MacRae and Australian Capital Territory (Compensation)

Case [2023] AATA 2828

MacRae and Australian Capital Territory (Compensation) [2023] AATA 2828 (28 August 2023)

Division:GENERAL DIVISION

File Number:          2019/3908 and 2022/1309

Re:Jade MacRae

APPLICANT

Australian Capital Territory And  

RESPONDENT

DECISION

Tribunal:Senior Member C. J. Furnell

Date:28 August 2023

Place:Melbourne

The Tribunal refuses the applicant's request for orders under section 35 of the Administrative Appeals Tribunal Act 1975 (Cth).

.........................[SGD]...............................................

Senior Member C. J. Furnell

Catchwords

PRACTICE AND PROCEDURE – application for confidentiality orders – application for non-publication of decision – application for removal of files from Tribunal database – whether confidentiality orders can be granted to prevent reputational harm – general principle of open justice – public interest – where decision had already been published – application for confidentiality orders refused

Legislation

Administrative Appeals Tribunal Act 1975 (Cth)

Cases

Australian Securities and Investments Commission v Administrative Appeals Tribunal [2009] FCAFC 185
Boardman and Secretary, Department of Social Services (Social services second review) [2021] AATA 3144
Catena v Australian Securities and Investment Commission [2010] FCA 598
De Pyle v Commonwealth [2023] FCA 597
Dring v Cape Intermediate Holdings Ltd [2019] UKSC 38
Kadeh and Migration Agents Registration Authority (Migration) [2018] AATA 4461
KPTT v Commissioner of Taxation [2021] FCA 464
Le and Secretary, Department of Education, Science and Training [2006] AATA 208
Lee v Deputy Commissioner of Taxation [2023] FCAFC 22
Ogawa (formerly Ms PD) v President of the Australian Human Rights Commission (Pseudonym) [2022] FCAFC 160
Panganiban v Australian Securities & Investments Commission [2016] AATA 703
Poidevin and Australian Securities and Investments Commission [2018] AATA 124
Poidevin and Australian Securities and Investments Commission [2020] AATA 782
Porter v Australian Broadcasting Corporation [2021] FCA 863
Salah (formerly HGMZ) v Secretary, Department of Social Services [2022] FCAFC 186
The Country Care Group Pty Ltd v Commonwealth Director of Public Prosecutions (No 2) [2020] FCAFC 44

Secondary Materials

‘Policy: Publication of decisions’, Administrative Appeals Tribunal (24 September 2020) < FOR DECISION

Senior Member C. J. Furnell

28 August 2023

  1. In a submission dated 4 June 2023, sent to the Tribunal by email on 2 July 2023, the applicant applied to the Tribunal for two things: “…a suppression or non-publication order to stop my records of the case… from being published anywhere on your website or any accessible for public viewing”; and “…the removal of my files from your database.”

  2. Addressing this second request first, while the Tribunal does have certain powers in relation to publication and disclosure, those powers do not encompass a power to make or issue an order or direction to itself of the type sought by the applicant.

  3. As to the applicant’s first request, the Tribunal has power to give orders restricting or prohibiting the publication or disclosure of certain information. That power remains exercisable despite the facts that:

    (a)no application for a suppression or non-publication order was made before the decision in this proceeding was made (even though the applicant was legally represented at the hearing of the proceeding); and

    (b)the decision in this proceeding had been made some time before the applicant applied for a suppression or non-publication order. While the Tribunal is functus officio in terms of its power to review the decision which the applicant had challenged in this proceeding, its capacity to exercise the separate head of power found in s 35 of its constituent legislation remains.[1] 

    [1] Le and Secretary, Department of Education, Science and Training [2006] AATA 208 at [14]-[15]; Poidevin and Australian Securities and Investments Commission [2020] AATA 782 at [47]-[48]. Under the Tribunal’s Publication of decisions policy issued in September 2020, a published decision may be recalled. It would then be re-published absent, say, an order prohibiting publication under Administrative Appeals Tribunal Act 1975, s 35: ‘Policy: Publication of decisions’, Administrative Appeals Tribunal (24 September 2020) <>

    While the Tribunal has power to prohibit or restrict publication of its decision and of the reasons for its decision in this proceeding, the question is whether it should exercise that power in the circumstances.

  4. Having considered the applicant’s submissions, the Tribunal has decided that it should not.

  5. Before proceeding to outline the reasons for that decision, mention should be made of some aspects of the procedural background.

