Kev Renovations Pty Ltd (Migration)

Kev Renovations Pty Ltd (Migration) [2019] AATA 2281 (7 May 2019)
DECISION RECORD
DIVISION:Migration & Refugee Division
APPLICANT:  Kev Renovations Pty Ltd
CASE NUMBER:  1615826
DIBP REFERENCE(S):  BCC2015/3319220
MEMBER:Karen McNamara
DATE:7 May 2019
PLACE OF DECISION:  Sydney
DECISION:The Tribunal sets aside the decision under review and substitutes a decision approving the nomination.

Statement made on 07 May 2019 at 1:52pm
CATCHWORDS
MIGRATION – nomination – Office Manager – building renovation business – Direct Entry Nomination stream – evidence of financial capacity provided – genuine need for position – role cannot be filled locally – nomination approved – decision under review set aside

LEGISLATION
Migration Act 1958 (Cth), ss 245AR(1), 359
Migration Regulations 1994 (Cth), rr 1.13, 5.19, 5.37(2)(a)
STATEMENT OF DECISION AND REASONS
APPLICATION FOR REVIEW

This is an application for review of a decision made by a delegate of the Minister for Immigration on 7 September 2016 to reject the application by Kev Renovations Pty Ltd (the applicant) for approval of the nomination of a position in Australia under r.5.19 of the Migration Regulations 1994 (the Regulations).
The applicant applied for approval on 11 November 2015. The requirements for the approval of the nomination of a position in Australia are found in r.5.19 of the Regulations which contains two alternative streams: a Temporary Residence Transition nomination (r.5.19(3)) stream and a Direct Entry nomination (r.5.19(4)) stream. If the application is made in accordance with r.5.19(2) and meets the requirements of either stream, then the application must be approved. If any of the requirements are not met then the application must be refused: r.5.19(5).
In this case, the applicant has applied for approval of a nomination, seeking to satisfy the criteria in the Direct Entry Nomination stream.
The delegate refused the application on the basis the applicant’s nomination did not satisfy r.5.19(4)(d) of the regulations because the delegate was not satisfied that the applicant is able to provide the nominee with full-time employment for at least two years.
Background
The applicant lodged an application for an employer nomination approval for the position of Office Manager (ANZSCO 512111) under the Regional Sponsored Migration Direct Entry stream. The proposed salary is $57,930 per annum.
When considering the application the delegate took into consideration the following issues;
·The application form indicates that the business employs three employees including a Carpenter. The organisational chart further indicates that there are six proposed positions plus the nominated position of Manager.
·In the nomination application form, the applicant indicates that the gross payroll expenditure of the business in the past 12 months is $12,000. The form does not specify the exact period that this figure was for.
·In the financial statements ending 30 June 2016, the total wages and salaries paid was $61,034, the nominated position is being offered a total annual remuneration of $57,930 per annum (exclusive of superannuation ) which will double the business expenditure on salaries.
·Based on the nominator’s most recent financial performance for FYE 30 June 2016 the business recorded a profit from ordinary activities before income tax of $32,619.
·The delegate noted that the nominator’s equity position over the 2016 fiscal period did not demonstrate, it had the financial capacity to incur the additional cost of employing a full-time Office Manager.
·The delegate had regard to advice from the applicant’s Accountant (14 January 2015) with projected figures however the information presented in the application did not show that the business turnover is expanding to such an extent that it can sustain paying an additional wage of $57,930 plus superannuation for at least the next two years.
·The delegate had regard to the letter from the Director dated 9 November 2015 advising the business need for position, however the information presented in the application did not show that the business turnover is expanding to such an extent that it can sustain paying an additional wage of $57,930 plus superannuation for at least the next two years
·The applicant did not provide documentation to verify a sustainable source of income.
·On 7 September 2016, the delegate found based on the evidence presented, the nominator failed to demonstrate the financial capacity to be able to pay the full time salary for the nominated position for at least two years.
The applicant applied to the Tribunal on 27 September 2016 for review of the delegate’s decision.
Information to the Tribunal
On the 8 January 2019, the Tribunal wrote to the applicant pursuant to section 359(2) of the Act (dispatched by email to the authorised recipient), requesting the applicant provide updated and current information that would assist to determine whether the criteria in r. 5.19(2) & (4) of the Regulations were met.
