Barkworth and Barkworth (Child support)

Barkworth and Barkworth (Child support) [2024] AATA 3584 (2 August 2024)

DIVISION:Social Services & Child Support Division
REVIEW NUMBER:  2024/AC027533
APPLICANT:  Mr Barkworth
OTHER PARTIES:  Child Support Registrar
Ms Barkworth

TRIBUNAL:Member S Hoffman
DECISION DATE: 2 August 2024
DECISION:

The Tribunal sets aside the decision under review and, in substitution, decides as follows:

Mr Barkworth’s adjusted taxable income is varied as follows:
oFrom 1 March 2023 to 30 June 2023, to $103,000
oFrom 1 July 2023 to 31 December 2024, to $105,000
Ms Barkworth’s adjusted taxable income is varied as follows:
oFrom 1 March 2023 to 30 June 2023, to $34,373
oFrom 1 July 2023 to 31 December 2024, to $25,000
The annual rate of child support payable by the father is increased as follows:
oFor the period 1 March 2023 to 31 December 2023, by $940
oFor the period 1 January 2024 to 31 December 2024, by $968
oFor the period 1 January 2025 to 31 December 2025, by $997
oFor the period 1 January 2026 to 31 December 2026, by $1,035
oFor the period 1 January 2027 to 31 December 2027, by $1,066.

CATCHWORDS
CHILD SUPPORT – departure determination – ground for departure – income, property and financial resources – just and equitable – date of determination – decision under review set aside and substituted

Names used in all published decisions are pseudonyms. Any references appearing in square brackets indicate that information has been removed from this decision and replaced with generic information so as not to identify involved individuals as required by subsections 16(2AB)-16(2AC) of the Child Support (Registration and Collection) Act 1988.

REASONS FOR DECISION

BACKGROUND

The child support case relevant to this review was registered with Services Australia – Child Support (Child Support) on 10 December 2015. Child Support has been involved with the collection of child support since 19 April 2023.
The father pays child support to the mother for the two children, [Child 1] and [Child 2], aged eight and six respectively.
For the period 16 March 2023 to 31 August 2023, the father was assessed to pay the minimum annual rate of child support of $459 a year, based on his adjusted taxable income of $16,404 for 2021-22 and the mother’s adjusted taxable income of $22,451 for 2021-22.
On 2 April 2023, the mother applied for a change of assessment (COA). At the time the mother had 100% care of both children.
An original decision was made on 7 July 2023, as follows:
· For the period 2 April 2023 to 31 October 2024, the father’s adjusted taxable income is varied to $107,000.

· For the period 21 August 2023 to 31 December 2024, the annual rate of child support otherwise payable is increased by the sum of 50% of the costs of tuition fees, capital development levy and school card less any relevant school card discount.

On 26 July 2023, the father objected to the original decision.
On 2 February 2024, an objections officer from Child Support set aside the original decision and replaced it with the following decision (the objection decision):
· For the period 11 January 2023 to 30 June 2023, the father’s adjusted taxable income is varied to $96,279.

·     For the period 1 July 2023 to 31 October 2024, the father’s adjusted taxable income is varied to $114,000.
·     The annual rate of child support payable by the father is increased in consideration of school fees as follows:
o   By $940 for the period 11 January 2023 to 31 December 2023
o   By $968 for the period 1 January 2024 to 31 December 2024
o   By $997 for the period 1 January 2025 to 31 December 2025
o   By $1,035 for the period 1 January 2026 to 31 December 2026
o   By $1,066 for the period 1 January 2027 to 31 December 2027.

On 20 February 2024, the father lodged an application for review with this Tribunal.

A directions hearing was held on 19 June 2024 via MS Teams audio (equivalent to conference telephone) and attended by both parents. Written directions were issued to both parents to provide certain evidence by close of business on 10 July 2024.
The main hearing was held on 31 July 2024. Both parents attended via MS Teams audio and gave sworn evidence.
Child Support had provided documents in two bundles numbered 1 to 482 and 483 to 485. The father submitted documents numbered A1 to A31 and the mother submitted documents B1 to B31. Copies of the documents before the Tribunal were provided to the parents before the main hearing, along with a covering letter that advised them that they could respond to the other parent’s written submissions at the hearing.
The father provided some of his written submissions on 23 July 2024. This was after the due date for submissions as set out in the directions letter but was before the hearing. Copies of these were sent to the mother. The mother then sent in a submission in response, received by the Tribunal on Friday 26 July 2024. Given that the main hearing was the following Wednesday and both parents would have opportunity to raise issues at that time, the Tribunal decided not to accept that submission from the mother. It was, of course, open to the Tribunal to direct either or both parents to provide further documentary evidence after the hearing if that was required for it to make its decision. The Tribunal is satisfied that the mother was not denied procedural fairness in this regard.[1]
[1] Also see paragraphs 17 to 23.
The Tribunal made its decision on 2 August 2024.

