Here is the cross examination of Dr Ravi Jayaram by Myers about child K. No it was not put to him that that the incident didn't happen.
Prosecution evidence, February 28th 2023, Day 63 - live updates Chester Standard -
LIVE: Lucy Letby trial, Tuesday, February 28
Child K
Dr Ravi Jayaram
Cross-Examination
2:26pm
Mr Myers says Dr Jayaram was worried about being irrational at the time.
Dr Jayaram said he was concerned and didn't want to see Child K in a different condition. They were not based on a clinical reason, or if Child K had any underlying conditions.
Mr Myers said he believed, from Dr Jayaram's interview with police, the suspicious behaviour had been deliberate.
Dr Jayaram: "That had crossed my mind, yes."
Mr Myers: "You 'got her', then?"
Dr Jayaram: "No."
Dr Jayaram said he wanted this investigated objectively in a proper way, and there was "absolutely no evidence that we could prove anything - as that is not our job, we are doctors."
Mr Myers said he had told the police if the tube had been dislodged on purpose. He asks if he had confronted Lucy Letby.
"No, absolutely not." Dr Jayaram said he was focused on the situation.
Mr Myers says it did not happen in the way Dr Jayaram describes.
Dr Jayaram: "I am interested in why you say that."
Mr Myers says it is not documented in medical notes.
Dr Jayaram says that would not be the sort noted in medical documentation.
Mr Myers says there is nothing to say the tube is dislodged.
Dr Jayaram says it is obvious from the medical notes.
2:30pm
He says, in isolation, the incidents were unusual, and more concerning in a pattern of behaviour.
He said: "We, as a group of consultants by this stage, had experience of an unusual event, and there was one particular nurse.
"All of these events were unusual. Yes, if we put in Datix [incident forms] we could have investigated sooner and been here [in court] sooner."
He said he, and his other consultants, wanted to know how this could be investigated, and tried their best to escalate concerns higher up the hospital.
Mr Myers says there is no record anywhere of the suspicious behaviour noted.
Dr Jayaram says he did not anticipate being sat in a courtroom, years down the line, speaking to Mr Myers.
"If you feel someone is deliberately harming [children], you would do so, wouldn't you?"
Dr Jayaram said concerns had been raised before February 2016, and were raised again following this incident.
Mr Myers says Lucy Letby continued to work at the unit for a further four months.
2:34pm
Dr Jayaram says the concerns were first raised in autumn 2015 with senior management, but were told that there was likely nothing going on.
He said the consultants went 'ok', and against their better judgment, carried on.
"We were stuck, as we had concerns.
"In retrospect, we wished we had bypassed them [senior management] and contacted the police."
"We by no means had played judge and jury, but the association was becoming clearer and clearer.
"This is an unprecedented situation for us - we play by a certain rulebook, and you don't start from a position of deliberate harm.
"It is very easy to see things that aren't there - in confirmation bias.
"But these episodes were becoming more and more and more frequent by association."
Dr Jayaram said it should have been documented throughout more.
He says he discussed the incident, but did not formally document it.
Dr Jayaram said he was getting "a reasonable amount of pressure from senior management not to make a fuss".
2:36pm
Dr Jayaram says he does not understand why an alarm did not go off, and why a call for help had not gone out when Child K was desaturating.
He said, in relation to the suspicions, he "did not want to believe it".
He said it "took a long time for police to be involved".
2:39pm
Dr Jayaram says the tube is 'very unlikely' to have been dislodged by a 25-week gestational age infant, in that short timeframe.
He says that can happen when a baby is 'very vigorous' - heavier, stronger babies, or when a baby is being handled or receiving cares.
Mr Myers said it was still possible for the tube to be dislodged by Child K.
Dr Jayaram says 'anything is possible', but Child K was 'not a very active baby', and a baby of this weight, size and age meant that was unlikely.
2:42pm
Dr Jayaram said the receiving consultant would not have assumed the tube had been dislodged by anyone else.
Mr Myers says the alarm on the ventilator was not alarming, according to Dr Jayaram.
Dr Jayaram says he had not got up because the alarm was going off. He said if it was, he would have been prompted to go in, and that would have been his reason for going in the nursery room.
Mr Myers asks if a conversation took place with Ms Williams after the desaturation.
Dr Jayaram says he does not recall the conversation. He says: "Why would I ask her what happened in the room when she wasn't there?"
2:48pm
The court is shown swipe data for Joanne Williams, who left the neonatal unit at 3.47am.
Mr Myers says it is very precise in coinciding with Dr Jayaram's recollection of waiting two-three minutes before the desaturation is timed at 3.50am, and asks if Dr Jayaram always has such a precise memory.
Dr Jayaram says "In this event, I did."
