HHJK and Secretary, Department of Education
[2023] AATA 1775
•22 June 2023
HHJK and Secretary, Department of Education [2023] AATA 1775 (22 June 2023)
Division:GENERAL DIVISION
File Number(s): 2022/6513
Re:HHJK
APPLICANT
AndSecretary, Department of Education
RESPONDENT
DECISION
Tribunal:Senior Member George
Date: 22 June 2023
Place:Adelaide
Pursuant to section 43(1) of the Administrative Appeals Tribunal Act 1975 (Cth), the Tribunal affirms the Reviewable Decisions of the Respondent dated 10 August 2022.
........................................................................
Senior Member George
CATCHWORDS
HIGHER EDUCATION SUPPORT – HECS-HELP – application for debt remission –Attention-deficit/hyperactivity disorder – whether requirement that remission application be made before end of application period can be waived – insufficient evidence – decision under review affirmed
LEGISLATION
Administrative Appeals Tribunal Act 1975 (Cth)
Administration Guidelines 2012 (Cth)
Higher Education Support Act 2003 (Cth)
CASES
CNPG and Secretary, Department of Education [2022] AATA 4349
Doulaveras v Daher [2009] NSWCA 58
Lushchayev and Secretary, Department of Education, Skills and Employment [2022] AATA 374
Montenegro v Secretary, Department of Education [2020] FCAFC 210
Peters and Secretary, Department of Education, Skills and Employment [2021] AATA 3800
Thomson and Secretary, Department of Education, Skills and Employment [2020] AATA 4672
REASONS FOR DECISION
Senior Member George
22 June 2023
The Applicant was born in Alice Springs. She lived in Tennant Creek and Nhulunbuy during her schooling years. Between 2005 and 2012, the Applicant lived in western Queensland on a remote cattle property. She enrolled in a Bachelor of Laws degree at the University of New England (“UNE”) in 2010. This degree was conferred on 12 December 2020.[1]
[1] Exhibit A2/R1, Joint Tender Bundle, T-Documents, T31, page 198.
As is common amongst students, the Applicant applied for and obtained a Higher Education Contribution Scheme Higher Education Loan Program (“HECS-HELP”) loan under the provisions of the Higher Education Support Act 2003 (Cth) (“the Act”). HECS-HELP is a type of Commonwealth assistance to higher education students to assist in meeting their liabilities to pay their contribution amounts for Commonwealth supported units of study. It is a HECS-HELP debt which has given rise to the application before the Tribunal.
On 6 July 2022,[2] the Applicant made two applications to UNE for the remission of certain HECS-HELP debts pursuant to subparagraph 36-20(1)(e)(ii) of the Act. The reasons given in both applications were substantially the same, being that special circumstances arose as the Applicant suffered from Attention-Deficit/Hyperactivity Disorder (“ADHD”) during her studies for which she received treatment in 2018. The Applicant said that her special circumstances prevented her from completing the unit requirements because “I believed I could complete the required study to successfully pass the courses but [I] mentally and physically could not. This was beyond my control”.[3]
[2] Exhibit A2/R1, Joint Tender Bundle, T-Documents, T14, pages 65-66; T15, pages 67-68. The date of 6 July is found on at T16, page 69; T17, page 75.
[3] Exhibit A2/R1, Joint Tender Bundle, T-Documents, T14, pages 66; similar wording appears in T15, page 68.
The first application sought a remission of debts related to the following subjects in 2010:
Semester 1, 2010 – Census Date 31 March 2010[4]
(a)LS101 – Law in Context (Result: Withdrawn; Passed in Trimester 3, 2012)[5]
(b)LS231 – Law of Torts 1 (Result: Withdrawn; Passed in Trimester 1, 2018)[6]
Trimester 2, 2010 – Census Date 31 August 2010[7]
(c)LS160 – Criminal Law and Procedure (Result: Fail Incomplete; Passed in Semester 1, 2011)[8]
(d)LS200 – Administrative Law (Result: Fail; Fail in Trimester 2, 2012; Passed in Trimester 2, 2020)[9]
[4] Exhibit A2/R1, Joint Tender Bundle, T-Documents, T4, page 36.
[5] Exhibit A2/R1, Joint Tender Bundle, Academic Record, page 435
[6] Exhibit A2/R1, Joint Tender Bundle, Academic Record, pages 435-436
[7] Exhibit A2/R1, Joint Tender Bundle, T-Documents, T4, page 37.
