IKP's opening Statement to the IICSA Lambeth Council Module

Imran Khan QC delivers his opening statement to the Chair and Panel presiding over the Independent Inquiry into Child Sexual Abuse. This investigation considers the extent of any institutional failures to protect children in the care of Lambeth Council from sexual abuse and exploitation. Watch a live stream of our opening statement here.


A copy of the transcript of the hearing can be accessed here and you can read IKP's opening statement below.


Before I start I would like to use a moment of my allotted time to observe a short period of silence to remember and acknowledge the victims and survivors of sexual and racial abuse.


Chair, as you know, we act for a range of Core Participants who were resident, as children, at a number of Lambeth Council’s residential care homes and in foster families and in particular, the Melting Pot Foundation, Shirley Oaks and Angell Road.


We have carefully examined the disclosure that has been provided to us. From our analysis of the material, a number of key themes have emerged. Those themes, which we address, very briefly because of the limitation of time, in the course of this Opening Statement, start with the unimaginable horror of the abuse, its scale and, moreover, the appalling fact that everyone knew but turned a blind eye to what was going on, or they were complicit.


It is our clients’ expectation Chair that, finally, after so many years of suffering and not being believed, this Inquiry will recognise, acknowledge and accept what they went through, uncover why it happened and who was responsible. It is only if this occurs that they might get some semblance of justice and a measure of closure.


Those placed into care needed, above all, a loving and stable environment. Each of our clients speaks of the hope of refuge and safety, of a new beginning, that they felt on entering care. They even had new parents, Lambeth Council, that was supposed to look after them. Tragically, this sense of reprieve did not last long. The first theme we invite the Inquiry to consider is the sheer horror and pervasiveness of the abuse of children. The sexual abuse was as much abhorrent in its character as it was industrial in its scale. It infected the Council’s care homes for decades. Sexual abuse of a violent, debasing and torturous nature, comprising unremitting rape and sexual assault, was deep rooted and ubiquitous in the Council’s very many residential and foster care homes. It was sexual abuse reinforced by threat, intimidation and mental and physical attack. The abuse was often carried out in the sanctity of a child’s own bedroom, in front of other children, or in the bedroom of the abuser. It occurred off site, and by strangers and visitors. There was no place that was safe.


As our client LA-A353 notes: “Whenever these men felt like doing something sexual we were there. That was what we were there for. We were their targets and they abused us whenever they wanted.


Another of our client LA-A351 states: “During my time at the Melting Pot, I felt like I was a sex slave. It was not a safe house, it was a hell house.


These children were used and abused at will with no consequence because - as far as the authorities were concerned –- no real child was involved. Their presence on earth meant nothing. And if they meant nothing, nothing needed to be done for, or about, them.


We wish to recognise every child that suffered whilst in Lambeth’s care and the courage they have shown in coming forward and reliving the most traumatic moments of their life. If it were not for their actions, and the painstaking investigation by Raymond Stevenson and Lucia Hinton of Shirley Oaks Survivors Association, we would all not be here. We pay tribute to these individuals, which is richly deserved and should be publicly noted.


The second theme Chair is that of racism.


As you will be aware, after the Second World War, Lambeth became one of the centres of the black community in Britain. And disturbingly, in Lambeth’s care system, black children were disproportionately represented because there is no doubt that racism was woven into, and became an inextricable part of the culture and governance of Lambeth Council. And it matters not a jot whether Lambeth Council or any other institution now publicly announces that it stands in solidarity with the Black Lives Matter movement or that it is now no longer institutionally racist, because the test of whether you are not institutionally racist or that you support the Black Lives Matter movement comes not from what is said in vague platitudes in public relations announcements, but in your actions and conduct, such as properly compensating all black victims and survivors in Lambeth for the abuse and racism they suffered as children.


In the four walls of the care home, black children suffered a steady diet of racism. Our client LA-A354 states: “I was told by staff that I was ‘damaged goods’. I was called a mongrel, half-breed, half-pint, or maladjusted and an imbecile.. They used the ‘N’ word against me and called me ‘dolly mixture’.


We invite the inquiry to recognise the heavy bearing that the racism suffered by our clients had on their lives and their sense of identity. For children, it was especially damaging as the racism was delivered by the very people who were – for legal purposes - their parents. The experience of racism at any stage in a person’s life is traumatic and will have an impact on their development, however, the adverse effect on children and young people will be particularly devastating. When young black children are racially abused and exposed to a steady diet of differential treatment and attitudes, their growth and development is impaired physically, intellectually and socially. They are more likely to develop a poor sense of positive identity, competence, belonging and security. These feelings of powerlessness lead black children to believe that they will never be able to succeed in the traditional achievement paths of the majority of society. In short, black people who experience racism are less likely to reach the goals of their white counterparts and will be tormented by feelings of self-hate and self-blame believing that their failure is due to personal inadequacies rather than the wrongs of society.


The simple fact is Chair that discrimination on the basis of a person’s skin colour is not a single act of prejudice but is deeply impactful and affects every aspect of the individual’s life. This means that redress for those children who were racially abused in Lambeth’s care needs to be tailored accordingly. It is an injustice to the thousands of black children in care who endured racist abuse to view their trauma as an added extra. It is even more of an injustice that many black children, such as those in the Mleting Pot Foundation, do not even fall to be considered in any redress scheme at all.


