Akcagoz; Secretary, Department of Social Services and (Social services second review)
[2017] AATA 815
•8 June 2017
Akcagoz; Secretary, Department of Social Services and (Social services second review) [2017] AATA 815 (8 June 2017)
Division:GENERAL DIVISION
File Number(s): 2016/5122; 2016/5123; 2016/5124
Re:Secretary, Department of Social Services
APPLICANT
Nuray AkcagozAnd
RESPONDENT
DECISION
Tribunal:Mrs J C Kelly, Senior Member
Date:8 June 2017
Place:Sydney
The Tribunal sets aside the decision under review and substitutes for that decision the decision that all the debts under review are to be recalculated on the basis that Ms Akcagoz was a member of a couple during the period 26 January 2007 to 20 March 2015.
........................[sgd]................................................
Mrs J C Kelly, Senior Member
CATCHWORDS
FAMILY ASSISTANCE AND SOCIAL SECURITY – Parenting Payment – Newstart Allowance – Family Tax Benefit – Child Care Benefit - applicant receiving Parenting Payment, Newstart Allowance, Family Tax Benefit and Child Care Benefit at the single rate– was the applicant a member of a couple during this period – applicant was a member of a couple – debt recoverable in full – decision under review set aside and substituted
LEGISLATION
Social Security (Administration) Act 1999 (Cth) s 4
Social Security (Administration) Act 1999 (Cth)
A New Tax System (Family Assistance) Act 1999 (Cth)A New Tax System (Family Assistance) (Administration) Act 1999 (Cth)
REASONS FOR DECISION
Mrs J C Kelly, Senior Member
8 June 2017
The applicant, the Secretary, Department of Social Services, claims that the respondent, Ms Akcagoz, owes a debt to the Commonwealth of $72,487.40. The Secretary claims that she was a member of a couple with her husband from 26 January 2007 to 20 March 2015 and was therefore not entitled during that period to receive Parenting Payment (PP), Newstart Allowance (NSA), Family Tax benefit (FTB) or Child care benefit (CCB) as a single parent.
Ms Akcagoz claims that she and her former husband separated on 1 February 2000 and that she was entitled to payment of the various benefits at the single rate. She and her husband were divorced on 11 November 2015.
Ms Akcagoz does not dispute the amount of the debt. It is therefore unnecessary to detail how it is made up.
The debts were raised in three decisions made in February, March and May 2016. Ms Akcagoz requested an internal review. On 27 May 2016, an Authorised Review Officer (ARO) affirmed the original decisions. Ms Akcagoz requested an external review of that decision. On 23 August 2016, the Social Services and Child Support Division of this Tribunal (AAT1) reviewed the ARO’s decision and substituted a new decision that all the debts under review are to be recalculated on the basis that Ms Akcagoz was not a member of a couple during the relevant period. It is that decision that the Tribunal is reviewing.
Background
Ms Akcagoz was born in 1970 and married in Turkey in 1994. Her parents have owned a home in Fairfield since 1986. She and her husband returned to live in Australia in 1998. Her parents’ address is referred to as the Fairfield premises.
There are three children of the marriage, two female children born in 1995 and 1999, and a male child born in 2001.
Ms Akcagoz registered with the Child Support Agency on 1 February 2000. A letter dated 14 March 2000 from the Regional Child Support Registrar addressed to her at the Fairfield premises, noted that she had requested Mr Akcagoz to pay the child support directly to her. She accepts that she has never requested assistance from that Agency to enforce Mr Akcagoz’s obligations. In a letter dated 5 November 2013, addressed to Ms Akcagoz at the Fairfield Heights premises, the General Manager, Child Support Smart Centres wrote that her application to include her 18 year child in the calculation of child support had been accepted.
The issue in this case
The issue in this case is whether Ms Akcagoz was a member of a couple during the debt period. The resolution of that question depends on whether the Tribunal accepts that Ms Akcagoz is a credible witness. That requires the Tribunal to decide whether it accepts the claims Ms Akcagoz has made and explanations she has given about her relationship with her former husband after the debt was raised, or accepts the representations she and her husband have made in applications to real estate agencies to lease premises in Smithfield and Fairfield Heights during the debt period that they would both be tenants of the premises, with three children. Other conduct of Ms Akcagoz and her husband during the debt period also has to be considered to determine whether she was a member of a couple.
