his own words he states:
“We were the Party that enacted the Human Rights Act 1998 and if you want a shining
example of how a quasi-judicial body can operate in breach of the spirit and
intendment of that Act, look no further. The Panel’s conduct was unfair, unreasonable
and the punishment disproportionate in a way that I have never previously
experienced in my long and diverse professional career. The whole process, starting
with the suspension in March 2016 and culminating in the Panel Hearing flies in the
face of accepted common law principles of natural justice developed over centuries;
the right of the accused to know the charges against them; disclosure of relevant
documents whether they assist a party’s case or not; the right to a fair trial at a
public hearing within a reasonable time by an independent and impartial tribunal; the
presumption of innocence until proved guilty; the right to know the reasons for the

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tribunal’s decision to find the charges proved and the appropriateness of the
punishment which should be set out in a written judgment; the right to ask for a
review of the decision on proportionality or procedural grounds (a right recommended
in the Chakrabarti Report of June 2016).”
To all intents and purposes this was a secret hearing effectively held behind closed doors. No
one was allowed in save for the parties and their representatives. I was refused permission to
speak nor to ask questions of witnesses. Witnesses were only allowed in to give their evidence
and then they were expected to leave. We were told no records would be kept and no report
produced. I was refused permission to record the event. Perhaps more importantly in this context
is that there was no facility to document the proceedings, either by audio recording or anyone
to take a written note. Further it was noticeable that the Panel members made very few notes
when witnesses were giving evidence. There was also an attempt to claim the proceedings
needed to be treated as confidential. I would have been quite happy for the proceedings to be
streamed live on TV.
The hearing lasted 20 hours. There were 11 witnesses altogether as well as myself. That is a lot
of evidence to consider. If the decision-makers are not taking notes, and if there is no official
record, I cannot fathom how they can hope to be able to remember what witnesses actually said
when they come to weigh up the evidence at the end of the process. It renders the giving of oral
evidence almost pointless; no one can retain that sort of information with any accuracy over
that timescale. However most significantly, my legal representative was not permitted to cross-
examine the witnesses in any sufficient detail. He was repeatedly, and rather rudely and
unprofessionally told that once replies had been given to a question, this had to be accepted and
not questioned.
I detail below some of the specific issues on which I have been advised I have a legal case. This
is something I am reluctant to do having been a committed member of the Party for 25 years.
a) The imposition of a hearing when legal proceedings were ongoing is improper and an example
of harassment.
b) The unfairness of forcing the cancellation of a family holiday when the NEC witnesses were
permitted to cause a last-minute cancellation of previous hearings. It is at the very least
insensitive.
c) The Panel Chair consistently harassed my witnesses claiming I had breached confidentiality
by providing them with extracts from the Charges Pack. There is no Party Rule or Procedural
Guidance that prevents a respondent to disciplinary proceedings disclosing documentation
that has been served on him/her by the NEC to third parties. These documents were passed
to us without any instruction that they could not be disclosed to third parties.
d) The Party has refused to disclose documentation of the interview between myself and Gordon
Pattison the Regional Director in June 2016 to discuss the matter, in spite of repeated
requests. This seems a breach of both data protection and natural justice.
e) The Chair allowed the complainants to introduce new evidence at the hearing over the issue
of confidentiality but did not provide us with the same opportunity to introduce evidence to
demonstrate that a part of the evidence the NEC was depending on, had been forged.
f) Three witnesses, who were members of the Rushcliffe CLP Executive Committee, provided
clear evidence to the Panel that a claim made by one of the NEC witnesses was false,
specifically regarding evidence used in the suspension. This was ignored by the Panel.
g) The Chair restricting my solicitor’s questioning of the NEC witnesses so that it was not
possible to ascertain the veracity of responses – many of which had been rebutted in my
Response.
h) The questions from the Panel members were of a one-sided nature – with their questions
rarely interrogating the evidence of the NEC witnesses.
i) The use of apparently forged evidence in an email and the consistent refusal to provide us
with the provenance of the same. This document – an email allegedly sent by me which I
deny ever sending - was presented to each of the witnesses as fact.
j) The Panel appears to have ignored the extensive evidence we provided that NEC witnesses
were making false allegations.
k) The intimidation of one of our witnesses– Cllr Chewings - who was shouted at by the Panel
Chair when attempting to answer a question.

