Antonious v Comcare
[2018] AATA 3968
•4 October 2018
Antonious and Comcare (Compensation) [2018] AATA 3968 (4 October 2018)
Division:GENERAL DIVISION
File Number(s):2018/4758; 2018/4759
Re:Artif Antonious
APPLICANT
AndComcare
RESPONDENT
DECISION
Tribunal:Chris Puplick AM, Senior Member
Date:4 October 2018
Date of written reasons: 22 October 2018
Place:Sydney
The applications for extensions of time in the two matters before the Tribunal (2018/4758 and 2018/4759) are granted to 22 August 2018.
.........................[sgd]...............................................Chris Puplick AM, Senior Member
CATCHWORDS
COMCARE – Extension of time applications – judicial guidance on time limits and extension of time applications considered – whether acceptable explanation of the delay – whether extension fair and equitable in the circumstances – whether applicant rested on their rights – prejudice to the respondent caused by the delay – prejudice suffered by general public - merits of substantial application – considerations of fairness as between the applicant and other persons – extension of time applications granted
LEGISLATION
Safety, Rehabilitation and Compensation Act 1988 - ss 16, 65
Administrative Appeals tribunal Act 1975 - s 29
CASES
Berkelaar v Comcare [1997] AATA 12015
Brisbane South Regional Health Authority v Taylor (1996) 186 CLR 541
Brown v Federal Commissioner of Taxation [1999] FCA 563
Carney v Comcare (Compensation) [2018] AATA 164
Comcare v A'Hearn [1993] FCA 498
Crick and Prosegur Australian Pty Ltd [2016] AATA 313
Dela Rosa and Minister for Immigration and Border Protection [2018] AATA 1262.
Djapouras v Comcare Oral decision dated 10 October 2017, No 2017/5266
Doyle v Chief of Staff [1982] FCA 124; (1982) 42 ALR 283
Emery and Comcare [2016] AATA 647
Hillman v Australian Postal Corporation [2017] AATA 1411
Hunter Valley Developments Pty Ltd and Others v Minister for Home Affairs and Environment (1984) 3 FCR 344
Jamal v Secretary, Department of Social Services [2018] FCA 513
Kim and Minister for Immigration and Border Protection 920180 AATA 155
Lucic v Nolan (1982) 45 ALR 411
MZABP v Minister for Immigration & Border Protection [2015] FCA 1391; 242 FCR 585
MZABP v Minister for Immigration & Border Protection [2016] FCAFC 110; 152 ALD 478
O’Gorman and Comcare (Compensation) [2017] AATA 2192
Outboard Marine Australia Pty Ltd v Byrnes [1974] 1 NSWLR 27
Phillips v Australian Girls’ Choir [2001] FMCA 109
Ralkon v Aboriginal Development Commission [1982] FCA 153
Romeo and Secretary, Department of Social Security [1992] 26 ALD 248
Wedesweiller v Cole [1983] FCA 94; (1983) 47 ALR 528
Windshuttle v Deputy Federal Commissioner of Taxation (Cth) [1993] 46 FCR 235Zizza v Federal Commissioner of Taxation [1999] FCA 848.
SECONDARY MATERIALS
Clinical Framework for the Delivery of Health Services, Transport Accident Commission and WorkSafe Victoria
REASONS FOR DECISION
Chris Puplick AM, Senior Member
22 October 2018
Applications for Extension of Time
Mr Antonious comes before the Tribunal to seek extensions of time (EOT) to lodge two applications for reviews of decisions made by Comcare. By agreement both applications were heard together by the Tribunal.
On 25 July 2017 Comcare decided that Mr Antonious had no present entitlement to a “health and fitness program” under section 16 of the Safety, Rehabilitation and Compensation Act 1988 (the Act). Under that Act, Mr Antonious had a period of 60 days in which to lodge an appeal to this Tribunal and he was notified of this fact in writing.[1] That 60 day period[2] expired on 23 September 2017.
[1] Comcare letter to Applicant dated 25 July 2017.
[2] This period is longer than the generally prescribed period of 28 days under the Administrative Appeals Tribunal Act section 29(2) due to the modifications contained in section 65(4) of the Safety, Rehabilitation and Compensation Act.
On 20 April 2018 Comcare made a decision declining to provide continuing support for “massage treatment”, also under section 16 of the Act. Again Mr Antonious was notified of his appeal rights and in this instance the 60 day period expired on 19 June 2018[3].
