Fuller v Lawrence

The appeal concerned a prisoner subject to a supervision order made by the Supreme Court of Queensland under the *Dangerous Prisoners (Sexual Offenders) Act 2003* (Qld). The prisoner contended that a direction given by a corrective services officer, which the prisoner was required to comply with under the supervision order, was invalid. The prisoner sought judicial review of the decision to issue the direction.

The High Court of Australia was required to determine whether the direction given by the corrective services officer was a "decision made under an enactment" for the purposes of administrative law. This involved considering whether the *Dangerous Prisoners (Sexual Offenders) Act 2003* (Qld) was the source of the direction's legal force and whether the prisoner was entitled to reasons for the direction.

The Court reasoned that a decision derives its legal force from an enactment if it takes legal force in part from that enactment. The Court found that the direction's purported efficacy depended on the making of a supervision order by a court, but this did not detract from the conclusion that the direction was "made under" the Act. The Act imposed an obligation on the prisoner to comply with every reasonable direction of a corrective services officer, and this obligation derived its force from the statute.

The appeal was dismissed with costs.