Frugtniet and Secretary, Department of Social Services (Social services second review)
[2019] AATA 547
•28 March 2019
Frugtniet and Secretary, Department of Social Services (Social services second review) [2019] AATA 547 (28 March 2019)
Division:GENERAL DIVISION
File Number(s): 2017/6320
Re:Rudy Noel Frugtniet
APPLICANT
AndSecretary, Department of Social Services
RESPONDENT
DECISION
Tribunal:Senior Member R. Pintos-Lopez
Date:28 March 2019
Place:Melbourne
The Tribunal affirms the decision under review.
.....................[sgd].............................................Senior Member R. Pintos-Lopez
Legislation
A New Tax System (Family Assistance) Act 1999 (Cth)
A New Tax System (Family Assistance) (Administration) Act 1999 (Cth)Data-Matching Program (Assistance and Tax) Act 1990 (Cth)
Social Security Act 1991(Cth)
Cases
Frugtniet and Secretary, Department of Family and Community Services [2004] AATA 996
REASONS FOR DECISION
Senior Member R. Pintos-Lopez
28 March 2019
The Applicant seeks review of a decision, dated 18 October 2017, made by the Social Services and Child Support Division of the Tribunal, which affirmed a decision of a delegate of the Respondent, dated 3 February 2017. The decision of the Respondent was to apply an amount of $19,665.85 of family tax benefit payments due to the Applicant, which was originally withheld and applied by the Respondent to a newstart allowance debt, to a parenting payment debt owed by the Applicant.[1]
[1] The application was determined without an oral hearing at the Applicant’s application, pursuant to section 34J of the Administrative Appeals Tribunal Act 1975 (Cth).
For the reasons that follow, the Tribunal affirms the decision under review.
I. BACKGROUND AND RELEVANT FACTS
This application represents one in a long and storied history of appeals by the Applicant of unfavourable administrative decisions, which, in this case, commences in 1998 until 2000, when the Applicant received approximately $19,000 of newstart benefits that he was not entitled to receive.
Following a number of appeals, the Respondent sought to recoup the amount from the Applicant by withholding the Applicant’s family tax benefits from 2004 until 2011.
In 2016, following a complaint by the Applicant to the Ombudsman, the Respondent determined that it ought to have provided the Applicant with notice before withholding those amounts.
Separately, the Respondent determined that from 2011 until 2015, the Applicant received $65,620.20 in parenting payments that he was not entitled to receive. The Applicant sought review of that decision. Those applications were unsuccessful.
The Respondent, having determined in 2016 that the Applicant ought to have been provided with notice prior to having his family tax benefits withheld to pay the newstart debt, then proceeded to determine that those amounts should be applied to reduce the $65,620.02 debt owed by the Applicant in respect of the parenting payments.
The Applicant objects. He submits that the Respondent, by having failed to give notice of the withholding of the family tax benefits to repay the newstart overpayment is now under an obligation to pay him $19,665.85 despite his debt of $65,620.02 in parenting payments.
In order to make sense of the events, it is necessary to set out the details of the:
(a)newstart debt;
(b)withholding of the family tax benefits; and
(c)parenting payment debt.
A. The Newstart Debt
On 11 February 2002, a delegate of the Respondent decided to recover a debt of $19,665.85 in relation to overpayments received by the Applicant between 21 August 1998 and 6 July 2000 in newstart allowance (the newstart debt). The Applicant appealed the newstart debt decision.
On 4 September 2002, an authorised review officer (ARO) of the Respondent affirmed the decision. The Applicant then appealed the decision of the ARO to the Social Security Appeals Tribunal (the predecessor to Social Services and Child Support Division of the Tribunal).
On 7 October 2003, the Social Security Appeals Tribunal affirmed the newstart debt decision. The Applicant made a further appeal.
On 24 September 2004, in Frugtniet and Secretary, Department of Family and Community Services [2004] AATA 996, the Tribunal set aside the newstart debt decision on the basis that the Respondent had failed to provide the Applicant with notice as required by s 11 of the Data-Matching Program (Assistance and Tax) Act 1990 (the Data-Matching Act).
The Tribunal stated:
At the time Mr Frugtniet lodged his claim for newstart allowance, he was conducting a business as a migration agent, although he said that the business was dormant at the time. He was not otherwise employed.