In response to this request the following information was provided to the Tribunal on 18 January 2019;
·Payslip for Mrs Vimaljit Kaur dated 26 May 2016
·PAYG summaries - handwritten dated 18 March 2018,19 December 2017 and 14 September 2018 for FY 2016, 2017 & 2018.
·ABN Current and historical extract
·ACN registration
·Regional Certifying Body approval Form 1404 dated 22 January 2016
·Organisational chart
·Position description
·Employment contract
·Employment contract salary discussion
·Market salary rate data
On 23 January 2019, the Tribunal received the following documents;
·BAS for the period September 2015 to June 2017
·BAS ATO integrated client account statement 2016 to January 2019
On 1 February 2019, the Tribunal received an updated organisational chart
At the hearing, the Tribunal requested that the applicant provide financial documentation including BAS returns as lodged via the ATO portal for July 2017 to June 2018, July 2018 to December 2018, business financial statements 2018 financial year, business tax return 2017 and 2018 financial years. ATO Notice of Assessments for Mrs Kaur 2016, 2017 and 2018. Mrs Kaur’s Payslips for the last three months (ie. November, December 2018 and January 2019. Business bank statement showing direct transfer of salary to Mrs Kaur since July 2018, Mrs Kaur’s bank statement for corresponding period showing direct deposit of wages, evidence of Mrs Kaur being paid superannuation and a copy of the business’s Workers Compensation policy.
The Tribunal received the following documents on 11 February 2019;
·     Financial Statements 2017 and 2018
·     Tax Return: Financial year ending 2017 and 2018
·     Tax Return: ATO Integrated Client Account balance
·     Tax Return: ATO Integrated Client Account lodgement history, 2015-2018.
The Tribunal received the following documents on 12 February 2019;
·PAYG 2016 - Mrs Kaur (signed on 18 March 2018)
·PAYG 2017 – Mrs Kaur (signed on 19 December 2017)
·PAYG 2018 –Mrs Kaur (signed on 14 July 2018 )
·PAYG 2017 – Mr Patel (signed on 19 December 2017)
·PAYG 2018 – Mr Patel (signed 14 July 2018)
·ATO Integrated Client Account of lodgement history 2016 to 2019.
·BAS July 2015 to June 2017 pre lodgement.
On 13 February 2019, the Tribunal received evidence of the applicant holding a Workers Compensation policy. The Tribunal notes this policy commenced on the 13 February 2019.
On 14 February 2019, the Tribunal received the following;
·Bank statement (extract) – Mrs Kaur 1 July 2018 to 13 February 2019
·Transaction history of superannuation payments (all transactions were made on 4 February 2019)
·Tax returns 2016, 2017, 2018 – Mrs Kaur. The Tribunal notes pre lodgement prepared by Accountant on 13 February 2019.
On 15 February 2019, the Tribunal received the following;
·Business bank statements 27 July 2018 to 15 January 2019
·BAS July 2016 to June 2017
·BAS July 2017 to June 2018
·BAS July to September 2018 pre lodgement
·BAS October to December 2018 pre lodgement
·Payslips – Mrs Kaur 23 May 2016 to 15 February 2019
·HESTA transaction history report
·Letter from Accountant (Cabot Square) dated 14 February 2019
The Tribunal notes advice from the nominee’s Migration Agent via email of 15 February 2019 that Mrs Kaur engaged an accountant to attend to her tax returns which were subsequently lodged on 14 February 2019 and that the associated Notice of Assessments will be provided to the Tribunal once received.
On 20 February 2019, the Tribunal wrote to the applicant (dispatched by email to the authorised recipient), requiring the provision of evidence to support that the applicant held a valid Workers Compensation policy prior to 13 February 2019. The Tribunal also noted that Mrs Kaur told the Tribunal at the hearing on 11 February 2019 that her tax returns were up to date. Subsequent evidence provided to the Tribunal on behalf of Mrs Kaur, indicates this was not correct and that Mrs Kaur lodged her 2016, 2017 and 2018 tax returns with the ATO on 15 February 2019. The Tribunal therefore provided 21 days for the provision of her Notice of Assessments from the date of the Tribunal’s letter of 20 February 2019.
The applicant represented by the business’ owner Mr Kaveh Yousefi appeared before the Tribunal by video conference on 11 February 2019 to give evidence and present arguments. The Tribunal also received oral evidence from the nominee Mrs Vimaljit Kaur. Mr Rajinder Pal Singh whilst sworn in as a witness did not provide any evidence.
A second hearing was held on 12 March 2019. Appearing before the Tribunal was the applicant, Mr Kaveh Yousefi and the nominee Mrs Vimaljit Kaur. The hearing was conducted via video conference.