[8] Exhibit A2/R1, Joint Tender Bundle, Academic Record, page 435.
[9] Exhibit A2/R1, Joint Tender Bundle, Academic Record, page 435.
The second application sought a remission of debts related to the following subjects in 2011-2013:
Trimester 2, 2011 – Census Date 31 August 2011[10]
(a)LS101 – Law in Context (Result: Fail Incomplete; Passed in Trimester 3, 2012)[11]
Trimester 2, 2012 – Census Date 31 July 2012[12]
(b)LS200 – Administrative Law (Result: Fail; Passed in Trimester 2, 2020)[13]
Trimester 1, 2013 – Census Date 31 March 2013[14]
(c)LS212 – Evidence and Proof (Result: Fail Incomplete; Passed in Trimester 3, 2018)[15]
[10] Exhibit A2/R1, Joint Tender Bundle, T-Documents, T4, page 41.
[11] Exhibit A2/R1, Joint Tender Bundle, Academic Record, page 435.
[12] Exhibit A2/R1, Joint Tender Bundle, T-Documents, T4, page 44.
[13] Exhibit A2/R1, Joint Tender Bundle, Academic Record, pages 435-436.
[14] Exhibit A2/R1, Joint Tender Bundle, T-Documents, T4, page 47.
[15] Exhibit A2/R1, Joint Tender Bundle, Academic Record, pages 435-436.
On 7 July 2022, UNE refused the first and second applications (collectively “the Decisions”). A material ground for refusal was that the Decisions were not received “within the required 12 month period and you have not demonstrated why it was not possible to do so within the required legislated timeframe”.[16]
[16] Exhibit A2/R1, Joint Tender Bundle, T-Documents, T16, page 67; T17; page 73.
On 10 and 11 July 2022, the Applicant applied to UNE for a review of the Decisions. Materially, the Applicant submitted that:
The decision maker has made the decision based on it was possible for me to apply for remission of fees since 2018 and I did not take the opportunity to [do] so, until 6 July 2022 so they have denied my application. From my understanding of the legislation there is no restriction or time limit for applying for special circumstances. The legislation does state the higher education provider waives the requirement that the application be made before the end of the 12-month application period, on the ground that it would not be, or was not, possible for the application to be made before the end of that period. Can you please point out exactly where in the legislation it is interpreted it to mean the higher education provider can cut of[f] the application period for special circumstances when the applicant has demonstrated they are physically and mentally able to do so before the date of application and they have not applied sooner?[17]
[Emphasis added]
[17] Exhibit A2/R1, Joint Tender Bundle, T-Documents, T16, page 70; T17; page 76.
On 10 August 2022, UNE separately affirmed the Decisions (collectively “the Review Decisions”). Referring to a letter from psychiatrist Dr Jules Begg dated 19 July 2022 (“the Second Begg Report”),[18] the Review Decisions materially addressed the issue of timeframes raised by the Applicant. The Review Decisions read:
The Timeframe for applying for a remission, as specified in the Higher Education Administrative Information for Providers, is 12 months after the end of the study period in which the units were undertaken or completed, or 12 months after the student withdrew from the units.
Unfortunately, in undertaking a full review of this case, there is insufficient evidence to support a waiver of the 12-month application timeframe.
If an application is made outside the application period, the provider should consider whether it is prepared to waive the requirement the application be made before the end of the application period on the grounds that it was not possible for the application to be made before the end of that period [HESA sections 36-20, 36-23, 104-25 and 104-40].
The additional evidence provided by you (dated 19 July 2022) in the form of a Psychiatrist’s Letter included in-depth information about your condition, which addressed each of the three (3) special circumstances criteria. However, the letter does not specifically or reasonably demonstrate why it was not possible for you to apply for a Remission of Fees within the 12-month timeframe for each relevant study period. In addition, you have not provided evidence in relation to what occurred prior to you resuming your studies in 2018, and why it was not possible for you to apply for a Remission of Fees.
