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on these days, was it always the defendant behind the wheel?’

‘As far as I recall. I would’ve noticed and stepped out if it wasn’t.’

‘Do you keep a record of the times that each vehicle enters and exits the premises?’

‘My Lady,’ I interrupted, half raising my hand. ‘The car’s presence on the morning in question is already agreed upon, as is the CCTV footage of the defendant arriving in said vehicle and driving through the barrier a few minutes before nine o’clock. The defence has no dispute with any of this.’

Again, she raised her brow. ‘You did just invite the prosecution to lead the witness through every word of his statement.’

‘That’s all right,’ Garrick snorted. ‘That’s all I have to ask, Mr Chapman. Please wait there while Mr Rook decides upon which supplementary questions he’d like to ask you.’

In Garrick’s stead, I got to my feet. ‘Mr Chapman, your booth is positioned on the inside of the outer gates, is it not?’

‘It is.’

‘For those present in the court who are not so familiar with the layout of Wormwood Scrubs, could you give us a basic description of the approach to the prison by vehicle?’

He ran a hand across his cheek, bemused. ‘I suppose I can, yes. The car comes along Du Cane Road, turns in through the outer gates and past my booth to the barriers, where it gets its ticket checked, like I said. Then it’s a straight drive forwards to the gatehouse.’

‘Those would be the iconic towers that I’m sure we’re all familiar with, correct?’

‘The same.’

‘Do the cars continue ahead through the gatehouse?’

‘No. Staff cars don’t. They turn either left or right, following the outer wall around, and the parking is down there on both sides.’

‘Once they are parked up, can you personally see the vehicles from your booth?’

‘Not directly, no, but I have a monitor relaying the CCTV from along the perimeter.’

‘And do these cameras focus on the staff vehicles?’

He paused, thinking about it. ‘They actually don’t. They’re aimed more at the walls.’

‘Why is that, do you think?’

‘Huh … Well, I’ve never really considered it, but I suppose you’d have to have some real big balls on you to break into a car in a prison car park, wouldn’t you?’

Another titter from the jury. I didn’t mind; this was going well enough.

‘Yes, Mr Chapman, I believe you probably would. What I also find interesting is that you said the cars follow the outer wall to either the left or the right and park up there.’

‘I did.’

‘All right, let’s see. So, if this represents the prison itself …’ With my left hand I held up a sheet of paper from my pile. ‘And this is a car …’ With the index finger of my right, I traced a path coming up to the paper from the centre underneath, then followed the perimeter of the paper over to the left and parked it there. ‘Wouldn’t that mean that the parking areas themselves are actually outside of the prison walls, even for members of staff?’

‘They are situated on the property, inside the outer fence, but security couldn’t have cars coming in and out of the main walls all day long. It’d be a nightmare.’

‘I’m sure it would.’ I returned the paper to the pile. ‘On the morning in question, do you recall whether the defendant turned left or right upon reaching the gatehouse?’

‘Left.’

‘You’re sure about that?’

‘Course. Even in prison, it isn’t every day you have dogs closing off half the car park. The Corsa was parked up in the south-western corner, close to my own car.’

‘Again, that is outside of the actual prison walls, yes?’

‘Yes.’

Garrick sighed; it must’ve been as loudly as he could manage. ‘My Lady, it seems as though the defence intends to suggest that the defendant’s car, as well as the contraband inside, could not have been in breach of smuggling laws because they were not actually discovered within the prison’s walls … Perhaps a reminder is required to refresh my learned friend on what constitutes prison premises?’

‘A considerate offer,’ I said, ‘but no reminder is necessary, thank you. Prison property begins at Mr Chapman’s booth and barriers, and by all accounts the defendant’s vehicle was most definitely onsite at the time of the discovery. The point I was trying to make is that it was parked up in the south-western corner of the grounds. Nothing unusual there – it is one of two parking zones reserved for staff – but would it be fair to say that this area is something of a dumping ground, Mr Chapman?’

‘In what respect?’

‘Well, I have seen the area for myself in the past, and would you agree or disagree with my observation that it is nothing more than a patch of loose, potholed concrete with a few industrial Biffa skips and piles of scrap metal and rubbish?’

He nodded. ‘I’d say that’s a good enough description, though you missed out the weeds. At the end of the day, it’s only a place to leave your car.’

‘Indeed. One can only assume that those enormous bins require emptying from time to time?’

‘Once a week. There’s a gate in the fence up there, padlocked. Every Tuesday I unlock it, let the wagons come in, then lock it back up again when they’re done.’

‘The gate leads back out onto Du Cane Road?’

‘Right.’

‘And are there any signs on these gates?’

He frowned a little. ‘Private property signs, mostly. An arrow pointing in the direction of the main entrance down the road. Nothing out of the ordinary.’

‘But it’s a prison, hardly an inconspicuous structure. Why the signs?’

‘Oh, that’s easy,’ he said, brightening up. ‘They’re for the fly-tippers.’

‘Fly-tippers?’ I cocked my head. ‘As in, members of the public dumping rubbish?’

‘Uh-huh, sure. There’s a low point at the very end of the fence down that side, must be about four feet high, which backs onto Wulfstan Street, the residential area to the west. People who can’t be bothered to hire a skip have a bad habit of just hopping over the

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