Complainant 352024 v Respondent 352024 (Discrimination)
[2024] ACAT 81
•24 October 2024
ACT CIVIL & ADMINISTRATIVE TRIBUNAL
COMPLAINANT 352024 v RESPONDENT 352024 (Discrimination) [2024] ACAT 81
DT 35/2024
Catchwords: DISCRIMINATION – claim of direct discrimination by an educational authority – claim under section 18, in the alternative, section 20 of the Discrimination Act 1991 – whether ‘C’ has a disability as defined by the Act – application of detriment test – whether the unfavourable treatment was ‘because of’ C’s disability – application dismissed – suppression orders made
Legislation cited: ACT Civil and Administrative Tribunal Act 2008 s 39
Disability Discrimination Act 1992 (Cth)
Discrimination Act 1991 ss 5AA, 7, 8, 18, 20
Human Rights Commission Act 2005 ss 43, 53CA, div 4.2A
Cases cited:Kidman v Casino Canberra [2020] ACAT 50
Prezzi, Patricia Anne and Discrimination Commissioner [1996] ACTAAT 132
Purvis v New South Wales [2003] HCA 62
Qantas Airways Ltd v Gama [2008] FCAFC 69
List of
Texts/Papers Cited: Commonwealth Attorney General’s Department, ‘Consolidation of Commonwealth Anti-Discrimination Laws’ (Discussion Paper, Australian Human Rights Framework, September 2011)
Samatha Edwards, ‘Purvis in the High Court Behaviour, Disability and the Meaning of Direct Discrimination’ [2004] Sydney Law Review 30
Tribunal:Senior Member D Kerslake
Date of Orders: 24 October 2024
Date of Reasons for Decision: 24 October 2024
Date of Publication: 6 November 2024
AUSTRALIAN CAPITAL TERRITORY )
CIVIL & ADMINISTRATIVE TRIBUNAL ) DT 35/2024
BETWEEN:
COMPLAINANT 352024
Applicant
AND:
RESPONDENT 352024
Respondent
TRIBUNAL:Senior Member D Kerslake
DATE:24 October 2024
ORDER
The Tribunal orders that:
The application is dismissed
Pursuant to section 39 of the ACT Civil and Administrative Act 2008, to protect the privacy of a child with a disability, there is to be no publication by any person (whether by social or traditional media, in digital, written, or oral form, or in any other manner) of the names or identities of any of the parties or witnesses in these proceedings. Public access to the Tribunal files or to the record of proceedings is prohibited.
………………………………..
Senior Member D Kerslake
REASONS FOR DECISION
Background
In 2021, Complainant 352024 (the applicant) enrolled her young son (C) at an early childhood centre in the ACT owned by Respondent 352024 (the respondent). On 11 January 2024, the applicant lodged a complaint with the ACT Human Rights Commission (HRC) alleging discrimination against her son by the respondent.
In the material supplied to the HRC, the applicant stated that C had attended the early learning centre for approximately two years and that he had an “expected future diagnosis” of ADHD and Autism. She listed a number of concerns about the care provided for C at the learning centre, including that he was segregated from other children at mealtimes to avoid “disruption” to the other children. She stated that on one occasion she was contacted and informed of an incident where C had “been very distressed and headbutted a glass door, smashing it”. A few days later she was invited to a meeting at the centre, which was attended by the owner and the centre director. She stated that during the meeting she was informed that C “was no longer welcome at the centre, [that] they could no longer manage his behaviours, and [that the parents] needed to find other care arrangements”. She stated that she was shocked when “offered 2 weeks to make other arrangements”.
The complaint was unable to be resolved by the HRC through conciliation. Pursuant to Division 4.2A of the Human Rights Commission Act 2005 (the HRC Act), in such circumstances a complainant has the right to request that the matter be referred to the ACT Civil and Administrative Tribunal (ACAT). Following such a request, the HRC referred the complaint to ACAT on 1 July 2024. In accordance with the ACT Civil and Administrative Act 2008 (the ACAT Act), such referrals are treated by ACAT as an application for orders (discrimination application) arising from the alleged breach. For the purposes of ACAT proceedings, the complainant thus becomes the applicant, and the organisation complained about in this case is the respondent.
