Let me take you all the way back to 12th May 2013, the date on which the mainstream media finally got around to noticing that Nadine Dorries MP had failed to declare her earnings from her appearance on ITV’s I’m A Celebrity Get Me Out Of Here on the House of Commons Register of Members’ Interests, which was only four days after the Ministry had actually broken this particular story.

In response to questions put to her by the Daily Mirror, Dorries had this to say about her failure to register this information with the House of Commons’ authorities:

Asked why she had not ­declared any earnings she said: “I am a backbencher, not a minister. My personal finances are my business.

“However, any payment I ­receive has to be reported to the Registrar within 30 days. Ergo, if I haven’t registered a payment, it’s because I haven’t received one.”

She added: “Please be clear, it would be a very stupid MP who received a payment and didn’t register it with the Standards Commissioner within 30 days. I register mine immediately. If I haven’t registered a payment, I haven’t received one.”

At 4:44pm on 11 November 2013, Dorries stood up in the House of Commons chamber to give the following personal statement:

Nadine Dorries (Mid Bedfordshire) (Con):

On Monday 11 November, the Committee on Standards published a report on my declaration in the Register of Members’ Financial Interests which concluded that I had breached the rules relating to how I registered information. Mr Speaker, I wish to apologise to the House fully and unreservedly for what was a genuinely inadvertent breach of the rules, with which I have at all times sought to comply.

Mr Speaker:

I thank the hon. Lady for that statement.

Having spent much of the last day or so reading, unpicking and digesting the contents of the Committee on Standards report together with the written evidence that was submitted to the committee for consideration I have to say that beyond validating in full her earlier assertion that “it would be a very stupid MP who received a payment and didn’t register it with the Standards Commissioner within 30 days” the cursory apology she offered to the House strikes me as a wholly inadequate and characteristically disingenuous response to the findings of the Parliamentary Standards Commissioner.

To understand why let me walk you through the facts of this case from start to finish, as disclosed by the committee’s report.

We’ll begin with the company at the centre of this case, Averbrook Ltd (company no. 02928407). The company was originally registered with Companies House on 12 May 1994 and traded as an engineering consultancy until around 2005 when it ceased all trading activities and was placed into a dormant state.

At this point in Averbrook’s history the company was wholly owned by a Mr Andrew James Rayment, who was also registered as a director and Company Secretary, while Mr Rayment’s wife, Mrs Ann Frances Rayment, was listed as Averbrook’s sole director and office manager.

At this point we’ll skip over any further details of Andrew Rayment’s past business activities, none of which are relevant to this case.

However, what you do need to know about Mr Rayment is that in addition to serving as Conservative Member of Mid-Bedfordshire District Council from 1995 to 2009, including three year (1999-2002) as Leader of the Council, he also held the position of  Chairman of Mid-Bedfordshire Conservative Association during 2009-10 and (so I understand) acted as Nadine Dorries’ election agent at the 2010 General Election.

Mr Rayment and his wife are also joint owners of the 4 bedroom property in Westoning, Bedfordshire (pdf) that Nadine Dorries has occupied as her constituency home since, it would appear, October/November 2011.

Much as I dislike delving into personal matters, there is back story here that needs to be explained in order to put this last piece of information into its proper context.

In January 2011, Dorries announced via her personal ‘blog’ that she has begun a romantic relationship with a family friend, much the irritation of this friend’s wife who labelled Dorries a ‘marriage wrecker’ only then to be publicly trashed by Dorries, again via her personal blog and in the Mail on Sunday.

At the beginning of October 2011, a number of newspapers reported that this romantic relationship had come to an end some time in June 2011 with Dorries moving out of a property in which the couple had cohabited since January 2011 into a terraced property in Westoning, which is where she was reported to be living at the time these reports were published.

As you will see from the Land Registry document posted above*, on 23 August 2011, Mr Rayment and his wife purchased a £345,000 4 bedroom (2 bathroom, 2 reception room) detached house in Westoning, a mere half a mile from their family home, in what I’ve been led to understand was a cash transaction, a property that Nadine Dorries moved into and began to use as her main/constituency home** somewhere around the time that the tabloids were reporting her latest bout of relationship problems.

* In an effort to keep Dorries’ usual paranoia at a manageable level I’ve redacted the address information from this document, even though both addresses are a matter of public record and can readily be obtained from documents filed at Companies House and from any number of company search/due diligence websites.