The law
Given that the issue in this case is one of credibility, it is unnecessary to extensively detail the relevant legal provisions. The legislative framework is set out in the Social Security Act 1991 (Cth) (the SS Act), the Social Security (Administration) Act 1999 (Cth) (the SSA), A New Tax System (Family Assistance) Act 1999 (Cth) (FA Act), and A New Tax System (Family Assistance) (Administration) Act 1999 (Cth) (FAA Act).
Subsection 4(1) of the SS Act defines “partner” as follows:
partner, in relation to a person who is a member of a couple, means the other member of the couple.
Section 4(2)(a) of the SS Act relevantly provides:
Member of a couple - general
2Subject to subsection (3), a person is a member of a couple for the purposes of this Act if:
(a)the person is legally married to another person and is not, in the Secretary's opinion (formed as mentioned in subsection (3)), living separately and apart from the other person on a permanent or indefinite basis; …
Section 4(3) of the SS Act outlines when a person is considered to be a member of a couple for the purposes of paragraph 4(2)(a) of the SS Act:
Member of a couple—criteria for forming opinion about relationship
3In forming an opinion about the relationship between 2 people for the purposes of paragraph (2)(a), subparagraph (2)(aa)(ii) or subparagraph (2)(b)(iii), the Secretary is to have regard to all the circumstances of the relationship including, in particular, the following matters:
(a)the financial aspects of the relationship, including:
(i) any joint ownership of real estate or other major assets and any joint liabilities; and
(ii) any significant pooling of financial resources especially in relation to major financial commitments; and
(iii) any legal obligations owed by one person in respect of the other person; and
(iv) the basis of any sharing of day-to-day household expenses;
(b)the nature of the household, including:
(i) any joint responsibility for providing care or support of children; and
(ii) the living arrangements of the people; and
(iii) the basis on which responsibility for housework is distributed;
(c)the social aspects of the relationship, including:
(i) whether the people hold themselves out as married to, or in a de facto relationship with, each other; and
(ii) the assessment of friends and regular associates of the people about the nature of their relationship; and
(iii) the basis on which the people make plans for, or engage in, joint social activities;
(d)any sexual relationship between the people;
(e)the nature of the people's commitment to each other, including:
(i) the length of the relationship; and
(ii) the nature of any companionship and emotional support that the people provide to each other; and
(iii) whether the people consider that the relationship is likely to continue indefinitely; and
(iv) whether the people see their relationship as a marriage-like relationship or a de facto relationship.
The evidence before the Tribunal
The Secretary provided to the Tribunal three bundles of documents comprising 1111 pages pursuant to s 37 of the Administrative Appeals Tribunal Act 1975 (Cth) (the T documents). The Secretary also provided to the Tribunal a comprehensive 19 page Statement of Facts, Issues and Contentions.
The objective evidence and Ms Akcagoz’s explanations
Ms Akcagoz does not dispute the objective contemporaneous evidence on which the applicant relies, including lease documents and immigration records, to show that she was a member of a couple during the relevant period. However, she gave explanations for her and her husband’s behaviour. She acknowledged to the Tribunal that she had not been truthful in the documents provided to real estate agents when applying for leases, said that she would do it again and that she is not the only one to tell lies to accommodate her family.
On 19 January 2007, Mr and Ms Akcagoz applied for a lease of a residential property at Smithfield in New South Wales. The application was made in writing to the managing agent. In support of the application:
(a)Mr Akcagoz supplied evidence of his income in the form of payslips;
(b)He produced his current NSW driver’s licence which showed his address was at Fairfield West;
(c)He provided rate notices for the residential property at Fairfield West;
(d)He provided the front page of a contract for sale of that property dated 7 December 2006, which showed that he was the vendor, and the sale price;
(e)Ms Akcagoz supplied a statement of account for her St George bank account for the period 20 August 2006 to 19 September 2006;
(f)Ms Akcagoz produced her current NSW driver’s licence, which showed her address as the Fairfield premises, a different address from that of her husband.
In the application for lease document dated 19 January 2007:
(a)Mr Akcagoz said that:
(i)His current address was at Fairfield West;
(ii)His reason for leaving his current address was “sold”;
(iii)His spouse was Ms Akcagoz, and he had three dependent children;
(iv)There would be five people living at the rented premises at Smithfield, being two adults and three children.