[3] Comcare letter to Applicant dated 20 April 2018.
Mr Antonious lodged an application with this Tribunal for an extension of time to appeal against both decisions on 22 August 2018.
In relation to the July 2017 decision this application is some 13 months out of time and in relation to the April 2018 decision it is just over two months out of time.
Under section 29(7) of the Administrative Appeals tribunal Act 1975, (the AAT Act) the Tribunal may grant extensions of time for applications for review to be lodged provided that: “the Tribunal is satisfied that it is reasonable in all the circumstances to do so.”
There is clear judicial guidance as to both why statutory time limits should be respected by the Tribunal and what matters should be taken into account when making decisions about extensions of time.
Judicial Guidance
McHugh J in the High Court case of Brisbane South Regional Health Authority v Taylor[4] gave four reasons why such limitations are an important part of the legal process. He noted that:
First, as time goes by, relevant evidence is likely to be lost. Second, it is oppressive, even “cruel”, to a defendant to allow an action to be brought long after the circumstances which gave rise to it have passed. Third, people should be able to arrange their affairs and utilise their resources on the basis that claims can no longer be made against them.
The final rationale for limitation periods is that the public interest requires that disputes be settled as quickly as possible.
[4] (1996) 186 CLR 541 at 552-553. Footnotes and citations omitted. The Respondent in the High Court case is not related to the Applicant in the present proceedings.
His Honour also noted that:
An applicant for an extension of time who satisfies those conditions [i.e. the conditions laid down in the relevant Act] is entitled to ask the court to exercise its discretion in his or her favour. But the applicant still bears the onus of showing that the justice of the case requires the exercise of the discretion in his or her favour.[5]
[5] Ibid at 551.
HUNTER VALLEY CHECK LIST
It is generally accepted that the “check-list” outlined by Wilcox J in Hunter Valley Developments Pty Ltd and Others v Minister for Home Affairs and Environment[6] should be taken as the guide by this Tribunal in determining EOT matters.
[6] (1984) 3 FCR 344.
That list provides as follows:
·an applicant must show an “acceptable explanation of the delay” and this it is “fair and equitable in the circumstances” to extend time;
·a distinction is to be made between an applicant who has “rested on his rights” and allowed the decision-maker to believe that the matter was finally concluded, and one who has continued to make the decision-maker aware that he or she contests the finality of the decision;
·any prejudice to the respondent caused by the delay;
·whether any others or the general public would suffer any prejudice as a result of the extension, or established practices be upset;
·the merits of the substantial application; and
·“considerations of fairness as between the applicant and other persons” in a similar position.
Judicial Guidance and the Tribunal’s Approach
Wilcox J did, however, warn that:
Although the section [s 11 of the Administrative Decisions (Judicial Review) Act] does not, in terms, place any onus of proof upon an applicant for extension, an application has to be made. Special circumstances need not be shown, but the court will not grant the application unless positively satisfied that it is proper so to do. The “prescribed period”….. is not to be ignored.” (Ralkon v Aboriginal Development Commission (1982) 43 ALR 535 at 530). Indeed it is the prima facie rule that proceedings outside that period will not be entertained (Lucic v Nolan (1962) 45 ALR 411 at 416). It is a precondition to the exercise of discretion in his favour that the applicant for extension show an “acceptable explanation of the delay” and that it is “fair and equitable in the circumstances” to extend time. (Duff v Freijah (1982) 43 ALR 479 at 485; Chapman v Reilly, Neaves J, 9 December 1983, not reported at p. 7)[7]
[7] Hunter Valley Developments Pty Ltd and Others v Minister for Home Affairs and Environment (1984) 3 FCR 344 at 348 - 349.
Developments Post Hunter Valley
A decision by the Tribunal in Hillman v Australian Postal Corporation[8] sets out four tests which it said should be met in deciding whether to grant a review of a decision where the application was made out of time. Those four grounds, which are in many ways merely a refinement of some of the principles laid down in Hunter Valley, are:
·Delay
·Prejudice
·Merits
·Fairness
[8] [2017] AATA 1411.