ISSUES

The statutory provisions relevant to this review are contained in the Child Support (Assessment) Act1989 (the Act). The Act provides for an administrative assessment of child support to be paid. Pursuant to section 98C of the Act, a decision to depart from the administrative assessment may be made if the following three requirements are met:
i.A ground is established; and
ii.It would be just and equitable as regards the child, the liable parent and the carer entitled to child support to make a particular determination; and
iii.It would be otherwise proper to make a particular determination.

The grounds for departure from an administrative assessment of child support are set out in subsection 117(2) of the Act.
If the Tribunal is satisfied that the three requirements are met, it may make one of the determinations prescribed in section 98S of the Act, which include variations to the annual rate of child support payable, or to the adjusted taxable incomes of the parents and/or carer, or to other components of the statutory formula used to calculate child support.

CONSIDERATION

Towards the end of the hearing, the mother advised that she and the father had spoken with each other about the hearing the previous week. The father said that he was happy to pay $600 a fortnight in child support and to contribute to the children’s school fees but what concerned him was the arrears he had ended up with. Following the original decision made on 7 July 2023, his tax refund was taken and applied against those arrears. He did not want his 2023-24 tax refund taken in the same manner.
On 30 July 2023, the father’s arrears were $7,907.62. As at 10 January 2024, the arrears were $868.48. Following the objection decision of 2 February 2024, his arrears increased to $5,341.17.
The original and objection decisions included different adjusted taxable incomes for the father but what also contributed to the increase to the father’s child support liability was that his adjusted income was varied from 2 April 2023 by the original decision and from 11 January 2023 by the objection decision.
The Tribunal asked the mother what she thought about this. She said she wanted a decision that was fair and if she was entitled to arrears of child support, then she wanted those paid.
The father also said that over $700 was taken from his pay every fortnight but only about $600 was paid to the mother. The father said he has a second child support case for which he also pays child support. This is consistent with information in the Child Support documents. The Tribunal observes that currently the father’s fortnightly child support liability for this case is $621.25 and that $683.86 was credited to him on 15 July 2024 which suggests that an extra amount is being deducted from his pay to be put towards his arrears.[2] The Tribunal cannot tell with any certainty from the documents if this is the case. If the father wants to follow this up, he should do so with Child Support.
[2] Page 484 of the Child Support documents.
The Tribunal also notes that each of the parents raised certain issues in the relation to the other in writing and at the hearing but said they did not want to pursue these. The Tribunal will note some of these briefly in these Reasons for Decision for the record.
The Tribunal would also acknowledge that it appreciated each of the parents clarifying what the main concerns were and that they both said they were not interested in pursuing some of the other issues that had been raised during the COA process and in documents they provided to the AAT. These Reasons have been written accordingly.

Issue 1 – Does a ground exist to depart from the administrative assessment?

Subparagraph 117(2)(c)(ia) of the Act provides a ground for departure exists where, in the special circumstances of the case, the administrative assessment of child support would result in an unjust and inequitable determination of the rate of child support because of the income, property and financial resources of either parent.

The father’s income

According to Child Support records, the father’s taxable income was $21,557 for 2020-21, $16,404 for 2021-22 and $54,498 for 2022-23.
The father said he was unemployed until January 2023 when he started work as a [Occupation 1] for [Company 1]. The father still works for them.
Based on a payslip that covered the period 11 January 2023 to 30 June 2023 (171 days), the father’s gross pay was $51,806. As just noted, his taxable income for 2022-23 based on Australian Taxation Office (ATO) records was $54,498. Child Support ascertained that he was paid $9,392 in income support payments during 2022-23. That suggests that the father also claimed allowable deductions of $6,700 ($51,806 + $9,392 = $61,198 - $54,498).
The annual equivalent of the father’s pay as a [Occupation 1] during 2022-23 was $110,580 ($51,806 / 171 = $302.96 x 365). Allowing, say, $7,580 as deductions results in annual pay of $103,000.
In relation to 2023-24, the father’s payslip recorded his annual gross pay to be $112,768. Allowing the same amount as for the previous year for deductions results in an income of $105,188; say, $105,000.
The Tribunal considers that $103,000 adequately reflects the father’s income for child support purposes from 11 January 2023 to 30 June 2023, and that $105,000 reflects his income for the 2023-24 financial year.

