CONSTRUCTION OCCUPATIONS REGISTRAR & FEKETE (Occupational Discipline)
[2012] ACAT 50
•20 July 2012
ACT CIVIL & ADMINISTRATIVE TRIBUNAL
CONSTRUCTION OCCUPATIONS REGISTRAR & FEKETE (Occupation Discipline) [2012] ACAT 50
OR 12/13
Catchwords: OCCUPATIONAL DISCIPLINE – CONSTRUCTION OCCUPATION – building certifier – breach of the Building Act 2004 – admission of breach - factors considered before making occupational discipline order under section 57 of the Construction Occupation (Licensing) Act 2004 - factors considered before making order for occupational discipline under section 65 of the ACT Civil and Administrative Tribunal Act 2008 – impact of contravention - public confidence in regulatory system – purpose of occupational discipline: protection of public, not punishment - penalty
List of legislation: ACT Civil and Administrative Tribunal Act 2008
(ACT),
ss 65(2) and (3), 66 (2) and 67
Building Act 2004, ss. 18, 19, 25A, 26(1), 28(1), 28(2)(b)(i) and (ii), 29(1)(g)(i),(ii) and (iii) and s 30(1)(a)
Construction Occupation (Licensing) Act 2004, ss 7(e), 9(1), 9(3), 9(4), 16, 55(1)(a) and 56(1)(a) and 57
Planning and Development Act 2007ss 46, 47, 50, 51(1), 54(1)(a)(b)and (c), 55(4), 116, 133 and 133,
List of Regulations: Planning and Development Regulation 2008, s. 20, schedule 1.100
ACT Civil and Administrative Tribunal Regulation 2009. reg.4
List of cases: Harb & Anor v Commissioner for Fair Trading NSW Office of Fair Trading [2007] NSWADT 175
Joseph Fekete and Chief Executive of ACT Department of Urban Services [2003] ACTAAT 6
The New South Wales Bar Association and Evatt [1968] 117 CLR 177
Tribunal: Ms E. Symons, Presidential Member
Date of Orders: 20 July 2012
Date of Reasons for Decision: 20 July 2012
AUSTRALIAN CAPITAL TERRITORY )
CIVIL & ADMINISTRATIVE TRIBUNAL ) OR 12/13
BETWEEN:
THE CONSTRUCTION OCCUPATIONS REGISTRAR
Applicant
AND:
JOSEPH FEKETE
Respondent
TRIBUNAL: Ms E. Symons, Presidential Member
DATE:20 July 2012
ORDER
1.The Respondent be reprimanded.
2.The Respondent pay the amount of $1,000 to the Territory within 28 days of the date of this order.
3.The Tribunal directs the Respondent to comply with the requirement that within 28 days of the date of this order he submit the procedures referred to in paragraphs 34 and 37 of his Witness Statement (Exhibit R1) to the Constructions Occupation Registrar (the Registrar) and that, subject to further order of the Tribunal, he implement any changes notified in writing to him by the Registrar within seven days of the date of such written notification.
4.The parties have liberty to apply in relation to Order 3.
………………………………..
Ms E. Symons
Presidential Member
REASONS FOR DECISION
This is an application by the Construction Occupations Registrar (‘the Applicant’) for occupational discipline under section 56(1)(a) of the Construction Occupation (Licensing) Act 2004 (‘the COL Act’).
Joseph Fekete, who is the Respondent in these proceedings, is the holder of a Principal Building Surveyors Licence, being Licence number 200016267 which expires on 28 September 2012. Mr Fekete is the sole director of and a nominee for Canberra Region Building Certifiers Pty Ltd (‘CBRC Pty Ltd’), which is the holder of a Principal Building Surveyors Licence, being Licence number 2011278.
It is common ground that in or about 1 August 2010 Mr Fekete (‘the Respondent’) was engaged by Mr Bill Vardos to provide building certification services at Block 4 Section 24 Casey (‘the Casey property’). The Applicant received a complaint in relation to the Respondent’s certification services in relation to the Casey property. The Applicant investigated the complaint and then notified the Respondent by letter dated 15 May 2012 of the complaint and allegations and sought submissions by 4 pm, 22 May 2012. The Respondent provided a response to the Applicant’s letter on 22 May 2012. The application for occupational discipline arises out of these circumstances.