In Phillips v Australian Girls’ Choir [2001] FMCA 109, McInnis FM provided a slightly amended version of the principles outlined by Wilcox J to take into account modifications made by other courts in considering the Hunter Valley Developments principles as follows:
1)There is no onus of proof upon an applicant for extension of time though an application has to be made. Special circumstances need not be shown, but the court will not grant the application unless positively satisfied it is proper to do so. The “prescribed period” of 28 days is not to be ignored (Ralkon v Aboriginal Development Commission [1982] FCA 153; (1982) 43 ALR 535 at 550).
2)It is a prima facie rule that the proceedings commenced outside the prescribed period will not be entertained (Lucic v Nolan (1982) 45 ALR 411 at 416). It is not a pre-condition for success in an application for extension of time that an acceptable explanation for delay must be given. It is to be expected that such an explanation will normally be given as a relevant matter to be considered, even though there is no rule that such an explanation is an essential pre-condition (Comcare v A'Hearn [1993] FCA 498; (1993) 45 FCR 441 and Dix v Client [sic] Compensation Tribunal [1993] VicRp 21; (1993) 1 VR 297 at 302).
3)Action taken by the applicant other than by making an application to the court is relevant in assessing the adequacy of the explanation for the delay. It is relevant to consider whether the applicant has rested on his rights and whether the respondent was entitled to regard the claim as being finalised. (See Doyle v Chief of Staff [1982] FCA 124; (1982) 42 ALR 283 at 287).
4)Any prejudice to the respondent, including any prejudice in defending the proceeding occasioned by the delay, is a material factor militating against the grant of an extension. (See Doyle at p 287).
5)The mere absence of prejudice is not enough to justify the grant of an extension. (See Lucic at p 416).
6)The merits of the substantial application are properly to be taken into account in considering whether an extension of time should be granted. (See Lucic at p 417)
7)Considerations of fairness as between the applicant and other persons otherwise in a like position are relevant to the manner of exercise of the court's discretion (Wedesweiller v Cole [1983] FCA 94; (1983) 47 ALR 528).
In addition to the above, this Tribunal has also given consideration to the length of the delay in question; the Applicant’s knowledge of his appeal rights and the availability of alternative avenues of relief should the original EOT not be granted.[9]
[9] Kim and Minister for Immigration and Border Protection 920180 AATA 155 at [20].
Equally, this Tribunal has noted that the check-list items in Hunter Valley “are not be applied mechanically” and that “an acceptable explanation for the delay” is not “an essential precondition to the exercise of that discretion although it is to be expected that such an explanation will normally be given.”[10]
[10] O’Gorman and Comcare (Compensation) [2017] AATA 2192 at [13], citing Comcare v A’Hearn (1993) 45 FCR 441.
The last relevant principle set out in Hunter Valley Developments is that the merits of the substantive appeal should to be taken into account. In Jamal,[11] Bromwich J followed the view expressed by Mortimer J in MZABP v Minister for Immigration & Border Protection,[12] to the effect that it will seldom be in the interests of justice to grant an extension of time where an appeal would have little prospect of success, given the additional resource demands that it would impose upon the parties and the Court, and the inevitable impact it would have on other users of the Court.
[11] Jamal v Secretary, Department of Social Services [2018] FCA 513 at [6].
[12] [2015] FCA 1391; 242 FCR 585 at [62]. Upheld by the Full Court in MZABP v Minister for Immigration & Border Protection [2016] FCAFC 110; 152 ALD 478
The general approach of the Tribunal in determining matters of extensions of time encompasses the fact that: “where genuine issues ought to be litigated, if such can be done with fairness to all concerned, it is appropriate to take a benign view of applications to extend time.”[13]
[13] Outboard Marine Australia Pty Ltd v Byrnes [1974] 1 NSWLR 27 at 30.
While the principles outlined above provide general guidance, each case must be considered according to its own circumstances.[14] In Brown, Hill J stated, in the taxation context (although this is still applicable to the general exercise of the Tribunal’s discretion), that the Tribunal should be “...guided by what the justice of the case requires.”[15] In determining the question of an extension of time, the Tribunal should weigh together all relevant factors.[16]
[14] Dela Rosa and Minister for Immigration and Border Protection [2018] AATA 1262.
[15] Brown v Federal Commissioner of Taxation [1999] FCA 563 at [59].
[16] Zizza v Federal Commissioner of Taxation[1999] FCA 848.