[Emphasis added]
[18] Exhibit A2/R1, Joint Tender Bundle, T-Documents, T1, pages 14-15
Also on 10 August 2022, the Applicant applied to the Tribunal for a review of the Review Decisions and attached a further report from Dr Begg dated 5 July 2022 (“the First Begg Report”). Materially, the Applicant addressed the issue of timeframes in her reasons why she claimed the Review Decisions were wrong. She stated:
The information that was not taken into account was that I could not reasonably apply within the 12 month period back then because I was totally unaware that I was suffering from the condition [of ADHD]. If I knew I actually had a reason for failing and not completing the subjects within the 12 month time frame required to apply, of course I would have applied back then. It was not until I was treated and successfully completed my studies that I had the reason and the evidence (my success in the course) to then put in an application.[19]
[Emphasis added]
[19] Exhibit A2/R1, Joint Tender Bundle, T-Documents, T1, page 9.
The hearing proceeded by audio-visual means on 11 May 2023. The Applicant was self-represented and gave evidence. The Respondent was represented by Ms Prasad of Minter Ellison.
Following the proceedings, and after allowing the parties an opportunity to make written submissions, the Tribunal has seen fit to make an order under s 35 of the Administrative Appeals Tribunal Act 1975 (Cth) to grant the Applicant a pseudonym. In making this order, the Tribunal has balanced the principles of open justice with the desirability to protect the privacy of Applicants. This decision will almost certainly be published in an open database operated by the Australia Legal Information Institute. The Applicant seeks a future in the legal profession. It is not the Tribunal’s desire that its consideration of the Applicant’s medical history would cause her future professional discomfiture.
The Tribunal received the written evidence that is listed in the Exhibit Register marked “Annexure A”.
LEGISLATIVE CONTEXT AND ISSUES
The legislative context for the incurring, and remission of HECS-HELP debts is neatly set-out by Senior Member Furnell in Peters and Secretary, Department of Education, Skills and Employment [2021] AATA 3800, at [7]-[18]. It is unnecessary to repeat these paragraphs in detail.
It is sufficient to note that Part 3.2 of the Act provides for who is entitled to receive HECS-HELP and how that assistance is paid. It is not in dispute that the Applicant was entitled to receive HECS-HELP assistance and that she did receive that assistance for her tertiary studies at UNE.
Chapter 4 of the Act provides for the repayment of loans made to students. Most notably, subparagraph 137-5(3) of the Act determines that a HECS-HELP debt is taken to be incurred “immediately after the census date for the unit”. The census date is defined in the Dictionary in Schedule 1 to the Act and is determined under section 169-25 of the Act. The census dates are not in dispute, nor is the fact that the Applicant owes a HECS-HELP debt to the Commonwealth.
Materially, Division 97 of the Act provides for the remission of HECS-HELP debts. It is not in factual dispute that the two applications for remission made on 6 July 2022 were made outside of the 12-month period specified in section 36-22 of the Act for each unit of study (“the application period”).
The first issue for factual determination by the Tribunal is whether the application period should be waived, in accordance with subparagraph 36-20(1)(f)(ii) of the Act “on the ground that it would not be, or was not, possible for the application to be made before the end of that period”.
Senior Member Morris observed in CNPG and Secretary, Department of Education [2022] AATA 4349, at [85], that the term “possible” means “reasonably possible in all the circumstances”.
Member Reitano observed in Thomson and Secretary, Department of Education, Skills and Employment [2020] AATA 4672, at [32], that the Applicant is required to satisfy the Tribunal that “an application could not have been made because of some incapacity whether mental or physical, and not necessarily confined to medical conditions, to make the application at all”.
Subparagraph 36-20(1)(f)(ii) of the Act cannot be satisfied unless the Tribunal finds that it would not be, or was not, possible for the various applications for remission to be made before the end of the application period. In that event, the Application cannot succeed.
If the Tribunal finds that subparagraph 36-20(1)(f)(ii) of the Act is satisfied, then the Tribunal must go on to consider whether “special circumstances” applied to the Applicant. Within the meaning of paragraph 36-20(1)(d) and section 36-21 of the Act, “special circumstances” arise where the Tribunal is satisfied that the circumstances that apply to the Applicant:
(a)are beyond the person’s control; and
(b)do not make their full impact on the person until on or after the census date for the unit of study; and
(c)make it impracticable for the person to complete the requirements for the unit during the period during which the person undertook, or was to undertake, the unit.
Chapter 3 of the Higher Education Support (Administration) Guidelines 2022 (Cth) (“the Administration Guidelines”) specifies matters that must be examined and considered by the Tribunal when assessing the applicability of “special circumstances” to an individual.
