Brougham v Aboriginal Health Council of South Australia
[2021] FCCA 2031
•27 August 2021
FEDERAL CIRCUIT COURT OF AUSTRALIA
Brougham v Aboriginal Health Council of South Australia [2021] FCCA 2031
File number: ADG 235 of 2020 Judgment of: JUDGE BROWN Date of judgment: 27 August 2021 Catchwords: INDUSTRIAL LAW – proceedings pursuant to the Fair Work Act 2009 (Cth) – general protection proceedings – practice and procedure – where the forum of the matter is disputed – whether matter should be conducted by electronic means or face to face – discussion of whether the court should depart from a traditional mode of hearing – discussion of an open and just court – discussion of what constitutes a fair hearing – balance of convenience – interests of justice and equity Legislation: Fair Work Act 2009 (Cth) ss 12, 340, 341, 346, 342, 351, 361.
Federal Circuit Court of Australia Act (1999) (Cth) ss 3, 13, 66, 69.Cases cited: Board of Bendigo Regional Institute of Technology and Further Education v Barclay [No1] (2012) 248 CLR 500.
Campaign Master (UK) Ltd v Forty Two International Pty Ltd (No 3) (2009) 181 FCR 152.
Capic v Ford Motor Company of Australia Limited (Adjournment) [2020] FCA 486.
Jones v Queensland Tertiary Admissions Centre Limited (No 2) [2010] FCA 399.
Shortv Ambulance Australia [2015] FCAFC 55.
Singh v Minister for Immigration, Citizenship, Migrant Services & Multicultural Affairs [2021] FCCA 726.
State of Victoria (Office of Public Prosecutions) v Grant [2014] FCAFC 184.Number of paragraphs: 63 Date of hearing: 23 August 2021 Place: Adelaide Solicitor for the Applicant: Starke Lawyers Counsel for the Applicant: Mr Manuel Solicitor for the Respondents: Edge Legal Counsel for the Respondents: Mr Collinson ORDERS
ADG 235 of 2020 BETWEEN: ANGELA JANE BROUGHAM
Applicant
AND: ABORIGINAL HEALTH COUNCIL OF SOUTH AUSTRALIA LIMITED ACN 616 917 090
First Respondent
POLLY SUMNER DODD
Second Respondent
ANNIE-ROSE THURNWALD (and another named in the Schedule)
Third Respondent
ORDER MADE BY:
JUDGE BROWN
DATE OF ORDER:
27 AUGUST 2021
THE COURT ORDERS THAT:
1.The matter be fixed for final hearing before Judge Brown commencing on 2 March 2022 at 10:00am in the South Australian District Registry NOTING 3 days hearing time has been allocated and will not be exceeded without leave of the Court.
2.The Applicant is to file and serve any further affidavits and other materials on which she wishes to rely at trial on or before Monday 25 October 2021.
3.The Respondents are to file and serve any further affidavits and any other materials on which they wish to rely at trial on or before Monday 22 November 2021.
4.The Applicant is to file and serve any affidavits in reply on or before Monday 6 December 2021.
5.The Applicant is to file and serve an Outline of Argument at least 20 clear business days prior to the commencement of trial.
6.The Respondents are to file and serve an Outline of Argument at least 10 clear business days prior to the commencement of trial.
7.Counsel for the Respondent is granted leave to appear electronically throughout the duration of the trial. HOWEVER it is directed that all witnesses resident in South Australia appear in person subject to any COVID-19 health protocols in place at the time of the final hearing.
REASONS FOR JUDGMENT
JUDGE BROWN:
INTRODUCTION:
These are general protection proceedings arising under the Fair Work Act 2009 (Cth) (‘the Act’). The parties concerned remain in dispute and require a final hearing. The issue currently requiring determination is whether that hearing should proceed in an electronic form or should take place, in the conventional manner, face to face, in the courtroom in Adelaide.
The Applicant, Angela Brougham, was employed by the First Respondent, the Aboriginal Health Council of South Australia Ltd (‘the Council’) as its Strategic Business Executive. She commenced employment in November 2018, pursuant to a contract of employment, which was scheduled to conclude on 30 June 2019 and which was later extended to 30 June 2020.
Ms Brougham’s contract was not extended after this latter date, notwithstanding the possibility that it could be so extended. It is Ms Brougham’s case that her employment was not extended because she exercised a workplace right to complain about being subject to harassment in the workplace and because of her religious beliefs and race, in contravention of sections 341 and 351 of the Act.
