Baroness Anne Longfield Chair of the Independent Inquiry Dear Home Secretary and Baroness Longfield, FORMAL SUBMISSION: THE TERMS OF REFERENCE – NATIONAL INQUIRY INTO GROOMING GANGS I, Maggie Oliver, on behalf of The Maggie Oliver Foundation (TMOF) and an advisory group of survivors and victims who TMOF supports (the TMOF Survivor Panel), write regarding the Government’s consultation document, publicized ahead of agreeing Terms of Reference for the National Inquiry into Grooming Gangs. On Friday 20th February 2026, we facilitated a meeting between yourselves, the Inquiry panel and our ever-growing TMOF Survivor Panel. Following detailed review and consultation with the group of survivors following that meeting, we set out in the attached document our combined formal concerns and recommendations prepared in consultation with our legal representatives at Howe & Co and Landmark Chambers. You have suggested that observations are provided via a supplied form. However, given the numbers of survivors we represent, and the detail of their views, it is appropriate to set out those view more fully and more formally. The observations and undertakings sought represent the collective position of the TMOF Survivor Panel, which is made up of over two dozen survivors and their families, people who have experienced the life-changing consequences of the crimes of so called “grooming gangs/rape gangs” and systemic failures to investigate, prosecute and prevent these crimes. Their insights are shared alongside my own 20 years of detailed professional experience handling hundreds of individual cases: as a former detective, as a whistleblower, through direct involvement in the independent Inquiry into Child Sexual Abuse (IICSA) “Organised Networks” strand, in our work with Baroness Casey on her audit last year and, of course, as Founder and Chair of The Maggie Oliver Foundation since 2019. Survivors experience the impact of their sexual abuse and exploitation daily over decades, as well as the trauma of not being properly protected by the very systems, agencies and individuals whose job it was to do so. Survivors we brought to meet you in February were 1
who spoke of the generational impact of their abuse; whereby their children were “marked” by Social Service at birth, as a consequence of the fact that they (the mothers) had been abused as children. Rather than be treated as victims of crime and supported, survivors are treated as suspects to be monitored; as so the failure to address organized abuse is transmitted to the next generation. Whilst a serving detective in Greater Manchester Police, I witnessed these failures firsthand when working on Operation Augusta and Operation Span, and in the two decades since have seen the same patterns countless times. Consequently, these reflections are grounded in lived experience, frontline investigation, and scrutiny of previous Inquiry processes, including where those processes have fallen severely short of delivering justice. During our meeting, survivors from across the country, including Rochdale, Rotherham, Telford, Barrow, Hull, Huddersfield, Bradford, Keighley and London told you very clearly that inadequate charges against their rapists and abusers had been authorized. Often serious rape and exploitation allegations were downgraded, and prosecutorial decisions failed to reflect the gravity of their sexual exploitation and abuse by organized networks of predators. Cases where offences of child rape for instance had led only to charges of ‘conspiracy to commit sexual activity with a child’ or ‘trafficking’. In some cases, a pregnancy had been the result of these rapes, yet police and prosecutors chose not to charge adequately Senior office holders, including prosecutors, have a duty to uphold the law without fear or favour. Where evidence suggests deliberate inaction, suppression, reckless failure to act, or protection of institutional reputation over child safety, criminal referral must follow. Public confidence depends on visible, enforceable accountability, not administrative discipline handed out by the very institutions responsible for the current collapse of public trust. We send this letter following a High Court judgement yesterday, granting permission for The Maggie Oliver Foundation to bring a judicial review against the Government for its failure to act on the recommendations of the Independent Inquiry of Child Sexual Abuse (IICSA). Mr. Justice Kimblin described our action as, “A paradigm example of public interest litigation”. While we understand that the Government is not obliged to implement the recommendations of any inquiry, yesterday’s judgement gives a clear signal that where repeated promises are made by the Government to act on the safety of children across the UK, they must justify why they will not do so. 2