** It was at this point in time that Dorries began to commute from her constituency home to Westminster and back on a regular daily basis, claiming for these journeys on expenses while at the same time renting a flat in Pimilico (also on expenses) which she used overnight, on average, for less than three days per month over the 15 months from October 2011 to December 2012. This, of course, resulted in the IPSA inquiry which ended Dorries having to repay more that £3,000 in incorrectly claimed travel expenses.

So, a couple of months after Dorries split from her then partner, Rayment bought a 4 bedroom detached house into which Dorries then moved only a matter of 2-3 months later, all of which makes Rayment her landlord in addition – as we’ll see very shortly – to his being her business partner.

Getting back to Averbrook Ltd, the company lay dormant until 31 March 2012 at which point, according to official documents filed with Companies House, Ann Rayment stepped down as a directer of the company and roughly six weeks later (15 May 2012) Andrew Rayment also stepped down as Averbrook’s company secretary, leaving that role to be filled by a firm of accountants from May until 3/4 October 2012.

This brings us up to start of Dorries’ involvement with Averbrook Ltd because, again according to documents filed at Companies House, including an Annual Return filed (32 days late) on 11 July 2013, on 3 October 2013 Andrew Rayment resigned as director of Averbrook Ltd. and on the same date he also transferred 90 of the 100 shares he owned to Nadine Dorries, retaining just a 10% stake in the company for himself. On that same day, the firm of accountants that had acted as company secretary since May 2012 also vacated that position with Averbrook Ltd.

On the following day (4 October), around a month before she jetted off to Australia to appear on I’m a Celebrity Get Me Out of Here, paperwork was filed with Companies House appointing Nadine Dorries as the sole director of Averbrook Ltd.

So, as should be obvious from all that, the official records filed at Companies House show that in October 2012 Averbrook Ltd was not a newly formed ‘off-the-shelf’ company but one that had previously traded but had lain dormant for several years.

The records also show that by 4 October 2012, Nadine Dorries had become the sole director of Averbrook and that she had acquired a 90% stake in the company, while the rules governing MP’s financial interests required her to register with one month – MPs are required to register their shareholding in a company if it amounts to 15% or more of the company’s shares.

So why did she not register Averbrook Ltd at that time?

The answer lies in two email exchanges between Dorries’ Parliamentary Office and the Registrar of Members’ Financial Interests, one of which took place on 4 October 2012, the other on 18 October 2012:

From the office of Ms Nadine Dorries MP to the Registrar of Members’ Financial Interests, 4 October 2012

Nadine has recently been made a director and secretary of a registered company: Averbrook Ltd. Company number 02928407.

Currently, her earnings from this are nil. We will of course update the register as soon as this changes, in the meantime could you let me know what other information is needed from Nadine about this position and company for the register to be complete?

From the Registrar of Members’ Financial Interests to the office of Ms Nadine Dorries MP, 4 October 2012

Thank you. It all depends on the exact arrangements:

If Ms Dorries is going to draw a salary from this position, it should be registered as a remunerated directorship (Category 1). Each payment will need to be registered, subject to the usual threshold. (If Ms Dorries will be paid only through dividends these do not require registration.)

If Ms Dorries has shares, and these are more than 15% of the issued share capital or they are worth more than £66,000, these should be registered under Category 9 (shareholdings).

Ms Dorries would need to provide a few words about what the company does for the Register, and we would also need its address if this is a remunerated directorship.

Feel free to give me a call to discuss if that is easier.

From the Registrar of Members’ Financial Interests to the office of Ms Nadine Dorries MP, 18 October 2012

I am writing to follow up the exchange [above].

We are preparing a Register to be published next week, so if Ms Dorries has anything which needs registration, it would be helpful to receive it as soon as possible.

From the office of Ms Nadine Dorries MP to the Registrar of Members’ Financial Interests 18 October 2012

Thanks for chasing this up.

The company is called Averbrook Limited and is a Writing and Media Consultancy. Nadine is the Director, Secretary and whole owner of the company but has not as yet received any payment from it since it has literally just been set up in the past few weeks and hasn’t done anything yet.

Is that enough information for the time being? We will let you have the company address as soon as Nadine receives a payment, the only reason we haven’t done that yet is that she had the address as [personal information] and has realised this is a problem and so is changing it as I write.

From the Registrar of Members’ Financial Interests to the office of Ms Nadine Dorries MP, 18 October 2012

Thank you. As no payment has yet been received, I will wait for you to contact me after the first payment has been made and after the address has been sorted. The rules require Members to make a Register entry within 28 days of receiving any payment.

