Day 053 - 22 Nov 94 - Page 04


     
     1   MS. STEEL:  I am coming to explain a bit more, anyway.  We would
     2        say that the word "link" is an ordinary English word which
     3        means "connection", "relationship" or "association", and
     4        that, accordingly, the word "linked" used in the leaflet
     5        means "connected", "related" or "associated".
     6
     7        For the assistance of the court, we would explain a bit
     8        more about "link", although we would not necessarily want
     9        this to be taken as an exhaustive list; and that is that
    10        "cause" is one type of link, statistical association is
    11        another, promotion is another, and treatment is another.
    12
    13        Additionally, the word encompasses -----
    14
    15   MR. JUSTICE BELL:  What do you mean by "treatment"?
    16        I understand the others.
    17
    18   MS. STEEL:  If, say, heart disease can be cured by adopting a
    19        certain diet, then it would follow that there was some kind
    20        of relationship there, some kind of link.
    21
    22        Additionally, the word encompasses an indirect link, for
    23        example, through obesity.
    24
    25   MR. JUSTICE BELL:  I understand that.  But that could be a
    26        causal link, could it not?
    27
    28   MS. STEEL:  Yes.
    29
    30   MR. JUSTICE BELL:  Because if you said fatty foods, the greater
    31        the risk of putting on weight, the greater the risk of
    32        obesity, more adipose tissue, breast cancer, you might say
    33        it is indirect, because you have had to go through a number
    34        of connective stages, but it would still be a causal link.
    35
    36   MS. STEEL:  Yes; and also changing of the age of menarche, and
    37        some of the other ones that were referred to.  There is
    38        also a protective factor which could be described as a link
    39        with fibre and foods with -----
    40
    41   MR. JUSTICE BELL:  The more fat you eat, the less fibre, you
    42        say; or there is a tendency, if you have a fatty diet, to
    43        have one which is lower in fibre; is that the point?
    44
    45   MS. STEEL:  If you have a diet, for example, that is high in
    46        animal products, proportionately, it must be lower in
    47        vegetable products, because the "high" indicates that there
    48        is more of one than the other.  So it is not just the
    49        protective effect of fibre; it is also vitamins A and C
    50        found in vegetables, in particular. 
    51 
    52        The leaflet does actually mention "low in fibre", so 
    53        obviously we would argue that there is a protective link
    54        inferred by that.
    55
    56        Any one of those, we submit, would be enough to prove the
    57        word "link"; and we would say that "cause" goes further
    58        than "link" and, if we prove "cause", then so much the
    59        better.  We would say that we feel we have proved cause, in
    60        any event.  But whether or not you felt that, we feel that

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