In Montenegro v Secretary, Department of Education [2020] FCAFC 210, the Full Court observed that a decision-maker must comply with the Administration Guidelines. Per Flick J, at [25], the Administration Guidelines must be identified by the decision-maker and the claimed circumstances must be measured against that content.[20] Furthermore, per Charlesworth J agreeing with His Honour and adding at [64], that the Administration Guidelines form part of the statutory scheme that confers, defines, and conditions the decision-maker’s powers.
[20] Montenegro v Secretary, Department of Education [2020] FCAFC 210 at [25] per Flick J.
SHOULD THE APPLICATION PERIOD BE WAIVED?
The Applicant had previously made a separate successful application in Trimester 1 2019 for the subject LAW455 – Jurisprudence, which is not the subject of these proceedings. This application had been made within the relevant 12-month timeframe.[21] Accordingly, the Applicant had become acquainted with the procedures for making an application for the remission of HECS-HELP debts prior to making the applications that are the subject of the current proceedings.
[21] Exhibit A2/R1, Joint Tender Bundle, T-Documents, T34, pages 427-434.
The Applicant has contended that it “would not be possible”, rather than “was not possible”, for her to make her application for remission within the application period. There is some technicality in this contention, but it is clarified with the reasoning that the Applicant “did not have her diagnosis of her ADHD until 2018 or the evidence of how her condition affected her academically before and after treatment within the 12 month time frame required”.[22] In her statement of 22 November 2022, the Applicant stated:
My argument is that it was not possible for me to make an application in the relevant time frames because I was not armed with a diagnosis or evidence within the time frames that would allow me to make an application if I wished to. I was incapacitated and prevented from making the application.[23]
[Emphasis added]
[22] Exhibit A1, Applicant’s Statement of Facts, Issues, and Contentions, pages 6-7. The Tribunal also notes the Statement of the Applicant dated 22 November 2022 where this distinction is also made: Exhibit A2/R1, Joint Tender Bundle, page 672.
[23] Exhibit A2/R1, Joint Tender Bundle, page 672.
The Applicant’s contention is consistent with the review application where she stated that “It was not until I was treated and successfully completed my studies that I had the reason and the evidence (my success in the course) to then put in an application”.[24] Similar reasoning was also provided in the course of the hearing that the Applicant did not have evidence of her academic success and therefore delayed her applications for remission of her HECS-HELP debts.
[24] Exhibit A2/R1, Joint Tender Bundle, T-Documents, T1, page 9.
The Tribunal notes that this issue of the necessity of proof of academic success was not central in first and second applications of 6 July 2022 or the applications for review on 10 and 11 July 2022. Indeed, in those latter applications the Applicant had centrally submitted that “there is no restriction or time limit for applying for special circumstances” and that she had demonstrated that she was “physically and mentally” unable to apply.[25]
[25] Exhibit A2/R1, Joint Tender Bundle, T-Documents, T16, page 70; T17; page 76.
The Applicant’s academic record contains several annotations asking her to Show Cause, permitting her to continue with restrictions, warning her on Academic Progress, and excluding her from enrolment in 2014.[26] In 2011, the Applicant found her exams “really difficult” to the point that she did not sit them all.[27] The Applicant had nevertheless long engaged with UNE regarding her mental health, particularly while applying for special examinations.[28] The Applicant also received counselling at the UNE Wellness Centre in 2011 and “reported concerns relating to situational stressors, physical health issues, depression and study difficulties”.[29]
[26] Exhibit A2/R1, Joint Tender Bundle, T-Documents, T31, page 198.
[27] Exhibit A2/R1, Joint Tender Bundle, T-Documents, T28, page 171.
[28] Exhibit A2/R1, Joint Tender Bundle, T-Documents, T29.
[29] Exhibit A2/R1, Joint Tender Bundle, page 675.
The psychological evidence of Ms Annette Berwald is that the Applicant was suffering Post-Traumatic Stress Disorder (“PTSD”) by 3 May 2012.[30] In the course of applying for special examinations, the Applicant told UNE that she suffered distress, embarrassment, anxiety, stress, and PTSD.[31] It is unclear to the Tribunal if UNE was provided with the report of Dr Helen Tingay of 26 February 2013, which stated that “she presents with generalised anxiety, panic anxiety disorder and Post Traumatic Stress Disorder on a setting of unspecified learning difficulties”.[32]
[30] Exhibit A2/R1, Joint Tender Bundle, T-Documents, T29, page 188.