Please let me know before then if Ms Dorries will be providing services in her capacity as an MP, as in that case further documentation would be needed.

As should be obvious here, the Registrar gave Dorries’ office the correct advice based on the information they were given about Averbrook Ltd and Dorries’ relationship with that company in the email of 18 October but, as we’ve already seen, the information supplied to the Registrar by her office was completely incorrect. Averbrook had not ‘literally just been set up in the last few weeks’ and she was not the ‘whole owner’ of the company.

These emails explain, in part, why Dorries ‘inadvertently’ failed to register Averbrook within one month of becoming a director and, according to the Company’s annual return, it’s majority shareholder.

That, however, is not quite the full story because when if we skip ahead* to the investigation carried out the Parliamentary Standards Commission, which began in June 2013 the first thing we find is that it was not until Dorries’ contacted the Registrar of Members’ Financial Interests to register Averbrook Ltd on 10 June 2013** that Registrar discovered that they had been given incorrect information about the company by her office back in October.

* I should note at this point that following this exchange of emails on 18 October 2012, the Registrar of Members’ Financial Interests went to contact Dorries and/or her office on five separate occasions (31 October 2012, 3 December 2012, 3 January 2013, 18 January 2013 and 21 January 2013) with reminders about the registration of Averbrook. On the last of these five occasions (21 January 2013) and following a telephone conversation, the Registrar emailed Dorries to advise her to register any payment(s) she had received in relation to ‘I’m a Celebrity…’ even if these had been paid to another organisation (i.e. Averbrook) and not directly to herself.

** This was seven days after the Parliamentary Standard Commissioner’s first letter to Dorries (3 June) asking for information about her appearance fee for ‘I’m a Celebrity…” in response to a complaint made by John Mann MP on 29 May 2013.

After being contacted by Dorries, the Registrar sent her a draft register entry for approval which included the following proposed addition to her entry:

9. Shareholdings

Director and sole shareholder of Averbrook, a writing and media consultancy. (Registered 10 June 2013)

To which Dorries’ responded with the following email:

From Ms Nadine Dorries MP to the Registrar of Members’ Financial Interests, 11 June 2013

The stock transfer forms have been signed but as yet, not allocated to me, although they will be very shortly. I am waiting for a call back from my accountant — when they are allocated, I will have more than 15% however I will not be the sole shareholder as they will be divided between another director and myself.

Just to make sure this is absolutely clear could you please remove the word ‘sole’ from the entry.

Many thanks.

So this is the first occasion on which the Registrar was informed that Dorries was not, in fact, Averbrook’s sole owner and shareholder and you’ll also note that Dorries claims that although the stock transfer forms have been signed she still has, at this point, no idea what her exact shareholding will be other than that it will be more than 50%.

This is, to say the least, a little odd when you consider that Averbrook’s annual return, which should have been filed no later that 9 June 2013 but which was eventually filed just over a month late on 11 July 2013, states for the official record that the stock transfer from Rayment to Dorries took place on 3 October 2013, with Dorries acquiring 90 of the company’s 100 ordinary shares.

On 15 August 2013, having completed her investigation of John Mann’s complaint – and we will briefly come back to Dorries’ behaviour during the investigation in due course – the Parliamentary Standards Commissioner sent Dorries a copy of the draft factual section of her report for review. This would be Dorries’ final opportunity to correct/dispute any factual matters contained in the report and/or add any further information or evidence she considered to be relevant to the case, before the Standards Commissioner completed her report and took a decision on whether or not to refer the case to the Standards Committee.

Dorries’ response was made by way of letters to the Parliamentary Standards Commissioner on 21 and 22 August the first of which is entirely characteristic of general attitude that she adopted towards the PSC’s inquiries from start to finish:

Letter to the Commissioner from Ms Nadine Dorries MP, 21 August 2013

Thank you for your letter of 15 August, I would like to make the following points:

I have never claimed Averbrook was a new company. It was an off the shelf company, owned by my business partner, which we decided to use rather than going through the process of establishing a new company. This is common business practice.

When I informed the registrar on 18 October that the company had only been set up a few weeks earlier it was in the context of a media consultancy and not as an engineering business. When I joined on October 4 this is what happened, the description of the business altered.

Your report makes a simple business transaction sound ambiguous, which it is not.

