The Dobbs Review – Will it ever see the light of day?

On Monday 26^th September 2016, the trial began of David Mills and five others – the HBoS corruption scandal.  The jury returned their verdicts on 30^th January 2017, and the defendants who had been convicted were sentenced later that week.

At the heart of the criminal case was the corrupt relationship between Lynden Scourfield and David Mills, which ran from April 2003 to September 2010, 7½ years.  Scourfield was the Lead Director of Impaired Assets for HBoS in the South of England and South Wales; this division of the bank provided strategic advice and assistance to corporate customers who were experiencing financial distress.  Mills was a former banker turned venture capitalist and business consultant.  He was engaged on a frequent basis by Scourfield to act as a turnaround consultant to the customers in his division.

They were required by Scourfield to engage the services of Mills in order to obtain further bank lending.  Once Mills was established, Scourfield advanced huge sums to the businesses and continued to do so well past the point when it would have been obvious to any honest banker that the debt could and would never be re-paid.  He acted in this way to enable Mills and his associates to demand and be paid very high fees for their ‘consultancy’ services and to give them the opportunity to take over some of the businesses and run them for their own benefit.  At the end of the day, the Bank incurred losses in the order of £245m in respect of customer lending managed by Scourfield, which ultimately had to be written off.

The motivation was greed.  The Police investigation uncovered evidence of huge rewards provided by Mills to Scourfield to corrupt him.  This took the form of money transfers, cash, gifts, a credit card for personal spending, unauthorised and inappropriately lavish hospitality, luxurious foreign travel, and sex with high class escorts.

In April 2017, Lloyds Banking Group [‘LBG’] appointed Dame Linda Dobbs DBE, a retired High Court judge, to conduct an independent inquiry into whether it had acted appropriately in respect of its legal and regulatory obligations.  In particular she was asked to investigate:

• What LBG knew, or should reasonably have known, about the misconduct.
• Whether LBG reported matters appropriately to the relevant authorities.
• Whether there was a cover-up.

Full details of the review can be found at https://www.dobbsreview.com/.

Dame Linda initially believed that she could complete the exercise in a “matter of months and certainly well under a year.”  In March 2020, she reported that the unexpected complexity of the exercise meant that it had taken much longer than expected, but that the report would be submitted to LBG that winter.  In July 2023, The Times reported that it had seen emails sent to witnesses that month indicating that the review was still receiving evidence and would not conclude until all of the evidence had been received.

In February 2025, amid concerns that the full report might never be published, Dame Meg Hillier, Chair of the Treasury Select Committee, stated that she expected Lloyds to place a full copy in the public domain once it is completed.

But when will that be?  And will it ever be made public?

In September 2025, Dame Linda reported that evidence gathering was “all but complete”, however, there was “a considerable amount of analysis to do” before she could reach her final conclusions.  She added that parts of the report may have to be sent to individuals and organisations who may be the subject of criticism, to enable them to comment thereon prior to it being submitted to the bank.  In that latest update, Dame Linda also explained that the review had “encountered many unexpected obstacles which have affected the timing of the Review.  They will be detailed in my Report.”

Which begs the questions: who has been obstructing her review and why?  And those are questions to which we might never know the answers, because as she wrote in the last paragraph of that update: “Finally, I want to address the question that has frequently been raised about whether my Review will be published.  I have always made clear that I favour transparency.  However, this decision is not mine to make.  I have made it clear from the outset that publication is a matter for Lloyds Banking Group.”  [Emphasis added]

Brian O’Neill KC (Brian was Leading Counsel for the Prosecution at the trial of Mills and others).