The Tribunal invited the applicant and nominee to attend a second hearing on 12 March 2019, to afford them the opportunity to be heard in relation to issues arising in the review. In accordance with s.359AA, at the hearing of 12 March 2019, the Tribunal put to the applicant and nominee information before the Tribunal that suggested there is not a genuine need for the nominator to employ a paid employee to work in the position under the nominator’s direct control.
The applicant was represented in relation to the review by its registered migration agent. The representative attended the Tribunal hearing.
For the following reasons, the Tribunal has decided to set aside the decision under review and substitute a decision approving the nomination.
CONSIDERATION OF CLAIMS AND EVIDENCE
The issue in this case is whether the applicant meets the requirements for approval of the nomination under the Direct Entry nomination stream set out in r.5.19(4), which is extracted in the attachment to this decision. For the nomination to be approved, all the requirements must be met.
The application is compliant: r.5.19(4)(a)
Regulation 5.19(4)(a) requires that the application for approval must be in the approved form, must be accompanied by the prescribed fee, and, where applicable, must include the required written certification relating to conduct that contravenes s.245AR(1). The application must also identify a need for the nominator to employ a paid employee to work in the position under their direct control.
Based on the material in the Department’s file, the Tribunal is satisfied that the application was made on the approved form. As the position is located in regional Australia, no fee is payable (r5.37(2)(a)). As the application was made prior to 14 December 2015, the requirement for written certification relating to conduct that contravenes s.245AR(1) of the Act, declared and signed by the applicant is not applicable. Accordingly the requirements of r.5.19(4)(a)(i) are met.
In considering whether the application for approval identifies a need for the nominator to employ a paid employee to work in the position under the nominator’s direct control, the Tribunal has had regard to the evidence before it, including written submissions and the oral evidence received at the hearing by Mr Yousefi and Mrs Kaur.
The Tribunal accepts on the evidence before it that the nominator operates a building renovation business in North Perth, Western Australia. The business reported an annual turnover for the 2017/18 financial year of $240,291 with net profit of $68,392 and total salary and wage expense $113,308.
ASIC records provided by the applicant to the Tribunal show that the business was registered on 7 November 2014.
The applicant told the Tribunal that he advertised the position and received several applications. Mrs Kaur was the only suitable and qualified applicant. The applicant told the Tribunal he needs the position, as he can no longer do all of the administration work and needs a person to manage the office and his diary.
On the totality of evidence before it, the Tribunal is satisfied that the application has identified a need for the nominator to employ a paid employee to work in the position under the nominator’s direct control. Accordingly, the requirement in r.5.19(4)(a) (ii) are met.
As the criteria in both r.5.19(4)(a)(i) and (ii) are satisfied, accordingly the requirements in r.5.19(4)(a) are met.
Nominator is actively and lawfully operating a business in Australia: r.5.19(4)(b)
Regulation 5.19(4)(b) requires the applicant is actively, lawfully and directly operating a business in Australia.
Based on the material provided to the Tribunal, including, financial statements, Business Activity Statements, ASIC Company details, payroll advice and evidence from Mr Yousefi about the operations of the business, the Tribunal is satisfied the applicant is actively and lawfully operating a building renovation business in Australia and directly operates that business.
Accordingly, the requirement in r.5.19(4)(b) is met.
Position is not labour-hire: r.5.19(4)(c)
Regulation 5.19(4)(c) applies to nominators whose business activities include those relating to labour hire to an unrelated business. In these cases, the nominated position must be within the business activities of the nominator.
There is no evidence before the Tribunal to suggest that the applicant’s business is involved in labour hire.
Accordingly, the requirement in r.5.19(4)(c) does not apply.
Term of employment of the visa holder: r.5.19(4)(d)
Regulation 5.19(4)(d) requires the nominee to be employed in the nominated position for at least 2 years full time, and the terms and conditions of that employment do not expressly exclude the possibility of an extension.