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Malice in Wonderland

l) The total lack of any documentary evidence supporting the NEC case, as we were told: “the
Regional Office didn't ask for it”.
m) The refusal to allow us to record the hearing or to have a notes taker – or indeed of any
record of the event.
n) The unjustified restriction on the number of our witnesses we were able to call, in direct
contravention of Labour Party Rule Book 2018, especially one witness who was subsequently
directly criticised by one of the NEC witnesses. This seriously weakened our case and was a
breach of Labour Party Rules.
o) The Chair placed considerable time restrictions on us and not on the NEC. They gave the
impression that our evidence was more of an incumbrance than an opportunity.
p) The Panel refused to provide any written reasons for their decision.
q) The Chakrabarti report, argued for fairness and proportionality in such cases. Neither of these
were apparent in this case.
r) Two of our witnesses, very long standing and highly respected local members – including the
Leader of the Labour Group on Rushcliffe Borough Council - presented an analysis of the case
within the context of changes taking place in the Party, and that such matters should not be
lodged at the feet of myself, whose behaviour, beyond the very small number of
complainants, has never been questioned.
Whilst there may be other matters that might surface during any future legal action, I believe
there are sufficient grounds here for questions to be asked. I will be submitting a further Subject
Access Request to obtain all information on this matter including all correspondence, notes made
by the panel and their annotated copies of the Charges Pack and Response document, including
all documentation which appears to have been removed from my first SAR; I am in
correspondence with the Information Commissioner over this. I wonder whether the Disputes
Panel (or indeed the NCC) were aware that I have already raised with the Chair of the Disputes
Panel and the Chair of the NEC serious irregularities in this process, namely:
• My SAR appears to be in breach of the Data Protection Act;
• The Charges Pack contains fabricated evidence and demonstrable untruths;
• Evidence has apparently been tampered with;
• Correspondence has been fabricated.
I believe this all is so serious that it should have been resolved before we considered whether
the case should proceed to a hearing. On the hearsay evidence of two complainants, who no
longer live in England, against a mountain of contrary evidence and witness statements, to
proceed with this case seemed ill-advised.
The sentence imposed by the NCC is exclusion from membership for two years and attendance
at bullying and harassment awareness training. The Party has already delayed the whole
disciplinary process for over two years. These delays are solely down to the Party and not at all
to me – I have already served a sentence of 27 months suspension from the Party. Had the
Party acted effectively in March 2016, I would now be back playing a full part in the Party. The
period of suspension appears not to have been taken into account when the Panel decided on
my exclusion for two years something very basic in the justice system.
Along with Rushcliffe CLP and West Bridgford BLP I am particularly concerned at the potential
fall-out from this case and the negative impact on morale and engagement of local members.
Both Rushcliffe CLP General Committee, and West Bridgford Branch members have
overwhelmingly passed a motion in support of me.
This is indeed a very bizarre set of events, in which I have been treated very badly and in
contravention of the Bullying and Harassment Policy and the Labour Party Rule Book.
Interminable delays have stretched what could have been resolved very easily, into over two
years of suspension, characterised by a repeated lack of response, failure to inform, and a refusal
to deal with Party members in a humane and comradely way.

So, Why Me?

The question though is – why me? Why go to such lengths, falsifying documentation, making
false allegations, holding a two-day hearing involving 19 people, tying-up so much of the Party

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resources? None of this was sufficiently investigated by the Party Investigator, so I will try to
draw some conclusions from what we do know. I will start with the following eleven questions:
• Why was a set of four coordinated allegations made in secret to the East Midlands
Regional Office, and kept secret from me and the CLP for over a year?
• Why did the East Midlands Regional Office never contact me to discuss these allegations
made in January but preferred to keep this secret for over a year?
• Why was the Labour Party procedure on complaints not followed?
• Why was an Executive Committee (EC) established in secret without the approval or
knowledge of the CLP General Committee?
• Why were members of the EC not informed of the purpose of the 7 th March 2016 meeting?
• Why would no one tell me what the meeting was about?
• Why did the Party produce a Charges Pack that was full of “terminological inexactitudes”?
• Why did the Chair of the Regional Board over-react at the 7th March 2016 meeting if the
meeting had been about resolving disagreements and “mediation”?
• Why did the Regional Director, Gordon Pattison not raise any complaints or allegations
with me when he “interviewed” me in June 2016?
• Why has the Party refused to produce any evidence to support any of the allegations?
• Why did the NCC restrict my witnesses contrary to the Party Rules?
It is difficult to ascertain whether this is merely a cock-up or a conspiracy; probably it is both.
The secrecy surrounding these eleven questions has to be a result of the falsity of the allegations
and lack of any substance; the allegations could not be made transparent or brought to the
attention of the CLP – simply because they would have been exposed as fanciful and mendacious.
Party members would know and begin to ask questions. Regional Officials appear to have acted
inappropriately in not following Party Rules, but also appear to me to have colluded with the
complainants in the process, misinformed the NEC Disputes Panel and denied me access to
documentation.
Secondly, what motivated these individuals, particularly the two individuals central to the
allegations (as no other complainant made any specific allegations) to feel they had to fabricate
allegations – and what led them to believe they would get away with it? I described earlier how
I believe I became a victim of a vendetta. For that is the only logical conclusion.
Finally, a larger question. Just who is in control of the “disciplinary” arm of the Labour Party that
seems to act for the few not the many?
The elephant in the room is Jeremy Corbyn. Like most of those suspended and expelled, I am
an enthusiastic supporter of Jeremy’s leadership of the Party. Not everybody else is. It is to the
detriment of our Party that some exercise this through mendacity rather than discussion.

