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Imran Khan QC delivers IKP’s Opening Statement to the Grenfell Tower Fire Inquiry

1. Sir, our client’s lives were dramatically, irrevocably and irreparably damaged in the aftermath of the Grenfell Tower fire. They lost friends, family members, and their homes in the course of one devastating night. Except they were not lost. It is perhaps more appropriate to say that they were taken. Friends, family members and homes were taken from our clients. Taken as a result of the callous acts of those who were duty bound to assist them: the Royal Borough of Kensington and Chelsea (‘RBKC’) and the Kensington and Chelsea Tenant Management Organisation (‘TMO’). Let us be clear, those that were taken were not nameless individuals; they had names, and they had lives which were prematurely cut short.

2. Following this trauma and loss caused by those responsible for the Grenfell Tower fire, our clients wanted, indeed needed and deserved, a response from the RBKC that was level-headed, organised and compassionate. It is apparent from the evidence disclosed to the Inquiry, that RBKC’s response to the Grenfell Tower fire was wholly inadequate and fell way short of what our client’s required. In our client’s eyes, this characterisation is a gross understatement of what happened. In the aftermath of the devastation of the Grenfell Tower fire, our clients were not treated with the dignity and respect they deserved. In our Submission, we set out what RBKC failed to do in the aftermath of the Grenfell Tower fire, and the impact these failures had on our clients.

London Local Authority Gold

3. By way of background, the Civil Contingencies Act 2004 (‘CCA’) provides the legislative framework for emergency preparedness in England and Wales. There are a number of bodies responsible for emergency planning, including London Local Authority Gold. In the event of serious emergencies in London, Local Authorities are able to work closely together, and to do this they have agreed to pool decision-making in the form of London Local Authority Gold (‘LLAG’). In her witness statement to the Inquiry, Ms Barbara Brownlee of Westminster City Council (‘WCC’) explained that:

“LLAG brings together a co-ordinated approach to resilience across the 32 boroughs and the City of London. On a voluntary basis, the Chief Executives of each London Borough take part in a ‘Gold’ rota, providing collective resilience across London. There is a LLAG resolution which vests the ‘Gold’ Chief Executive with the necessary powers to act on behalf of all London local authorities”.

4. This shows that a system existed to deal with emergencies such as the Grenfell Tower fire.

5. At the time of the fire, Mr John Barradell, the Chief Executive of the City of London Council, was on the ‘Gold’ rota and eventually led the response to the Grenfell Tower fire.

6. Importantly, in the event of an emergency situation, it is initially the responsibility of the Local Authority in which the incident happens, such as RBKC, to provide the response to an emergency. It is only possible for the Local Authority response to be upgraded to a regional response with support from LLAG with the consent of the Local Authority. In short, LLAG cannot become involved in an emergency response without an invite. As Ms Brownlee says in her witness statement:

“Once involved, LLAG implement regional plans and strategies and have greater experience, capability and access to resources.”

7. As Mr Friedman Queen’s Counsel has made plain, it is a clear flaw that LLAG cannot intervene without a request being made. We invite the Inquiry to explore the necessary changes that need to be made to the LLAG protocol in the light of this response to the fire. We further concur with Mr Friedman that Central Government should have been aware that RBKC would not have been able to cope in the first instance.

8. In addition, there is also a formal Mutual Aid agreement between the thirty two London Boroughs and the City of London to enable coordination between the Boroughs in the event of small and large-scale emergencies. In the event of a small-scale incident, the Mutual Aid could have consisted of neighbouring boroughs assisting with arrangements or staffing for rest centres or equipment. In the event of a large-scale emergency, such as the Grenfell Tower fire, LLAG is able to arrange funding and staffing to support the Mutual Aid process.

The Aftermath: RBKC’s failure to ask for help

9. In the immediate aftermath of the Grenfell Tower fire, the former Chief Executive of RBKC, Mr Nicholas Holgate, was offered additional assistance in the form of invoking the formal Mutual Aid agreement between the London Local Authorities. In his witness statement to the Inquiry, Mr David Kerry, the Contingency Planning Manager of RBKC:

“raised the possibility of invoking Mutual Aid at the meeting with Nicholas Holgate on the morning of 14 June 2017.

10. He went on to state:

Whether to formally invoke the Pan-London Local Authority Mutual Aid Agreement was a strategic decision that could only be made by the Chief Executive”.