The Applicant’s Contentions
In the Application for Disciplinary Action lodged on 5 June 2012 the Applicant alleged that two grounds for occupational discipline existed, namely:
i.that on or about 16 August 2010 Respondent contravened section 30(1)(a) of the Building Act 2004 (‘Building Act’) by issuing building approval for Block 4 Section 24 Casey, for development which was not exempt development; and
ii.that on or about 16 August 2010, the Respondent contravened sections 28(2)(b)(i) and (ii) of the Building Act by issuing building approval for Block 4 Section 24 Casey without reasonable grounds for believing that each approval requirement was met, and in circumstances where building approval should not have been issued under section 30 of the Building Act.
The Applicant contends:-
a. that the Respondent certified that the single dwelling at the Casey property is exempt from development approval (DA) when in fact the gross floor area of the dwelling was too large for the RZ1 block size, causing the plot ratio to be greater that 50% in contravention of section 29(1)(g)(iii) of the Building Act;
b. the Respondent issued a building approval and Building Commencement Notice for the Casey property, classed as RZ1 without obtaining development approval in contravention of sections 28 and 30 of the Building Act; and
c. that if these breaches are established, there may be grounds for occupational discipline under section 55 of the COL Act.
The Respondent’s Contentions
Importantly, the Respondent acknowledged that the Building Act had been breached. This admission is made in the Respondent’s letter to Mr Shaun(sic) Moysey dated 22 May 2012 which is Annexure “D” to the Respondent’s Witness Statement dated 11 July 2012 which was admitted into evidence.
The Respondent contended that, while accepting full responsibility, the breach was unintentional, that the plans for the Casey property had been pre-reviewed by the estate developer and approved on 24 June 2010 and no issue regarding the plot ratio had been raised by them and that there had only been a localized impact on the immediate neighbours.
The Hearing
The Applicant was represented by Mr Wayne Sharwood of Counsel and the Respondent was represented by Mr Philip Walker of Counsel. Evidence was given by Mr Fekete and his Witness Statement dated 11 July 2012 was admitted into evidence (Exhibit R1).
Applicable Law
The application to the Tribunal for an occupational discipline order is brought under section 66 of the ACT Civil and Administrative Tribunal Act 2008 (‘the ACAT Act’). Pursuant to subsection 66(2)(e) of the ACAT Act, such an order can be made if the Tribunal is satisfied under sub-section 65(2) of that Act that a ground for occupational discipline exists against the person. The application is also made under section 56 of the COL Act. That section provides as follows:
(1) If the registrar believes on reasonable grounds that a ground for
occupational discipline exists in relation to a licensee, the registrar
may —(a) apply to the ACAT for an occupational discipline order in
relation to the licensee; ...
10. The Tribunal notes, in passing, that the Construction Occupations Registrar has independent powers under section 56 of the COL Act to take various forms of disciplinary action such as reprimanding the licensee; requiring the licensee to complete a stated course of training or imposing a condition on the licence or amending an existing condition.
11. Section 55(1) of the COL Act identifies grounds for occupational discipline for persons holding licences under the COL Act. Relevantly, in these proceedings the Applicant relies on section 55(1)(a) – that the licensee, or a nominee or employee of the licensee, contravened an operational Act. The term ‘operational Act’ is defined by section 16 of the COL Act to include the Building Act and the Planning and Development Act 2007 (‘the PD Act’). The contraventions of the Building Act that have been alleged are:
a)section 30(1)(a) – A certifier must not issue a building approval if carrying out the work to which the application for the approval relates would result in the contravention of this Act or any other law in force in the ACT because of the design or siting of a proposed building;
b)section 28(2)(b)(i) and (ii) – After receiving the application for approval, the certifier must, if satisfied on reasonable grounds that the plans meet each applicable approval requirement under section 29 and is not prevented from being issued under sections 30 or 30A must prepare a notice (building approval certificate) certifying what approval requirements apply to the application and why the building approval is not prevented from being issued
Mr Fekete’s evidence
12. The Respondent gave evidence that he was a Principal Building Surveyor. In this capacity he has issued a total of approximately 4,500 certifications. He had one earlier disciplinary matter in 2003, which arose in 2001, which resulted in a restriction on his licence. He confirmed that the contents of his Witness Statement were true.