The Tribunal has had regard to the contract for employment for the nominee dated 16 January 2019. The contract, which sets out the terms and conditions of employment, indicate that the period of employment is three years upon the granting of a subclass 187 visa. At the hearing, the applicant advised the Tribunal that he would employ Mrs Kaur for as long as he could. The contract stipulates the base salary is $59,964.29 with hours of work 38 per week. The nominee is to be paid 9.5% superannuation. Leave entitlements are in accordance with the National Employment Standards. There is no term excluding an extension of the contract. The Tribunal has had regard to the business’ financial documentation and ATO BAS statements and Mrs Kaur’s PAYG’s, Tax returns, payslips and bank statements. Based on this material, the Tribunal is satisfied that the applicant has the financial capacity to maintain the nominee’s employment as they have done since February 2017. Accordingly, the requirement in r.5.19(4)(d)(i) is met.
The Tribunal is also satisfied based on the employment contract and other material before it, that the nominee will be employed on a full-time basis for at least two years on terms that do not exclude the possibility of extending the period of employment. The contract stipulates that the position is full time commencing on approval of the nominee’s visa and will continue until terminated in accordance with the agreement. Accordingly, the requirement in r.5.19(4)(ii) is met.
As the criteria in both r.5.19(4)(d)(i) and (ii) are satisfied, accordingly the requirements in r.5.19(4)(d) are met.
No less favourable terms and condition of employment: r.5.19(4)(e)
Regulation 5.19(4)(e) requires that the terms and conditions of employment applicable to the nominated position will be no less favourable than those that are, or would be, provided to an Australian citizen or permanent resident performing equivalent work in the same workplace at the same location.
The contract of employment dated 16 January 2019, sets out the terms and conditions of employment and indicates that the nominee’s base salary will be $59,964.29 per annum excluding superannuation upon the grant of the nominee’s visa. The Tribunal has received payslips and bank statements confirming that Mrs Kaur is currently being paid $57,980 per annum. The Tribunal is satisfied the nominee will be paid in accordance with the terms of employment.
The Tribunal is satisfied on the totality of the evidence before it that the terms and conditions applicable to the position will be no less favourable than those that would be provided to an Australian citizen or permanent resident performing equivalent work in the same workplace at the same location.
Accordingly the requirements of r.5.19(4)(e) are met.
No adverse information known to Immigration: r.5.19(4)(f)
Regulation 5.19(4)(f) requires that there is no adverse information known to Immigration about the nominator or person associated with the nominator; or it is reasonable to disregard any such information. For these purposes, ‘adverse information’ and ‘associated with’ have the meaning given in rr.1.13A and 1.13B.
There is no evidence before the Tribunal to indicate that there is adverse information known to the Department about the applicant or an associated person.
Accordingly the requirements of r.5.19(4)(f) are met.
Satisfactory compliance with workplace relations laws: r.5.19(4)(g)
Regulation 5.19(4)(g) requires that the applicant has a satisfactory record of compliance with the laws of the Commonwealth, and of each State or Territory in which the applicant operates a business and employs employees in the business, relating to workplace relations.
There is no evidence before the Tribunal that indicates the applicant does not have a satisfactory record of compliance with the relevant Commonwealth and State workplace relations laws.
Accordingly the requirements of r.5.19(4)(g) are met.
Tasks of the position genuine need for the position and training requirements r.5.19(4)(h)
Regulation 5.19(4)(h) contains a number of alternative requirements. These are set out in detail in the attachment to the decision but can be briefly summarised as requiring either that:
·the tasks to be performed in the position will be performed in Australia and correspond to those of an occupation specified by the Minister in an instrument, the occupation is applicable to the proposed employee in accordance with any specifications made in that instrument, and specified training requirements are met; or
·the position and nominator’s business is located in regional Australia, there is a genuine need for the paid position under the nominator’s direct control which cannot be filled by a locally resident Australian citizen or permanent resident, the tasks of the position correspond to those of an occupation specified in the relevant legislative instrument, the occupation is applicable to the proposed employee in accordance with the specification of the occupation and that a regional certifying body has advised the Minister about certain matters relating to the position.
In this case, the applicant claims to meet the requirements in r.5.19(4)(h)(ii). The Tribunal has considered each of these requirements as follows;