(b)Ms Akcagoz said that:
(v)Her current address was the Fairfield premises;
(vi)Her spouse was Mr Akcagoz, and she had three dependent children; and
(vii)Her occupation was “self employed” (her business was a cleaning business), and she worked in that business at the Fairfield West address (Mr Akcagoz’s nominated residential address which he had owned before sale).
On 22 January 2007, Mr and Ms Akcagoz signed a residential tenancy agreement for the Smithfield premises as tenants. The tenancy agreement was to commence on 26 January 2007.
On 1 February 2007, Mr and Ms Akcagoz lodged a bond of $1,360 with the Department of Fair Trading for the Smithfield premises.
On 19 September 2008, Mr and Ms Akcagoz signed another residential tenancy agreement for the Smithfield premises.
On 30 August 2009, Mr and Ms Akcagoz travelled overseas together, returning together on 16 October 2009.
On 2 June 2011, Mr and Ms Akcagoz applied for a lease of a residential property at Fairfield Heights.
In his application form dated 2 June 2011, Mr Akcagoz relevantly said that:
(a)His current address was the Fairfield premises;
(b)he had lived there for six years;
(c)he had not been renting those premises;
(d)two adults and three children would occupy the premises at Fairfield Heights.
In her application form dated 2 June 2011, Ms Akcagoz relevantly said that:
(a)her current address was the Smithfield premises;
(b)she had lived there for four and a half years;
(c)her emergency contact was her mother at the Fairfield premises; and
(d)two adults and three children would occupy the Fairfield Heights premises.
On 14 June 2011, Mr and Ms Akcagoz vacated the Smithfield premises and gave their forwarding address as Fairfield Heights.
On 1 January 2013, Ms Akcagoz started receiving Newstart Allowance (NSA) as a single parent, and continued receiving that payment at that rate until 31 October 2014.
On 2 August 2014, Mr and Ms Akcagoz signed another residential tenancy agreement for the Fairfield Heights premises. In response to a notice from Centrelink dated 11 June 2015, the real estate agency confirmed that Mr and Ms Akcagoz were the tenants of that property.
On 30 July 2015, Ms Akcagoz participated in an interview with a Departmental officer (the interview). Her answers were recorded. She agreed that the written answers were correct.
Throughout the relevant period, the Department sent letters to Ms Akcagoz asking her to inform it of any changes to her circumstances which may affect her entitlement to or the rate of benefits or payments.
The claims Ms Akcagoz made during the interview on 30 July 2015
During the 30 July 2015 interview, Ms Akcagoz claimed that:
·She and the children lived with her parents at the Fairfield premises from 1998 when she returned to Australia until 2007 when she moved to the Smithfield premises.
·She agreed that her father moved into the Smithfield premises for a while and then went overseas. Departmental records showed that her father’s claimed address from 28 January 2007 to 7 June 2011.
·Mr Akcagoz’s name was on the lease for the Smithfield premises because she needed a second name. A lot of her friends said she would have a better chance of getting the property if she had a second applicant. As she told Child Support, rather than Mr Akcagoz paying regular amounts, it was logical he would help pay half the rent. That was their mutual agreement. As he was paying half the rent, it was logical his name would be on the lease. He never lived there but came over a lot to see the children. He probably stayed over.
·She had a business and a work vehicle registered in her name at the time of the lease for the Smithfield premises. She accepted that the business was registered at the Fairfield West premises owned by Mr Akcagoz but said that she went there for work but never lived there. Departmental records showed that the business was registered as trading and earning income from approximately September 2006 to January 2010.
·The income recorded in her application form lodged on 19 January 2007 with the real estate agency as earnings as “self-employed person” was not from the business, but from the parenting allowance.
·The second adult referred to in the 2011 application for the lease for the Fairfield Heights premises, was her father and not Mr Akcagoz. She claimed that Mr Akcagoz comes over regularly. He comes early and takes the children to school and picks them up. He sometimes stayed for dinner. He takes their son to soccer.
·She did not know where Mr Akcagoz lived “at the moment”. She said that he sometimes uses her parents’ address or a postal address or the Fairfield Heights address and that he stays at her parents’ house three or four times a week.
·She had changed the “customer name” on the lease agreement for the Fairfield Heights premises to her name on 2 August 2014. This is inconsistent with the real estate agency’s letter to the Department dated 11 June 2015.
