[5] Lawyers representing the group have acted in major public inquiries including into the Hillsborough, Grenfell Tower and Manchester Arena disasters.

for topics to address in the inquiry have included: the scientific advice given to ministers, the death rate in the UK, the test, track and trace system, communication of infection control measures and implementation of lockdown measures, travel restrictions, attempts to redress the disproportionate impact of COVID-19 on ethnic minorities, as well as a review of the functioning of the National Health Service and its staff during the pandemic.

[21] He said the date was chosen because of a possible winter surge in infections, but that preparatory work on the terms of reference would start earlier, as would choosing a chair.

Issues covered included the UK's preparedness, the use of lockdowns and other non-pharmaceutical interventions, pandemic management in hospitals and care homes, equipment procurement, and the financial support made available.

[36] The Cabinet Office launched legal action, a judicial review, on 1 June over their concerns that handing over all the material would compromise ministers' and other individuals' right to privacy.

[38] Former prime minister David Cameron told the inquiry that his government had focussed too much on preparations for an influenza pandemic, and that there were failures to act on findings from the 2016 Exercise Alice simulation; he denied that austerity measures had weakened the health service.

[41] Former Scottish First Minister Nicola Sturgeon told the inquiry that Scotland did not have a "set plan" to deal with a pandemic such as Covid 19.

[45] In WhatsApp messages sent to senior adviser Lee Cain, Cummings said that then prime minister Boris Johnson believed that the pandemic would "be like the swine flu".

[46] In other messages in reference to deputy cabinet secretary Helen MacNamara, he called her propriety and ethics "bullshit" and said that it was "designed to waste huge amounts of his time".

[49] Heneghan said that the inquiry should consider the side effects of the "Protect the NHS", messaging that Heneghan believes reduced care for diseases other than covid; whether the confinement of care-home residents was a good policy, which he believes was both ineffective and had immense human costs; the reliability of test-and-trace; and the accuracy and use of epidemiological modelling in decision making.

[49] Michael Simmons, writing in The Spectator, said that the Inquiry was asking the wrong questions and had learned nothing about the problems of the use of modelling which he thought had led to inaccuracies in decision making.

He says that the models failed to consider the effects of behaviour change, citing historic work by Neil Ferguson, and evidence given Ben Warner.

[49] Simmons said that the Inquiry should answer whether lockdowns worked definitively, citing evidence given by Simon Stevens that expressed the same view.