It is also important to note that in making a decision about what is reasonable in all the circumstances, the Tribunal must consider all of the circumstances of each individual case.[17]
[17] Crick and Prosegur Australian Pty Ltd [2016] AATA 313 at [14].
The Case in Question
Having established the principles upon which the Tribunal should proceed, the Tribunal now turns to examine Mr Antonious’s application in line with those principles using the Hunter Valley check-list. It should be noted that the discretion of the Tribunal in deciding these matters is generally accepted as being “very wide”[18] and its overriding responsibility is to make a decision which is “reasonable in all the circumstances.”
An acceptable explanation for delay
[18] Carney v Comcare (Compensation) [2018] AATA 164 at [8] per Deputy President Humphries.
In his Statement to the Tribunal Mr Antonious sets out the following:
(17) When Comcare declined the gym program in mid-2017 and the massage treatments in April 2018 I was devastated. I did not think there was anything much I could do about it. My wife helped me request reviews but Comcare still declined liability.
(18) After the June 2017 determination my wife called my previous solicitor Max Emmanuel. He said words in or to the effect ‘you can’t win this one’ and ‘they won’t pay for it because it won’t get you back to work’. My wife suggested that we lodge a reconsideration request and Max said ‘there’s no harm in trying but you won’t get it.’ After the reconsideration I did not file an application in the AAT because of Max’s previous advice which I relied upon.
(19) My wife also sought a reconsideration of the massage determination in 2018. When this was rejected we did not take it any further because of Max Emmanuel’s previous advice.[19]
[19] Applicant’s Statement in respect of Extension of Time Application dated 28 September 2018.
His Statement goes on:
(23) On 15 August 2018 my wife telephoned Max Emmanuel to obtain further advice. We had in mind to bring a permanent impairment claim. Max had previously told us something to the effect that once you get permanent impairment compensation Comcare stop harassing you. Max told us to contact Grant Watson at Greive Watson Kelly Lawyers. We contacted Grant immediately and arranged an appointment to see him at his office in Sydney on 20 August 2018.
(24) We met with Grant Watson on 20 August 2018. We brought with us all of our recent paperwork relating to the claim, including the Comcare decisions relating to the gym program and massage treatments. Grant advised me that I had a good case to challenge the reviewable decisions. He looked at the medical reports and told me that my doctors and Comcare’s independent doctor all supported the claim.
As a result of this further discussion Mr Antonious proceeded to lodged his EOT extension application on 22 August 2018.
Although blaming third parties for faulty or misleading advice is an easy argument to advance there does, at least to the Tribunal, seem to be some reasonable explanation encompassed in Mr Antonious’s narrative of events. How Mr Emmanuel came to suggest that Mr Watson should be consulted is not altogether clear but it at least suggests that after the second decision the possibility of making an appeal to this Tribunal was more actively canvassed.
The Tribunal is inclined to accept Mr Antonious’s explanation for the delay, at least in relation to the April 2018 claim which, in itself is only a relatively short period of time outside the statutory limit.
Given that the Tribunal is persuaded on the April 2018 claim it seems like only a matter of common sense that the July 2017 claim should be joined with it as the two are inextricably linked in terms of the dispute between Comcare and Mr Antonious as to the appropriateness of this treatment regime under section 16 of the Act and under the general provisions of the Comcare Clinical Framework for the Delivery of Health Services upon which it relies for its determinations.
Resting on Rights
It is true that Mr Antonious sought internal reviews of both of the decisions, thereby indicating that he challenged them ab initio. However once the unfavourable review decisions were confirmed he failed to take any action within the 60 day period prescribed for the lodging of appeals. However it is also true that, through his wife (who has his Power of Attorney[20]), he was seeking legal advice, initially through Mr Emmanuel and thereafter through Mr Watson.
[20] Copy provided to the Tribunal dated 28 June 2016.
Once he had received advice from Mr Watson on 20 August 2018 he (or his wife) acted with some expedition and lodged his current applications.
Nevertheless I do give some weight to the submission of the Respondent which demonstrates that Mr Antonious was more than familiar with the procedures and time limits required for filing appeals. The Respondent demonstrated that Mr Antonious had lodged four previous appeals to the Tribunal each of which was within the proscribed time. The Tribunal thus accepts that Mr Antonius was aware of the requirements.[21]
[21] Respondent’s Submission at paragraph [3.6].