The discrimination application was heard over two days. In addition to the substantive discrimination application, the parties were also invited to make submissions as to whether a non-publication order made at an earlier directions hearing should be continued. Having heard from the parties, the Tribunal formed the view that, while there are public interest considerations that favour making its findings public, it is also important to take necessary steps to protect the privacy of a young person. This is reflected in the order made for the names of the parties and witnesses to be withheld, and accords with section 39 of the ACAT Act.
Relevant legislation
Section 43(1)(c) of the HRC Act allows a parent to bring a complaint on behalf of a child or young person. It is appropriate, therefore, for C’s mother to be the applicant in these proceedings. The claim made by the applicant is that the respondent has engaged in unlawful discrimination in contravention of the Discrimination Act 1991 (the Discrimination Act). Section 7(1)(c) of the Discrimination Act lists a range of attributes that are protected from discrimination. The relevant attribute in this case is disability. ‘Disability’ is defined in section 5AA to mean:
(1) In this Act:
disability means—
(a)total or partial loss of a bodily or mental function; or
(b)total or partial loss of a part of the body; or
(c)the presence in the body of organisms that cause disease or illness; or
(d)the presence in the body of organisms that are capable of causing disease or illness; or
(e)the malfunction, malformation or disfigurement of a part of the body; or
(f)a disorder or malfunction that results in a person learning differently from a person without the disorder or malfunction; or
(g)a disorder, illness or disease that affects a person’s thought processes, perception of reality, emotions or judgment or that results in disturbed behaviour; or
(h)any other condition prescribed by legislation.
(2) For this Act, disability includes—
(a)behaviour that is a symptom or manifestation of the disability; and
(b)a disability that a person may have in the future, including because of a genetic disposition to the disability; and
(c)a disability that it is thought a person may have in the future, whether or not—
(i)the person has a genetic disposition to the disability; or
(ii)there is anything else to indicate the person may have the disability in the future.
The claim brought by the applicant is based on a claim of direct discrimination, not indirect discrimination.[1] Section 8(2) of the Discrimination Act defines direct discrimination as follows:
For this section, a person directly discriminates against someone else if the person treats, or proposes to treat, another person unfavourably because the other person has 1 or more protected attributes.
[1] Applicant’s outline of claim dated 25 September 2024 at [34]
The Discrimination Act sets out different areas in which discrimination can occur. The applicant submits that in this case the respondent engaged in discrimination as an educational authority or, in the alternative,[2] as the provider of services within the meaning of section 20 of the Discrimination Act. With respect to education, section 18 of the Discrimination Act provides that:
[2] Applicant’s outline of claim dated 25 September 2024 at [74]
(1) It is unlawful for an educational authority to discriminate against a person—
(a)by failing to accept the person's application for admission as a student; or
(b)in the terms or conditions on which it is prepared to admit the person as a student …
(2) It is unlawful for an educational authority to discriminate against a student—
(a)by denying the student access, or limiting the student's access, to any benefit provided by the authority; or
(b)by expelling the student; or
(c)by subjecting the student to any other detriment.
In relation to the provision of services, section 20 provides that:
It is unlawful for a person (the provider) who (whether for payment or not) provides goods or services, or makes facilities available, to discriminate against another person—
(a) by refusing to provide those goods or services or make those facilities available to the other person; or
(b) in the terms or conditions on which the provider provides those goods or services or makes those facilities available to the other person; or
(c) in the way in which the provider provides those goods or services or makes those facilities available to the other person.
Section 53CA(2) of the HRC Act deals with the onus of proof in a claim of unlawful discrimination. It is a rebuttable presumption that discrimination has occurred if the complainant:
(a) establishes that—
(i)for a complaint about direct discrimination—the treatment or proposed treatment is unfavourable; and …
(b) presents evidence that would enable the ACAT to decide, in the absence of any other explanation—
(i)for a complaint about direct discrimination—that the treatment or proposed treatment is because of a protected attribute of the other person.
The applicant’s submissions
Although the applicant addressed a wide range of concerns in her original complaint to the HRC, at the ACAT hearing she stated that she is no longer pursuing all of those concerns, nor all four of the orders originally sought. The order sought from the Tribunal is that the respondent pay $15,000 in damages for hurt, humiliation, and distress experienced by C and his family as a result of the respondent’s conduct. The applicant claims that the respondent subjected C to direct discrimination because of his disability in the area of education, or in the alternative, in the area of service, when it terminated C’s enrolment at the learning centre. The following is considered to be a fair and accurate summary of the applicant’s claims and supporting evidence.