    Aspects of procedural background

  6. The decision in this proceeding was made on 24 May 2023. It and the reasons for it were published on 30 May 2023. As mentioned earlier, in a submission dated 4 June 2023 sent to the Tribunal by email on 2 July 2023, the applicant applied to the Tribunal for, amongst other things, a suppression or non-publication order.

  7. The respondent opposed that application by submission lodged with the Tribunal on 18 July 2023.

  8. In a further submission of 26 July 2023, the applicant replied to the respondent’s submission in opposition.

  9. Both the respondent and the applicant consented to the Tribunal considering the parties’ submissions without holding a hearing.

    Applicant submissions

  10. The applicant states that she intends to “work in the rewarding fields of mental health, forensic prisons and detention facilities and on aircraft that also transports detainees…”. It is contended that it is highly likely that the applicant’s “case with the AAT could be used” by clients with whom the applicant would engage in the context of that work, being people who may “…tend to engage in such acts as clients trying to harm my reputation through cohesion, identity theft, stalking, bullying, discrimination, interference, and shunning.”

  11. The applicant also states that publication of matters concerning her proceeding before the Tribunal might adversely affect her prospects of obtaining employment in the Australian defence industry and may adversely affect her reputation. According to the applicant “[i]n the view of the general public, reputational harm and bias take precedence over ‘open justice.’”

  12. Lastly, the applicant submits that information concerning her medical conditions ought not be published as it is confidential.

    Consideration

  13. In considering whether to exercise its power to prohibit or restrict publication of the decision in this proceeding and the reasons for it, the Tribunal is required to take, as the basis of its consideration, the principle that it is desirable that, amongst other things, evidence given before the Tribunal should be made available to the public.[2]

    [2] Administrative Appeals Tribunal Act 1975, s 35(5).

  14. This requirement of the Tribunal reflects a broader principle of open justice,[3] a principle the purposes of which are to “…‘enable public scrutiny of the way in which courts decide cases’ and ‘to enable the public to understand how the justice system works and why decisions are taken’.”[4]

    [3] See Kadeh and Migration Agents Registration Authority (Migration) [2018] AATA 4461 at [15]. See also Australian Securities and Investments Commission v Administrative Appeals Tribunal [2009] FCAFC 185 at [75], where it is said that “In the AAT itself facts which parties would not wish to be published and which may disadvantage them are frequently published. Social security applications are a good example. The reason these matters are not kept secret is the overriding importance of justice being administered openly and in public.”

  15. Safeguarding the public interest in open justice means that suppression or non-publication orders should only be made in exceptional circumstances.[5] This is in a context where the “…precept of the rule of law that similar cases be treated similarly cannot be met unless the public is able to have access to the Tribunal’s decisions and able to compare one case with another.”[6]

    [5] The Country Care Group Pty Ltd v Commonwealth Director of Public Prosecutions (No 2) [2020] FCAFC 44 at [7]–[9], cited in De Pyle v Commonwealth [2023] FCA 597 at [15]. See also Ogawa (formerly Ms PD) v President of the Australian Human Rights Commission (Pseudonym) [2022] FCAFC 160 at [28], where it is said that “…a court has power to make an order derogating from the law’s insistence that it exercise its jurisdiction in open court in accordance with the principle of open justice only where the public disclosure of evidence or other matter, or the identity of a party to, or a person involved in, a proceeding would frustrate the administration of justice.” In Salah (formerly HGMZ) v Secretary, Department of Social Services [2022] FCAFC 186 at [8], it was said that a “…person who wishes to litigate a proceeding before a court of law does so in light of, and subject to, the principle of open justice. Suppression or non-publication orders, including the use of pseudonyms, must be applied only in circumstances where such an order is necessary in the interests of justice…”.

    [6] Le and Secretary, Department of Education, Science and Training [2006] AATA 208 at [29]. See also Poidevin and Australian Securities and Investments Commission [2020] AATA 782 at [73].

  16. While the principle of open justice is not unyielding, the submissions made by the applicant in support of her application are not such as to warrant its non-application in the circumstances. It was up to the applicant to “make a compelling case”[7] justifying a departure from the usual requirement for publication. She has not done so.

    [7] Boardman and Secretary, Department of Social Services (Social services second review) [2021] AATA 3144 at [13].

  17. First, the applicant’s submission concerning a risk of people seeking to harm her reputation, or engaging in identify theft, using information published in this proceeding, does not move beyond mere speculation. This is in a context where the applicant has not identified any particular information in the material she seeks not to be disclosed that might be thought to be capable of misuse or of causing significant harm to her.