13. He said that, in approving a dwelling at the Casey property which exceeded the allowable plot ratio he made an error and accepted full responsibility for it. He has since changed the administrative processes in his practice in respect to dwellings which may be DA exempt. Whereas he was operating with two part time employees, these two employees, Paul Thomas, who is a general surveyor, and Julie Seaman, who is an office administrator, are now working full time. He also said that he has changed his approval practices dramatically so that they are more rigorous and methodical, and that he has drawn up a check list and he and Mr Thomas cross check each other’s appointments using this check list.
14. In cross examination, he acknowledged he had received five demerit points in 2010 for five separate jobs, because he did not lodge plans with ACT Planning and Land Authority (ACTPLA) within seven working days. In re examination, he said he did not agree that all five of these points had been correctly imposed as one had the wrong block and section number, one did not have a date and two were demolitions allegedly in a Greenfields area and this did not occur.
15. He was questioned at length about his calculation of the plot ratio. He said he had used the square metre figures on the plan, which was annexed to his Witness Statement, in the block entitled “Building Area” and excluded the 31.00 square metres for the Alfresco area. He agreed that the floor plan on this plan clearly stated “BLOCK 4 SECTION 24 540 M2”. When asked how he got the wrong figure, such as on a calculator he replied “I made a mistake”. In his office he had the “Single Dwelling Assessment for Exempt Development” forms prepared by ACTPLA. This form for the Casey property was included in the Application lodged by the Applicant on 5 June 2012 and the Respondent agreed he had selected Zone RZ2 under Part A Zone Specific Controls on this form and stated that it had complied with the Rule R6A for Plot Ratio.
16. The Respondent said, in June 2010, he had returned from overseas and was busy due to the work which had built up while he was away. He found that he was still busy two months later as he had constant work coming to him through lots of land being released at this time. He had not previously done work for Bill Vardos, the owner of the Casey property. Mr Vardos was an owner/builder who wanted to get going and he was putting pressure on the Respondent. He made a couple of phone calls to the Respondent and he wanted to know what was happening with the plans. He agreed that his being busy and the pressure from Mr Vardos caused his error.
17. He also said he had assumed that the estate developer must have checked the plans for the Casey property as he had seen their stamp on the plans. He acknowledged that it was not wise to make assumptions and that he should rely on his own calculations.
18. While he had always had a process in place at his office, this process has been evolving constantly and as a result of the changes he has made he has had a really rigorous checking process for the last twelve months, maybe a bit longer. This process includes a thorough check list, a copy of which he did not have at the hearing, which now forms part of each file and is used for checking.
19. He confirmed that he has approximately 470 active projects which have come from repeat clients such as builders. He said he is not taking on new clients.
Consideration
20. The Applicant’s allegations, in essence, arise out of the same conduct by the Respondent. As Counsel for the Respondent acknowledged, it is to the Applicant’s credit that he has conceded he made an error. While it was not readily apparent from the evidence how the error occurred, to some degree, this may be understandable as the conduct which was in error occurred in 2010.
21. The Application asks for final orders that the Tribunal reprimand the Respondent pursuant to section 66(2)(a) of the ACAT Act; that the Respondent pay $1,000 to the Territory pursuant to section 66(2)(h) of the ACAT Act and that the Respondent’s licence be suspended for a period of four months pursuant to section 66(2)(e) of the ACAT Act.
22. When Counsel for the Respondent submitted that the Respondent says he is happy to see the Registrar to see if his current procedures measure up, Counsel for the Applicant submitted, in the light of this statement and the statement in the Respondent’s Witness Statement at paragraph 37 “I would like to submit my procedures to the Applicant for his comments”, that the Tribunal may consider giving the Respondent a direction to comply with a requirement or condition on his licence or registration for a nominated period of time to ensure that the Respondent follows through with this statement.
23. When a party has applied for an occupational discipline order, the Tribunal is obliged to consider the factors under section 57 of the COL Act and section 65 of the ACAT Act before making such an order. These provisions are set out in full below.
24. Section 57 of the COL Act:
57 Considerations before making occupational discipline orders
(1) This section applies if the ACAT is considering an application for an occupational discipline order in relation to a licensee.