11. It beggars belief that Mr Holgate did not invoke the Pan-London Local Authority Mutual Aid Agreement immediately, rather than, as we shall see, waiting until days after the fire.

12. In his witness statement, Mr Kerry did not address the response he received from Mr Holgate. Mr Stuart Priestly, the Chief Community Safety Officer at the time of the fire, created a log of events on 14 June 2017, in which Mr Holgate’s response to the suggestion was recorded. In the log, Mr Priestly referred to the fact that Mr Kerry raised the possibility of invoking formal Mutual Aid agreements available via LLAG as early as 6.30am on 14 June 2017. Mr Holgate’s response to the suggestion provides some insight into his attitude in the aftermath of the fire. His response to the suggestion of mutual aid was to say:

“That looks like we can’t cope”. The conversation on mutual aid at that point ceased”.

13. Mr Holgate, it would seem, was too concerned with RBKC’s appearance to invoke formal Mutual Aid agreements via LLAG on the morning of 14 June 2017. While Mr Kerry stated in his statement to the Inquiry that Mr Holgate was “making calls with London Authority Gold very early on”, RBKC did not activate formal Mutual Aid arrangements until 15 June 2017.

14. It seems that RBKC’s reluctance to accept help was primarily due to the concern that RBKC would have appeared that it “can’t cope”. Shamefully, Mr Holgate, prioritised RBKC’s appearance and reputation over the welfare of our clients. By way of example, we note an email sent at 12.25am 16 June 2017 by Mr Charlie Parker of WCC to Councillor Nickie Aiken, also of WCC. Mr Parker stated, in respect of the issue of permanent housing following the fire, that:

“I have offered NH [Nicholas Holgate] total WCC [Westminster City Council] support however, I don’t believe he quite understands the magnitude of the problem […] “there is apparently a sense anecdotally from RBKC members that they are reluctant to take housing assistance from Labour Councils? Again Nickie you might want to check that out/follow it up.”

15. Why on earth was Mr Holgate apparently so reluctant and unable to accept help and why did he fail to appreciate the scale of the disaster? It is especially troubling that there was a “sense” that RBKC were reluctant to take housing assistance from Labour Councils. Was this, in fact, the case and if so, what impact did this have on the response? If it was indeed the case that RBKC were “reluctant to take housing assistance from Labour Councils”, it would suggest that petty party politics took priority over the lives of our clients.

16. Concerns were also expressed within Central Government about Mr Holgate’s reluctance to accept help in the days after the fire. In her witness statement to the Inquiry, Dr Jo Farrar, the Director General for Local Government and Public Services at the Ministry of Housing, Communities and Local Government (‘MHCLG’) at the time of the fire, stated:“I do not understand why it [RBKC] did not draw on the resources and expertise of central government, other London councils and third parties”. On the afternoon of the 15 June 2017, Dame Melanie Dawes, the former Permanent Secretary at MHCLG discussed RBKC’s response with Dr Farrar. In her witness statement to the Inquiry, she explained that, while the Department’s view at the time was:

“in responding to the housing challenge, RBKC was capable and had significant expertise and experience […], [there were] concerns that were being raised about the wider response and the apparent reluctance of RBKC to accept help did not give me confidence that they would be able to manage the relief effort as it moved into the recovery stage”.

17. Only one day after the fire, Dame Dawes was already troubled that RBKC were not drawing on the resources, expertise and experience of others to the extent that was required in the aftermath of the fire. We ask again – given the scale of the disaster, why was this allowed to happen? Was it purely because Mr Holgate did not want RBKC to appear as if it could not “cope” with the disaster, or was it something else? Mr Holgate has a lot to answer for.

18. At 12.30pm on 15 June 2017, Dr Farrar spoke to Mr Holgate for the first time and offered him further assistance, particularly in relation to housing. A ‘readout’ of Dr Farrar’s call with Mr Holgate, which was recorded in an internal email sent later that day, stated: “Jo offered to help with anything needed […] There is plenty of support from DCLG and others”. In her witness statement, Dr Farrar referred to the above telephone call with Mr Holgate. She stated that, during the telephone call at 12.30pm on 15 June:

“I twice raised the issue of whether RBKC needed support, but he was firm in his assurances that no further support was needed. Given the scale of the disaster and the number of people bereaved and made homeless, it seemed unlikely – based on my own experience- that RBKC did not need substantial support, but Nicholas Holgate’s clear position was that RBKC had plenty of support”.