Other relevant information was elicited during the interview including:
·When the interviewer told Ms Akcagoz that there were bank statements in both her and her husband’s name for the period 14 January 2000 to 11 June 2002 that were sent to the Fairfield address, she denied that they both lived there. She said that was where her husband was residing at the time.
·The address of Ms Akcagoz’s bank account in August/September 2006 was the Fairfield premises. There were deposits from a third party into that account. Ms Akcagoz said that she had worked at a warehouse for a period before starting the business and the income disclosed in the application for the lease for the Smithfield premises probably included income from that work.
·Ms Akcagoz acknowledged that $5,640 deposited in a bank account sometime in the period 25 October 2007 to 16 March 2015 was from her employer for her wages.
·Ms Akcagoz acknowledged that she and Mr Akcagoz had a joint personal loan from 22 September 2006 to 24 December 2012 which she said was for the business and said that they both paid the loan.
·Ms Akcagoz had disclosed in the lease application for the Fairfield Heights premises in 2011 that she had begun work as a kitchen-hand at a restaurant on 9 June 2009 earning $15 per hour for 15 hours work per week. She agreed that was correct and said that she was paid in cash.
·An ANZ bank statement in Ms Akcagoz’s name for 17 September 2010 to 4 November 2010 showed wage transfers from that restaurant. She could not remember why she had failed to disclose that to the Department.
·On the same application, Ms Akcagoz disclosed a former employer from November 2006 to May 2009. During the interview she acknowledged that she had worked for that employer.
·Ms Akcagoz acknowledged that Mr Akcagoz deposited $13,185 into one of her bank accounts in the period 25 October 2007 to 16 March 2015. She said that was sometimes for rent or for the children.
·When asked about two bank accounts held in her name from September 2010 which had not been disclosed to the Department, Ms Akcagoz said that she thought she had told the Department.
·When asked about NSW Roads and Maritime Services information that two motor vehicles, a Nissan and a Toyota, were held in her and Mr Akcagoz’ joint names from 3 November 2009 to 17 February 2014 and from 6 March 2000 to 1 October 2013 respectively, Ms Akcagoz said that she did not know why those vehicles were never disclosed to the Department. She denied that the Nissan, which she said Mr Akcagoz drove, was ever registered in her name.
·When asked whether Mr Akcagoz paid Child Support, Ms Akcagoz said that he pays some of the rent, not half, and usually gives her $200 per week, and sometimes he pays for or buys food and groceries for the children.
·Ms Akcagoz said that when other people see them, they regard them as a couple. They have some friends as a couple but the majority of the time they spend time with their own circle of friends.
·Ms Akcagoz said that they go out together once in a while. The children ask if they can go out, and if Mr Akcagoz is around, he will go out for dinner with them.
·Ms Akcagoz said that they did go overseas together once. The children said they would go if she went. When Ms Akcagoz was told that the information showed that they had both gone overseas on 28 May 2003 and 30 August 2009, Ms Akcagoz said that they went with the children and Mr Akcagoz paid for everything and she had some of her own spending money.
·Ms Akcagoz denied attending children’s events together but said that they did attend family events together.
·When asked about the birth of her youngest child being more than 12 months after their separation in 2000, Ms Akcagoz said that after a family event they had talked about getting together, but she was not sure, and at that time Mr Akcagoz had moved out of the Fairfield premises but she could not recall where he was living.
·When asked if she and Mr Akcagoz provided any companionship or emotional support to each other, Ms Akcagoz said yes, when they are around the children because she does not want the children to suffer for their differences.
·Ms Akcagoz told the interviewer that Mr Akcagoz’s workers compensation “had finished recently”, that he had received a lump sum payment and was going to court “for his super”, which she had heard from the children.
·Ms Akcagoz said that she intended to divorce Mr Akcagoz when he returned from overseas, and that he was taking one of their daughters and their young son overseas for five weeks, on the day of the interview.
Information before the Tribunal that is consistent with Ms Akcagoz’s claims
The following information before the Tribunal is generally consistent with Ms Akcagoz’s claims:
·The 2006 water bill for the Fairfield West property was addressed to Mr Akcagoz only.
·Records of rent for the Smithfield premises shows that the payments were made by direct deposits from a bank account in in the name of Ms Akcagoz.