Whether C has a disability as defined by the Discrimination Act
The evidence relied upon by the applicant included statements from the following persons:
(a)C’s mother, who stated that while he is too young for formal diagnosis, he has an expected future diagnosis of ADHD and Autism; has a global delay in speech; struggles with self-regulation; and has been receiving regular speech and occupational therapy.
(b)C’s stepfather, who gave substantially similar evidence.
(c)A letter of referral to a medical practitioner prepared by an Occupational Therapist, stating that C probably had ADHD and/or Autism.
(d)The respondent’s written response to the discrimination application, which made reference to:
(i) A global delay in C’s speech;
(ii) Significant emotional control and regulation difficulties, behavioural issues, and sensory difficulties;
(iii) Difficulty understanding directions; and
(iv) Auditory, oral, visual processing and movement difficulties.
Referring to sections 5AA(1)(f) and 5AA(1)(g), the applicant submitted that the above evidence establishes that C has a disorder that results in learning differently from a person without the difficulty; and that affects a person’s thought processes, perception of reality, emotions or judgement or that results in disturbed behaviour. The applicant submitted that, pursuant to section 5AA(2)(a), the meaning of disability was extended to include behaviour that is a symptom of manifestation of C’s disability. It was further contended that there was no requirement under the relevant provisions for a formal diagnosis of disability to have been made by a medical practitioner. Rather, in the applicant’s submission, it was a matter for the Tribunal to be satisfied based on the available evidence that C has a disability within the meaning of the Discrimination Act.
The claim of discrimination by an educational authority
The applicant referred to a number of factors to support the contention that the early learning centre fits the definition of an educational authority, including the facts that the respondent refers to learning development as part of its activities, to its staff as educators; and such organisations are overseen by the ACT educational authority. Noting that the term ‘student’ is not defined in the Discrimination Act, the applicant submitted that in the context of an education authority, having applied to be enrolled at the centre and having his enrolment accepted, C became a student at the centre, and it was therefore unlawful for the respondent to discriminate against him in the ways prohibited by section 18 of that Act.
The provision of goods and services
The applicant’s claim was also based on an alternative claim of unlawful discrimination in the provision of services pursuant to section 20 of the Discrimination Act, the term ‘services’ being defined in the dictionary of that Act to include any profession, trade, or in this case in the applicant’s submission, a business. The applicant submitted that the respondent in effect communicated to C’s mother that if she did not remove C from the school, it would act to terminate his enrolment. This, the applicant submitted, amounted to “a denial, or a proposed denial” of C’s access to a service.
The ‘because of’ requirement
The applicant noted that under the Discrimination Act, it is necessary to establish that the claimed unfavourable treatment was because of C’s disability. In that regard, the applicant contended that while the respondent may have held genuine concerns for C’s safety and that of others, the underlying reason for its actions was C’s behaviour, and that such behaviour was a manifestation of C’s development delays, which the applicant contended meet the definition of disability. On this basis, the applicant submitted that the respondent’s actions were ‘because of’ C’s behaviour linked to his developmental delay, and hence were ‘because of’ C’s disability.
The outcome sought
In concluding remarks at the Tribunal hearing, the applicant submitted that it was appropriate for the Tribunal to reach a finding of unlawful discrimination, and to make an order for compensation in the range of $10,000 to $15,000.
The respondent’s submissions
Whether C has a disability within the meaning of the Discrimination Act
The respondent drew the Tribunal’s attention to case law that it submitted was persuasive for the view that a disability needs to be established with a reasonable degree of precision.[3] While accepting that the definition of disability includes a behaviour or symptom of disability, the respondent submitted that the applicant has not submitted any medical documentation, legal authority, or factual basis to support the claim that C has, or may have in the future, a diagnosis of Autism and ADHD, as opposed to his behaviour being that of a 3-year-old child. The respondent also stated that at no time during C’s enrolment had the learning centre been informed that C had been formally diagnosed with a ‘disability’.[4]
Whether there has been a contravention of section 18 or section 20 of the Discrimination Act
[3] Qantas Airways Ltd v Gama [2008] FCAFC 69
[4] Witness statement of Director dated 28 August 2024 at [5]
The respondent submitted that, even accepting that childcare or early learning centres fall within the meaning of educational institution, it was not aware at the time of C’s enrolment that he had or may have a disability. In support of that contention, the respondent stated that the applicant had indicated on C’s enrolment form that he did not have a serious illness, did not require regular medication, and had not experienced language or speech difficulties. The respondent further submitted that it had provided C with all the same benefits as any other child, and that any action it took in relation to C’s behaviour was for his benefit, not to his detriment, where his behaviour created a risk to himself and others.