Finally
Lessons have to be learned at all levels. I have learned the power of solidarity, through the
incredible support and encouragement from comrades in the Party, especially when I felt like
giving it all up. These are the people who make the Labour Party what it should be; an open,
transparent, comradely Party of democratic socialism, for the many, not the few. It should not
be a party of malicious and vexatious allegations, made in secret behind closed doors, and
intended to take the place of legitimate debate. I have certainly learned to my cost to the damage
that can be done to the Party by toxic and mendacious allegations. Indeed, this may have been
the intention all along. Mistakes have been made, but it is time to move on.
I strongly believe that I have neither been treated with respect nor dignity, as is required under
page 2 of the Labour Party Bullying and Harassment Policy (LPBHP). I have been assumed guilty
of allegations which were not declared to me and for which I was never asked for my response.
Information has been kept from me such that I was unable to defend myself against
unsubstantiated rumours contrary to the definitions of acceptable behaviour in LPBHP (page 3).
As such I felt intimidated and belittled. The documentation I received contains derogatory
remarks which are neither supported by any evidence and, in many cases, nor can they be. I
have been unjustifiably excluded from the CLP, and from all communication in spite of this not
being required by the Regional Party. It was only by my partner complaining to the Membership

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Malice in Wonderland

Secretary that she was having to be the go-between, passing on information to me that I had a
legitimate reason to receive, that this changed - first in the BLP but only more recently in the
CLP. There is no justification for this exclusion as is outlined on page 3 of LPBHP.
Furthermore, there are a considerable number of statements in the Charges Pack that twist what
I might have said or done and invent conversations and actions that never took place. At no
time have I been asked whether I actually did say or do those things, contrary to the definitions
of acceptable behaviour on page 3 of LPBHP.
In the CLP General Committee (GC) meeting on 16 th November 2015, a barbed comment was
made about a disability I have which makes writing difficult, and this is repeated in the Charges
Pack. This disability for which am receiving medical treatment, makes taking minutes impossible.
I have been ridiculed and belittled because of that and have not had a sensitive understanding
of the effect that might have on me. This behaviour which patronises and offends me as a result
of a physical disability, falls into the definition of harassment under page 4 of LPBHP.
Furthermore, on page 48 of the Charges Pack, there is a slanderous statement that I am “a
dishonest and highly manipulative individual”, which goes unchallenged especially as it is made
without any evidence. My recollection of my dealings with this individual is that I was always
professional and respectful. Yet, this person acted toward me in a thoroughly disrespectful and
uncomradely manner contrary to LPBHP.
It was only on 28th July 2017 - eighteen months after some of these allegations were made -
that I had any knowledge of any allegations or complaints against me. Save for one meeting
with the then Regional Director, there was, in those eighteen months, no personal contact with
me, no conversations with me and no instigation of any informal procedure about these issues
that could have resolved any issues early on. This appears to be contrary to the informal
procedures described in page 5 of the LPBHP.
In conclusion, I feel that, in various ways over the past two years, I have experienced what the
Labour Party Bullying and Harassment Policy defines as harassment, bullying, and exclusion. At
no time has anyone tried to ameliorate the situation or effectively intervene through any form
of mediation. Through my solicitor I raised this with the Secretary of the NCC, who ignored it. I
have also been discriminated against as a result of a physical disability, which may seem
relatively minor compared to what some colleagues have to bear, but which nevertheless impacts
on my daily life and my own self-image.
During this whole process, I have faced a level of personal abuse that is frankly little short of a
scandal. That no one thought it appropriate to talk to me at any time, face to face, about these
allegations at the time rather than send a coordinated set of secret emails, is highly suspicious.
It is not for me to impute motives for the gross misrepresentation of events in these documents.
There are procedures in the Party for undertaking such complaints. Here, I am solely responding
to allegations that are inexplicably and completely without foundation. It is for the relevant Party
structure to consider whether malicious and vexatious complaints have been made against me.
My task here is to set the record straight and to work on moving forwards, and to pull together
in order to advance the programme of the Labour Party rather than to cause division. It is not
my intention to be tendentious; rather, to respond in a positive and constructive manner. I very
much resent the fact that I was never presented with these matters nor asked for a response
for eighteen months. This is a total lack of natural justice that needs to be dealt with. It
fundamentally brings the Party into disrepute. Lord Denning when Master of the Rolls said:
If the right to be heard is to be a real right which is worth anything, it must carry
with it a right in the accused man to know the case which is made against him. He
must know what evidence has been given and what statements have been made
affecting him: and then he must be given a fair opportunity to correct or contradict
them … It follows, of course, that the judge or whoever has to adjudicate must not
hear evidence or receive representations from one side behind the back of the other.
The process followed was totally outside any form of principles of natural justice. I was not told
the case against me, I was not told what evidence and statements were given against me – for
two years! It is wholly unacceptable that the Compliance Unit of the Labour Party is able to