On 27 March 2001, the respondent requested and received a further data match review from the Australian Taxation Office (the ATO), which disclosed that Mr Frugtniet’s taxable income for the period 1999/2000 differed from that declared in his newstart allowance forms.
...
As a result of the data matching review, the respondent discovered that, in addition to conducting a migration agency business, Mr Frugtniet was also employed by Network Recruitment until 7 July 2000.[2]
[2] [5] and [9].
The decision of the Tribunal to set aside the Respondent’s decision was strictly because of the lack of notice. The Tribunal stated that the Respondent could, in future, recover the debt with proper notice being given to the Applicant.[3]
[3] Frugtniet and Secretary, Department of Family and Community Services [2004] AATA 996 at [45]-[46].
On 25 October 2004, an officer of the Respondent contacted the Applicant in relation to the Tribunal’s decision.[4] The Applicant requested that he be paid the amounts collected to date in connection with that debt. It was made plain to him that, although that amount would be returned, that the Respondent intended to again seek to recover the newstart debt.
[4] Supplementary T-Documents (ST) 30/69.
On 8 November 2004, the Respondent issued a cheque to the Applicant in the sum of $8,701.09, on the basis of the Tribunal’s decision, in relation to amounts collected in connection with the newstart debt.[5]
The family tax benefit payments withheld and applied to the newstart debt
[5] ST21/42
Following the Tribunal’s decision, the Respondent again sought to recover the newstart debt.
From 22 December 2004 to 28 July 2011, the Respondent withheld payments due to the Applicant by way of family tax benefit (the family tax benefit payments) and applied those payments to the Applicant’s newstart debt. The Respondent again failed to provide the Applicant with notice as required under s 11 of the Data-Matching Act in relation to the withheld payments. The Respondent later determined in October 2016, as discussed below, that these payments lacked the necessary notice.
From 22 December 2004 until 28 July 2011, there were 173 instances of withholdings from the Applicant’s family tax benefit payments that were applied to recover the newstart debt.
B. The Parenting Payment Debt
On 15 February 2016, the Social Services & Child Support Division of the Tribunal affirmed an earlier decision of the Respondent in relation to a parenting payment debt owed by the Applicant (the parenting payment debt).
In that decision, the Tribunal set out the background:
Mr Frugtniet was granted parenting payment with effect from April 2008. Payment was made on the basis that he was separated from his former partner Meenakshi Callychurn. On 24 August 2012 parenting payment was cancelled as Mr Frugtniet’s dependent child [Child 1] turned eight years of age. Mr Frugtniet was transferred to newstart allowance at the single rate. On 12 December 2012 Mr Frugtniet advised that his child [Child 2], born 8 May had entered his care. Parenting payment was regranted with effect from 7 December 2012.
As part of a review of Mr Frugtniet’s entitlement in 2013, investigation into his income, assets and marital status was undertaken. In November 2014 a decision was made that Mr Frugtniet had received $52,159.20 in parenting payment in the period 9 April 2008 to 20 September 2011 due to undisclosed income, this comprising deposits into his various bank accounts. Mr Frugtniet requested a review of this and the decision was set aside.
A further determination was made in February 2015 that Mr Frugtniet was in a marriage like relationship with Ms Callychurn. Payment was suspended pending enquiries. Mr Frugtniet was subsequently notified by letter dated 19 May 2015 that he had incurred a recoverable debt of $65,557.46 in the period 4 May 2011 to 17 February 2015.
Mr Frugtniet sought review of the decisions. The matter was referred to authorised review officers of Centrelink. On 1 June 2015 an authorised review officer set aside the decision to suspend Mr Frugtniet’s parenting payment and substituted a new decision that payment be cancelled. On 30 September 2015 another authorised review officer varied the decision to raise and recover a debt such that the debt amount was $66,349.27 in respect of the period 8 May 2011 to 17 February 2015.[6]
(Names of children redacted.)
[6] T-Documents (T) 3/11, [2]–[5].
The Tribunal determined that the Applicant was a member of a couple for the period from 8 May 2011 to 17 February 2015.
The Tribunal determined that the decision to cancel parenting payment and to raise and recover a debt of $66,349.27 in relation to parenting payments was to be set aside and remitted for reconsideration and recalculation of the debt on the basis that the Applicant was a member of a couple in the period 8 May 2011 to 17 February 2015.