  18. Second, considerations of embarrassment or personal sensitivity, of themselves, are usually insufficient to justify a grant of a prohibition or suppression order.[8] In this regard, in bringing proceedings seeking compensation for injury, an applicant for review ought be taken to have accepted the inevitability of disclosure of information about their medical conditions. Applicants “… come before the Tribunal…in the knowledge that, unless there are compelling reasons to the contrary, the public interest requires open hearings and accessible decisions.”[9]

    [8] Ogawa (formerly Ms PD) v President of the Australian Human Rights Commission (Pseudonym) [2022] FCAFC 160 at [27], where it is said that “Considerations of embarrassment, convenience or personal sensitivity to the publication of personal and often very private circumstances given in evidence or revealed in the course of a proceeding in open court, of themselves, cannot justify or support the exercise of any inherent or implied power of a court to suppress or prohibit the publication of those matters.” See also Catena v Australian Securities and Investment Commission [2010] FCA 598 at [24].

    [9] Cat Media Pty Limited, Carotino (Australia) Pty Limited, Pharm-a-Care Laboratories Pty Ltd and Minister for Health and Aged Care [2022] AATA 1254 at [94]; Boardman and Secretary, Department of Social Services (Social services second review) [2021] AATA 3144; Re Sheepskin and Opal Exporters and Export Development Grants Board (1984) 6 ALD 594.

  19. Third, as submitted by the respondent, the mere potential for damage to the applicant's reputation and employment prospects alone is not a sufficient justification for the making of a non-publication order.

  20. In purportedly refuting this submission, the applicant referred to material suggesting that reputational harm can cause mental health issues, that unfair termination can be a breach of confidence and that embarrassment is an injury resulting from privacy violations.

  21. Essentially, the applicant appeared to be contending that the potential for reputational damage is of itself a sufficient justification for a non-publication order, given the nature of the harm that might be suffered by a person whose reputation is affected.

  22. I reject that contention. Indeed, reputational harm can be an inevitable consequence of open justice.[10] The risk of it, and how it might adversely affect a person’s prospects of being involved in a particular industry,[11] is usually insufficient justification for the making of a suppression or non-publication order.[12]

    [10] Lee v Deputy Commissioner of Taxation [2023] FCAFC 22 at [90], where it is said that the “…fact that a person will suffer reputational or commercial harm from publication of evidence relied upon in open court does not have the necessary consequence that the proper administration of justice is or will be prejudiced. Such harm can be an inevitable part of open justice.” In KPTT v Commissioner of Taxation [2021] FCA 464 at [7], it was said that “parties must accept the damage to their reputation, and the possibility of consequential loss, which may be inherent in being involved in litigation”.

    [12] Poidevin and Australian Securities and Investments Commission [2018] AATA 124 at [17], where it is said that “Reputational damage will generally not be enough and it is for the applicant to satisfy the Tribunal that there should be a departure from the ‘norm’”. In Panganiban v Australian Securities & Investments Commission [2016] AATA 703 at [12], SM Taylor stated that “…mere apprehension about the potential for reputational harm directly resulting from the reviewable decision will usually not provide a persuasive basis for restricting the publicity of review proceedings.”

  23. Fourth, while the grant of a prohibition or suppression order is not precluded by the fact that the decision in this case and the reasons for it have been in the public domain for some time (and were in the public domain for more than a month before the applicant sought a non-publication order), that fact does weigh against such a grant.[13]

    [13] De Pyle v Commonwealth [2023] FCA 597 at [29], where it was said that the information the publication of which was sought to be suppressed “…had been in the public domain for almost one month before the application was foreshadowed and it must be reasonably supposed that any confidentiality has been lost once and for all.” See also Ogawa (formerly Ms PD) v President of the Australian Human Rights Commission (Pseudonym) [2022] FCAFC 160 at [37]-[38].

    Decision

  24. The applicant has applied to the Tribunal for “…a suppression or non-publication order to stop my records of the case… from being published anywhere on your website or any accessible for public viewing” and for “…the removal of my files from your database.”

  25. Insofar as it has power to make a decision with respect to those applications, the Tribunal refuses to grant them.

  26. In particular, the Tribunal refuses to grant a suppression or non-publication order with respect to its decision, and the reasons for its decision, in this proceeding.

I certify that the preceding 27 (twenty-seven) paragraphs are a true copy of the reasons for the decision herein of Senior Member C. J. Furnell

............................[SGD]............................................