The ‘termination’ of C’s enrolment
The respondent submitted that it had not expelled C from the centre. Rather, C’s parents had withdrawn his enrolment. The respondent further submitted that the purpose of the meeting with the applicant on 14 November 2023 had been to discuss C’s best interests and navigate a way forward that took account both of C’s interests and the welfare of other children and educators. At the meeting it conveyed that on account of C’s self-harming and destructive behaviour, he needed one-on-one care that the centre was not set up to provide. The respondent stated that the applicant had been contacted by email the day after the meeting because it had identified what appeared to be a misunderstanding on the applicant’s part, had sought to clarify that it had not terminated C’s enrolment, and that it remained open to discussing C’s needs and challenges. It contended that it could not be to blame for an apparent misunderstanding on the applicant’s part when it had made the position clear in writing almost immediately after the meeting. The respondent submitted that, on this basis, it did not deny or limit C’s access to any benefit it provided, nor did it expel him or subject him to any other detriment within the meaning of section 18(2) of the Discrimination Act.
Direct discrimination and relevant comparator
Although the respondent denied any responsibility for the termination of C’s enrolment, out of “abundant caution” it submitted that even if the Tribunal found to the contrary, it could not be said that the applicant has established that any action taken by the centre was ‘because of’ C’s disability. The respondent submitted that it was appropriate for the Tribunal in this case to apply a relevant comparator, which it submitted should be a child with the same behavioural characteristics as C, without C’s disabilities: that is, the Tribunal should consider whether another child without C’s disability, but who engaged in the same behaviour, would have had their enrolment “terminated”. In this regard, the respondent submitted that any decisions, suggestions, or recommendations it made with respect to C’s care were based on a threat to his own wellbeing and that of others, having regard to:
(a)C’s behaviour, including disruption and physical violence;
(b)Educators’ inability to apply any physical intervention where such behaviour occurred; and
(c)The risk to C’s safety and that of other children and educators.
The Tribunal’s decision and reasons
To conclude that the respondent’s conduct amounts to direct discrimination, the Tribunal must be satisfied that C has a protected attribute (in this case, a disability); that the conduct in question occurred in an area protected under the Discrimination Act (the provision of education and/or of a service); that the respondent’s conduct amounted to unfavourable treatment; and that the unfavourable treatment was “because of” C’s disability.
Whether C should properly be regarded as having a disability or future disability
The respondent has pointed to the fact that the applicant has not submitted any medical documentation that C has or may have a disability. While I acknowledge that a medical diagnosis would be of some assistance, I do not consider that the absence of a medical opinion precludes the Tribunal from reaching a view under the Discrimination Act, taking account of other relevant and reliable evidence. Accordingly, I note that the respondent itself has acknowledged that C has significant developmental difficulties and delays. I have also taken note of a report tendered by the applicant from a qualified paediatric occupational therapist, who has helped C with his development, and who is of the opinion that he probably has Autism and ADHD.[5] Taking these factors into account, I am satisfied that C can reasonably be regarded as meeting the definition, in section 5AA(1)(f) of the Discrimination Act, of having “a disorder or malfunction that results in a person learning differently from a person without the disorder or malfunction”. I also note the evidence of C engaging in significant self-harming behaviour, and consider that this satisfies the definition set down in section 5AA(1)(g).
Whether section 18 and/or section 20 of the Discrimination Act are enlivened
[5] Progress report of Penny Gardner, Subpoena documents
I am satisfied that the early learning centre meets the definition of ‘other’ educational authority as defined in the Dictionary of the Discrimination Act, in that it provided educational services to younger children, and hence falls within the ambit of section 18. This is borne out, inter alia, by its reference to staff as educators. I am also satisfied that the respondent was engaged in the provision of a business service and hence meets the definition of “services” for the purposes of section 20.