19. Despite Mr Holgate’s clearly unjustifiable position that RBKC had “plenty of support”, merely a day later, LLAG was activated and took control of the response to the fire due to RBKC’s inability to cope with the situation at hand. At 2pm on 16 June 2017, LLAG operations were formally activated. In his witness statement to the Inquiry, Mr Barradell stated that he conducted an immediate review and assessment of RBKC’s response. Mr Barradell formed the Grenfell Fire Response Team (‘GFRT’) under his leadership, which drew on resources from the other London Boroughs. In his statement to the Inquiry, Mr Kerry explained that:

“It got to the stage where the Council did not have the capacity to deal with the aftermath and a London LA-wide response was required. I believe that none of the 33 LAs could have coped with the scale of the Grenfell Tower and response on their own”.

20. Mr Kerry was undoubtedly right when he says that it is unlikely that any local authority could have coped with a disaster on the scale of the Grenfell Tower fire. Mr Kerry knew it, it is obvious that was the case, and so why is it that Mr Holgate did not? Why did RBKC not draw on resources to the extent that was required? Why did RBKC miss a crucial opportunity to activate LLAG in the immediate aftermath of the fire? Such conduct and failure undoubtedly compounded the distress and trauma that the bereaved, survivors and relatives were experiencing.

21. Ms Sue Redmond, who was the Interim Executive Director for Adult Social Care and Public Health at Hammersmith and Fulham, RBKC and WCC expressed concern that LLAG had not been activated in the first instance. Ms Redmond was invited to a Gold meeting on the afternoon of 16 June, which was chaired by Mr John Baradell and other London Local Authority Chief Executives. Ms Redmond stated that:

“I did ask why London Gold did not help from day one and was told they had to be invited. I thought in these circumstances this protocol needed to be changed”.

22. We invite the Inquiry to explore the necessary changes that need to be made to the LLAG protocol in the light of this response to the Grenfell Tower fire.

23. Mr Charlie Parker of Westminster City Council summarised the situation following LLAG’s takeover of the response on 16 June 2017 in an email to Councillor Nickie Aiken. He stated:

“there have been a number of developments this evening regarding the Grenfell Tower disaster […] after numerous discussions and attempts to help from London Government and WCC, Nicholas has now agreed that London Resilience needs to be stood up and start to take a bigger role in matters as RBKC are not able or equipped to deal/manage the situation. Tomorrow there will be an opportunity for John Barradell to go into RBKC as chair of LAAP to start to create some rigour into their handling”.

24. We also note a particularly damning email sent by Councillor Aiken to Mr Alex Aiken Executive Director for Government Communication, at 8.26am on 16 June 2017. Cllr Aiken stated, in reference to RBKC:

“Only took them two days to decide they can’t cope. We told them first thing on Wednesday that they wouldn’t be able to cope”.

25. And so, despite Mr Holgate’s apparent concern that RBKC would “look like we can’t cope”, it was abundantly clear, even at the time, that they could not.

26. Dr Farrar’s statement noted the improvement in the organisation of the response following LLAG’s takeover. Dr Farrar stated that, following the handover of the response to LLAG on 16 June 2017:

“I was confident that the relief effort was being brought under proper control under John Barradell’s leadership, and that it was now a matter of allowing the structure and measures he had put in place to take effect. This was quickly borne out.”

26. An email sent at 8.28pm on 16 June 2017 by Dame Dawes to Mr Mark Sedwill of the Cabinet Office, gives an insight into what was then happening:

“[…] John Barradell took over at lunch time as gold command for the whole recovery [...] He has clearly made very significant progress this afternoon and I think we can now be assured that the situation is coming under proper control.


5. There is significant capability from other boroughs within teams, and this is growing. This includes proper housing management people.


7. They are moving the humanitarian crisis centre and turning it into something much more professional-looking rather than the “pillow and blanket” approach of the sports centre. Housing officers have been at the centre this evening (for the first time) working with those still remaining there.

8. But in essence this is now a pan-London effort – with all the depth of capability that implies.”

27. Mr Sedwill responded that:

“John [Barradell’s] sense of grip was palpable so I hope that the situation on the ground will now gain and demonstrate some momentum”

28. Ms Emma Strain of the Greater London Authority stated that by Saturday 17 June 2017:

“I recall that things started to feel more organised and under control, following the implementation of pan-London resilience arrangements. […]”.