We turn to our next, and third, theme. Chair, whilst those who have made witness statements have identified, as best they can, the individuals who were responsible for their abuse, it is also abundantly clear from the disclosure that the fact of their abuse was widely known at the time to those in authority, across the Council and the Metropolitan police. Those who were abused tried in vain to tell others who they hoped and believed might assist them. But they didn’t help.


The evidence is blindingly obvious in the innumerable reports and inquiries which were authored by, or came to the attention of, the Council and the police. The evidence was there in the repeated, unheeded, declarations of the children who were abused.


That evidence unmistakably determined that sexual abuse was rife and had to be confronted; each investigation, report and failure to act represented a missed opportunity to protect children and save lives.


Those responsible for sexual abuse were not, as was expected then, as it is now, held accountable. They were not dismissed or disciplined; they were not prosecuted. Extraordinarily, sexual abusers were reinstated or promoted. Shockingly, access to children was granted or extended.


The fact that the authorities knew of the abuse, and the fact they didn’t do anything about it, and the fact that the witness statements are so similar in the accounts that they give of the abuse, suggests that this was not the result of incompetence or individual neglect but that it was more likely than not corruption and collusion. We suggest that the evidence points to the fact that there were paedophiles who were known to those in authority, that they were able to act with impunity and who sought to safeguard themselves from exposure. We are concerned that the failures to act on what was happening was not accidental or an isolated act of oversight but that there may have been a common purpose at play which involved the deliberate sexual abuse of children and protection of the offenders.


Chair, the fourth theme is that you are likely to be met with excuses from the institutions involved in this Inquiry because there is a view, held by some when looking at events that took place decades ago, that we should look at what happened then in the light of the standards of those days, and not by the values of what is expected now. They may say that there was a dysfunctional administration, and that it was their fault that children were abandoned. That the Council and police today are very different to that of the 1970’s. The emphatic response to any of these suggestions must be: child abuse is child abuse, and it is inexcusable, whenever it happened. What is more, Lambeth Council and the state institutions did not operate according to some institutional blank slate in respect of child safeguarding. At the time, there were laws and systems to ensure supervision, training and the protection of children. What needed to be done was known. Why it was not, must be questioned and determined by this Inquiry.


Chair, in our submission, these arguments serve dual purposes: of expunging our clients’ experiences from historical memory and of disclaiming responsibility. Our client’s want a real apology and meaningful lasting change because the apologies given so far appear empty and heavily laden with excuses. We look forward to - indeed we specifically invite - every legal representative of the state institutions involved in this Inquiry, to unequivocally apologise in their Opening Statements for their client’s role - because each of them played some part - in the sexual abuse of our clients and their failure to protect them. Our clients also seek a commitment to provide them with the necessary and appropriate redress.


Chair, we will hear evidence over the next few weeks of a haunting, national scandal; of the most horrifying examples of systematic sexual abuse in the history of the United Kingdom.


It has also been a personal scandal that our clients know all too well – of a care system that tried its best to destroy them because they had the misfortune to become a child of Lambeth Council.


We must not lose sight of the fact that we have lost a generation of highly intelligent, hardworking and resilient individuals because of the abuse they suffered. We have heard accounts from our clients as to how, as children, they wanted to be pilots, nurses, doctors, teachers and lawyers but because of the abuse they suffered, those dreams were shattered. The state institutions were, collectively, responsible for that.


On leaving care, those abused were forced to face their future alone, which became blighted by prison, prostitution, and substance abuse. In short, these children were made to pay for the failures of those meant to protect them with their futures and, on occasions, their lives. It is a travesty that in return for their lifetime of loss all they can claim by way of financial compensation is about the same as what some professionals make in a year or so.


Chair, this Inquiry offers the only opportunity our clients have of publicly documenting their horrific past experience, and recording why it was allowed to happen. They also want those individuals and institutions to be publicly exposed and confronted, and responsibility assigned. But that is not all they want. Our clients are anxiously looking to this Inquiry to pass judgment on what Lambeth Council, and the other state institutions involved, have done and are now doing for them and all the other children who were abused. Commemorative rhetoric is not enough. Institutions that have been found guilty of discreditable conduct invariably say that they have learnt from the past and things have changed. Our clients want to establish whether these institutions have truly learnt from their failures and whether they have, in fact, as they have previously said and are now likely to say, put into place policies, practices, procedures and schemes which are fit for purpose. It appears to our clients, Chair, that when this Inquiry comes to consider the Terms of Reference for this module, the evidence is likely to show that the nature and extent of the abuse was horrific, that there were innumerable failings by Lambeth Council and other state institutions to protect children from that abuse, and there were countless reports and repeated recommendations which were not acted upon. If this is the case, it does seem that lessons have not been learnt and throws into doubt whether there is any sincerity or willingness for change. Chair, what we see from the state institutions is the appearance of change without any actual change. This Inquiry must put a stop to that if it is to give all those who suffered sexual and racial abuse a lasting legacy. That must be our common aim.

Thank you.

Imran Khan QC

Daniel Cooper

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