it will act on her panel’s findings and recommendations, and will do so within one year of the final report being laid before Parliament. The Maggie Oliver Foundation does not wish to find itself in the High Court again, in three years’ time, seeking to compel government (again) to implement urgent recommendations designed to safeguard our children. We look forward to working with you to ensure this Inquiry puts survivors at its heart and delivers much-overdue change. Yours sincerely, Maggie Oliver along with The Maggie Oliver Foundation and survivors, victims and their families 3
CONSULTATION ON THE DRAFT TERMS OF REFERENCE SUBMISSION ON BY THE MAGGIE OLIVER FOUNDATION (TMOF) AND THE ADVISORY GROUP OF SURVIVORS AND VICTIMS WHO TMOF SUPPORTS (THE TMOF SURVIVOR PANEL) 6 MARCH 2026 1. On 9 December 2005 the Chair of the Independent Inquiry into Grooming Gangs (The Inquiry) officially launched its public consultation on the draft Terms of Reference (ToR), with an invitation for victims, survivors, and the public to submit their views. The consultation closes on 6 March 2026. 2. The Maggie Oliver Founation (‘TMOF’) make these initial observations on the draft terms of reference published by the Secretary of State (‘Secretary of State’) on behalf of the members of TMOF and the Advisory Group of Survivors and Victims (TMOF Survivor Panel). 3. The final Terms of Reference must be drafted in a manner that is sufficiently wide, so as to encompass the issues that are raised in these submissions. Preliminary issues 4. First, we seek confirmation from the Chair that the TMOF Survivor Panel, and others, will be afforded the opportunity to make observations on the actual draft Terms of Reference when they are settled by the Secretary of State. It is important that the Secretary of State does not omit any material matters from the Inquiry’s 4
settled, TMOF, those they represent and others are afforded the opportunity to make observations on them before they are finalised. 5. The document that we have been asked to make observations on, “Independent Inquiry into Grooming Gangs: draft terms of reference” (11 December 2025), is not a set of draft Terms of Reference, it is a wider document that appears to seek view on a wide range of issues that will lead to the development of draft Terms of Reference. We refer to this throughout as the Consultation Document. 6. Second, and as set out below and in the letter sent on behalf of TMOF on 27 February 2026 (further copy enclosed), victims and survivors have a profound trust deficit. This concern is well founded, for example as a result of the failure to implement the recommendations of the Independent Inquiry into Child Sexual Abuse (IICSA) and Baroness Casey’s National Review. These matters raise the natural concern that any recommendations made by this Inquiry will not be implemented. 7. The TMOF Survivor Panel and TMOF therefore ask that the Chair seek and obtain an undertaking from the Government that it will implement any recommendations made by the Inquiry within one year of those recommendations being laid before Parliament. 8. Third, TMOF, the TMOF Survivor Panel and others, are deeply concerned at the descriptor term “Grooming Gangs/Rape Gangs”. This phrase downplays the violence and seriousness of this national issue. Serious thought must be given as to how to describe this distinct form of abuse. Background 5
Inquiry, other than to note that had the Government implemented Recommendation One of the IICSA, this Inquiry might not have been necessary. 7. These initial submissions follow the meeting on 20 February 2026, between the Inquiry Chair and panel and the TMOF Survivor Panel. We have consulted with survivors in the short time available since that meeting. 8. As you are aware, survivors of organised abuse are uniquely placed to provide essential insights due to their lived experiences of abuse at the hands of the socalled “Grooming Gangs/Rape Gangs”, and the systemic failures to investigate, prosecute and prevent these crimes. 9. In addition to the experiences of the victims, TMOF brings Maggie Oliver’s 20 years of focused professional experience handling hundreds of individual cases — as a former detective, as a whistleblower, through direct involvement as a Core Participant in the IICSA “Organised Networks” strand, in our work with Baroness Casey on her audit last year and, of course as Founder and Chair of The Maggie Oliver Foundation since 2019. Recommendations of the Independent Inquiry on Child Sexual Abuse (IICSA) 10. As detailed in the introduction to these submissions, survivors have serious concerns that any recommendations made by the Inquiry will not be implemented. 11. Baroness Casey in her National Audit Report predicated all of her recommendations, including recommendation 2 (which grounds this Inquiry) on “Before setting out this audit’s recommendations, we want to acknowledge the importance of the recommendations made by the Independent Inquiry on Child Sexual Abuse (IICSA) in their final report to improve how child sexual abuse as a 6