29. Given the improvement in the response following LLAG, how effective would the response to the fire have been had LLAG arrangements been activated by RBKC in the first few moments after the fire, rather than days after the fire? LLAG had no choice but to pick up the pieces of RBKC’s shambolic response to the fire, and this could have potentially been avoided had a pan-London LLAG response been invoked earlier. The Mayor of London, no less, has condemned RBKC’s response, stating:

“It was obvious to me very early on that RBKC did not have an adequate grip on the response and could not cope on their own. Without a doubt this had a very serious detrimental impact on the humanitarian response in the first days after the fire, because RBKC’s failure to invoke the mutual aid resolution meant that no-one else could step in and take charge of the situation either. This was extremely frustrating because I could see that pan-London support and coordination was urgently needed. To this day I still don’t really understand why RBKC were apparently so unwilling to ask for help when they clearly needed it and it was available to them”.

30. We note that forty-eight hours after the fire, the Mayor of London and others wrote to Downing Street asking for the introduction of Commissioners to be appointed to ensure that bereaved, survivors and residents were properly supported and the emergency response properly governed. The Mayor’s letter was never answered and his request never granted. Given the clearly chaotic response in the aftermath of the fire, we ask why this was the case.

31. The Mayor’s sentiments have been echoed by Dame Melanie Dawes:

“RBKC’s response, and in particular, their seeming lack of willingness to accept help, created problems which affected not just the immediate aftermath, but also the Gold Command recovery efforts for some time to come”.

32. This is particularly apparent in the observations of the disorganised and chaotic way in which RBKC ran the Westway Centre, which was set up as a rest centre in the immediate aftermath of the fire. We turn to this now.

The response on the ground: the Westway Centre

33. At 9am on 16 June 2017, Dr Farrar visited the Westway Centre, which was at that time still being run by RBKC. She recalled that:

“the visit itself was not reassuring. I had first-hand knowledge of what a well-managed and properly coordinated relief effort should look like. To me this did not appear to be either.”

34. Dr Farrar criticised RBKC’s poor organisation of the centre, she commented that there was:

“a notable absence of senior RBKC officers visible to me at the rest centre; in my experience I would have expected them to be there.”

35. It was also apparent to Dr Farrar that RBKC did not have an adequate relief plan in place at the Centre. In her witness statement to the Inquiry, Dr Farrar commented that it was concerning that an RBKC councillor admitted to her that:

“RBKC were very lucky that the manager of the Westway Centre had allowed it to be used as a rest centre”, as it suggested that RBKC did not have a “tried-and-tested relief plan in place”. Dr Farrar also noted that:

“In addition, there was a lack of suitable blow-up beds, with apparently people sleeping on the floor with no mattresses. I would expect any council to have made arrangements in advance for appropriate equipment to be provided in the event of emergency, but that did not appear to have been the case.”

36. The previous day the Mayor of London visited the Westway Centre, he noted that:

“I heard frustration from volunteers at the centre about things not being properly coordinated”.

37. Despite this, RBKC were again desperate to appear in control of the response. In his witness statement, the Mayor observed that:

“[…] on my way to the site before, I had a telephone conversation with the then leader of RBKC, Councillor Nicholas Paget-Brown. He had given me the impression that the response was all “under control”. It was clear from what I saw on 15 June that this was not the case.”

38. After activation of LLAG on 16 June 2017, Mrs Rupinder Hardy of the London Borough of Ealing took control of the Westway Centre. At approximately 7am on 17 June 2017, Mrs Hardy attended the Westway Centre. Mrs Hardy produced a document entitled ‘Personal Briefing Document, Grenfell Tower Fire Response Team in July 2017, in which she documented her initial assessment of RBKC’s management of the Westway Centre. Her assessment of RBKC’s management of the rest centre was highly critical. She said this:

“I advised that things were chaotic and there was a high degree of mistrust and an abject lack of delivery [sic] to outcomes needed as well as service desks to meet those outcomes”.

39. She noted that her immediate impression was that “there was a lack of leadership and command authority” from RBKC. Mrs Hardy noted that, in particular, the handover from RBKC’s shift to the London Borough of Ealing’s shift was: “minimal in detail with more questions raised than answers given”. She also noted that: “all documentation was paper based in terms of residents/staff/volunteers on site”.