The evidence before the Tribunal indicates that the applicant’s business, which is operated by the applicant and the position are located in North Perth, postcode 6006 which is a postcode specified in the relevant instrument as being in regional Australia, accordingly r.5.19(4)(h)(ii)(A) and (E) are met.
The Tribunal next considered whether there is a genuine need for the applicant to employ an Office Manager and for the tasks of that position. The evidence before the Tribunal indicates the applicant is the owner of a building renovation business in North Perth, Western Australia. Mr Yousefi gave evidence at the hearing that he established the business in 2014 and has a turnover of approximately $267,620 p.a (confirmed by BAS returns for 2018 FY). He has plans to diversify the business to include a consultancy division. The applicant told the Tribunal he requires someone to run the office as he can no longer do this and his wife cannot help, particularly as she takes care of the couples twin daughters.
The nominee, Mrs Kaur initially worked part time with the applicant and commenced working full time approximately in February 2017. The Tribunal has considered evidence supporting the nominee’s suitability in so far as her experience and qualifications for the position. The Tribunal has sighted Mrs Kaurs certificates and academic transcripts which confirm that she holds a Master of Art –Economics issued by Gurunanak Girls College in India, Bachelor of Education (India) Diploma of Business from Business Technology Institute of Australia, Diploma in Multimedia AQF Certificate IV in Business, Cert III Graphic Pre-press, Cert III in Aged Care, Cert III in Home and Community Care. At the hearing Mrs Kaur told the Tribunal that she had worked in admin in India. Mr Yousefi told the Tribunal that Mrs Kaur is competent and he is reliant on her.
The Tribunal has considered the evidence attesting to Mrs Kaur’s experience and is satisfied that Mrs Kaur is suitably qualified for the position.
At the hearing of 11 February 2019, Mrs Kaur told the Tribunal that her tax returns were up to date. Subsequently on 14 February 2019, the Tribunal received information from the nominee, showing that the nominee’s tax returns for 2016, 2017 and 2018 were prepared and lodged by her Accountant on 13 February 2019.
The Tribunal noted that the tax returns show that she worked for other employers, that being two aged care providers, in addition to the nominee. Prior to the provision of her tax returns to the Tribunal on 15 February 2019, it was not disclosed to the Tribunal that she was working for two other employers. The evidence shows that Mrs Kaur in the 2018 financial year received an income of $42,053 from SwanCare Group and $24,612 from Amana Living (Inc) and in 2017 financial year, received an income of $41,292 from SwanCare Group and $20,996 from Amana Living (Inc). Based on the evidence provided by the nominee, the Tribunal, in accordance with s.359AA, at the hearing of 12 March 2019, put to the nominee that it may not accept that she is working full time with the applicant as the information contained in the tax returns indicate that she is working fulltime in another job (SwanCare Group).
Mrs Kaur told the Tribunal she is able to work three jobs, as her role with the aged care facilities involve night work and provide opportunity for rest. Mrs Kaur subsequent to the hearing provided the Tribunal with Statutory Declarations from Amana Living and SwanCare which confirm the nature of her role in their respective facilities, her rostered hours and the opportunity for rest during her shift.
The Tribunal has considered this information and is satisfied on the basis of the information provided in the Statutory Declarations that it is plausible for the nominee to work full time for the applicant and with the aged care facilities in the evenings and weekends.
The Tribunal is therefore satisfied that there is a genuine need for a paid employee to work in the position of Office Manager under the nominator’s control. The Tribunal is also satisfied that the tasks of the position to be performed correspond to the tasks of an occupation specified by the Minister in an instrument in writing for this sub-subparagraph. Furthermore, the Tribunal is satisfied that the occupation is applicable to the person identified under subparagraph (a)(ii) in accordance with the specification of the occupation. Accordingly the requirements of r.5.19(4)(h)(ii) (B) and (D) and (DA) are met.
The Tribunal is satisfied that the material and evidence provided supports the applicant’s claims that they have made efforts to fill the position locally by an Australian citizen or permanent resident. The applicant provided evidence that he has been unsuccessful in sourcing an experienced and qualified Australian citizen or a permanent resident to the positon. The applicant advised the Tribunal that he advertised the position in the West Australian newspaper and online on Jobfinder.com.au and careerone.com.au .
The Tribunal also gives weight to the RCB’s advice that the position cannot be filled locally. On the evidence, the Tribunal is satisfied that the position cannot be filled by an Australian citizen/permanent resident living in the same local area. Accordingly, the requirements of r.5.19(4)(h)(ii)(C) are met.
The Tribunal has cited the completed Form 1404 dated 22 January 2016 from the relevant RCB, Skilled Migration WA, Department of Training and Workforce Development, indicating that they are satisfied regarding the matters specified in paragraph (e) and sub subparagraphs (B) and (C). On this basis, the Tribunal is satisfied that r.5.19(4)(h)(ii)(F) is met.
Given the above, the Tribunal finds that the requirements of r.5.19(4)(h)(ii) are met and accordingly r.5.19(4)(h) is met as a whole.
Conclusion
Based on the findings above, the Tribunal is satisfied that the applicant meets the requirements of r.5.19 for approval of the nomination of the position in Australia.
DECISION
The Tribunal sets aside the decision under review and substitutes a decision approving the nomination.
Karen McNamara
Member