Whether C was treated unfavourably by the respondent
The next matter I need to consider is whether C was treated in a way that constitutes unfavourable treatment. The Discrimination Act does not define ‘unfavourable treatment’. Using the ACAT decision in Kidman v Casino Canberra Ltd[6] (Casino Canberra) as a helpful guide, the test to be applied is an objective one. The Tribunal in that case stated:
The Discrimination Act does not invite a comparison between the way in which a person who has a particular attribute is treated compared with a person without that attribute or who has a different attribute. In other words, it does not ask: “were you treated less favourably than others?” It asks, “were you treated unfavourably?” This is an objective test. It calls for an examination of the treatment accorded to the complainant. If the consequence of the treatment is unfavourable to that person there is ‘unfavourable treatment’ and the question then turns to the reason for that unfavourable treatment, and whether it is because of the attributes they possess.[7]
[6] [2020] ACAT 50
[7] [2020] ACAT 50 at [22]
In her initial application, the applicant referred to a number of circumstances where she submitted that C had been treated unfavourably. In the course of the hearing, this was narrowed to unfavourable treatment related to the termination of C’s enrolment. There is an evident difference of view between the parties as to the circumstances in which C ceased to be enrolled at the learning centre. In an email to the applicant dated 15 November 2023, the owner of the centre stated: “We have categorically NOT terminated your son [C’s] enrolment and do not plan to do so yet however we see this as the likely outcome based on the evidence and available options to date.” Although the respondent appears to have been seeking to clarify that no action was being taken to “expel” C or to withdraw services at that time, use of the terms “yet” and “likely” clearly suggests that action to terminate C’s enrolment was liable to occur at some time in the future. Although the respondent argues that it was the parents’ own decision to withdraw C’s enrolment, I am satisfied that C and his family were treated unfavourably. I accept that the learning centre had formed the view that it could no longer accommodate C’s needs, and that the family needed to look to an alternative service provider. The centre may well have been prepared to allow the applicant time to explore other options. The clear message conveyed, however, was in my view that at some point C’s enrolment would come to an end. This message in itself was adverse to the interests of C and his family, and can properly be categorised as unfavourable treatment.[8]
Whether the unfavourable treatment was ‘because of’ C’s disability?
[8] See Prezzi, Patricia Anne and Discrimination Commissioner [1996] ACTAAT 132
Applying the test laid down in Casino Canberra, it still remains for the Tribunal to consider whether the unfavourable treatment experienced by C was ‘because of’ his disability, as per section 8(2) of the Discrimination Act. Although the respondent denies that it had decided to terminate C’s enrolment, it has argued in the alternative that if the Tribunal finds that it did do so, this cannot be said to have been ‘because of’ C’s disability. In formulating this submission, the respondent referred to the High Court’s consideration of the ‘because of’ issue in Purvis v New South Wales[9] (Purvis). This is a case that bears some factual similarities with the current matter, in that it related to termination of the enrolment of a student who had engaged in anti-social behaviour, such as acts of aggression towards other students and teachers. A key consideration was whether, under the relevant legislation, the school was under an obligation to accommodate the effects of a person’s disability — in that case, disturbed behaviour — in order to avoid being found to have engaged in unlawful discrimination.[10] The respondent referred to the approach adopted by the plurality of judges in Purvis, who held:
Once the circumstances of the treatment or intended treatment have been identified, a comparison must be made with the treatment that would have been given to a person without the disability in circumstances that were the same or were not materially different … [Unlawful discrimination is established] only if it were found that [the student] was treated less favourably than a person without his disability would have been treated in circumstances that were the same or were not materially different …[11]
[9] [2003] HCA 62
[10] Samatha Edwards, ‘Purvis in the High Court Behaviour, Disability and the Meaning of Direct Discrimination’ [2004] Sydney Law Review 30
[11] Purvis per Gummow, Hayne and Heyon JJ, at [224]–[225]
Before proceeding further, it is important to note a difference between the relevant provisions considered in Purvis (section 5 of the Commonwealth Disability Discrimination Act 1992), and section 8 of the ACT’s Discrimination Act. The former applies what is commonly referred to as a ‘comparator test’, focussing on whether direct discrimination is established by comparing the treatment of the complainant to the treatment of a theoretical person who does not have the same protected attribute. The ACT provisions, on the other hand, apply what is referred to as a ‘detriment test’. The elements of the latter are:
(a)the unfavourable treatment must cause the complainant to experience detriment or disadvantage, and
(b)the treatment must have been caused by the complainant’s protected attribute.[12]
[12] See, for example, Commonwealth Attorney General’s Department, ‘Consolidation of Commonwealth Anti-Discrimination Laws’ (Discussion Paper, Australian Human Rights Framework, September 2011), page 10
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Although the ACT legislation applies what appears to be a simpler test and does not make specific reference to a comparison with other persons, it nonetheless remains necessary in a claim of discrimination to consider why the alleged perpetrator took the action it did. For the applicant to succeed, it is not necessary to establish that the respondent intended to discriminate against C, but it is necessary to show that the detriment or unfavourable treatment complained of was caused by his disability. As noted in the ACAT decision in Casino Canberra, referring to Purvis, the “central question” is: why was the applicant treated as he was?[13] Applying the provisions set down in section 53CA(2)(b)(i) of the HRC Act, the question is whether the applicant has presented evidence that would enable the Tribunal to decide — in the absence of any other explanation — that there is a direct causal link between C’s unfavourable treatment and his disability.