40. Mrs Hardy further criticised RBKC’s disordered handling of the Westway Centre:

“There was a clear lack of “grip” at the Rest Centre, it seemed disorganised and chaotic, with lots of people in it, but I could not tell who the staff were from residents. There did not seem to be a clear command structure that I could identify, or anyone with overall decision-making responsibility.”

41. She also condemned the state of the Westway Centre, stating that it was:

“a mess, it did not appear to be a safe, welcoming, or an inviting place and it failed to encourage residents to come in […] It was a chaotic situation. Confusion and a lack of any joined up working to meet the urgent and pressing needs of those who presented at the Rest Centre was rife.”

42. What our clients needed following the loss of their loved ones was safe, secure and stable surroundings. Instead, what they got was a complete and utter “mess”.

43. Indeed, RBKC’s evidently chaotic response in the immediate aftermath of the Grenfell Tower was not only detrimental to those tasked with taking over the response following the activation of LLAG, it was severely damaging to our clients. In her assessment, Mrs Hardy also noted that RBKC’s process for distributing emergency cash to survivors was disorganised and done without checks:

“Whilst emergency money was being handed out, this was also being documented on paper without a proper process to manage funds and who received it. Again, no checking process”.

44. Mr Michael Adamson, the Chief Executive of the British Red Cross, stated in his witness statement to the Inquiry that he offered assistance to Mr Holgate in respect of the distribution of emergency cash. On 15 June 2017, Mr Adamson spoke to Mr Holgate on the phone and made a number of offers of assistance, including:

“assistance with cash distribution in the form of small amounts of money to be given to those who had been affected to buy food and personal items”.

45. According to Mr Adamson, Mr Holgate:

“did not wish to take up most of the BRC’s offers of additional assistance. He told me that RBKC had the cash distribution process covered.”

46. Mr Adamson was clear that this was not the case. In fact, Mr Adamson

“subsequently became aware that, although the council had attempted to distribute cash, the manner in which it had done so was haphazard, and had been conducted by a number of different officials and different actors. This made it impossible to track who received what”.

47. By failing to manage the cash distribution process, our clients failed to receive financial assistance when they needed it most. By way of example, our client Mr Abdulwahab Abdulhamid, who was a resident of Flat 14 of Grenfell Tower, stated that, having lost his home and his community, he was forced to fight for financial assistance from RBKC. He said this:

“It was very difficult to get financial assistance from the Council, as I did not know who was responsible for controlling the distribution of funds […] it was an uphill battle for my brother-in-law and I to obtain funds from RBKC. I did not understand why it was such a struggle to obtain funds from the Council and why, as a resident and survivor, I received no help or information”.

48. No survivor of such a tragedy had to go through what Mr Abdulhamid did.

Handling of information

49. RBKC’s chaotic approach extended to its handling of information related to the residents of Grenfell Tower. RBKC’s initial method of registering survivors of the Grenfell Tower fire at the Westway Centre, as well as the other rest centres at Rugby Portobello and the Clement James Centre, was utterly disorganised and moved at a snail’s pace. As Mrs Hardy noted on her arrival:

“I did not even have a potential list of Grenfell Tower Residents, which would have enabled me and the officers working with me to understand the extent of the situation and the names of individuals/families who were seeking support, who was missing and which of the services we could ask for assistance”.

50. At 11am on 14 June 2017, staff members from RBKC and the TMO attended a meeting of the Kensington and Chelsea Grenfell Tower Fire Gold Group at Kensington Town Hall. The TMO was asked to assist RBKC in running the rest centres. The action sheet produced by Mr Holgate after the meeting noted that, in the immediate aftermath of the fire:

“Two rest centres have been set up- Rugby Portobello Trust (RPT) and the Clement James Centre. […] No idea on the number of people in the rest centres but they are very busy”.

51. The action sheet also stated that “although there were no Council officers present at the rest Centres for a long time, they are now there.” At the 3pm meeting of the same group, the action sheet stated that: “30 households have been identified in the Clement James Centre. No numbers from the other rest centres”.