On 6 April 2016, a delegate of the Respondent recalculated the parenting payment debt and determined that the debt due from the Applicant from 8 May 2011 to 17 February 2015 was $65,620.02.
The family tax benefit payments withheld then applied to the parenting payment debt.
On 31 October 2016, as noted above, a delegate of the Respondent determined that the Applicant had not been provided with the necessary notice in relation to the withheld payments due to the Applicant by way of family tax benefit and applied to the Applicant’s newstart debt. The delegate stated:
On 22 December 2004, upon your claim and grant of Family Tax Benefit, recovery of Debt Id 35225379 [i.e. the NSA debt of $19,665.85] recommenced, via withholdings from your Centrelink payments. Withholdings continued until the debt was fully recovered on 22 December 2004.
We accept that a fresh notice was not given to you after the AAT decision of the 24 September 2004 and therefore the Department did not strictly satisfy the requirements to recommence recovery on 22 December 2004.
On that basis the Department has given consideration to refunding withholdings for Debt 35225379. However, under the debt recovery provisions of the Social Security Act 1991, the withholdings can be applied to an outstanding debt owed to the Department. Accordingly, repayments recovered from Debt Id 35225379 will be transferred to outstanding debt Id P2243926. As you are aware, Debt Id 2243926 relates to a parenting payment debt as first notified to you on 18 May 2015.[7]
[7] ST21/42.
On 7 December 2016, a delegate of the Respondent determined that the withheld family tax benefit payments due to the Applicant (from 22 December 2004 to 28 July 2011) were to be applied to reduce the Applicant’s parenting payment debt.
On 3 February 2017, an ARO of the Respondent affirmed the decision.
On 8 March 2017, the Applicant sought review of the decision in the Tribunal.
On 18 October 2017, the Social Services and Child Support Division of the Tribunal affirmed the decision.
On 24 October 2017, the Applicant applied for second review of the decision.
The Respondent summarised the Applicant’s submissions, stating:
In substance, and amongst other matters, the Applicant has raised the following objections to the transfer of $19,665.85 to his PP debt of $65,620.02:
a.Recovery of the NSA debt is statue-barred.
b.The FTB withholdings used to satisfy the Applicant’s NSA debt should not have been transferred to his existing PP debt. Rather, the FTB withholdings totalling $19,665.85 should have been transferred to him.
c.The Applicant made reference to Member Fice’s 2004 decision; which required the return of withholdings from FTB due to DHS’s failure to have issued a subsection 11(1) Data-Matching Act notice.
d.As no section 11 Data-Matching Act notice had been issued by DHS, the Applicant objected to the withholdings from his FTB being used to satisfy the NSA debt ab initio.
e.The Applicant essentially contends DHS cannot take action.to recover an overpayment before it has complied with subsection 11 (1) of the Data- Matching Act:
... Centrelink have not followed the procedure for recovery and therefore transferred monies recovered in error towards an existing debt instead of refunding these monies directly back to me.[8]
[8] ST23/46
The Applicant has given the Tribunal notice that, if unsuccessful here, the matter will continue on its appeals’ journey.[9]
[9] Applicant’s written submissions, dated 29 January 2018 at [2].
II. THE RELEVANT LEGISLATION
The application gives rise to issues concerning statutory provisions contained in the:
(a)A New Tax System (Family Assistance) Act 1999 (the Family Assistance Act);
(b)A New Tax System (Family Assistance) (Administration) Act 1999 (the Family AssistanceAdministration Act);
(c)Social Security Act 1991 (the Social Security Act); and
(d)Data-matching Act.
A. The Family Assistance Administration Act
The Family Assistance Act and the Family Assistance Administration Act concern family assistance payments to assist with the cost of raising children in circumstances where a person:
(e)has a dependent child or full time secondary student aged 16 to 19 who is not receiving a pension, payment or benefit such as youth allowance;
(f)who provides care for the child for at least 35% of the time; and
(g)who meets an income test.
The various parts of the Family Assistance Administration Act provide the legislative context for the Respondent’s submission that it was entitled, under s 84A, to set off the amounts withheld from the Applicant’s family tax benefit payments against the parenting payment debt.