Associate

Dated: 28 August 2023

Interlocutory hearing: On the papers
Applicant: Self-represented
Solicitors for the Respondent: HWL Ebsworth Lawyers

Details
AGLC
MacRae and Australian Capital Territory (Compensation) [2023] AATA 2828
Case
[2023] AATA 2828
Decision Date

CaseChat Overview and Summary

The applicant, MacRae, sought confidentiality orders from the Administrative Appeals Tribunal (AAT) to prevent the publication of a decision and the removal of case files from the Tribunal's database. The respondent, the Australian Capital Territory, opposed this application. The dispute arose after the AAT had already made and published its decision concerning MacRae's compensation claim.

The central legal issue before the Tribunal was whether it should exercise its power to grant suppression or non-publication orders, despite the decision already being published and the applicant's delay in making the request. This required the Tribunal to consider the principle of open justice, the public interest in the accessibility of court decisions, and the circumstances under which exceptions to this principle might be warranted. The applicant contended that publication would cause reputational harm, affect future employment prospects, and expose sensitive medical information, arguing that these concerns outweighed the principle of open justice.

Senior Member Furnell SM reasoned that while the Tribunal retained the power to make such orders, the applicant had failed to establish exceptional circumstances justifying a departure from the principle of open justice. The Tribunal noted that the applicant's concerns about reputational harm and potential misuse of information were speculative and not supported by specific evidence of how particular information might be exploited. Furthermore, considerations of embarrassment or personal sensitivity were generally insufficient grounds for suppression orders, and applicants in compensation proceedings were expected to accept the inevitability of disclosure. The fact that the decision had been public for some time also weighed against granting the requested orders.

Ultimately, the Tribunal refused the applicant's request for a suppression or non-publication order regarding its decision and the reasons for it, and also refused the application for the removal of files from the database.

Orders

Orders of the court

Full text does not contain this section.