52. Ms Clare Richards, CEO of the Clement James Centre (‘CJC’) commented on the TMO’s shambolic approach to the registration of potential survivors of the fire in her statement. Ms Richards stated that, during their time at St Clement’s Church:

“TMO staff wrote information on scraps of paper and they didn’t appear to have a system. They didn’t seem to be capturing an accurate record of everyone that was arriving at the site and who they were looking for”.

53. Ms Richards further stated that the staff at the CJC offered the use of their laptops to aid the registration process, but that this was turned down. Ms Richards stated that as a result of this, “I asked the staff on the entrance to the church to note down who was entering and direct them to the TMO table and to make a note of anyone who was leaving.” Ms Richards explained that:

“a member of TMO staff saw that we were doing this and asked for our records, as she said that they should be collecting this information and that it would be confusing if there was more than one list. We handed over the records. As the TMO continued to record their information on scraps of paper with no clear system (with the potential to miss residents), I continued to offer the assistance of our staff team and laptops. They repeatedly turned down this offer. They didn’t return our records from that morning”.

54. Mr Kiran Singh of the TMO attended St Clements Church rest centre to assist his KCTMO colleague, Ms Teresa Brown. He stated that initially, “Teresa Brown was passing information about persons safe, missing and unknown on handwritten sheets to the Fire Brigade”.

55. The lack of a centralised and accurate information held by RBKC and KCTMO and the haphazard approach to the collection and handling of information had a lasting and damaging impact on the response to the Grenfell Tower fire. Mr Adamson of the British Red Cross, noted that:

“the problems with the registration process initially instigated by RBKC had a very negative impact on the ability of responders to identify who needed help, what the needs of those individuals were, and the ability to track down how those needs were addressed”.

56. He further stated that this early failure meant that GFRT did not “inherit a complete picture of those who had been affected from RBKC” upon taking over the response on 16 June 2017. Further to this, Mr Adamson stated that the lack of adequate registration hindered the effectiveness of the distribution of charitable donations to survivors of the fire. In particular, Mr Adamson stated that the issues with the registration process:

“made it difficult for the [London Emergencies Trust] to ascertain to whom the funds that had been raised from the BRC fundraising appeal ought to be distributed in a situation where many of those who had been affected were in dire need of immediate financial assistance”.

57. Ms Richards of CJC recalled:

“that we found it challenging to get a definitive answer from the Local Authority regarding which building had been evacuated to assess who was eligible for cash donations and the official list of Grenfell Tower residents”.

58. In short, no one knew who the victims were, no one knew who was still left in the Tower, no one knew who needed help and no one knew who needed money.

Emergency accommodation

59. We now turn to RBKC’s provision of emergency accommodation in the immediate aftermath of the Grenfell Tower fire. It is clear that provision of emergency accommodation by RBKC not only demonstrated a lack of respect and dignity for our clients, it was simply appalling.

60. The Mayor of London stated that in the aftermath of the Grenfell Tower fire, he spoke to survivors of the fire, who expressed their grievances to him:

“these ranged from inadequate and unsuitable hotel allocations, to a lack of communication about whether those in hotels were required to check in or out each day […]”.

61. Our clients experienced these very same grievances in the immediate aftermath of the fire, as a consequence of RBKC’s shambolic response.

62. Our client, Ms Aziza Raihani, and her twenty four year old daughter, Ms Hind Raihani were residents of Grenfell Tower for twenty years. The Raihanis have told us that their home at Grenfell Tower was their “palace”. On the night of the fire, their home - their palace - , was taken from them. Ms Hind Raihani also lost her dear friend, Ms Mariam Elgwahry and her family. In her witness statement to the Inquiry Ms Aziza Raihani stated that she and Ms Hind Raihani:

“were provided with one double bedroom to share. This accommodation was not suitable as the room was very small and the windows did not open, which made me feel very anxious. There was only one double bed that I was expected to share with my daughter.”

63. The Raihanis lived in a two bedroom flat, Flat 126, in Grenfell Tower and yet they were only provided with one bedroom. RBKC were aware that the Raihanis had a two bedroom flat in Grenfell Tower. At 10am on 14 June 2017, KCTMO provided Ms Amanda Gill, Head of Housing Needs at RBKC, with an Excel spreadsheet of a list of residents. The spreadsheet stated that Flat 126 was, in fact, a two bedroom flat. Following the trauma of loss of their home, the Raihanis were expected to share a bed between them.