The Council is a not-for-profit organisation, which is the peak body for Aboriginal health organisations in South Australia. It is an independent and community-controlled organisation, which is primarily funded through the Commonwealth and State governments and is directed, in its charter, to improve health outcomes for all Aboriginal and Torres Strait Islander people living in South Australia. I accept, in general terms, the Council is not well resourced financially and its preference would be to direct its government funding towards its constituent bodies.
The Second Respondent, Polly Sumner-Dodd is the Chairperson of the Council. At relevant times, Annie-Rose Thurnwald was a Manager and Debra Stead the Senior Finance Officer at the Council. They had personal involvement with Ms Broughton and were her superiors. She complains that they subjected her to bullying and harassment.
Ms Brougham commenced proceedings, in the Adelaide Registry of the Court, on 8 July 2020. She is a resident of South Australia, as are each of the named Respondents. Her solicitor and counsel are also based in Adelaide.
A Response was filed, on behalf of the First Respondent, on 7 August 2020. Efforts to reach common ground between the parties, through a process of Alternative Dispute Resolution, were unsuccessful. The Council has elected to retain solicitors in Hobart.
In its Response, the Council has asserted that Ms Sumner-Dodd, Ms Thurnwald and Ms Stead were not the decision makers in respect of the Council’s decision not to extend Ms Brougham’s contract of employment. It is the Council’s position that this decision was made by its Chief Executive Officer, Shane Mohor.
Mr Mohor has filed an affidavit in anticipation of the trial. It is his evidence that the decision not to extend Ms Brougham’s contract of employment was his and it was made for financial reasons relating to the Council’s recurrent funding and its need to direct resources towards combating the pandemic crisis. Mr Mohor’s evidence is supported by an Affidavit of Laura Azar, who was and is employed by the Council as its Human Resources Business Partner.
In these circumstances, the First Respondent does not propose to call the Second, Third and Fourth Respondents, none of whom have filed an Affidavit in the proceedings. They will rely on evidence from Mr Mohor and Ms Azar, both of whom is resident of South Australia. At this stage, as the Court is currently advised, Ms Brougham proposes to call only herself. Accordingly the trial is likely to take around 2 to 3 days to complete.
The trial was previously listed, on 23 August 2021, for 3 days before Judge Heffernan, who was formally a Judge of this Court. He is now a Judge of the District Court of South Australia, having been appointed to that Court on 1 April 2021. In these circumstances, regrettably, the trial listed for 23 August 2021 could not proceed.
For these reasons, the case was listed before me for mention in order for the hearing to be re-assigned. At this stage, an issue arose as to whether the trial could be heard electronically by a Judge of the Court from interstate or whether it needed to be heard, in the presence of each of the parties, in the Court in Adelaide.
Ms Brougham would prefer that the case take place in Adelaide in the conventional manner. It is her positon that the interests of justice dictate that she should be able to cross-examine Mr Mohor and any other relevant decision-maker at the Council directly to garner the full forensic potential of such an examination, which may lose its potency and efficacy, if conducted at a metaphorical arm’s length via an electronic format.
On the other hand, the Council points to its not-for-profit status and the fact that it has retained solicitors, as it is entitled to do so, in Tasmania. In the circumstances, it is submitted that the reasons why Mr Mohor decided as he did is not an unduly complicated issue and is therefore one which is readily amenable to the electronic format and it is therefore expedient that the hearing be held in this manner, as it will be the quickest and most cost effective way for it to be concluded.
LEGAL PRINCIPLES APPLICABLE TO GENERAL PROTECTION PROCEEDINGS:
Part 3-1 of the Act is headed General Protections. Pursuant to section 340(1) a person must not take “adverse action” against another person because that other person has a workplace right.
Section 341 provides the definition of workplace right. A person has such a right if, amongst other matters, they are:
able to make a complaint or inquiry:
(i) to a person or body having the capacity under a workplace law to seek compliance with that law or a workplace instrument; or
(ii) if the person is an employee—in relation to his or her employment.
Section 342(1) of the Act contains a table setting out the circumstances in which a person is to be regarded as having taken adverse action against another person. The first item of the table provides as follows:
Adverse action is taken by an employer against an employee if the employer:
(a) dismisses the employee; or
(b) injures the employee in his or her employment; or
(c) alters the position of the employee to the employee’s prejudice; or
(d) discriminates between the employee and other employees of the employer.”