The mother’s income

The mother’s taxable income was $27,579 for 2020-21, $22,451 for 2021-22 and $34,373 for 2022-23.
The mother works as a [Occupation 2]. She said that she works on a casual contract basis term to term. She does not get paid for the three months of the year when there are school holidays. From last week, her hours have dropped to three days a week.
The father had contended that the mother had additional income from selling products]. The mother said she sold six [products] for $400 each in 2023 and that did not take into account costs she incurred for [specified expenses], which cost $85 a [product]. She said this happened just the once. Later in the hearing the father said he did not want to pursue this issue and the Tribunal will not consider it any further.
Based on her income from employment, the Tribunal considers that $34,373 represents the mother’s income for child support purposes for 2022-23 and will use $25,000 for 2023-24 as the mother is working fewer hours compared to the previous year. These different incomes for the mother have a minor effect on the rate of child support, as can be seen from paragraphs 37 and 38 below.

How does the administrative assessment compare with an assessment of child support using the Tribunal’s income figures for the parents?

The figures that follow should be regarded as estimates, due to the complexity of the child support formula. They only show an estimate of child support based on the parents’ incomes, before any adjustment is made for school fees.
On 2 April 2023, the mother applied for a COA. At the time the father was assessed to pay child support of $459 based on his adjusted taxable income of $16,404 for 2021-22 and the mother’s adjusted taxable income of $22,451 for 2021-22. The mother was recorded as having 100% care of the children.
Using the Tribunal’s income figures of $103,000 for the father and $34,373 for the mother, the father’s annual child support liability would be $13,360 ($513 a fortnight).
Using $105,000 for the father and $25,000 for the mother results in an annual child support liability of $13,708 ($507 a fortnight).

Given the difference between the father having an annual child support liability of about $13,360 or $13,708, rather than $459, the Tribunal is satisfied that in the special circumstances of this case, the administrative assessment does result in an unjust and inequitable rate of child support, and that a ground for departure from the administrative assessment has been established pursuant to subparagraph 117(2)(c)(ia) of the Act.

Issue 2 – Is it just and equitable to make a particular departure determination?

As the Tribunal is satisfied that there is a ground to depart from an administrative assessment of child support, the next step is to consider whether it is just and equitable as regards the children, the father and the mother to make a particular determination in accordance with sub-subparagraph 98C(1)(b)(ii)(A) of the Act. This in turn requires the Tribunal to consider a variety of factors, as set out in subsection 117(4) of the Act.[3]
[3] The Tribunal is required to give “overt consideration” to relevant factors listed in subsection 117(4) of the Act: Tyagi and Meares (SSAT Appeal) [2008] FMCAfam 886.
Section 3 of the Act makes it clear that parents have the primary duty to maintain their children, and that this duty has priority over all commitments of the parents other than commitments necessary for self-support or the support of another person the parent has a duty to maintain. In this case the father and the mother have the primary duty to financially support the children of this case.

Income, property and financial resources – the father

In his Statement of Financial Circumstances dated 10 July 2024, the father wrote that he earned on average $1,200 a week. He said this was his take home pay. The Tribunal has ascertained his gross pay from his payslips, as set out earlier.
The father said that he borrowed about $50,000 to purchase a 2020 [vehicle]. The father said that he did not own property or have a place of his own that he rents. He said that he stays with different people during the week including at his girlfriend’s place. The mother disputed this. She claimed he owned assets such as a motorbike and jet skis which he disputed. The Tribunal explained that it would be relying on the father’s income which could be ascertained from his payslips. Where he lived and what he owned, in the context of this particular case, were unlikely to have a bearing on the Tribunal’s decision. This is because it is not unreasonable for a person on an income of about $100,000 to own assets such as a motorbike or jet skis. Owning assets such as these do not suggest that the father has another source of income. Therefore, whether the father does or does not own these assets is of little consequence when determining an income for him for child support purposes. The parents broadly agreed that these issues did not need to be pursued. The Tribunal will not consider them any further.
In his SFC, the father wrote that he lives week to week, and he has paid way too much child support. He referred to him struggling financially and that still Child Support wants to take more from him by way of arrears. The question of his arrears was mentioned earlier and will be discussed more fully later in these Reasons.
The father did not provide much information in his SFC and there was nothing else of particular note recorded in it.