64. Our client, Ms Maryam Adam, who was pregnant at the time of the Grenfell Tower fire, lived with her adult brother, Mr Yasin Yusuf Adam, her husband, Mr Abdulwahab Abdulhamid and her friend, Ms Amna Mohammed, in Flat 14 of Grenfell Tower. On the night of the fire, Ms Adam and her family lost their home; they lost their community; and they lost their friends: Rania Ibrahim, Nura Jemal, Fathia Ahmed and Amalahmedin Tuccu. In the aftermath of the Grenfell Tower fire, Ms Adam and her family were forced to share one room with one double bed between the four of them. In a spreadsheet exhibited by Ms Gill of RBKC, entitled ‘Housing Allocation Spreadsheet’, Ms Adam was listed as having been allocated one room at the Premier Inn in Earls Court. In her witness statement to the Inquiry, Ms Adam stated that on 14 June: “we were given a room at the Premier Inn Hotel in Earls Court but the council only booked one room for four people and it only had one double bed”. In Mr Abdulhamid’s Phase Two witness statement, he stated that:

“At the hotel, my brother in law and I took turns sleeping on the one bed that we had, at other times, I also slept on the floor. My wife could not use the bed due to her disability and condition. She slept on a makeshift bed on the floor that was not suitable as she was pregnant.”

65. Due to the inadequacy of the hotel accommodation, Ms Mohammed has informed us that she had no choice but to stay for an additional night on the floor of the Westway Centre.

66. We understand Flat 14 of Grenfell Tower was a one-bedroom flat, but it housed four adults. However, had RBKC recorded accurate information about the actual composition of the residents of the flat, more suitable accommodation could have been provided. In his witness statement to the Inquiry, Mr Singh of the TMO stated that KCTMO provided assistance to RBKC, including:

“providing information to RBKC of household composition so that RBKC could provide suitable accommodation to residents”.

67. In an Excel spreadsheet dated 18 June 2017 and entitled ‘Housing Placement Figures’, Ms Adam is listed at row 121 in respect of her and her family’s hotel placement. At columns D and E the spreadsheet incorrectly stated that two adults and one child were allocated to Ms Adams’s room. Mr Abdulhamid stated that the hotel room at the Premier Inn was:

“extremely cramped and uncomfortable for us but we just did not have any information or interaction with anyone about getting a more suitable room or multiple rooms, or support”.

68. It is unforgivable that our clients, having lost so much, were forced to endure such dire circumstances.

Provision of food

69. The scarcity of information passed from RBKC to survivors of the Grenfell Tower fire applied across their response in the aftermath of the fire. In her witness statement to the Inquiry, Ms Richards of CJC stated that:

“there was no clarity around whether food and drink was included within people’s hotel accommodation. Some individuals had run up bills for food and drink and were then told it was not included. I believe a daily allowance for food and drink was eventually agreed but I do not believe the allowance limit was made clear initially.”

70. Our client, Ms Genet Shawo was a resident of Flat 153 and tragically lost her five year old son, Isaac Paulos, on the night of the fire. She stated that during the entire time that she stayed in emergency hotel accommodation, she received no information about the weekly food allowance. She stated:

“I did not know what I was entitled to, so often I would just eat one meal a day as no one told me what I was allowed to have.”

71. Ms Shawo, a grieving mother, should have been immediately provided with such basic information.

Rugby Portobello Trust

72. We now turn to separate issue, which is of equal importance to our clients: the adequacy of the distribution of charitable funds, particularly in relation to the Rugby Portobello Trust. In his witness statement to the Inquiry, Mr Mark Simms of the Trust explained that:

“the RPT issued over 3,200 individual grants totalling more than £16.8 million. These funds, donated by the public, were collected by multiple organisations and passed onto RPT for distribution to Grenfell residents”.

73. In his statement, Mr Simms conceded that the RPT “were not set up to distribute significant sums of financial aid”, and yet he agreed to design and administer the grants programme. We ask why it was that an organisation which was not equipped to deal with the task at hand was granted such an important role? By way of example, our client, Rhea Rojo, was denied access to charitable funds by the Rugby Portobello Trust. Ms Rojo was an unofficial tenant of Grenfell Tower and a resident of both Flats 96 and Flat 186. Following complications in establishing her residency of the Tower, Ms Rojo was recognised as a survivor of the fire and was provided with emergency accommodation by RBKC in July 2017. Despite this, our client informs us that Rugby Portobello Trust refused to add her to the list of recipients of charitable funds.