However, in his counsel’s submission it is adverted that: “Most people receive competent legal advice. Mr Antonious did not.”[22] The Tribunal is in no position to evaluate the veracity of the first sentence, however it recognises, not so much that Mr Antonious was provided with negligent or faulty advice but rather that he was provided with discouraging advice as his own Submission tends to suggest.
[22] Applicant’s further Submission dated 4 October 2018 at paragraph [12].
On balance the Tribunal does not find that Mr Antonious rested on his rights to a degree that weighs adversely against him in the determination of this application.
Prejudice to the Respondent
It is hard to establish that there is any prejudice to the Respondent other than a general issue of inconvenience. There is no doubt that all the necessary records would still be available to it and that it would not have any difficulties in assessing medical and other relevant reports.
In some respects this distinguishes this application from those where the effluxion of time has been so substantial as to make a latter-day evaluation of merits almost impossible.[23]
[23] Romeo and Secretary, Department of Social Security [1992] 26 ALD 248 at [19].
The Tribunal notes that in Berkelaar v Comcare this matter of access to records was considered but it was decided there that a delay of five years was not excessive in the particular circumstances.[24] The delays in this matter are approximately two and 13 months respectively.
[24] [1997] AATA 12015.
The respondent drew the Tribunal’s attention to a decision in Emery and Comcare[25] in which an application for an extension of time, covering a period of 44 days was denied. That decision sets out the possible prejudice which can occur for an organisation such as Comcare in facing difficulties in being able to define its liabilities (as an insurer) beyond a definite period. There is much merit in this claim; however the facts in Emery are sufficiently different as to be distinguishable from this matter. In that case the applicant caused major disruptions to the timetable and proceedings of the Tribunal itself, he admitted that his delay was entirely his own fault by way of “oversight” and the Tribunal found that his submission was merely an “inconclusive dialogue (of 51 pages) from which no reasonably minded reader could discern anything in the way of a contended submission(s).”[26]
[25] [2016] AATA 647
[26] Emery and Comcare (Compensation) [2016] AATA 647 at [4-7]; [25] and [12].
Those characteristics are not present in this case and the Tribunal does not find Emery to be a persuasive precedent for it on this occasion.
Prejudice to the general public or the upsetting of established practices
The Tribunal cannot ascertain any matters which would arise here unfavourable to the granting of this application.
Again, this point was disputed by the Respondent using the precedent established in Emery. Here the Respondent argued that Mr Antonious had merely “changed his mind about appealing” and that an “inequitable situation” would result from granting the EOT compared with other applicants who had failed to receive such an extension. The Tribunal is not persuaded on this point. The inequity would arise were those other applicants to be denied the opportunity to lodge an EOT application of their own in the first place. To the extent that they are, then they are not in a comparatively inequitable position as their claims would be accorded the same degree of scrutiny by the Tribunal and a decision would result from objective consideration of the merits of their application. A grant of EOT to this applicant does not, ipso facto, disadvantage any other applicant.
Merits of the substantial application
It is decidedly not the role of the Tribunal at this stage to pronounce on the merits of the decisions which Mr Antonious seeks to have reviewed. That is a separate matter for determination in another place and at another time.
However as the authorities suggest, it would be otiose to allow any EOT to be granted if this would result in a claim going forward which has no prospect of success. That prospect does not have to be a strong one, it merely has to be arguable. In Windshuttle the Federal Court referred, in an EOT application, to there being “an arguable case on the pleadings”[27] and in O’Gorman this Tribunal granted an EOT in a matter where the material before it “does not indicate the substantive matter has no merits.”[28]
[27] Windshuttle v Deputy Federal Commissioner of Taxation (Cth) [1993] 46 FCR 235 at 243 per von Doussa J.
[28] O’Gorman v Comcare [2017] AATA 2192 at [25].
The Tribunal acknowledges that the Respondent drew its attention to a decision of the Tribunal in Djapouras, but without further elucidation the Tribunal is not sure what to take from this as the decision was rendered orally by the Tribunal and there do not appear to be any written reasons explaining the decision, which, as the Tribunal understands it from submissions granted an extension of time of one day.[29]
[29] Djapouras v Comcare Oral decision dated 10 October 2017, No 2017/5266 per Senior Member Stefaniak.
There is conflicting evidence before the Tribunal as to the validity and utility of Mr Antonious’s treatment either in relation to massage therapy or participation in gym-based exercise programmes.