[31] Exhibit A2/R1, Joint Tender Bundle, T-Documents, T28, page 171, T29, pages 183, 187, 189, 194.
[32] Exhibit A2/R1, Joint Tender Bundle, page 670.
The Tribunal notes that, in general, adults with ADHD may be highly emotionally dysregulated.[33] On the medical evidence before the Tribunal, placing weight on the First Begg Report of 5 July 2022, the Tribunal is satisfied that the Applicant had undiagnosed ADHD prior to 2018. From that time “there has been a very good response” such that the Applicant “now demonstrates good psychological self-management”.[34] Material parts of the First Begg Report read as follows:
[The Applicant] fits this classical description of the adverse effects of undiagnosed ADHD on young adults. [I]t was the significant underlying factor in her problems, with the poor executive functioning impairing her ability to complete her academic studies.[35]
[33] Exhibit A2/R1, Joint Tender Bundle, page 649.
[34] Exhibit A2/R1, Joint Tender Bundle, T-Documents, T1, page 15.
[35] Exhibit A2/R1, Joint Tender Bundle, T-Documents, T1, page 15.
Evidence of the Applicant’s good psychological self-management following treatment by Dr Begg sits with her academic success. By 2 November 2020,[36] the Applicant had completed her Bachelor of Laws degree and it was conferred on 12 December 2020.[37]
[36] Exhibit A2/R1, Joint Tender Bundle, Academic Record, page 435.
[37] Exhibit A2/R1, Joint Tender Bundle, T-Documents, T31, page 198.
The Tribunal notes, however, that neither the First Begg Report nor the Second Begg Report specifically or reasonably demonstrate why it was not possible for the Applicant to apply for a Remission of Fees within the 12-month timeframe for each relevant study period.
Material parts of the Second Begg Report read as follows:
It is therefore probable, that as you say, you became overwhelmed as the academic term drew to its conclusion leading to your failures. I understand that you have demonstrated by subsequent academic success when on treatment that treatment of your ADHD has been an important component in your ability to manage academic stress.
I therefore concluded, on the balance of probabilities, that you likely overestimated your capacity at the time of the census date but as the academic term drew to its conclusion, you did not manage the stresses of the assignments and examinations, leading to failure. Your ability to learn from these mistakes would have been diminished, a common occurrence seen in people with ADHD.
If you were not adequately treated from your ADHD it would have been very difficult for you to complete the requirements for your study unit.[38]
[Emphasis added]
[38] Exhibit A2/R1, Joint Tender Bundle, T-Documents, T1, page 17.
An issue with the Dr Begg’s vague reference to “the census date” is that there are in fact several relevant census dates: 31 March 2010, 31 August 2010, 31 August 2011, 31 July 2012, and 31 March 2013. Indeed, it is unclear as to the date of clinical onset, or material aggravation(s), of the Applicant’s ADHD.
The evidence before the Tribunal is clear that the Applicant had been diagnosed with, and adequately treated for, ADHD such that she was able to have her Bachelor of Laws degree conferred by 12 December 2020. However, the evidence is also clear that she did not make her applications for over 18-months until 6 July 2022. This 18-month delay is central to the Tribunal’s consideration.
In her statement of 22 November 2022, the Applicant said that she was “incapacitated and prevented from making the application” in time “because I was not armed with a diagnosis or evidence within the time frames”.[39] The Tribunal is guarded in its consideration of this evidence as it materially differs to the Applicant’s application for review of the Decisions of 10 and 11 July 2022 where the Applicant expressed her understanding as to a lack of time limits.[40]
[39] Exhibit A2/R1, Joint Tender Bundle, page 672.
[40] Exhibit A2/R1, Joint Tender Bundle, T-Documents, T16, page 70; T17; page 76.
The evidence before the Tribunal does not support a finding that the Applicant lacked the legal capacity to carry out the tasks necessary for making her applications at any material time.[41] On the contrary, she was able to “perform routine administrative actions during the relevant 12-month periods”.[42] Consistent with this was the Applicant’s various demonstrated ability to apply for special examinations.
[41] See Doulaveras v Daher [2009] NSWCA 58, [76]-[159].
[42] Exhibit A2/R1, Joint Tender Bundle, page 672.