Part 3 of the Family Assistance Administration Act provides for family assistance payments to be made by way of family tax benefits.[10] Similarly, under Part 3, if not satisfied, the Respondent must determine, for example, that a person is not entitled to be paid family tax benefit: s 19 of the Family Assistance Administration Act. A claimant may be paid by instalment into a bank account nominated and maintained by the claimant: s 23 of the Family Assistance Administration Act.[11] The Family Assistance Administration Act also provides for variation of determinations.
[10] See e.g. ss 5-7, 13 and 16-18.
[11] Where a claimant is entitled to be paid an amount of family tax benefit under s 58AA of the Family Assistance Act the amount may be paid in a single lump sum: s 24A of the Family Assistance Act.
Division 5 of Part 3 of the Family Assistance Administration Act is entitled “payment protection and garnishee orders” and provides at s 66 that payments of the various family payment entitlements are “absolutely inalienable, whether by way of, or in consequence of, sale, assignment, charge, execution, bankruptcy or otherwise” subject to:
(b) section 84 (about deductions from a person’s family tax benefit to repay a debt of the person); and
(ba) section 84A (about setting off a person’s entitlement to family assistance against a debt of the person); and
(bb) section 87A (setting off debts against various payments);
(c) section 92 (about a person consenting to deductions from the person’s family tax benefit to repay the debt of someone else); and
(ca) section 92A (about setting off family assistance of a person to repay the debt of another person); and
(cd) Division 3 of Part 8B (about payments to payment nominee); and
(d) section 225 (about making of deductions from family assistance for payment to the Commissioner of Taxation); and
(e) section 226 (about setting off a family assistance entitlement against a tax liability); and
(f) section 227 (about deductions from family tax benefit to repay certain child support debts); and
(g) Parts 3B and 3D of the Social Security (Administration) Act 1999.
(Emphasis added.)
It ought be remembered at this stage that the Respondent does not claim that the Applicant owes any amount as a result of overpayment of family tax benefit but rather that it was entitled to withhold and set off those amounts to pay off another debt due in relation to parenting payments.
Part 4 of the Family Assistance Administration Act is entitled “overpayments and debt recovery”.
Section 68 of the Family Assistance Administration Act provides:
For the purposes of this Part, an amount of family assistance is taken to be paid to a person if:
(a) the amount is applied against a liability of that person or another person for:
(i) a primary tax; or
(ii) a debt under this Act or the Social Security Act 1991; or
(b) the amount is set off under this Part against another amount.
Section 84A of the Family Assistance Administration Act provides:
(1) This section applies:
(a) to a person if the person is entitled to an amount of family assistance; and
(b) to a debt owed by the person if:
(i) under section 82, the debt is recoverable by the Commonwealth by means of setting off family assistance to which the person is entitled against the debt; or
(ii) the debt is a debt due by the person to the Commonwealth under the Social Security Act 1991, the Data‑matching Program (Assistance and Tax) Act 1990, the Farm Household Support Act 2014, the Paid Parental Leave Act 2010, the Social Security Act 1947, the Student Assistance Act 1973, the Veterans’ Entitlements Act 1986 or the Military Rehabilitation and Compensation Act 2004; or
(iii) the debt was incurred under Part 8 of the Student and Youth Assistance Act 1973 as in force before 1 July 1998.
(2) The Secretary may determine that the whole or a part of the entitlement is to be set off against the debt.
…
(4) If the Secretary makes a determination under subsection (2), the amount of the entitlement and the amount of the debt are reduced accordingly.
(Emphasis added.)
The wording of ss 66 and 84A, insofar as they concern the setting off of an “entitlement” to an amount of family assistance, is relevant to the Respondent’s position.
B. Parenting payments
Parenting payment is an income support payment that provides financial assistance to principal carers with parenting responsibilities for a young child and provides them with incentives to increase workforce participation and reduce dependency on income support. Parenting payment is for single and partnered parents and it is payable to one member of a couple.
Part 2.10 of Chapter 2 of the Social Security Act 1991 contains provisions relating to parenting payments.[12]
[12] See for example s 503, which determines how to calculate a person’s parenting payment rate.
Chapter 5 of the Social Security Act provides for overpayments and debt recovery.