·A 2011 telephone bill for the Smithfield premises was addressed to Ms Akcagoz.
·On 19 July 2011, the Consumer, Trader and Tenancy Tribunal ordered the balance of a bond for the Smithfield premises to be paid to Ms Akcagoz, although the document showing lodgement of the bond dated 1 February 2007 shows both Mr and Ms Akcagoz as tenants.
·A 2010 certificate of registration for a Holden motor vehicle was addressed to Ms Akcagoz at the Smithfield address.
·A 2010 certificate of registration for a Nissan motor vehicle was registered in the name of Mr Akcagoz at the Fairfield address.
·In April and May 2011, workers compensation payments were being sent to Mr Akcagoz at the Fairfield address.
·Ms Akcagoz listed her mother as the emergency contact in the 2011 Fairfield Heights tenancy application.
·In the 2011 Fairfield Heights tenancy application, Mr Akcagoz listed the Fairfield address as his last address for six years and a male friend as the emergency contact.
Additional or inconsistent Information Ms Akcagoz gave to the Tribunal
The following is additional or inconsistent information that Ms Akcagoz told the Tribunal:
·She had tried applying for properties on her own without success before applying in 2007 to lease the Smithfield property with Mr Akcagoz. That property was five minutes’ drive from her parents’ Fairfield home. At the time, she was only receiving NSA. Friends said that she needed a second applicant, every agent asked for a second tenant, and Mr Akcagoz was willing to help her because of the children. He just supplied what the agent requested. He lived with her parents after he sold the Fairfield West property because he was injured at work, was receiving workers’ compensation payments, and was scared he could not make the repayments. Her mother is his aunt.
·She paid for the bond on the Smithfield property. She said that Mr Akcagoz was paying child support and there were letters from the Child Support Agency telling him how much to pay.
·In 2009, Mr Akcagoz wanted to take the children overseas. The majority of his family is there and she refused to send the children with him because he has always had it in mind to move overseas. She paid for herself. She was scared. She stayed in her father’s unit in Istanbul. She has family there. The children took turns staying with their father. This is a different explanation to that given at the interview.
·When asked about Mr Akcagoz giving the Fairfield address for the past six years in the 2011 Fairfield Heights tenancy application, Ms Akcagoz said that that was his main address for a very long time. She does not know if that was true.
·There were a few periods when her father lived with her. Her parents were separated under one roof for 26 years but Centrelink did not accept that. She said that the reason she had not divorced Mr Akcagoz was that her father did not approve of divorce until he saw how it was affecting her.
·It was logical for Mr Akcagoz to pay her half the rent instead of child support and he paid her in cash. He started off paying her $250 a month. The Child Support Agency told him to pay more according to his earnings.
·When they attended community events they looked like a normal family.
·The children know that they are separated but she and Mr Akcagoz do not argue in front of the children. They give each other advice but there is no companionship between them.
·Mr Akcagoz paid for the children to go overseas in 2009.
·To the best of her knowledge, she always reported correctly to Centrelink.
·She gave her husband’s address to her son’s school because that address was close to the school.
·She was not concerned about Mr Akcagoz abducting the children when he took them overseas in July 2015 because they were then 13 and 19.
·Mr Akcagoz permanently left Australia in July 2016. She had informed him that he might get a call from the Department.
·Her adult daughter, who lives with her, was not giving evidence because that is the past and she does not want her children going back to the past and her daughter was never involved in the fights with her father.
Consideration of the evidence and findings
Ms Akcagoz is asking the Tribunal to accept that while she lied to the real estate agents in order to provide accommodation for her family, she has been honest in her dealings with the respondent and when giving evidence before AAT1 and this Tribunal.
For the following reasons, the Tribunal does not accept Ms Akcagoz’s evidence about where Mr Akcagoz lived, particularly during the period 2007 to 2015.
The unasked and unanswered question which stands out from the above evidence is why did Ms Akcagoz move out of the Fairfield premises in 2007, after living there since returning from Turkey in 1998 for about nine years? That timing coincides with Mr Akcagoz having to sell the Fairfield West premises because he had been injured and was receiving workers compensation payments. That finding is supported by objective contemporaneous evidence: the contract for sale of those premises and payment records showing that Mr Akcagoz was receiving workers compensation from at least December 2006.