The Applicant did not submit her applications upon the successful completion of each unit of study. The Applicant made a separate successful application in Trimester 1 2019 for the subject LAW455 – Jurisprudence, which is not the subject of these proceedings.[43] The Applicant never successfully completed LAW455 – Jurisprudence.[44]
[43] Exhibit A2/R1, Joint Tender Bundle, T-Documents, T34, pages 427-434.
[44] Exhibit A2/R1, Joint Tender Bundle, T-Documents, T34, page 436.
By December 2020, the Applicant had both her diagnosis of her ADHD and the evidence of her academic success that she believed she required to make her relevant applications for fee remissions. However, even then she still did not make these applications for another 18-months. In all the circumstances, this delay has not been reasonably explained on the evidence before the Tribunal.
For the Tribunal to find that the application period be waived, the balance of the evidence must support a finding for each unit of study that, pursuant to subparagraph 36-20(1)(f)(ii) of the Act, it would not be, or was not, possible for the applications to be made before the end of the application periods. Considering the evidence before the Tribunal wholistically, but each unit of study separately, the Tribunal makes the following findings:
Semester 1, 2010
(a)LS101 – Law in Context: The evidence before the Tribunal is insufficient for it to be satisfied that it would not be, or was not, possible for the application to be made before the end of the application period in June 2011.
(b)LS231 – Law of Torts 1: The evidence before the Tribunal is insufficient for it to be satisfied that it would not be, or was not, possible for the application to be made before the end of the application period in June 2011.
Trimester 2, 2010
(c)LS160 – Criminal Law and Procedure: The evidence before the Tribunal is insufficient for it to be satisfied that it would not be, or was not, possible for the application to be made before the end of the application period in November 2011.
(d)LS200 – Administrative Law: The evidence before the Tribunal is insufficient for it to be satisfied that it would not be, or was not, possible for the application to be made before the end of the application period in November 2011.
Trimester 2, 2011
(e)LS101 – Law in Context: The evidence before the Tribunal is insufficient for it to be satisfied that it would not be, or was not, possible for the application to be made before the end of the application period in November 2012.
Trimester 2, 2012
(f)LS200 – Administrative Law: The evidence before the Tribunal is insufficient for it to be satisfied that it would not be, or was not, possible for the application to be made before the end of the application period in October 2013.
Trimester 1, 2013
(g)LS212 – Evidence and Proof: The evidence before the Tribunal is insufficient for it to be satisfied that it would not be, or was not, possible for the application to be made before the end of the application period in June 2014.
CONCLUSION
Consistent with the reasoning contained in the Decisions under review, the Applicant has not specifically or reasonably demonstrated why it was not possible for her to apply for a remission of fees within the 12-month application timeframe for each unit of study.
The Tribunal is therefore not satisfied that it would not be, or was not, possible for the relevant applications to be made before the end of the relevant application periods.
Accordingly, the Tribunal cannot not grant a waiver pursuant to subparagraph 36-20(1)(f)(ii) of the Act.
The requirements of subparagraph 36-20(1)(f)(ii) of the Act having not been satisfied, the Application cannot succeed. It is not necessary to proceed to consider special considerations under paragraph 36-20(1)(d) of the Act and the Administration Guidelines and, indeed, to do so would be irrelevant. Accordingly, the Tribunal must affirm the Reviewable Decisions of the Respondent dated 10 August 2022.
DECISION
Pursuant to section 43(1) of the Administrative Appeals Tribunal Act 1975 (Cth), the Tribunal affirms the Reviewable Decisions of the Respondent dated 10 August 2022.
I certify that the preceding 45 paragraphs are a true copy of the reasons for the decision herein of Senior Member George
.............................[sgnd]..................................
Date of Decision: 22 June 2023
Date of Hearing: 11 May 2023 Representation for the Applicant: Self-Represented Solicitor for the Respondent:
Ms Subasha Prasad
Minter EllisonANNEXURE A – Exhibit Register
EXHIBIT
DESCRIPTION OF EVIDENCE
PARTY
DATE OF DOCUMENT
DATE RECEIVED
DATE TENDERED
A2/R1
Joint Tender Bundle
A/R
Various
11/05/2023
11/05/2023
A1
Statement of Facts, Issues and Contentions
A
Undated
27/02/2023
11/05/2023
R2
Statement of Facts, Issues and Contentions
R
14/02/2023
14/02/2023
11/05/2023
2
5
0