[13] Kidman v Casino Canberra [2020] ACAT 50
The respondent has submitted that any decision that it took or sought to suggest to the applicant, was made not on the basis of C’s disability but because his behaviour presented a threat to the safety and well-being both of C himself and other children as well as staff at the centre.
The applicant, in her Outline of Claim, stated that at her meeting with the centre owner and director on 14 November 2024, they advanced a ‘variety of reasons underlying their conduct’,[14] as well as for the follow up email sent to the applicant the following day. The various reasons for the respondent’s conduct were stated by the applicant to include concern for C’s safety and the safety of others, and concern that the centre might lose staff. The applicant contended, however, that underlying these concerns was a concern about C’s behaviour, which it submitted was a manifestation of C’s developmental disorder and hence of his disability. The applicant outlined the following chain of reasoning:
(a)The respondent acted as it did because it held a variety of concerns.
(b)It held those concerns because of aspects of C’s behaviour.
(c)These aspects of behaviour were a manifestation of C’s developmental delays.
(d)C’s developmental delays constitute a disability within the statutory definition.
(e)It must be, therefore, that the respondent’s acts were because of C’s disability.
(f)The acts therefore constitute unlawful discrimination in that they constitute unfavourable treatment because of C’s disability.
[14] Purvis at [79]
I have taken this to suggest that because staff at the centre were concerned about C’s behaviour, and such behaviour is a manifestation of C’s disability, then staff at the learning centre can only have taken the actions they did because of that disability. I am not persuaded by this line of reasoning. The fact that a person’s behaviour is a manifestation of a disability does not mean that, in a causal sense, another person’s response to such behaviour must be attributed or predominantly linked to that disability, and cannot be attributed to some other explanation. This is supported by the wording in section 53CA of the HRC Act, “in the absence of any other explanation”.
The respondent provided witness statements from staff members at the learning centre, all of whom also gave evidence on oath. They stated that C had often engaged in self-harming behaviour, for example “head-butting” a glass door with sufficient force to cause injury to himself and damage to the door. They also consistently reported regular instances of destructive behaviour and physical aggression (“lashing out”) towards other students and staff. The respondent had a duty to C; to other children in its care; and to the staff it employed. Taking the above factors into account, and the veracity of the testimony provided, I am satisfied that the respondent acted out of concern about the risk constituted by C’s behaviour to other children, to staff, and importantly, to C himself. I acknowledge the applicant’s evidence that she felt disadvantaged by the matters raised by the respondent, and that they resulted in emotional distress. Direct discrimination only applies, however, where unfavourable treatment occurs “because of” a person’s protected attribute. Based on the available evidence, I am satisfied that the respondent did not discriminate against C on the basis of his disability, in either the area of education or in the provision of a service.
I therefore order that the application is dismissed. I also order that, to protect the privacy of a child, the names of the parties as well as witnesses in these proceedings are not to be published, and the file should remain closed to the public.
………………………………..
Senior Member D Kerslake
Date(s) of hearing: 24 and 25 September 2024 Solicitor for the Applicant: Mr J Raine, Raine Litigation Solicitor for the Respondent: Ms A Tahhan, Chamberlains Law Firm
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