30th November 1979 an in-house committee of Air New Zealand met on the
instruction of Mr Davis for the purpose of deciding how to collect
together all available information relevant to the accident. It seems
that it began its practical work on Monday 3rd December. In that regard
and as an example of the way in which the applicants say the cover-up
allegation could have been answered by those affected they placed
material before this Court which would suggest that the formation of
such a committee is a conventional step taken by an airline when
confronted with any serious disaster, that it was required by this
company's Accident Investigation Procedures Manual, and that this
committee was appointed accordingly. If it had been before the Inquiry
it would have supported the view that Mr Davis had decided the chairman
should not be associated with the flight operations side of Air New
Zealand and for that reason he appointed Mr Watson who had charge of
certain related companies. There is also an affidavit sworn by Captain
Priest who was appointed by the Airline Pilots Association to sit as its
representative on the committee. Taken at its face value it is to the
effect that he took part in the committee's work from the meeting on 3rd
December. In the affidavit he has explained: "My position on that
Committee was an ALPA watchdog--there were two other independent
members"; that as the inquiry progressed "it became apparent that the
committee was amassing a large amount of papers"; and that Mr Watson
then announced that he had been directed by the chief executive to get
all the information onto one file and any surplus disposed of to avoid
information getting into the wrong hands. The affidavit indicates that
it was then agreed by the committee itself that this should be done on
the basis that the master file was to be available to the committee
members at any time and it appears that Captain Priest joined in that
decision. It is not for us to decide what would have been the effect or
significance of all this material if it had been placed before the Royal