(2) Without limiting the matters the ACAT must consider in relation to a
licensee, the ACAT must consider the following:
(a) the degree of responsibility of the licensee for the act or omission that made up the ground for occupational discipline;
(b) the number of people detrimentally affected by the doing of something, or not doing something, that made up the ground for occupational discipline;
(c) the extent to which it is necessary to discourage the licensee and others from doing something, or not doing something, that made up the ground for occupational discipline;
(d) whether, and the extent to which, it is necessary to protect the public from the licensee;
(e) the desirability of making the licensee responsible for the consequences of the licensee’s acts or omissions;
(f) the desirability of maintaining public confidence in the regulatory system set up by this Act;
(g) the licensee’s regard, or disregard, for public safety and protection of the environment when doing something, or not doing something, that made up the ground for occupational discipline.
25.Section 65 of the ACAT Act:
65 Considerations before making orders on application for occupational discipline
(1) This section applies if the tribunal is considering an application for
occupational discipline against a person (the subject person).
(2) The tribunal may make an order for occupational discipline in
relation to the subject person if satisfied that a ground for occupational discipline exists against the person.
(3) In considering what occupational discipline to use against the
subject person, the tribunal must consider the following:
(a) whether the person took reasonable steps to avoid the action (the
contravention) that is the ground for occupational discipline;(b) whether occupational discipline has previously been used against the
person for a similar act;(c) whether the person has taken steps to mitigate the effect of the
contravention;(d) the impact of the contravention on any other person;
(e) the likelihood that the person will act in a way that is a ground for
occupational discipline in the future;(f) whether the entity bringing the application has applied for particular
occupational discipline to be used and, if so, the kind of occupational
discipline applied for.(4) The tribunal may consider any other relevant matter.
26. The Tribunal shall, firstly, address the criteria under section 57 of the COL Act. The criterion in section 57(2)(a) requires the Tribunal to consider the degree of responsibility of the licensee for the act or omission that made up the ground for occupational discipline. Consideration of this criterion raises the related considerations set out in section 57(2)(e) of the COL Act – the desirability of making the licensee responsible for the consequences of the licensee’s acts or omissions. In this case, the Respondent has accepted full responsibility for the acts and omissions which constitute breaches of the Building Act and the COL Act. He admitted that there were flaws in the way he managed statutory compliance at this time. He said that he has been implementing new procedures; he described this as an evolving process and that the new process, which he described as a rigorous process, has been in operation for at least 12 months.
27. Pursuant to section 57(2)(b) of the COL Act, the number of people detrimentally affected by the ground of occupational discipline is confined as the breaches have mainly affected the lessees of the premises, albeit probably in a beneficial way as the property is bigger than it ought to have been. However, although there was no evidence of the neighbours’ views, it is an inescapable conclusion that they now have a bigger house nearby which should not have been approved. The Respondent said he had apologized to the lessees and to the neighbours.
28. The Tribunal must also consider, under section 57(2)(c), the extent to which it is necessary to discourage the licensee and others from doing something that makes up the ground for occupational discipline. It is critical that the legislative standards set under the COL Act and the Building Act are maintained. This is closely related to the criterion in 57(2)(f) of the COL Act, i.e. the desirability of maintaining public confidence in the regulatory system set up by the COL Act, since lessees must have faith that all participants in the construction process are fully aware of and fulfil their statutory responsibilities and these responsibilities are not negotiable. Counsel for the Respondent submitted that this did not require the Tribunal to impose a severe penalty for this to occur.
29. The purpose of the exercise of disciplinary powers is to protect the public and not to punish. (NSW Bar Association v Evatt (1968) 117 CLR 177). The criterion in section 57(2)(d) requires the Tribunal to consider whether it is necessary to protect the public from the Respondent. Counsel for the Respondent submitted that no one can ever protect the public from errors occurring. The Respondent readily acknowledged his error. This criterion needs to be considered alongside the evidence that the Respondent has issued a total of approximately 4,500 certifications and apart from this occupational discipline matter he has had one previous occupational discipline matter where the circumstances giving rise to it occurred in 2001 and the decision was handed down in 2003. The earlier matter involved a finding that Mr Fekete had turned a blind eye to an obviously fraudulent document.
30. Finally, section 57(2)(g) of the COL Act, which requires the Tribunal to consider whether the licensee has disregarded public safety or the protection of the environment, is not applicable as the Respondent’s breaches do not raise either of these issues.