The expression workplace right is defined by section 341(1) of the Act;
(1) A person has a workplace right if the person:
(a) is entitled to the benefit of, or has a role or responsibility under, a workplace law, workplace instrument or order made by an industrial body; or
(b) is able to initiate, or participate in, a process or proceedings under a workplace law or workplace instrument; or
(c) is able to make a complaint or inquiry:
(i) to a person or body having the capacity under a workplace law to seek compliance with that law or a workplace instrument; or
(ii) if the person is an employee—in relation to his or her employment.
Section 12 of the Act defines workplace law and workplace instrument. Relevantly, workplace law means the Act itself or any other law of the Commonwealth or a State, which regulates the relationships between employers and employees (including by dealing with occupational health & safety matters). A workplace instrument is any document made pursuant to a workplace law, which concerns the relationship between employers and employees.
Section 351 provides other protections for employees. Its provisions prohibit an employee from taking adverse action against an employee because of the employee’s race, religion or other specified attitudes.
It is currently Ms Brougham’s case that she was subject to such adverse action, for protected reasons, which relate to her race and religion and because she made a complaint about bullying in the workplace.
Clearly, she was subject to some form of adverse action as her contract was not extended. However, the central issue in the case is the reason why her contract was not extended. Ms Brougham has asserted her view, whilst Mr Mohor has asserted that it was for operational reasons, which were not influenced by any of the factors articulated by Ms Brougham in her application.
Clearly, this will be the central issue in the case. The only persons who definitively know why Ms Brougham’s employment was not extended are the relevant decision makers concerned. In these circumstances, it is likely to be a matter of controversy, as to what factors influenced them in their decision making role and what was the extent of this influence.
Collier J in Jones v Queensland Tertiary Admissions Centre Limited (No 2) explained the operation of section 361 of the Act in the following terms:[1]
That the employee is required to first prove the existence of objective facts which are said to provide a basis for the alleged adverse action, before the onus shifts to the employer in respect of the prohibited reason … it is not sufficient for [an applicant] to simply allege that she had a workplace right and that she was the subject of adverse action – rather on the assumption that [an applicant] is able to prove these allegations, the burden is then cast on to [the employer] to prove that adverse action was not taken against [an applicant] because of [her] workplace rights for the purposes of section 340 and 361 of the Act.
[1] Jones v Queensland Tertiary Admissions Centre Limited (No 2) [2010] FCA 399 at [10] (Collier J).
In Bendigo Regional Institute of Technology and Further Education v Barclay & Anor,[2] the High Court, in the context of section 346 of the Act, which provides protection for employees against adverse action motivated by an employer in respect of industrial activities, discussed the application of the onus arising under section 361. In the case, Gummow and Hayne JJ said as follows:
In determining an application under s 346 [it is necessary to] to assess whether the engagement of an employee in an industrial activity was a “substantial and operative factor” as to constitute a “reason”, potentially amongst many reasons, for adverse action to be taken against that employee. In assessing the evidence led to discharge the onus upon the employer under s 361(1), the reliability and weight of such evidence was to be balanced against evidence adduced by the employee and the overall facts and circumstances of each case; but it was the reasons of the decision-maker at the time the adverse action was taken which was the focus of the inquiry.[3]
[2] Board of Bendigo Regional Institute of Technology and Further Education v Barclay [No1] (2012) 248 CLR 500.
[3] Ibid at 542 [127] (Gummow & Hayne JJ).
In Shortv Ambulance Australia (‘Short’)[4] the Full Court of the Federal Court (comprised of Dowsett, Bromberg and Murphy JJ) provided an erudite and very useful summary, in respect of the application of section 361 and the authorities which relate to it, as follows:
When an employee alleges that an employer has taken action against him or her because the employee exercised a workplace right s 361 casts the onus on the employer to “prove otherwise”. Under s 360, while there may be multiple reasons for an employer to have taken the adverse action, the employer takes action for a prohibited reason if the reasons for the action include that reason. The rationale for the presumption was … as being to throw on to the employer the onus of proving that which lies peculiarly within its own knowledge
Where adverse action is taken by one person against another, the task of a court in a proceeding alleging contravention of s 340 or s 351 is to determine why the person took the adverse action and to ask whether it was for a prohibited reason or reasons which included a prohibited reason … The relevant inquiry is therefore into the “particular reason” of the decision-maker for taking action … which is a determination of fact to be made by the court taking account of all the facts and circumstances of the case and available inferences…
To displace the presumption created by s 361 in light of the effect of s 360, the respondent must prove that its conduct was not motivated in whole or in part by the prohibited reason alleged. A failure to displace the presumption enables the allegation by an applicant of adverse action for a prohibited reason to stand as sufficient proof of that fact.[5]
[4] Shortv Ambulance Australia [2015] FCAFC 55.