basis that their proposals for change are being implemented.” [Emphasis added]: 12. This has not happened, and The Maggie Oliver Foundation has been required to issue judicial review proceedings in the High Court. On 5 March 2026 Mr Justice Kimblin granted permission on two grounds of challenge and described the action as “A paradigm example of public interest litigation”. 13. Victims and survivors have serious concerns about what the effectiveness of this Inquiry will be, having undergone the traumatic experience of giving evidence to IICSA, and then (over 3 ½ years after those recommendations were made) needing to seek a Judicial Review in an attempt to secure implementation of those Recommendations. 14. The trust deficit held by victims and survivors are therefore well founded. It is for the Inquiry and its Chair to allay this fundamental concern. 15. In order to foster a trusting relationship with victims, it is important that there is an undertaking in the final ToR (which as yet are unpublished) that any recommendations made by this Inquiry are implemented within one year of being laid before Parliament. At the very least a clear timetable for implementation should be provided within a year of the Inquiry reporting. Restorative Justice 16. One initiative that the ToR could provide for (or provide the Chair with latitude to instigate), is that the Inquiry either implement, as part of its work, or consider and recommend, the establishment of a national restorative justice programme. This would be consistent with recommendation 11 of the Post Office Horizon IT Inquiry 7
that recommendation. Transparency 17. The State has failed to protect victims. TMOF maintains that the ToR should make explicit provision for representatives of the relevant authorities to be compelled to provide evidence to the Inquiry and not to be able to rely upon any form of confidentiality and/or public interest excuse to withhold evidence. 18. Institutional Core Participants should act in accordance with the statutory duty of candour, that will be imposed when the Public Accountability Bill is enacted. Criminal Accountability for Senior Public Servants and Prosecutorial DecisionMaking 19. The Inquiry ToR must provide the Inquiry with full powers to investigate and address failures by senior public servants, including police leaders, council executives, safeguarding heads and senior prosecutors within the Crown Prosecution Service (CPS). Such investigation must extend to scrutiny of inadequate charges being brought. Given that a statutory inquiry does not have the power to make criminal or civil findings, the Inquiry if it finds that conduct amounts to potential criminal conduct, must have the power (and the ToR permit) to refer such conduct for investigation and potential prosecution. The language in the Consultation Document around accountability is wholly insufficient, referring only to referrals to “relevant professional bodies…..where failures to carry out duties and responsibilities are suspected”. 8
to address/include the following: • Examine where failures by councils, police forces and the CPS amount to criminal neglect/misconduct; • Address deliberate cover-ups, suppression of evidence, premature case closures, or intimidation of whistleblowers; • Clarify that regulatory or internal disciplinary processes cannot ever substitute for criminal investigation; • The reports already published in relation to towns and cities around the UK (including Rotherham, Manchester (Operation Augusta), Rochdale (Operation Span) and Telford) must be part of the evidence scrutinised by this Inquiry. The evidence has already been gathered in those inquiries, and they are a rich source of information which must not be overlooked. 21. In respect of the CPS, the Inquiry must examine where, when and why: • The CPS failed to pursue appropriate charges against child abusers and potential perpetrators; • The CPS, for reasons of expedience, proceeded with lesser or alternative offences, when stronger charges were available; • Prosecutorial caution, cultural sensitivities or institutional risk-aversion influenced charging decisions; • Senior decision-makers knowingly authorised inadequate charges despite available evidence; • Failures to prosecute robustly or deliver inadequate sentences enabled continued abuse. 22. We would highlight that public confidence depends on visible, enforceable accountability, not the closed door internal administrative discipline handed out by the very institutions responsible for the current collapse of public trust. 9
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