applicant gave his account. I do agree that Person 14 would have been well-placed to see the engagements described by the applicant if they had occurred.
753 These are the submissions that the respondents, who filed their closing written submission first, anticipated would be made by the applicant based on his cross-examination of Person 14 and their answers to the submissions. The submissions the applicant made about Person 14's evidence in both his closing written submissions and his closing oral submissions were as follows. Person 14 should not be accepted as a reliable witness. Person 14 is a perjurer and the applicant challenges his credibility (honesty) as well as his reliability. The applicant relies on the submissions he makes in the context of the mission to Chinartu concerning Person 14's reliability as a witness. I have addressed those matters in Section 5 of this Part. As I said early in this Section, the whole of a witness' evidence must be taken into account. In addition, the applicant relied on the matters which follow.
754 First, the applicant submits that Person 14 was, to start with, not completely honest in answering questions about his dealings with journalists and that this lack of honesty was not confined and affects his evidence more generally. The applicant submits that Person 14 was evasive about his contact with Mr Masters. He said that Mr Masters called him in January 2018 trying to organise a "catch up" in Canberra. Person 14 suggested that Mr Masters indicated that the catch up was as a result of, or connected with, Mr Masters developing or preparing a second edition of his book. He said that he had no further contact with Mr Masters after January 2018. Later in his cross-examination, he admitted that he had another meeting with Mr Masters in 2018. Person 14 said in his evidence that another meeting with Mr Masters was coming back to him on there being mention of Mr McKenzie (the second respondent). Initially, Person 14's evidence was that at the subsequent meetings with Mr Masters and Mr McKenzie, he did not discuss operations in Afghanistan.
755 Secondly and relatedly, the applicant submits that Person 14's evidence that he could not recall what was discussed in meetings with Mr McKenzie at further meetings that occurred in February and/or March 2018 was not credible in view of his recollection of the topics he discussed at the meeting with Mr Masters in January 2018. In addition, Person 14's denial that he provided information against the applicant to Mr McKenzie was not credible. He was asked about his meetings with Mr McKenzie and Mr Masters in or around February and March 2018. Person 14 said he definitely did not discuss matters concerning operations in Afghanistan in the subsequent meetings. Later, he agreed that he told Mr Masters at the meeting at which