ATTACHMENT - EXTRACTS FROM THE MIGRATION REGULATIONS 1994
5.19Approval of nominated positions (employer nomination)
…
(2)The application must:
(a)be made in accordance with approved form 1395…; and
(b)be accompanied by the fee mentioned in regulation 5.37.
…
Direct Entry nomination
(4)The Minister must, in writing, approve a nomination if:
(a)the application for approval:
(i)       is made in accordance with subregulation (2); and
(ii)      identifies a need for the nominator to employ a paid employee to work in the position under the nominator’s direct control; and
(b)the nominator:
(i)       is actively and lawfully operating a business in Australia; and
(ii)      directly operates the business; and
(c)for a nominator whose business activities include activities relating to the hiring of labour to other unrelated businesses — the position is within the business activities of the nominator and not for hire to other unrelated businesses; and
(d)both of the following apply:
(i)       the employee will be employed on a full-time basis in the position for at least 2 years;
(ii)      the terms and conditions of the employee’s employment will not include an express exclusion of the possibility of extending the period of employment; and
(e)the terms and conditions of employment applicable to the position will be no less favourable than the terms and conditions that:
(i)       are provided; or
(ii)      would be provided;
to an Australian citizen or an Australian permanent resident for performing equivalent work in the same workplace at the same location; and
(f)either:
(i)       there is no adverse information known to Immigration about the nominator or a person associated with the nominator; or
(ii)      it is reasonable to disregard any adverse information known to Immigration about the nominator or a person associated with the nominator; and
(g)the nominator has a satisfactory record of compliance with the laws of the Commonwealth, and of each State or Territory in which the applicant operates a business and employs employees in the business, relating to workplace relations; and
(h)either:
(i)       both of the following apply:
(A)the tasks to be performed in the position will be performed in Australia and correspond to the tasks of an occupation specified by the Minister in an instrument in writing for this sub-subparagraph;
(AAA)the occupation is applicable to the person identified under subparagraph (a)(ii) in accordance with the specification of the occupation;
(B)either:
(I)the nominator’s business has operated for at least 12 months, and the nominator meets the requirements for the training of Australian citizens and Australian permanent residents that are specified by the Minister in an instrument in writing for this sub-sub-subparagraph; or
(II)the nominator’s business has operated for less than 12 months, and the nominator has an auditable plan for meeting the requirements specified in the instrument mentioned in sub-sub-subparagraph (I); or
(ii)      all of the following apply:
(A)the position is located in regional Australia;
(B)there is a genuine need for the nominator to employ a paid employee to work in the position under the nominator’s direct control;
(C)the position cannot be filled by an Australian citizen or an Australian permanent resident who is living in the same local area as that place;
(D)the tasks to be performed in the position correspond to the tasks of an occupation specified by the Minister in an instrument in writing for this sub-subparagraph;
(DA)the occupation is applicable to the person identified under subparagraph (a)(ii) in accordance with the specification of the occupation;
(E)the business operated by the nominator is located at that place;
(F)a body that is:
(I)specified by the Minister in an instrument in writing for this sub-subparagraph; and
(II)located in the same State or Territory as the location of the position;
has advised the Minister about the matters mentioned in paragraph (e) and sub-subparagraphs (B) and (C).

[2019] AATA 2281

7 May 2019

Key Legal Topics

Areas of Law

Immigration

Administrative Law

Legal Concepts

Judicial Review

Statutory Construction

Procedural Fairness

Appeal