31. In relation to the factors which must be considered under section 65 of the ACAT Act, the first consideration under section 65(3)(a) is whether the person took reasonable steps to avoid the contravention. The Respondent’s evidence was that he had been away overseas in the middle of 2010 and the work was mounting up for his attention on his return. He was the only full time person in his office. He had two part time workers, one a general surveyor and the other an administrative officer. As well as being very busy from being overseas, he said he was also busy due to the ongoing release of land. In addition to this his client for the Casey property was an owner/builder who was applying some pressure to him to find out what was happening with his plans. He assumed that the plans were DA exempt as they had been stamped by the estate developer. The Respondent conceded at the hearing that the square metres were clearly identified on the plans as being 540 and that this should have alerted him to the fact that this was not an exempt property. A more careful reading of the plans could have minimized or removed the opportunity for the Respondent to make this error. The Tribunal could not be confident from the evidence that the Respondent had given the plans more than a cursory glance. The Tribunal is not satisfied that the Respondent took reasonable steps to avoid the contravention.
32. The Respondent’s evidence was that he has, however, taken reasonable steps to avoid a repetition of the action which gave rise to the contravention by implementing rigorous checking processes in his office whereby each file has a procedures check sheet and the Respondent checks his employed surveyor’s work and the employed surveyor checks the Respondent’s work .
33. The Tribunal must consider whether occupational discipline has previously been used against the person under section 65(3)(b) of the ACAT Act. In 2003 the Respondent was the subject of previous disciplinary action before the Administrative Appeals Tribunal General Division (see Joseph Fekete and Chief Executive of ACT Department of Urban Services [2003] ACTAAT 6) in relation to the Respondent’s conduct as a certifier in 2001. The Tribunal notes that President Peedom stated at paragraph 18,
“The applicant said that no other disciplinary action had ever been taken against him and that he had learnt a lot from his experience in dealing with the certification of the building project. He had learnt that he should not trust people in business and about being open with and trusting people. He believed he had been too trusting in this instance.”
34. The act that gave rise to that occupation discipline matter occurred in 2001. The act that has given rise to the current matter occurred in 2010. While the Respondent gave assurances at the earlier hearing, the current matter appears to have been brought about by work pressures and a clearly inadequate or non-existent office management system with the necessary professional checks and balances for approval processes. This has, according to the Respondent, been overhauled. His Witness Statement shows a list of the professional checks and balances (in paragraph 34) he has implemented and his willingness to submit his procedures to the Applicant for comment (in paragraph 37).
35. The Respondent acknowledged that he had five demerit points registered against him around this time (August 2010) which may have also been playing on his mind. Mr Sharwood submitted that these points are further examples of the Respondent not abiding by the Rules. Mr Walker submitted that the demerit points should not be relevant in these proceedings as the person is not given the opportunity to challenge decisions imposing demerit points until such time as sufficient demerit points have been accumulated, i.e. 15 points, for the Registrar to consider taking away a person’s licence. It is this decision which is appellable. Essentially, Mr Walker submitted that the Tribunal should not attach any weight to the Respondent’s five demerit points in the light of the Respondent’s own evidence which clearly raises an issue as to the validity of these points and the fact that these points have not been tested. The Tribunal agrees.
36. In considering whether the person has taken steps to mitigate the effect of the contravention under section 65(3)(c) and the impact of the contravention of any person under section 65(3)(d), it is clear that once the Respondent became aware of the error, the home at the Casey property had been built. Short of demolishing the home there was little else practically he could do. He responded to the letter from the Applicant within 10 days promptly acknowledging his error. He has apologized to the owners and the neighbours. While acknowledging the importance of his error and not seeking to minimize the impact of his error, the Respondent submitted that the error has not caused this house to be unstable or dangerous.
37. The Tribunal considers, notwithstanding the earlier disciplinary proceedings, that there is little likelihood that the Respondent will act in a way that is ground for occupational discipline in the future. The Tribunal notes the evidence that the Respondent has immediately, upon being notified of his contraventions, accepted the responsibility, acknowledged that his then procedures were inadequate and implemented a rigorous process of professional checks and balances which he agrees to submit to the Applicant for comment. He is now operating his business with full time employees instead of part time employees.
38. The Applicant asks for the Respondent to be reprimanded, fined $1,000 being the maximum payable by an individual and that his licence be suspended for four months. Mr Walker submits that suspension will not protect the public and is not an appropriate outcome particularly when the Respondent has immediately acknowledged the error, taken positive steps and implemented a rigorous procedure and is happy to see the Registrar to see if his current procedures measure up. Mr Walker also submitted that the reprimand will stay on his record.