[5] Ibid at [54]-[56] (Dowsett, Bromberg and Murphy JJ).
In this context, it is the submission of Mr Collinson, counsel for the Council, that the issue as to the particular reason why Ms Brougham’s contract was not extended is a not unduly complicated one, given that it will only turn on the Court’s assessment of the credibility of Mr Mohor, in particular. He has already provided the reasons why the decision was made, which related to funding consideration relevant to the Council rather than anything specific to Ms Brougham’s conduct.
Mr Collinson submits that these reasons are not inherently complex in any way and does not turn on the assessment of Mr Mohor’s credit to any significant degree. As such, the task set for the Court of determining why the Council took the action which it did can be easily undertaken through an electronic format. In this context, he points to the fact that his client is an non-government organisation and it will be expensive for it to retain counsel in Adelaide, given that his instructor is based in Hobart, Tasmania.
On the other hand, it is the submission of Mr Manuel, counsel for Ms Brougham, that the case will turn to a very large degree on the assessment of the relevant decision maker’s credit and this will put Ms Brougham, at a significant disadvantage, if the hearing proceeds electronically. It is his submission that the use of video fundamentally impedes the cross-examination by either party. Essentially, he submits that it is not unknown for employers to confabulate reasons to dismiss a person in order to achieve an illegal outcome.
In addition, although Mr Manuel accepts, as he must, that the First Respondent is entitled to appoint solicitors from wherever in Australia it deems appropriate, the fact of the matter is that all the parties and witnesses concerned in the case are resident in the State of South Australia and the cause of action arose in this state.
It is the submission of Mr Manuel that these factors tip the balance of convenience in favour of the case proceeding in the conventional manner as was originally envisaged, when it was set for hearing before Judge Heffernan.
CONSIDERATIONS RELEVANT TO ELECTRONIC HEARINGS:
Pursuant to section 13(2) of the Federal Circuit Court of Australia Act (1999) (Cth) (‘the FCCA Act’) the jurisdiction of the Court must be exercised in open court.
The Federal Circuit Court of Australia is a lower level federal court, whose objects include that it operate as informally as possible and use streamlined procedures.[6]
[6] See Federal Circuit Court of Australia Act 1999 (Cth) s 3(2).
In this context, pursuant to section 66(1) of the FCCA Act, the Court may allow any relevant testimony to be given by video or audio link. This discretion is subject to the conditions stipulated in section 69.
The stipulation that proceedings be conducted in open court, in respect of video hearings, can be augmented by a general invitation being provided to any interested member of the community to attend such a hearing through his/her personal computer. This has frequently occurred during the last 18 months or so of the pandemic crisis.
In determining whether or not to depart from the traditional manner in which justice has previously been dispensed in Australia, including in the Federal Circuit Court, the Court must consider two issues above all others, which can be summarised under the following headings:
·Open justice;
·Procedural fairness.
A court hearing, which is open to the scrutiny of all, is a public demonstration of the rule of law. The rule of law is exemplified by impartiality; demonstrable fairness in procedures; and the ability for the public to observe legal argument and the delivery of reasons. As is often stated, justice must be seen to be done to ensure public confidence in the administration of justice.
In theoretical terms, as indicated above, any interested person could attend a hearing to be conducted via an electronic platform, if provided with contact details in respect of such a hearing. If they have a computer, or even a smart phone, they would be able to see and observe the proceedings, as if they were in court.
In addition, counsel for a party can take part in such a hearing and would be able to conduct a cross-examination of a witness, via such a platform. In my experience, there are some difficulties in this process. It is common for an interlocutor to cut across a witness, due to an inability to be attuned to the inherent body language inherent in such situations and the almost imperceptible time delays arising from such electronic transmission.