There are:
·positive assessments from Dr Karin Reinhardt, a consultant psychiatrist with St John of God at Richmond Hospital[30] and from Ms Tina Testa (a massage therapist)[31]
·reports from Dr Moffatt which refer to symptom amelioration and the limited prospects of significant improvement almost irrespective of proposed and ongoing treatments.[32] Dr Moffatt also opines that it is difficult to “provide specific evidence for such generalised treatment terms as ‘massage therapy’ and ‘gym membership’ in the context of the very specific DSM-IV-TR diagnosis of “Adjustment Disorder with mixed anxiety and depression.””[33]
·at least one report which could, at best, be described as ambivalent from psychologist Dr Roy Laube,[34] and
·at least one report of far more qualified nature, doubting the benefits of further psychological treatment, from Dr Frank Chow, another consultant psychiatrist.[35]
[30] Reports to Comcare dated 14 January 2016 and 30 May 2017.
[31] Response to a request for advice from Comcare, email dated 30 January 2018.
[32] Report to Comcare dated 9 December 2015.
[33] Report to Comcare dated 15 January 2016.
[34] Report to Comcare dated 11 November 2015.
[35] Report to Comcare dated 6 September 2018. This report appears to have been based on a previous document created or printed on 28 August 2018.
Counsel for Mr Antonious put to the Tribunal that “all the medical evidence was one way” in terms of validating and supporting the gym membership and massage therapy parts of his client’s management routine while counsel for the Respondent questioned this, especially in terms of relating those treatments to the specific compensable conditions under review.[36] The question of continuing treatments which are merely ameliorative as distinct from contributing to any long-term improvement in a patient’s condition is clearly a matter which should be tested in a full and informed hearing.
[36] Respondent Submission dated 4 October 2018 at paragraph [4.22].
What is called into question is the continuing benefit of the treatments, support for which has now been denied by Comcare, especially when evaluated against the Clinical Framework for the Delivery of Health Services which Comcare uses as a guide to its decision making in association with section 16 of the Act.
[The Tribunal accepts the point made by counsel for the Applicant that this document does not have any force of law in terms of being provided with a legislative authorisation or being adopted as formal policy under a legislated regulatory authority.]
All these matters have been considered in the various review decisions by Comcare, which decisions are challenged by the Applicant.
It is not obvious to the Tribunal that the balance of evidence lies on one side or the other, despite the arguments of the Applicant. Rather, it is obvious that there is an arguable case which needs to be decided. It will not be decided here and now.
The existence of that arguable case does however mean that it should be given an opportunity for hearing which can only occur if the EOT application is granted.
Consideration of Fairness as between other Parties
The Tribunal sees no matters arising in this context. Any other application along similar lines would no doubt be treated in the same manner and accorded the same degree of attention and procedural fairness.
Consideration
Extensions of Time should not be allowed as some sort of routine or matter of course. The Tribunal should, for example “be mindful not to automatically grant an extension of time due to an apparent mere absence of prejudice.”[37] Applicants should have to demonstrate that there is sufficient merit for them to overbear the important public policy principles set out by the High Court in Brisbane South. In seeking to establish if such a case is made out the Tribunal relies upon the guiding principles laid down in Hunter Valley.
[37] Emery and Comcare (Compensation) [2016] AATA 647 at [31].
In its examination of Mr Antonious’s application against those Hunter Valley principles, the Tribunal has come to the conclusion that the application succeeds and should be allowed to take forward the process of review of the two disputed Comcare determinations. That is not to imply that the application succeeds on every point in Hunter Valley but rather that there is success on a sufficient number of grounds to satisfy the provisions of the AAT Act to grant the application having regard to “all the circumstances”.
Decision
The applications for extensions of time in the two matters before the Tribunal (2018/4758 and 2018/4759) are granted to 22 August 2018.
I certify that the preceding 54 (fifty-four) paragraphs are a true copy of the reasons for the decision herein of Chris Puplick AM, Senior Member
............................[sgd]............................................
Associate
Dated: 22 October 2018
Date of hearing: 4 October 2018 Counsel for the Applicant: Mr J Mrsic, 4 Selborne Chambers Solicitors for the Applicant: Mr J Clarke, Grieve Watson Kelly Lawyers Solicitors for the Respondent: Ms L Turonek, Comcare
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