39. The Tribunal must ask ‘what about the role the Respondent plays in ensuring that the Territory and the public are protected when he is certifying building work?’ Certifiers are the gate keepers who provide the policing of developments under the Building Act. Building Approval is an important role. Appropriately qualified and skilled persons have been responsible for looking after the public interests when building plans are approved and homes are being built or renovated. Certifiers are required to take a professional approach and to carry out their certification correctly and properly. The reality is that the Casey property is now built from plans which should not have been approved.
Orders
40. For the reasons stated above the Tribunal considers that an order for occupational discipline should be made in relation to the Respondent . Such orders are made under section 66 of the ACAT Act. The Tribunal considers in this case that a reprimand is appropriate under section 66(2)(a).
41. The amount that the Tribunal may require a person to pay under section 66(2)(h) of the ACAT Act is not more that the amount prescribed by regulation. Regulation 4 of the ACT Civil and Administrative Tribunal Regulation 2009 states that the maximum amount for an individual is $1,000. In assessing the monetary amount the Tribunal must take into account the factors set out above.
42. The Tribunal has considered the case law of other jurisdictions where similar orders for occupational discipline have been made in the construction industry and notes that certain factors in this case bring it within the middle range of orders made. These factors are as follows:
· The breach did not lead to concerns about public safety;
· The breach was due to inadequate management rather than intentional misbehavior;
· The 2003 proceedings concerned the Respondent turning a blind eye to an obviously fraudulent document;
· The intent is to protect the public rather than punish those found guilty of improper conduct; and that
· A useful comparative case is Harb & Anor v Commissioner for Fair Trading NSW Office of Fair Trading [2007] NSWADT 175 where the builders had had prior occupational discipline orders made against them. In this case it was stated, in terms of the seriousness of the breach, the defects were of a relatively minor nature that could be readily rectified which the Applicants remained willing and able to undertake if access to the property was allowed. The Acting Deputy President found that the public interest and protection of consumers of building services would not be served by cancelling or imposing a period of disqualification. The Acting Deputy President issued both Applicants with a reprimand for their improper conduct and imposed a penalty of $2,000 on one of the Applicants.
43. The Tribunal has considered the Respondent’s financial position and the fact that he has approximately 470 active projects. He would suffer a financial loss by being prevented from working as a certifier if a period of suspension was imposed. The Tribunal is not satisfied, given all of the above matters, and in the particular circumstances of this matter, that the public interest and protection of consumers of building services would be served by imposing a period of suspension on the Respondent.
44. The Tribunal agrees with what, ultimately, can be seen as joint submissions of Counsel, to direct the Respondent to comply with a requirement imposing a condition on the Respondent’s licence or registration pursuant to section 66(2)(d) and section 67 of the ACAT Act.
For the reasons stated above, the Tribunal makes the following orders that:
1. The Respondent be reprimanded; and
2. The Respondent pay the amount of $1,000 to the Territory within 28 days of the date of this order; and
3. The Tribunal directs the Respondent to comply with the requirement that within 28 days of the date of this order he submit the procedures referred to in paragraphs 34 and 37 of his Witness Statement (Exhibit R1) to the Constructions Occupation Registrar (the Registrar) and that, subject to further order of the Tribunal, he implement any changes notified in writing to him by the Registrar within seven days of the date of such written notification.
4. The parties have liberty to apply in relation to Order 3.
………………………………..
Ms E. Symons
Presidential Member
PUBLICATION DETAILS
TO BE PUBLISHED
To be completed by Tribunal Staff
PART A
FILE NUMBER: | OR 12/13 |
PARTIES, APPLICANT: | CONSTRUCTION OCCUPATIONS REGISTRAR |
PARTIES, RESPONDENT: | FEKETE |
COUNSEL APPEARING, APPLICANT | Mr Wayne Sharwood |
COUNSEL APPEARING, RESPONDENT | Mr Philip Walker |
SOLICITORS FOR APPLICANT | ACT Government Solicitor |
SOLICITORS FOR RESPONDENT | Trinity Law |
TRIBUNAL MEMBERS: | Ms E Symons, Presidential Member |
DATES OF HEARING: | 13 July 2012 |
PLACE OF HEARING: | Canberra |
PART B
RECOMMENDATION:
FULL REPORT ( ) CASE NOTE ( ) UNREPORTED DECISION ( )
COMMENTS:
1
2
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