As we have already seen, it is perfectly true that Dorries did not personally claim that Averbrook was a new company but that’s only because she didn’t personally inform the registrar of anything on 18 October 2012. She delegated that responsibility to a member of her office staff who told the Registrar that:

The company is called Averbrook Limited and is a Writing and Media Consultancy. Nadine is the Director, Secretary and whole owner of the company but has not as yet received any payment from it since it has literally just been set up in the past few weeks and hasn’t done anything yet.

So it was one of her minions that screwed up?

Well… yes and no.

Although the contact with the Registrar came from Dorries’ office and not from Dorries, the rules governing the registration of financial interests make it perfectly clear that MPs are held to be personally responsible at all times for ensuring that their Register entries are both complete and accurate, so even if an MP delegates the responsibility for passing information to the Registrar to an underling that MP is still duty bound to ensure that the information that they give to their staff and that their staff then give to the Registrar is accurate, up to date and fully compliant with the rules on registration.

Although the transaction itself might not have been ambiguous, the manner in which it was reported to the Registrar was, and the rules are clear that that is Dorries’ personal responsibility and not something she can bullshit her way out of.

Dorries then adds:

I can provide you with a very long list of MPs in all parties who do not declare payments made to their companies or even their shareholdings, given that they maintain such shareholdings below 15%.

For the purpose of this letter I will cite [another Member]; who runs a [ … ] business. Are you seriously suggesting that every payment made to his busy family business by clients should be declared in the Register of Member’s Interests?

I also take issue that, in light of there being no specific rule requiring MPs to register payments made to their Limited Company, you will make one up by telling members they should and therefore attempting to establish a precedent.

I would imagine the reasons why there is no rule requiring that MPs have to register payments are numerous and legitimate. However, as I have stated, some MPs do declare SOME, some declare all and the vast majority abide by rules.

The issues raised here are dealt with in full in the final Standards Committee report, the meat of which begins on page 4, paragraph 9:

9. As Ms Dorries said, the rules do not require Members with shareholdings of below 15 per cent of a company to register them, providing that they are not greater in value than the current parliamentary salary. Nor do they require those with registrable shareholdings to register every payment made to those companies in which they have an interest. In many cases such payments will have nothing to do with any activity of the Member who holds the shares, or the payment will be unrelated to a Member’s parliamentary role and fall below the registrable threshold. The requirement to register arises when payments are made to a company in respect of work done by the Member concerned.

The report then goes on to explain the full background to the rules covering registration of payments to companies for work undertaken by MPs noting that this is covered by the Code of Conduct and Guide to the Rules relating to the Conduct of Members that was issued to all MPs in June 2009 along with additional detailed guidance on resolutions passed in February and April of that year which includes the following information in relation to the registration of financial interests (as noted at para 11 of the final report):

11. That guidance contained the following:

a number of Members run their own companies. When considering how to make entries in respect of these, Members should distinguish between earnings which are result [sic] from their efforts alone and those which result also from those of others. Members in such a position should:

a) register a company in the appropriate category, which would usually be Category 1;

b) register under Category 3 (Clients) within four weeks of receipt all payments to the company from clients of the company to whom they provide personal services together with the nature of the work and the number of hours worked.

It remains extant on the Commissioner’s webpages, on the page where forms for registration can be found.

The committee report then goes on to note the existence of prior guidance and an almost exact precedent for the situation that Dorries entered into when she became a director/shareholder of Averbrook and began to use the company to receive payments for her media work on her behalf, dating all the way back to 2000/2001:

12. The June 2009 advice on registration of payments to companies was based on established practice. The Committees charged with considering standards cases have consistently required Members to register work done through companies.In its Seventh Report of Session 1999–2000, published in March 2000, the Committee on Standards and Privileges gave guidance on the registration of fees for media appearances and related work, which included the statement that “in the case of any fees which are paid to a company, rather than directly to the Member, the person or organisation paying the fees should be registered under Category 3 (Clients) as a client of the company if not registered under Category 2”. There is an almost exact precedent for the payment to a third party in respect of work done by a Member of Parliament dating from 2001:

Members are required to register any employment “in which the Member has any pecuniary interest”.[….] Because the company was owned by Mr Robinson and his own services were an integral part of the agreement for services for which the remuneration was sought, the fact that the payment was to be made to his company, TransTec, for services provided by that company does not alter our view of this case. Whether the payment was intended to be made to Mr Robinson or TransTec is immaterial.

That Report was approved by the House on 31 October 2001.