In Singh v Minister for Immigration, Citizenship, Migrant Services & Multicultural Affairs,[7] Judge Kendall described these problems as being hiccups, which could not be considered insurmountable.[8]
[7] Singh v Minister for Immigration, Citizenship, Migrant Services & Multicultural Affairs [2021] FCCA 726.
[8] Ibid at [49] (Kendall J).
I agree that the technology is indeed remarkable and it is commendable that both the courts and the legal profession have adapted quickly to the administration of justice through such means.
Given the lockdowns which have been necessitated on public health grounds throughout Australia, particularly in its larger states, it has been the case of the courts responding to necessity. To adopt an ancient adage needs must, when the devil drives.
Although an electronic trial is far from perfect, I am satisfied that it can satisfy the requirements of open justice and the stipulation contained in section 13 of the FCCA Act that proceedings be heard in open court, if interested parties are able to respond to an invitation to access the relevant electronic platform.
A more difficult issue is whether such a forum will provide a fair hearing. Procedural fairness dictates that a party to proceedings is entitled to be given the opportunity to present any arguments, which he or she considers vital to the case concerned and, significantly in a case such as the present, is able to test evidence comprehensively through a process of cross-examination.
If a person is deprived of either of these opportunities, the relevant trial cannot be characterised as a fair one and, as such, would represent an affront to the principles of justice. A more nuanced issue arises if a party considers, on subjective grounds, that a case conducted electronically is, in some way, a Clayton’s trial, in the sense that it represents an unsatisfactory compromise or inferior substitute to a face to face trial.
As I understand it, it is Ms Brougham’s case that she will not be able to adequately cross-examine the applicable decision makers at the Council and so expose what she asserts is their overall lack of credibility and the fact that they are, in some way, concealing the operative reason why her contract of employment was not extended. As such, she asserts that the process if potentially fundamentally unfair to her.
In Capic v Ford Motor Company of Australia Limited (Adjournment),[9] Perram J alluded to these problems, when he said as follows:
My impression of those platforms [which include Microsoft Teams which is the platform proposed for the electronic hearing in the current matter] has been that I am staring at the witness from about one metre away and my perception of the witness’ facial expressions is much greater than it is in Court. What is different—and significant—is that the video-link technology tends to reduce the chemistry which may develop between counsel and the witness. This is allied with the general sense that there has been a reduction in formality in the proceedings. This is certainly so and is undesirable. To those problems may be added the difficulties that can arise when dealing with objections.[10]
[9] See Capic v Ford Motor Company of Australia Limited (Adjournment) [2020] FCA 486.
[10] Ibid at [19] (Perram J).
Added difficulties are likely to arise, when the system fails unexpectedly. Such hearings are likely to take longer, in a virtual environment with which parties and the court itself is unfamiliar, which will increase rather than lessen expense. In addition, if a party is called upon to refer to a document, there may be logistical issues arising.
The rationale for requiring cross-examination, in ordinary circumstances, to take place in open court, was expressed by Buchanan J in Campaign Master (UK) Ltd v Forty Two International Pty Ltd (No 3):[11]
I am particularly troubled by the prospect (or possibility) that the cross-examination of an important witness might be rendered less effective by the limitations of video link technology or the absence of the witness from the courtroom. Although the days are gone when witnesses are expected to feel any sense of intimidation as an aid to telling the truth, there is no doubt in my mind that the requirement to give evidence on oath or affirmation in the (generally) solemn atmosphere of a courtroom in the presence of a judge, and to answer questions in cross-examination in the presence also of cross-examining counsel, has at least three potential benefits. It enhances the prospect that the witness will remain conscious of the nature and solemnity of the occasion and of his or her obligations. It affords the cross-examiner some reassurance that the gravity and immediacy of the moment, and of the supervising presence of the judge, are not lost on the witness and the cross-examination is not thereby rendered any less effective, to the possible prejudice of the cross-examining party. It provides the Court with a more satisfactory environment in which to assess the nature, quality and reliability of responses by a witness, both to questions and to the overall situation presented by the necessity to give evidence in court. To my mind there remains, even in the modern context, a certain ‘chemistry’ in oral interchanges in a courtroom, whether between a judge and counsel (or other representative) or between cross-examiner and witness. I would not wish too lightly to deprive a cross-examiner of that traditional forensic element in the exchange although, as the cases universally make clear, the Court must now, if asked to do so, balance the interests of a cross-examining party against claimed inconvenience both in individual cases and with respect to individual witnesses. Notwithstanding the increased availability and use of video link technology, in my view, a case must be made out for the use of video link evidence if it is opposed by an affected party.[12]
[11] See Campaign Master (UK) Ltd v Forty Two International Pty Ltd (No 3) (2009) 181 FCR 152.