74. The above failure was compounded by RPT’s failure to keep funds aside for those who were unable to access funds in the immediate aftermath of the fire. Due to complications in establishing her residency in the Tower, our client, Ms Halima Diejomaoh, was unable to access the Fresh Start Grant provided by RPT in the first instance. Once it was established that Ms Diejomaoh was eligible for the Fresh Start Grant, Mr Simms informed our client that RPT no longer had the funds to provide our client with financial assistance.

75. We also note a document produced by the London Emergencies Trust, who were responsible for distributing funds raised by the BRC, entitled ‘Distributing Funds in a Disaster”. In the document, it stated that:

“it is worth noting that RPT could probably only have taken on the role it did because it had the finance team of a national organisation behind it”.

76. In addition, the document noted that in distributing charitable funds, namely the Fresh Start Grant of £10,000 to ‘survivor households’, the issue of defining a household was a “contentious” one. In an email sent by a survivor of the fire to RBKC Councillor, Judith Blakeman, in the aftermath of the fire, the survivor expressed concern that a single household would only receive £10,000, despite splitting into two households after the fire. We invite the Inquiry to investigate this issue further and to ask what more could have been done to ensure an equitable distribution of charitable funds.

The limited scope of Module 4

77. Finally, we ask the Inquiry why the scope of the Inquiry’s investigation into the aftermath of the fire is only limited to the first seven days after the fire. As I think is obvious from what Mr Friedman has just said, our clients do not have the luxury of limiting the impact of the Grenfell Tower fire to the first seven days after the fire. We ask why the Inquiry has thought it appropriate to limit the scope of its investigations. Our clients are deeply concerned that by limiting the scope of the Inquiry so severely, questions will go unanswered and injustices will continue. Since the fire, our clients have continued to be impacted by the shambolic response to the fire, particularly in respect of accommodation.

78. Ms Adam, who as we have stated was forced to share a hotel room with one bed, had no choice but to sleep on the sofa or the floor of the hotel room. She was not only pregnant, but also suffered from a slipped disc at the time of the fire. In her witness statement to the Inquiry, Ms Adam stated that:

“I was in a lot of pain and my back condition worsened whilst I was at this hotel”.

79. Ms Adam suffers from severe back problems to this day, which were exacerbated by being forced to sleep on the floor.

80. Ms Halima Diejomaoh, was a resident of Flat 203 of Grenfell Walk. For over a year, Ms Diejomaoh had no choice but to reside in a hotel. Finally, in October 2018, she was provided with permanent accommodation by RBKC. However, our client has informed us that her bathroom was not fit for purpose and she was forced to use the shower at her local gym. During the COVID-19 lockdown, the gyms were closed and Ms Diejomaoh had no access to a working shower. Our client has informed us that the problem was not resolved until 2021.

81. Our clients, Mrs Shakila and Mr Farhad Neda lost their beloved husband and father, Mr Mohamed Amied ‘Saber’ Neda, on the night of the fire. Not only did Mrs Neda endure the loss of her husband, but she was in a coma following the fire. The Neda’s were eventually provided with permanent accommodation by RBKC. However, with sick irony, they have been rehoused at Hortensia Road, a building with the same combustible cladding as Grenfell Tower. In her witness statement to the Inquiry, Ms Shakila Neda stated:

“We were horrified upon finding out that the council had moved us into a building […] that has the same flammable cladding that was on Grenfell Tower. Further, a report was produced which concluded that there were no adequate procedures for disabled residents to be evacuated”.

82. This is more than an inexcusable failure on the part of RBKC. It is truly a disgrace that RBKC have once again put our client’s lives at risk.


83. We conclude by saying this: the survivors of a tragedy in one of the richest boroughs in the country should not have had to endure the hardship and indignity that we have described. They should not have had to fight for support in the way that they were forced to do so. RBKC’s response in the initial aftermath of the Grenfell Tower fire was chaotic, disorganised and detrimental to LLAG’s response. RBKC’s response exacerbated what was already a dire situation and was severely damaging to the lives of our clients. Not only that, the response did not respect our clients. It did not treat our clients with the dignity that they deserved, it does feel like it is a broken record but we have repeatedly said, had the tragedy not occurred in social housing, the response would have undoubtedly been very different.


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