Given the reference here to the June 2009 advice being based on ‘established’ this seem a opportune time to note Dorries’ response to that term when it was put to her, by the PSC in July 2013, that it was the ‘established practice’ of the Registrar’s office to advise MPs to register payments made for MPs services even if the payment were made to another organisation:

Letter to the Commissioner from Ms Nadine Dorries MP, 10 July 2013

…

With regard to your point;

`it is established practice for her office to advise that Members should register remuneration for their work, even if that remuneration is paid not to the Member but to another organisation’

It may be the established practice of her office to recommend that Members, in her opinion, should but it is not a requirement or an obligation that the Member must. I am not the only director of Averbrook Ltd, therefore, I choose to strictly abide by the rules and not by subjective requirement. Information I place in the public domain pertains to an additional shareholder who does not hold public office.

[The Registrar] quotes that some Members do declare payments made to their own company. I’m sure some do, but certainly not all, indeed, not many. This is because there is no specific legal requirement for them to do so.

Should I ever speak in the Chamber on matters relating to DCMS [the Department for Culture, Media and Sport] I will of course declare my interest as someone who works within the industry before doing so as is required.

With Dorries having been an MP since 2005 one might have expected her to have realised by now that Parliament operates as much on the basis of ‘established practice’ and informal conventions as it does on rules and regulation, if not more so on matters of convention, but evidently this is an observation that has entirely failed to register.

But I digress… so let’s get back to Dorries’ missive of 21 August 2013, which she concludes with what can only be described as a blatant, if thoroughly hollow, attempt to intimidate the Parliamentary Standards Commissioner.

I should inform you that I feel your report amounts to a witch hunt and I have forwarded it on to legal professionals for further advice regarding my position in relation to the committee and you personally.

You are choosing to use a vexatious complaint made against me to reinforce your ‘on the hoof, make it up as you go’ policy. I will not tolerate that or any report which invokes libellous negative coverage against me as a result and will not hesitate to pursue you personally should that be the case.

There is a slight impediment her that one might have expected a sitting MP to be aware of but which has also evidently escaped Dorries attention as any report published by the Parliament Standards Commission would clearly be deemed to constitute part of the official proceedings of Parliament and would therefore be subject to the article 9 of the 1689 Bill of Rights:

That the Freedome of Speech and Debates or Proceedings in Parlyament ought not to be impeached or questioned in any Court or Place out of Parlyament.

And, of course, the Parliamentary Papers Act 1840, which provides that all publications made under the House’s authority enjoy absolute privilege against civil and criminal proceedings.

All of which suggest that the one thing you are guaranteed not to find in Dorries’ Parliamentary Office is a copy of Bagehot.

On a purely personal note I have to say that that last couple of paragraphs amount to one of the more egregious and grossly misplaced pieces of attempted quasi-legal thuggery I’ve seen in a very long time, but on the off-chance that Dorries may be minded to send a similar nastygram to the Ministry, should she read this article, I should point out that there’s an email link she’s welcome to use and I look forward to filing any such communications under “see – Arkell vs Pressdram”.

Moving on, Dorries sent a second missive to the PSC on 22 August, which reads as follows:

Apologies for the second letter in two days, the text was sent electronically to my Westminster office and this should have been the concluding part of yesterday’s letter.

It is not noted in your factual findings that the share certificate for Averbrook was signed only on 13 June 2013. A copy of this can be provided as required.

I would also like to state that the registrar’s criteria of ‘openness’ is made within the context of pecuniary interest having relevance or influence upon a Member’s work in Westminster. My media work has no such bearing upon my representation of Mid-Bedfordshire.

Curiouser and curiouser, said Alice…

… because 13 June 2013 is, of course, 3 days after Dorries registered her shareholding in Averbrook with the Registrar of Members’ Interests but something over 9 months later than the date (3 October 2013) on which Averbrook Ltd’s annual return to Companies House states that Dorries acquired a 90% holding in the company from Andrew Rayment – and to make matters even more interesting, although the annual return was not filed with Companies House until 11 July 2013, it is actually dated for 12 May 2013.

Naturally enough, the PSC’s office responded to this last letter on 23 August by asking Dorries to forward copies of the share certificate and share transfer form to the PSC, a request to which Dorries’ office responded by email on 11 September 2013, as follows:

My apologies for the delay in getting back to you. I have now been told that Nadine has nothing further to add to the last letters sent to the Commissioner so there is no additional response from this office.

I understand that the case now progresses to discussion by the Standards Committee?

Many thanks for your ongoing help.