[12] Ibid 171 [78] (Buchanan J).
However, I am well aware that the existence of the pandemic and the uncertainty about when it will be controlled are factors which impact upon the balance of convenience between adopting the electronic mode of trial, with the imperfections relating to cross-examination which it may entail, and the prejudice arising from the proceedings being adjourned, perhaps for a reasonably lengthy period of time.
At this juncture, an interstate judge (that is a judge from a sate other than South Australia) may be able to hear the case prior to the end of the year via Microsoft Teams. Such an option would entail all of the parties and any other interested parties attending court remotely via their respective computer screens. Many such links would be involved and, in my view, it would not be an enterprise without its potential complexities and pitfalls.
The other option is that the hearing takes place, in a conventional way, in the Adelaide courtroom before me. Due to other Court commitments, the earliest I could allocate a 3 day hearing would be 2 to 4 March 2022.
The obvious advantage of such an outcome is that all the witnesses concerned and at least one counsel, would be physically present in Adelaide. This would be particularly important insofar as any cross-examination of any relevant decision makers is concerned.
In order to minimise expense, in my view, it would be possible for counsel for the First Respondent to attend court via an electronic platform, if this was the preference of his client, particularly in terms of the reduction of expense. The major drawback of such an outcome is that it would delay the resolution of the case.
In my view, an electronic trial is different to one taking place in the courtroom which necessarily provides its own chemistry and theatre, particularly in the form of the direct interactions between counsel and witnesses and the proceeding judicial officer. An electronic trial does not permit evidence to be gathered and assessed in the natural and organic way provided by an open hearing. Necessarily there is a reduction of body language, and expression which can be best summarised of the conscious and unconscious movements and postures, by which attitudes and feelings are communicated.
In the current case, the operative reason as to why Ms Brougham was dismissed is central. It is essentially her position that the relevant decision makers have conveniently manufactured other reasons, relating to funding, to justify her dismissal, when the real reason is attributable to their perception of her as a trouble maker in the workplace and other protective attributes relevant to her.
Given the reverse onus created by section 361 of the Act, this is a complex and nuanced issue, both in legal and evidentiary terms. Axiomatically, at this stage, I am not in a position to resolve this controversy in the context of the current proceedings. However, in my view, this forms the framework in which the resolution of the discovery aspects of the case must be considered.
When the case is ultimately determined, the Court will be required to seek out the substantial and operative factor as to why Ms Brougham’s contract was not extended. This is a question of fact rather than conjecture. When boiled down, this means that the Court will be required to ascertain the real reason why the contract was not extended. This is a question to be answered “in the light of all the facts established in the proceedings”.[13]
[13] See State of Victoria (Office of Public Prosecutions) v Grant [2014] FCAFC 184 at [32] (White J).
In all the circumstances of this case, in my view, this is an issue which would be better determined in the context of a conventional hearing, rather than an electronic one, given the potential moment of the decision for all concerned, which may well turn on the Court’s assessment of the credibility of each of the parties concerned.
In my view, it is also important that Ms Brougham have confidence in the process concerned and not perceive that she has been provided with an inferior medium through which this issue, of such fundamental importance to her, is to be determined.
In my view, a balance to the pragmatic considerations raised by Mr Collinson is that he be given leave to appear, in the trial when it is scheduled, by electronic means, but the relevant witnesses, all of whom are resident in South Australia can appear personally in Adelaide for the trial.
The earliest trial dates available are in early March of next year. I will fix the trial for this time and make the necessary directions.
For all these reasons, the orders of the Court will be as set out at the commencement of these reasons for judgment.
I certify that the preceding sixty-three (63) numbered paragraphs are a true copy of the Reasons for Judgment of Judge Brown. Associate:
Dated: 27 August 2021
SCHEDULE OF PARTIES
ADG 235 of 2020 Respondents
Fourth Respondent:
DEBRA STEAD
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