Section 1222A of the Social Security Act in relation to debts due to the Commonwealth provides:
If an amount has been paid by way of social security payment, or by way of fares allowance under the Social Security (Fares Allowance) Rules 1998, the amount is a debt due to the Commonwealth if, and only if:
(a) a provision of this Act, the 1947 Act, the Social Security (Fares Allowance) Rules 1998 or the Data matching Program (Assistance and Tax) Act 1990 expressly provided that it was or expressly provides that it is, as the case may be; or; or
(b) the amount:
(i) should not have been paid; and
(ii) was paid before 1 January 1991; and
(iii) was not an amount to which subsection 245B(2) of the 1947 Act applied.
Section 1223 of the Social Security Act provides:
(1) Subject to this section, if:
(a) a social security payment is made; and
(b) a person who obtains the benefit of the payment was not entitled for any reason to obtain that benefit;
the amount of the payment is a debt due to the Commonwealth by the person and the debt is taken to arise when the person obtains the benefit of the payment.
Section 1224C of the Social Security Act concerns the data matching and provides:
If:
(a) an amount has been paid to a person by way of a social security payment; and
(b) the amount is a debt due to the Commonwealth under subsection 11(6) of the Data matching Program (Assistance and Tax) Act 1990;
the amount so paid is recoverable by the Commonwealth.
Section 1228 of the Social Security Act provides:
(1) If:
(a) an amount has been paid to a person by way of a payment or payments to which subsection (2) applies; and
(b) the amount should not have been paid; and
(c) the person to whom the amount was paid is receiving a social security payment; and
(d) the person is qualified for the social security payment under this Act and the social security payment is payable to the person;
the amount is an overpayment that is recoverable by the Commonwealth by means of deductions.
(2) This subsection applies to:
(aa) a payment of family assistance within the meaning of the A New Tax System (Family Assistance) Act 1999…
It is worth noting again that the Respondent does not claim that the Applicant owes any amount as a result of overpayment of family tax benefit, but rather that it was entitled to withhold and set off those amounts to pay off another debt due in relation to parenting payments. Section 1228 the Social Security Act is relevant insofar as it shows the overlap and recoverability of overpayments with respect to different benefits or allowances. It provides that an overpayment of family assistance may be recoverable by deductions from a benefit under this Act: see also s 1231 of the Social Security Act.
Section 1229 of the Social Security Act concerns notices in respect of debt and provides:
(1) If a debt by a person to the Commonwealth under the social security law has not been wholly paid, the Secretary must give the person a notice specifying:
(a) the date on which it was issued (the date of the notice); and
(b) the reason the debt was incurred, including a brief explanation of the circumstances that led to the debt being incurred; and
(c) the period to which the debt relates; and
(d) the outstanding amount of the debt at the date of the notice; and
(e) the day on which the outstanding amount is due and payable; and
(ea) the effect of sections 1229A and 1229B; and
(f) that a range of options is available for repayment of the debt; and
(g) the contact details for inquiries concerning the debt.
(2) The outstanding amount of the debt is due and payable on the 28th day after the date of the notice.
(3) The Secretary may give more than one notice under subsection (1) in relation to a person and a debt of the person.
Section 1230C of the Social Security Act contains methods of recovery which resemble those under s 82 of the Family Assistance Administration Act.
C. The Data Matching Act
Data-matching involves bringing together data from different sources and comparing it. The Data-matching Act regulates how the various assistance agencies and the Australian Taxation Office use tax file numbers to compare personal information so they can detect incorrect payments. Agencies match data so that they can identify people for further investigation or action.
Section 6 of the Data-matching Act provides:
(1) Subject to subsections (2) and (3):
(a) data about persons may be transferred between agencies; and
(b) data about persons may be matched or otherwise dealt with by the matching agency or the tax agency; and
(c) the results of the matching may be given to source agencies;
in accordance with the data matching program made up of data matching cycles the steps in which are set out in section 7.
(2) There are to be no more than 9 data matching cycles in any one year.
(3) Only one data matching cycle is to be in progress at any one time.
Section 11 of the Data-matching Act contains a notice requirement and provides:
(1) Subject to subsections (1A), (1B) and (4), where, solely or partly because of information given in Step 1, 4 or 6 of a data matching cycle, an assistance agency considers taking action:
(a) to cancel or suspend any personal assistance to; or
(b) to reject a claim for personal assistance to; or
(c) to reduce the rate or amount of personal assistance to; or
(d) to recover an overpayment of personal assistance made to;
a person, the agency:
(e) must not take that action unless it had given the person written notice:
(i) giving particulars of the information and the proposed action; and
(ii) stating that the person has 28 days from the giving of the notice in which to show cause orally or in writing why the action should not be taken; and
(f) must not take that action until the person has responded orally or in writing to the notice or the 28 days end, whichever occurs first.