Income, property and financial resources – the mother

The mother’s SFC was submitted on 10 July 2024. According to that, her weekly income including parenting payment, family tax benefit (FTB) and child support is $1,610 ($83,720 a year). Her weekly outgoings amount to $2,057 ($165 plus $1,892), resulting in a shortfall of $447 a week or $23,244 a year.
The mother did not record having any cash in her bank account. She owns a 2008 [vehicle] which she valued at $6,000. Her assets include her home worth $500,000. She owns 99% of it and her mother, [Ms A], owns 1%. Her household contents are worth $15,000. She has $4,084 in superannuation.
The mortgage over the property is $245,000. The mother wrote that she owed [Ms A] $32,000 for a personal loan.
The mother lives with the two children of the case and two older children, aged 14 and 11, for whom she also receives child support.
The SFC includes a schedule in which parents record their weekly expenses against 32 different expense types. The mother recorded $150 a week against electricity which seemed high. She said she paid about $800 a quarter which is equivalent to about $60 a week. The difference between $150 and $60 a week is $90 a week or $4,680 a year, which reduces the shortfall of $23,244 noted earlier by $4,680.
The mother recorded her outlay on children’s activities, including sports, to be $142 a week She said it was about $30 a week for each child. She recorded $110 a week ($5,720 a year) for education expenses which the Tribunal understands relates to the four children, not just the two children of this case.
The mother also recorded costs she incurs for speech therapy for one child and a podiatrist for the other. She was adamant she was not seeking an adjustment to the rate of child support in respect of these costs and the Tribunal will not consider them further.

Other issues pertaining to the parents’ incomes, property and financial resources

Should a parent’s earning capacity be taken into account in the child support assessment?

Subsection 117(7B) of the Act prescribes the circumstances in which a parent’s earning capacity may be taken into account; certain criteria have to be met.
These include that the parent has failed to demonstrate that decisions made about their work arrangements were not substantially motivated by the effect they would have on the rate of child support.
The decision maker is required to consider whether, for example, changes to a person’s work arrangements are justified on the basis of their caring responsibilities and/or their state of health. If those do not apply, the decision maker is then required to consider whether the parent has demonstrated that affecting the rate of child support was not a major purpose of decisions the parent made about their work arrangements.
The father is working full time and earning reasonable pay compared with his situation before January 2023. The mother cares for four children aged between six and 14. She works part time. Her pay was higher in 2022-23 than in previous years and has recently reduced to what she was earning before 2022-23. The difference in her pay does not have a material effect on the rate of child support.[4]
[4] See paragraphs 37 and 38 of these Reasons.

The Tribunal is satisfied that there is no basis for adjusting either parent’s income for child support purposes in relation to their earning capacity. The Tribunal concluded that it need not consider the application of subsection 117(7B) of the Act in relation to either parent any further.

Commitments of each parent to support him or herself

The Tribunal is required to have regard to the commitments of each parent that are necessary to enable the parent to support himself or herself, or any other child or another person that the person has a duty to maintain (paragraph 117(4)(e) of the Act).
The mother cares for two other children and the father is party to another child support case which are recorded in the records held by Child Support. There was no evidence before the Tribunal of either parent having particular needs that should be taken into account with regard to the amount of child support payable.
The Tribunal is satisfied that it need not consider paragraph 117(4)(e) of the Act any further.