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suspend based on no investigation, no evidence, no communication with the accused and without
the prior knowledge of the accused. The reason why this had to happen was simply because
there was no case against me, but the Regional Officers had gone so far in colluding with a tiny
number of mendacious individuals they could not back down. This deceit and mendacity reached
all the way to the Disputes Panel and the National Constitutional Committee.
I was suspended for over two years, due totally to delays by the Party and some oversights by
Party officials, but by what appears to be a totally dysfunctional disputes process. I have my
suspicions that such delays are fully intentional. To then be excluded from membership when no
one has been able to document any wrongdoing by me has to be malicious and within the Party
definition of bullying and harassment. Had I been accused and found guilty of a criminal offence,
the two years “on remand” would have been taken into account. Ken Livingstone had his
“sentence” reduced by the length of time he had been suspended. No such sense of justice
seems to be apparent in the National Constitutional Committee. Just malice.
I will close with several pertinent extracts from the Chakrabarti Report:
It is also important that the procedures explain that those in respect of whom
allegations have been made are clearly informed of the allegation(s) made
against them, their factual basis and the identity of the complainant – unless
there are good reasons not to do so (e.g. to protect the identity of the complainant).
Particularly where a swift and informal resolution has not been possible, it is
important that the procedures lay down clear time-lines within which a
complaint will usually be dealt with. Whilst there are understandably competing
pressures on staff involved in the different stages of a disciplinary matter, would-be
complainants, complainants and those against whom complaints are made should
have the requisite degree of certainty in this respect.
Another matter which has been brought to my attention is the frequency of resort to
the power of interim suspension in cases where an allegation that a member has
acted in breach of the rules is before the General Secretary and/or his staff. Indeed,
an early lesson that any new General Counsel might offer his/her colleagues is on
the application of the vital legal principles of due process (or natural justice) and
proportionality. I hope that my earlier comments make clear that I do not subscribe
to the view that every allegation of misconduct within the Party is a factional mischief,
but nor do I feel that every investigation warrants immediate publicity (a punishment
in itself), nor administrative suspension (with the inevitable shame and opprobrium
that is likely to follow) - even if the allegation has attracted public controversy.
It is important to remember that the beginning of an investigation into alleged
misconduct is just that. The making of a complaint marks the beginning, not the end,
of a hopefully fair process that might end in a warning, admonishment, some further
sanction up to and including expulsion from the Party, or exoneration and no further
action whatsoever.
Once you understand these basic natural justice principles, you realise that
administrative suspension from the Labour Party need not be employed every (or
nearly every) time a complaint (however credible) is made against a member.
Civil courts do not grant interim injunctions, nor criminal courts issue arrest warrants
every time a complaint is made. The principle of proportionality requires some
consideration of any grave and summary sanction that will no doubt have a
detrimental effect on a person who is yet to be investigated, let alone heard.
To finish, I provide the letter I was sent by the NCC and let you decide for yourself whether this
is the way to treat a committed and loyal member of 25 years standing. It was the only piece of
correspondence I received from the Party that appeared promptly or without repeated requests.
It is pure and intended Malice in Wonderland. It is a travesty of any concept of justice and no
way to manage a democratic socialist party. It brings the Labour Party into disrepute.
I believe I have the moral right to be reinstated, indeed natural justice demands it.

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Malice in Wonderland

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