…
(1B) If the assistance agency takes action referred to in subsection (1A), it must give the person written notice, with particulars of the information and the action:
(a) if practicable—before the action is taken; or
(b) if not—as soon as practicable after the action has been taken.
(Emphasis added.)
III. CONSIDERATION
I find that the amounts of the Applicant’s family tax benefit payments from December 2004 until July 2011 should not have been withheld by the Respondent. I make this finding not on the basis of the decision in Frugtniet and Secretary, Department of Family and Community Services [2004] AATA 996—which concerned the Applicant’s newstart debt, and found that the Respondent had improperly recovered approximately $8,000 of Newstart overpayments because of a failure to notify the Applicant as required under s 11(1) of the Data-matching Act—but rather because the Respondent herself has made that admission and determination. Had I considered this question, which is unnecessary for me to determine in this application, I may not have interpreted those provisions in the same manner.
As a result of the fact that the Respondent should not have withheld those family tax benefit payments, the Applicant gained an entitlement to be paid family tax benefit payments. There is no question of a “refund” or “repayment” as the Applicant retains merely an entitlement.
There is nothing in the relevant legislation that indicates that there is any penalty to be imposed upon the Respondent for its mistake. Nor are there questions more broadly put. It may be for an appeal court to divine from the statutory provisions’ penumbras, formed by its emanations, some penalty or punishment for the Respondent.
The Respondent’s failure to satisfy the Data-matching Act’s requirement of notice under s 11(1), if applicable, would have put the Applicant in the same position, that is, having an entitlement to a benefit.
The Social Security Act gives rise to the parenting payment entitlement whereas the Family Assistance Administration Act provides for the entitlement to family tax benefit payments.
Both of those enactments giving rise to entitlements contain provisions regarding the recovery of assistance payments incorrectly made by the Respondent: for example, Chapter 5 of the Social Security Act and Part 4 of the Family Assistance Administration Act, both of which concern overpayments and debt recovery. The Data–matching Act is an enactment, in itself, intended to grant the Respondent power to investigate and recover incorrect payments.
Section 82 of the Family Assistance Administration Act concerns methods of recovery, which are analogous to those contained in s 1230C of the Social Security Act.
Section 84A of the Family Assistance Administration Act provides, not for recovery of family assistance payments, but for recovery of other debts; in this case a debt under the Social Security Act for overpayment of parenting payments. But more importantly, it stands to the benefit of the Applicant by providing a means to reduce his obligation to repay the debt due to the Respondent by application and setting off with the family tax benefit payments.
Set off provisions such as this, and set off under the general law, provide for a rational efficiency in circumstances where a person is presented with a debt claim by another person, that first person may assert a corresponding debt due from that other person in order to have the first debt reduced without having to pay first the full amount of the first debt.
The necessary application, then, is, first, to determine what the Applicant has by reason of the failure by the Respondent to give notice under the Data-matching Act. In this case it is an entitlement to a benefit, being family tax benefit payments. That entitlement is to be paid $19,665.85 by the Respondent in family tax benefit payments.
Second, it is determined that Applicant has an obligation to pay the Respondent $65,620.02 as a debt due to the Respondent for overpayments of parenting payments. The inverse is also true, that is the Respondent has an entitlement to be repaid that amount.
Third, the requirements of s 84A(1) of the Family Assistance Administration Act are satisfied, being: (a) the Applicant is entitled to an amount of family assistance; and (b) a debt is owed by the Applicant, being a debt due by the Applicant to the Commonwealth under the Social Security Act 1991.
Fourth, the requirements of s 84A(2) of the Family Assistance Administration Act give power to the Respondent to determine that the whole or a part of the entitlement is to be set off against the debt. The Respondent has made that determination.
IV. DECISION
The Tribunal affirms the decision under review.
I certify that the preceding 70 (Seventy) paragraphs are a true copy of the reasons for the decision herein of Senior Member R. Pintos-Lopez
........................[sgd]...........................................
Associate
Dated: 28 March 2019
Representative for the Applicant: Self-Represented Representative for the Respondent: Mr T De Uray
Department of Human Services
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