While Ms Akcagoz’s explanation is plausible, another plausible explanation is that she, Mr Akcagoz and the children lived in the Fairfield West premises before leasing the Smithfield premises and then moved there. Although she denied living at the Fairfield West premises, the business was registered at that address and she said that she went there to conduct her business.
The evidence is clear that Ms Akcagoz is quite prepared to lie to benefit her family. Maximising the benefits she receives from the respondent benefits her family, as did lying to her son’s school about where he lived. Her evidence in cross-examination demonstrated that she had failed to disclose information to the respondent about her employment, earnings and bank accounts, contrary to her claim that she had disclosed all relevant information. The Tribunal found Ms Akcagoz’s uncertainty about where Mr Akcagoz lived to be inconsistent with the evidence that shows he was providing the Fairfield premises address over a long period of time. If he was living with her parents, or at least her mother who is his aunt, the Tribunal does not accept that Ms Akcagoz would not have known.
The Tribunal does not believe Ms Akcagoz’s claims about her and Mr Akcagoz’s living circumstances. The Tribunal finds that they were living together in the properties which Mr Akcagoz owned and that they leased together. In making that finding, the Tribunal accepts that they have now divorced but does not accept that that demonstrates that their relationship has ended.
While not essential to the findings in this case, the evidence shows that while Mr Akcagoz was claiming to live at the Fairfield premises, Ms Akcagoz’s father was claiming to live at the Smithfield and Fairfield Heights premises, although travelling overseas from time to time.
Ms Akcagoz told the interviewer that a $19,976 deposit into one of her bank accounts on 20 November 2014 was money her father had brought back from overseas to surprise her mother and that he used it to pay for a Toyota Corolla in December 2014. Wishing to surprise his wife in such a way is inconsistent with their being separated under the one roof for years as Ms Akcagoz claimed.
Ms Akcagoz told the Tribunal that Centrelink would not accept that her parents had separated under the one roof. She also said that they divorced in 2016. The Tribunal infers that her parents had been seeking to be paid a single rate of pension.
That Mr Akcagoz left Australia on the day of the interview with two of the children is a notable coincidence, as is his having more recently returned to Turkey to live permanently. Ms Akcagoz told AAT1 on 23 August 2016 that her former husband had left Australia to go and live in Turkey as a permanent resident in July 2016. She also said that her father had left for Turkey about three months before. AAT1 had wanted to take evidence from Mr Akcagoz and Ms Akcagoz’s father. The hearing before this Tribunal was held on 14 March 2017. Mr Akcagoz was in Turkey. The Tribunal accepts that it could have tried to call him to give evidence using an interpreter but did not do so.
The Tribunal finds that Mr Akcagoz has always provided financial support for his children according to Ms Akcagoz and was closely involved in his children’s lives, including taking his son to soccer. The Tribunal does not accept that his returning to Turkey permanently is consistent with that close involvement. The Tribunal has taken into account that the children are now about 22, 19 and 16 years of age. However, it does not accept that he has in fact returned to live in Turkey permanently. Rather he has sought to avoid or make difficult being questioned in relation to the circumstances giving rise to the debt. In making that finding, the Tribunal has taken into account the email correspondence between him and the respondent in February 2017.
Taking into account all the evidence before the Tribunal and the criteria in s 4(3) of the SS Act, it finds that Ms Akcagoz was a member of a couple during the period 26 January 2007 to 20 March 2015. It follows that the debts has been properly raised and are legally recoverable debts to the Commonwealth.
There is no administrative error in this case and therefore no waiver is to be applied on that basis under the relevant legislation. This is no other basis for the debt being waived or written off.
Decision
The Tribunal sets aside the decision under review and substitutes for that decision the decision that all the debts under review are to be recalculated on the basis that Ms Akcagoz was a member of a couple during the period 26 January 2007 to 20 March 2015.
I certify that the preceding 46 (forty-six) paragraphs are a true copy of the reasons for the decision herein of Mrs J C Kelly, Senior Member
........................[sgd]................................................
Associate
Dated: 8 June 2017
Date(s) of hearing: 14 March 2017 Solicitors for the Applicant: Dr S Thompson, Department of Human Services Respondent: In person
Key Legal Topics
Areas of Law
-
Administrative Law
-
Statutory Interpretation
Legal Concepts
-
Appeal
-
Judicial Review
-
Procedural Fairness
-
Statutory Construction
0
0
0