So, after claiming that her share certificate for Averbrook had not been signed until 13 June 2013, which was after she’d registered her shareholding with the Registrar of Members’ Interests, Dorries decline to provide any evidence whatsoever to support that claim, which is probably just as well given that this would then have contradicted the information filed with Companies House on 11 July 2013 in Averbrook’s annual return, raising some rather awkward questions in relation to s1250 of the Companies Act 2006:

1250. Misleading, false and deceptive statements

(1)A person is guilty of an offence if—

(a)for the purposes of or in connection with any application under this Part, or

(b)in purported compliance with any requirement imposed on him by or by virtue of this Part,

he knowingly or recklessly furnishes information which is misleading, false or deceptive in a material particular.

Completists might like to note that the maximum sentence for knowingly or reckless filing false information with Companies House is 12 month imprisonment on a summary offence or 2 years imprisonment on indictment.

I said earlier that I’d return briefly to the subject of Dorries’ conduct during the PSC’s investigation, which is perfectly summed up by the Parliamentary Standards Commissioner in paragraph 62 of her own report to the Standards Committee:

62. I have offered Ms Dorries several opportunities to answer the questions I have put to her and I have reminded her of her obligation under the Code of Conduct to cooperate with my inquiry. It would have been open to her, if she could not herself provide the evidence I sought, to authorise ITV or her agent to do so. I note that the Committee on Standards and Privileges, reporting in 2010 on an inquiry into Ms Dorries’ conduct, endorsed the then Commissioner’s view that Ms Dorries had taken too long to provide evidence to the Commissioner and concluded that “that prompt, full and open responses to the Commissioner’s inquiries are of great importance”. I am sorry that on this occasion Ms Dorries has chosen not to co-operate with my inquiry and I accordingly conclude that she is in breach of the Code of Conduct in this respect.

Beyond that, the most noticeable feature of Dorries’ refusal to co-operate with the PSC’s investigation – and I would suggest you read the letters that the PSC and Dorries exchanged between June and August 2013 for yourself as they’re in written evidence document which you can download at the start of this article – is that pretty much all of the information that Dorries refused to provide to the PSC is no more than the same information that she should, under the rules of the House, have registered in the Register of Members’ Interest, and which the Standards Committee has now ordered her to register within 21 days of the publication of the report.

32. Ms Dorries must register the details required by the rules. That leaves her initial failure to abide by the Registrar’s advice, and her attitude toward the Commissioner’s inquiry. The House’s Code of Conduct and disciplinary system depend on Members being prepared to explain their conduct, to submit to public scrutiny and where necessary, to respond to the Commissioner’s inquiries. We recommend that Ms Dorries

– register all payments in respect of her employment, whether or not they have been channelled through Averbrook Ltd or any other third party and

– apologise to the House by way of a Personal Statement.

We expect Ms Dorries to consult the Registrar in person about the detail of her Register entry within 21 days of publication of this Report.

We will monitor Ms Dorries’s compliance and will recommend further action if necessary.

For me this rather glosses over the fact that Dorries refused point blank to provide any information to the House of Commons authorities  about the payments received by Averbrook for her outside media work even after this information as requested as part of a formal investigation by the Parliamentary Standards Commissioner under an assurance that any such information would remain confidential unless or until any of it was published as part of the PSC’s report.

Put simply, Dorries’s initial failure to register her shareholding with Averbrook may have been ‘inadvertent’ given that the initial advice given to her office was correct but based on information that Dorries’ staff had provided which proved to be completely incorrect.

However, having through the committee report and associated written evidence in full, it beggars belief than anyone could reasonably take the same view of her refusal to supply any information beyond referring the PSC to whatever was published at the time via the Companies House webcheck service.

If nothing else it seems evidently clear from the report that Dorries’ repeated claims that rules on the registration of financial interests were being effectively made up on the hoof have absolutely no basis in fact and that Dorries’ had, in fact, arrived at her own preferred but wholly incorrect interpretation of the rule which she stuck to rigidly though out, an interpretation which all too conveniently would permit her to avoid disclosing any specific payments received by Averbrook Ltd for media work she had undertaken.

This is not, in my own honest opinion, the kind of conduct that anyone could reasonably describe as inadvertent, not least in view of the contents of paragraph 30 of the Standards Committee report:

30. It was only after the Committee shared the paper on confidentiality with her that Ms Dorries informed us that she would “seek to ensure that future contract wording is amended to include the exemption provisions” about confidentiality. She also asked to include the following information in her Register entry:

For the year from October 31st 2012 to October 31st 2013:

 Approximate gross income is £142,000

 Giving a profit of £82,000

 A dividend payment of £10,000 is being paid to Nadine today (30.10.2013)

 Nadine spent approximately 60 days working on Averbrook’s projects, which are still best described as ‘writing and media appearances’.