Costs related to the children

In determining the proper needs of the children, it is necessary to have regard to the manner in which they are being, and in which the parents expected them to be, cared for, educated or trained, and any special needs they may have (subsection 117(6) of the Act).
The children attend a fee-paying school. The father submitted evidence showing he contributed to the school fees during 2022 through to February 2023. He said he was happy to contribute to the children’s school fees.
The objections officer decided that the father should contribute 75% of the children’s school fees and the mother should contribute 25% to reflect the difference in their taxable incomes. Given this and that the mother is not seeking any assistance in paying for the children’s speech therapy or podiatry, the Tribunal considers this to be a reasonable approach. The Tribunal will adopt the calculations used in the objection decision, such that the father’s annual rate of child support will be increased by the following amounts:
·$940 for any period falling within the 2023 calendar year
·$968 for calendar year 2024
·$997 for calendar year 2025
·$1,035 for calendar year 2026
·$1,066 for calendar year 2027.
When the mother filled in the ‘average weekly expenses’ schedule in the SFC, she did not allocate any of the costs just to the children of this case. That being the case, the Tribunal considers it appropriate to rely on the Costs of the Children Table available from Child Support’s website.[5]
[5] For the parents’ information, a Costs of the Children Table is available at the Services Australia website which can be found at align="left">Hardship
1. The Tribunal is required to consider any hardship its determination might cause and is guided by Gyselman and Gyselman[6] in this respect:
  This requires the Court to balance the “hardship” which the parents or the children may suffer as a result of either making or refusing to make the order. It is a recognition of the circumstance that in this area there is likely to be hardship both ways and the Court is required to take into account the balance of that hardship and give it the weight which is appropriate to the circumstances of the individual case.
  [6] [1991] FamCA 93.
2. The father’s level of pay is such that he should be able to cover his regular living costs. The Tribunal is not satisfied that his SFC accurately reflects what these costs are. If he does not have his own home and is staying with friends during the week, that would suggest his living costs are lower than average. He did claim that he gives money to friends that he stayed with for letting him stay.
3. The Tribunal notes again that the father said that he was agreeable to paying child support of $600 a week and his issue was with the arrears, particularly those that arose after the objection decision.
4. It appears that the mother has a more difficult challenge in managing her finances, given she cares for four children and is on a much lower income than the father. She made the point that changes to child support affect the amount of FTB she is paid. The Tribunal also notes that it appears the mother is assisted by her mother, [Ms A].
Any other relevant matters
1. The Tribunal may take into account any other matters it considers relevant in making a particular departure determination (subsection 117(9) of the Act).
2. The Tribunal considered the date from which it should start its determination, noting that the original decision started from 2 April 2023 and the objection decision started from 11 January 2023. It also notes that Child Support only started collecting child support from the father on 19 April 2023. Before then, the parents had a private arrangement regarding the payment of child support. When Child Support starts collecting child support on behalf of a parent, it can consider collecting any arrears of child support going back three months.
3. Generally, a decision resulting from a COA application starts from a date on or around the date when the COA application was made, which was 2 April 2023 in this case. This is because parents should be able to rely on, and budget for, the child support assessment then in place until such time that they become aware that the assessment might change.
4. The reason for using a start date of 11 January 2023 was that this was when the father started work and his income increased significantly from that date.
5. The Tribunal observes that generally, the child support system does not require a parent to inform Child Support when their pay increases. The exception is if a parent lodged an income estimate and then their pay increased. They should then tell Child Support and lodge a revised income estimate. But this was not the father’s situation. He had not previously lodged an income estimate that he failed to update.
6. The fact that the father’s income had increased would have been picked up when he lodged his tax return, and the higher income would then have been applied to the child support assessment. The fact that the mother lodged a COA application is appropriate as it allowed for the father’s income to be examined sooner.
7. However, as there was no obligation on the father to inform Child Support that he had started work and his income had increased, the Tribunal does not consider it to be just and equitable to him that he should be expected to pay arrears of child support from 11 January 2023 rather than from a date closer to when the mother lodged her COA application with Child Support.