He adds: "I kept telling myself, don't be ridiculous [about my suspicions]. I looked at my watch - I didn't have a stopwatch."
Dr Jayaram says he has never seen the swipe data, nor had cause to look at any data.
Dr Jayaram says it would be appreciated if Mr Myers gave an indication of where he was going with his questioning.
Mr Myers says an earlier police interview had Dr Jayaram not giving a precise estimate how long Joanne Williams had been out, but is able to give a more precise estimate now, several years later.
Dr Jayaram says he has had more time to reflect on this incident.
Dr Jayaram: "The point is, this incident happened in the window when she [Joanne Williams] was out."
He tells the court the incident of this night is "emblazoned" in his mind.
2:54pm
Dr Jayaram adds he "refutes" the allegation the care the hospital team provided contributed to the outcome of Child K.
Mr Myers asks if the focus on this incident was to "distract" from the overall care provided by the medical team to Child K.
Dr Jayaram: "Well, that's an easy one to answer: Absolutely not."
"Are you seeking to bolster suspicion against Lucy Letby?"
"Absolutely not."
Mr Myers asks if there was an opportunity, within the 48 hours before Child K's mother gave birth, to transfer her to a tertiary centre. Dr Jayaram says he does not have that decision to make, and cannot answer that, but adds there were many factors to consider.
2:57pm
Dr Jayaram is asked about the intubation process.
Mr Myers says the process was carried out by a 'relatively junior registrar', Dr James Smith. Dr Jayaram said Dr Smith had been assessed as competent and experienced enough, and it was 'standard practice' to carry out these procedures.
"I could see he could do this, and safely."
He adds if Child K was struggling to be ventilated at the time, and the heart rate and saturations were not being maintained, then he would have taken over.
3:00pm
Mr Myers asks about the high air leak.
Dr Jayaram says the 94% leak is a measured value, and is significant is the baby is struggling to be ventilated; but if the baby is being ventilated, then it is just noted.
Mr Myers says lung surfactant should be administered within five minutes of intubation. Dr Jayaram: "Ideally, yes."
He says it is used to improve gas exchange.
If it is given slightly later than expected, it would "not make much difference in the long run", as it is important the baby is receiving ventilation at the time.
3:07pm
Mr Myers asks why only Dr Jayaram and not Dr James Smith made notes. Dr Jayaram says he does not know why that was the case.
Dr Jayaram's medical notes are shown to the court, and the medicines are highlighted. Mr Myers says it appears the antibiotics have been delivered at the right time.
3:10pm
A prescription chart is shown for one of the medicines, 'time given 0445'. Dr Jayaram agrees it appears it was administered at that time, and should have been administered sooner.
He says the late administration of the antibiotics is important, the vitamin K not so.
Mr Myers says he will next talk about the morphine infusion.
3:28pm
Dr Jayaram is asked about the morphine infusion recorded, which appears on the notes above a note added, timed at 3.50am.
Dr Jayaram says, having seen the prescription chart, the morphine infusion would not have happened before the desaturation.
Mr Myers said Dr Jayaram had told police Child K had been sedated with morphine. Dr Jayaram said that was what he had believed at the time.
Dr Jayaram says Child K was not on a morphine infusion prior to the desaturation. "However", she was not a vigorous baby.
He says, in retrospect, he will accept the morphine was not running prior to the desaturation.
He says he is "surprised" it was not running sooner.
He says he believed, "in good faith", the morphine was running at the time.
Mr Myers: "Have you tried to shift your evidence? That you can't blame it on morphine?"
Dr Jayaram: "Even accounting for the fact she was not on morphine, she was a 25-week gestational age", small, and weighing 600g and was stable - 'poorly, but stable'. He says that the dislodging happened in such a short space of time was "concerning".
He says Child K was able to move her arms and legs, but not enough to dislodge a tube.
He says his previous statement was based on a "genuine misunderstanding based on my notes".
He says he does not accept he made a "deliberate error".
3:30pm
Dr Jayaram says he is not aware of a nursing note recording 'blood-stained oral secretions'.
The nursing note by Joanne Williams which refers to this is shown to the court.
Dr Jayaram says that is in the back of Child K's mouth, not in the tube, and is not clinically relevant. It was "not a significant finding".
He says he would have noted if the tube had been blocked, and he would have noted it.
3:33pm
Dr Jayaram says the tube blockage would lead to a gradual deterioration, quite quick, but did not fit the pattern of Child K's deterioration.
Mr Myers suggests the care of Child K provided could have been improved.
Dr Jayaram said it could have been better.
Mr Myers suggests Dr Jayaram has added to his account over the years.
Dr Jayaram: "I would disagree with that - you would be questioning my brevity and honesty."
