The sole survivor of a sectarian massacre of 10 Protestant workmen in Northern Ireland has led a solitary life since the slaughter, a lawyer told an inquest.
Alan Black was shot 18 times and left for dead alongside the lifeless bodies of his friends, cut down in a hail of bullets by a South Armagh roadside in 1976, blamed on the IRA.
He has problems trusting people and suffered health issues, a Belfast courtroom was told. The elderly former engineer applied for legal representation in an upcoming coroner's investigation into a mass killing near the village of Kingsmill, one of the most notorious Troubles shootings.
Barrister Fiona Doherty told the hearing: "He has not been able to work since the shooting and leads a solitary life."
The textile workers were gunned down after a masked gang stopped their minibus close to Kingsmill as they were travelling home from work.
They were forced to line up alongside the van and ordered to divulge their religion. The only Catholic was told to flee while the 11 remaining were shot.
No-one has ever been convicted of the murders, widely blamed on the IRA even though the organisation never admitted responsibility.
Ms Doherty said the only survivor had left school at 15 and worked as a mechanic or engineer until the incident.
She argued that she should be allowed to represent him, alongside relatives of the deceased, during what is expected to be one of the largest inquests in recent times in Northern Ireland.
She claimed it would be nearly impossible for him to properly understand and respond to the evidence and stressed his importance to shed light on what happened.
"He is not simply a witness, he is a survivor.
"He is the only person who can give a first hand account of what happened."
She told coroner Brian Sherrard it may be only when another witness gave evidence or documents were made available that the value of his input was realised.
"The court should be very slow to disregard that full input and the benefit that you and the inquest get from having that input."
She argued counsel for the coroner could not adequately replace a dedicated lawyer.
"He needs help and support to come from people he knows and trusts and has built up a rapport with. He has issues with trust stemming from the incident...and he needs help and support to be fully informed."
She warned the consequences of not granting legal representation could be profound.
"There is a real risk that the inquest will pass him by."
A barrister for the Police Service of Northern Ireland (PSNI), Peter Coll, asked what purpose would be served.
"What extra element will be brought to the inquest proceedings, what marks Mr Black out as being different from a witness/survivor in any other incident?
"We respectfully say there would be nothing to be gained from it."