 These figures are provisional before the full accounts are produced in December but Nadine would like the register to be updated as soon as possible.

This information gives a broad view of Ms Dorries’s major activities, and the time she spends upon them. It does not meet the requirement that under category 3 of the register “Clients”:

Members must register […] the precise amount of each individual payment made, the nature of the work carried out in return for that payment, the number of hours worked during the period to which that payment relates.

So even after Dorries’ last line of defence, which relied on confidential clauses in agreements she’d signed for media work, particularly in relation to her appearance ‘I’m  a Celebrity…’, had been comprehensively dismantled, she still attempted to file a register entry which failed completely to provide anything more than a cursory overview of the general state of Averbrook’s finances rather than the list of individual payments received by the company as required by the rules governing the registration of financial interests.

* The question of how Averbrook managed to incur operating costs of £60,000 in the last 12 month is a matter I’ll leave to another occasion.

Although the question of whether or not Averbrook was “a a way of concealing earnings from media appearances and articles” was specifically put to Dorries by the Standards Committee while taking oral evidence from Dorries, the committee’s pursuit of an answer to this question was, to say the least, rather less vigorous than some might expect from their having seen other Parliamentary committees at work:

Q2 Chair: I will open up the questioning and then other members may want to join in. Was Averbrook Ltd a way of concealing earnings from media appearances and articles?

Nadine Dorries: Absolutely not. In fact, that is probably evidenced by the fact that on the very day that Averbrook existed, the first thing that I did was ring the Registrar to say that I wanted the company to be registered. My business partners, who have nothing to do with me personally—he is just a business partner, with his wife—were very clear that, in going into business, they did not want to be brought into the public domain via my political position. I was very keen, however, that everything was done properly, so I rang the Registrar. I did not know at the time what my shareholding was in the company. I said, “I want to be registered,” and was told, “You can’t be.” At the time, I thought it was going to be a minimal shareholding. I was told, “You can’t be, because you haven’t got”—I remember insisting and wanting the company to be registered and for it to be out there, so that I could follow the rules exactly and have it open and there for everybody to see. It is not a means for me to conceal my earnings, because it is not just about me.

And that’s it.

There a couple of observations to be made here.

The first is that Dorries not only claims to have contacted the Registrar personally about registering Averbrook ‘on the very day that Averbrook existed’ – for obvious reasons we’ll take this to be a reference to October 2012, when Dorries became a director and not May 1994, when the the company was actually registered  – but she also claims that she remembers ‘insisting and wanting the company to be registered’.

However, when the Registrar of Members’ Interests was asked by the Parliamentary Standards Commissioner about the advice their office had given on the registration of Averbrook when they were contacted October 2012 they gave this account of their initial contact with Dorries’ office.

You ask what advice this office has given to Ms Dorries about registering her relationship with Averbrook. Ms Dorries has already supplied copies of my email exchanges with her office on October 2012. From these I understood that Averbrook was a new company, to be wholly owned by Ms Dorries, and that it had not yet started trading. I therefore took the view that registration was not needed at that stage. On 18 October I concluded the exchanges by asking Ms Dorries’ office to let us know after she had received the first payment from Averbrook and after its address had been confirmed. We telephoned on 31 October to ask if there was anything to register in relation to Averbrook, and were told there was not. Further reminders were included in my emails of 3 December 2012 and 3 and 18 January 2013.

You’ll notice that there is no mention whatsoever of anyone speaking directly to Dorries in October 2012, let alone Dorries trying to insist that Averbrook should be registered irrespective of the rules – and, indeed, there is nothing whatsoever in the rules to prevent MPs voluntarily registering interests even if this is not actually required by those same rules.

The written evidence provided by the registrar seems to indicate that the email exchanges between Dorries’ office and the Registrar’s Office on 4 and 18 October represent the totality of any contact between the two regarding the registration of Averbrook and as this information forms part of the factual information reported to the committee by the PSC one might have expected this to this obvious discrepancy between Dorries’ oral evidence and that provided by the Registrar to have been noticed and at least commented upon, if not form the basis of further questioning.