8. With regards to the mother, the Tribunal does not want to create a situation where the mother has been overpaid child support. It has factored this in when considering the date from which its determination should start, after estimating the effect of its decision as follows:
9. Based on the objection decision the father was required to pay $22,307 in child support from 11 January 2023 to 30 June 2024, made up as follows:
  · Annual rate of child support of $11,736 from 11 January 2023 to 30 January 2023 (20 days): $643
· Annual rate of child support of $13,208 from 31 January 2023 to 30 June 2023 (151 days): $5,464
· Annual rate of child support of $16,200 from 1 July 2023 to 30 June 2024:[7] $16,200.
[7] In this period the annual rate varied between $16,180 and $16,240.
1. The Tribunal estimates that the amount of child support the father will be required to pay for the period 11 January 2023 to 30 June 22024 according to its determination is $18,277, made up as follows:
  ·     Annual rate of child support of $459 from 11 January 2023 to 1 April 2023 (81 days): $101
  ·     Annual rate of child support of $14,300 from 2 April 2023 to 30 June 2023 (90 days): $3,526
  ·     Annual rate of child support of $14,650 from 1 July 2023 to 30 June 2024:[8] $14,650.
  [8] The annual rate will vary between $14,648 and $14,668 because of the small increase in the contribution to school fees at the start of each calendar year.
2. This means there would be an overall reduction in the father’s child support liability of $4,030. The main reason for this reduction is that in the Tribunal’s calculation, the father is assessed for child support based on his income from employment from April 2023 rather than from January 2023.
3. As at 30 June 2024, the father’s arrears of child support were $5,313. As at 15 July 2024, his arrears were $4,566. The Tribunal’s decision will therefore reduce his arrears to an amount that is less than what he is currently paying in child support each fortnight.
4. The Tribunal does not want to create an overpayment for the mother. That would be unfair to her especially as she was paid child support for some months based on the father having an adjusted taxable income of $16,404 when he was in fact earning over $100,000 a year.
5. As the Tribunal’s decision records a lower adjusted taxable income for the father compared to the objection decision, and Child Support appears to have collected between $25 and $60 extra a fortnight in relation to the arrears, it is possible that when the Tribunal’s decision is given effect by Child Support in August or September 2024, Child Support records may show that the mother has been overpaid by a small amount.
6. The Tribunal has decided to build in a buffer against that happening by starting its determination from 1 March 2023. The Tribunal considers that this balances the interests of both parents.
7. The Tribunal has already recorded that the father said he was agreeable to pay child support of $600 a fortnight. The Tribunal’s determination results in his fortnightly child support payments for this case to be $563. The difference between $600 and $563 is $37, equivalent to $962 a year or $1,282 for the period from 1 July 2023 to 30 November 2024. Starting the determination from 1 March 2023 rather than 2 April 2023 is broadly equivalent to the father’s rate of child support being $600 a week from 2 April 2023 to 30 November 2024.
8. In its decision, the Tribunal has varied the parents’ incomes until 31 December 2024; after that date, it is expected that their taxable incomes for 2023-24 will be applied to the child support assessment.
9. The Tribunal has ended its determination on 31 December 2027 to cover the contribution that will be made by the father to the children’s school fees.
10. It remains open to either parent to apply for a change of assessment at any time if their circumstances change.
Issue 3 – Is it otherwise proper to make a particular departure determination?
1. The requirement to consider whether a departure determination would be otherwise proper is concerned with what is fair to the community; it is preferable for a child or children to be primarily supported by their parents rather than by government assistance. Paragraph 117(5)(b) of the Act means that the Tribunal must consider whether the level of a benefit, in particular FTB, received by the party caring for a child or children, may be affected by the level of child support.
2. During the period relevant to this review, the mother has been in receipt of FTB. The Tribunal is satisfied that its determination will result in an appropriate apportionment of financial responsibility between the parents and the community and would be otherwise proper.
DECISION
The Tribunal sets aside the decision under review and, in substitution, decides as follows:
- Mr Barkworth’s adjusted taxable income is varied as follows:
  oFrom 1 March 2023 to 30 June 2023, to $103,000
  oFrom 1 July 2023 to 31 December 2024, to $105,000
- Ms Barkworth’s adjusted taxable income is varied as follows:
  oFrom 1 March 2023 to 30 June 2023, to $34,373
  oFrom 1 July 2023 to 31 December 2024, to $25,000
- The annual rate of child support payable by the father is increased as follows:
  oFor the period 1 March 2023 to 31 December 2023, by $940
  oFor the period 1 January 2024 to 31 December 2024, by $968
  oFor the period 1 January 2025 to 31 December 2025, by $997
  oFor the period 1 January 2026 to 31 December 2026, by $1,035
  oFor the period 1 January 2027 to 31 December 2027, by $1,066.

[2024] AATA 3584

2 August 2024

Key Legal Topics

Areas of Law

Family Law

Legal Concepts

Jurisdiction

Statutory Construction

Remedies

Procedural Fairness