Dorries also states, on the record, that her business partners – Andrew Rayment and his wife, Ann – ‘have nothing to do with me personally’ and yet, as has already been noted, Rayment is a former Chairman of Dorries’ own constituency association who, so I understand, also acted as her election agent at the 2010 General Election and who, only last year, ran unsuccessfully for the office of President of Mid Bedfordshire Conservative Association, not to mention a former Member and Leader of Mid Bedfordshire District Council, a former High Sheriff of Bedfordshire (2003-4), a parish councillor in Westoning, a serving trustee of Bedfordshire and Luton Community Foundation and, to cap it all, of course, Rayment is also her landlord and owns the property that Dorries occupies as her main/constituency home, which he bought within a couple months of Dorries finding herself in considerably reduced living circumstances after her relationship with a married man broke down.

And yet. according to Dorries’ evidence to the Standards Committee, he has nothing to do with her personally and does not want to be brought into the public domain by her political position.

And yet the committee let all this pass without comment and moved on to the next question without even going to the trouble of bringing out the comfy cushions, leaving one to wonder whether they somehow managed to mistake Dorries for a spook.

To wrap things up, in the last couple of hours I’ve been forwarded an article published today by the Leighton Buzzard Observer in which, believe it or not, claims that the apology she gave in the House of Commons on Monday was only for ‘being bolshie’ and not for failing to correctly register her interest in Averbrook Ltd:

In response to a report published by the Standards and Privileges Committee the Tory MP said she apologised “fully and unreservedly” for her “inadvertent” breach of the rules in a personal statement read in the House of Commons on Monday.

But speaking to the LBO following the media backlash surrounding the announcement, Ms Dorries said she was actually apologising for being bolshie towards the parliamentary commissioner for standards, Kathryn Hudson.

Ms Dorries, who represents Woburn, said: “I have only done what every other MP does, but the new Parliamentary Commissioner for Standards justified it to put a different interpretation on the role and has used my profile as a way of informing all the other MPs that this is the way it is now.

“My accounts are out there in the public domain, so it’s not like they’re concealed; they’re not, they’re there for everybody to see.

“Lots of MPs have outside earnings, but because I’m so high profile it comes more under the microscope.

“Obviously the impression people got on Twitter and what the media put out was that I had concealed my earnings, but I haven’t.”

…

Ms Dorries added: “I was apologising because the Standards Commissoner wanted me to as I had been so bolshie with her.

“If you read the report what I am apologising for is not cooperating with her. That’s what she is making me apologise for.

“Labour is very much in pack mode at the moment, there are a lot of Labour trolls attacking my Twitter line, but people out on the street are saying to me ‘why are you always getting it?’

“My accounts are fully out there and already reported in the media so I have never attempted to hide anything at all.”

Well, if you’ve got this far then you’ll have already seen that absolutely the one thing that Dorries did not, and has not, apologised publicly and explicitly for is her refusal to co-operate with the investigation carried out by the Parliamentary Standards Commissioner, conduct which has quite clearly had the effect of concealing Dorries’ income from ‘I’m a Celebrity…’ and from her other media work.

You also have learned that neither the rules on registering financial interest nor the manner in which those rules are interpreted have changed since at least 2009 and that there is a direct precedent for disclosure of information that the Standards Committee has now required Dorries to make dating all the way back to 2001.

And, of course, the Parliamentary Standards Commissioner has not made Dorries apologise for anything because the power to apply sanctions when an MP breaks the rule is one reserve solely to the Standards Committee itself.

As usual, what we see in her comments to the Leighton Buzzard Observer is Dorries reverting to her default setting for dealing with situations in which her own rank ineptitude and stupidity has succeeded in dropping her in the mire, which is to spin a complete load of bullshit to the press, blame everyone but herself for own incompetence and then trust that no one, least of all anyone in her constituency, will go to the time and trouble of checking the veracity of her claims.

As the Princeton philosophy professor Harry G Frankfurt observed in his classic monograph ‘On Bullshit’.

It is impossible for someone to lie unless he thinks he knows the truth. Producing bullshit requires no such conviction. A person who lies is thereby responding to the truth, and he is to that extent respectful of it. When an honest man speaks, he says only what he believes to be true; and for the liar, it is correspondingly indispensable that he considers his statements to be false. For the bullshitter, however, all these bets are off: he is neither on the side of the true nor on the side of the false. His eye is not on the facts at all, as the eyes of the honest man and of the liar are, except insofar as they may be pertinent to his interest in getting away with what he says. He does not care whether the things he says describe reality correctly. He just picks them out, or makes them up, to suit his purpose.

For me, that describes Dorries perfectly.