Background

Background to the litigation

As to the applicant’s first request, the Tribunal has power to give orders restricting or prohibiting the publication or disclosure of certain information. That power remains exercisable despite the facts that:(a)no application for a suppression or non-publication order was made before the decision in this proceeding was made (even though the applicant was legally represented at the hearing of the proceeding); and(b)the decision in this proceeding had been made some time before the applicant applied for a suppression or non-publication order. While the Tribunal is functus officio in terms of its power to review the decision which the applicant had challenged in this proceeding, its capacity to exercise the separate head of power found in s 35 of its constituent legislation remains.[1] [1] Le and Secretary, Department of Education, Science and Training [2006] AATA 208 at [14]-[15]; Poidevin and Australian Securities and Investments Commission [2020] AATA 782 at [47]-[48]. Under the Tribunal’s Publication of decisions policy issued in September 2020, a published decision may be recalled. It would then be re-published absent, say, an order prohibiting publication under Administrative Appeals Tribunal Act 1975, s 35: ‘Policy: Publication of decisions’, Administrative Appeals Tribunal (24 September 2020) <>While the Tribunal has power to prohibit or restrict publication of its decision and of the reasons for its decision in this proceeding, the question is whether it should exercise that power in the circumstances.Having considered the applicant’s submissions, the Tribunal has decided that it should not. Before proceeding to outline the reasons for that decision, mention should be made of some aspects of the procedural background.Aspects of procedural backgroundThe decision in this proceeding was made on 24 May 2023. It and the reasons for it were published on 30 May 2023. As mentioned earlier, in a submission dated 4 June 2023 sent to the Tribunal by email on 2 July 2023, the applicant applied to the Tribunal for, amongst other things, a suppression or non-publication order.The respondent opposed that application by submission lodged with the Tribunal on 18 July 2023.In a further submission of 26 July 2023, the applicant replied to the respondent’s submission in opposition.Both the respondent and the applicant consented to the Tribunal considering the parties’ submissions without holding a hearing. Applicant submissionsThe applicant states that she intends to “work in the rewarding fields of mental health, forensic prisons and detention facilities and on aircraft that also transports detainees…”. It is contended that it is highly likely that the applicant’s “case with the AAT could be used” by clients with whom the applicant would engage in the context of that work, being people who may “…tend to engage in such acts as clients trying to harm my reputation through cohesion, identity theft, stalking, bullying, discrimination, interference, and shunning.”The applicant also states that publication of matters concerning her proceeding before the Tribunal might adversely affect her prospects of obtaining employment in the Australian defence industry and may adversely affect her reputation. According to the applicant “[i]n the view of the general public, reputational harm and bias take precedence over ‘open justice.’”Lastly, the applicant submits that information concerning her medical conditions ought not be published as it is confidential.ConsiderationIn considering whether to exercise its power to prohibit or restrict publication of the decision in this proceeding and the reasons for it, the Tribunal is required to take, as the basis of its consideration, the principle that it is desirable that, amongst other things, evidence given before the Tribunal should be made available to the public.[2] [2] Administrative Appeals Tribunal Act 1975, s 35(5).This requirement of the Tribunal reflects a broader principle of open justice,[3] a principle the purposes of which are to “…‘enable public scrutiny of the way in which courts decide cases’ and ‘to enable the public to understand how the justice system works and why decisions are taken’.”[4] [3] See Kadeh and Migration Agents Registration Authority (Migration) [2018] AATA 4461 at [15]. See also Australian Securities and Investments Commission v Administrative Appeals Tribunal [2009] FCAFC 185 at [75], where it is said that “In the AAT itself facts which parties would not wish to be published and which may disadvantage them are frequently published. Social security applications are a good example. The reason these matters are not kept secret is the overriding importance of justice being administered openly and in public.”[4] Dring v Cape Intermediate Holdings Ltd [2019] UKSC 38 at [42]-[43], cited with evident approval in Porter v Australian Broadcasting Corporation [2021] FCA 863 at [85].Safeguarding the public interest in open justice means that suppression or non-publication orders should only be made in exceptional circumstances.[5] This is in a context where the “…precept of the rule of law that similar cases be treated similarly cannot be met unless the public is able to have access to the Tribunal’s decisions and able to compare one case with another.”[6][5] The Country Care Group Pty Ltd v Commonwealth Director of Public Prosecutions (No 2) [2020] FCAFC 44 at [7]–[9], cited in De Pyle v Commonwealth [2023] FCA 597 at [15]. See also Ogawa (formerly Ms PD) v President of the Australian Human Rights Commission (Pseudonym) [2022] FCAFC 160 at [28], where it is said that “…a court has power to make an order derogating from the law’s insistence that it exercise its jurisdiction in open court in accordance with the principle of open justice only where the public disclosure of evidence or other matter, or the identity of a party to, or a person involved in, a proceeding would frustrate the administration of justice.” In Salah (formerly HGMZ) v Secretary, Department of Social Services [2022] FCAFC 186 at [8], it was said that a “…person who wishes to litigate a proceeding before a court of law does so in light of, and subject to, the principle of open justice. Suppression or non-publication orders, including the use of pseudonyms, must be applied only in circumstances where such an order is necessary in the interests of justice…”.[6] Le and Secretary, Department of Education, Science and Training [2006] AATA 208 at [29]. See also Poidevin and Australian Securities and Investments Commission [2020] AATA 782 at [73]. While the principle of open justice is not unyielding, the submissions made by the applicant in support of her application are not such as to warrant its non-application in the circumstances. It was up to the applicant to “make a compelling case”[7] justifying a departure from the usual requirement for publication. She has not done so.[7] Boardman and Secretary, Department of Social Services (Social services second review) [2021] AATA 3144 at [13].First, the applicant’s submission concerning a risk of people seeking to harm her reputation, or engaging in identify theft, using information published in this proceeding, does not move beyond mere speculation. This is in a context where the applicant has not identified any particular information in the material she seeks not to be disclosed that might be thought to be capable of misuse or of causing significant harm to her. Second, considerations of embarrassment or personal sensitivity, of themselves, are usually insufficient to justify a grant of a prohibition or suppression order.[8] In this regard, in bringing proceedings seeking compensation for injury, an applicant for review ought be taken to have accepted the inevitability of disclosure of information about their medical conditions. Applicants “… come before the Tribunal…in the knowledge that, unless there are compelling reasons to the contrary, the public interest requires open hearings and accessible decisions.”[9][8] Ogawa (formerly Ms PD) v President of the Australian Human Rights Commission (Pseudonym) [2022] FCAFC 160 at [27], where it is said that “Considerations of embarrassment, convenience or personal sensitivity to the publication of personal and often very private circumstances given in evidence or revealed in the course of a proceeding in open court, of themselves, cannot justify or support the exercise of any inherent or implied power of a court to suppress or prohibit the publication of those matters.” See also Catena v Australian Securities and Investment Commission [2010] FCA 598 at [24].[9] Cat Media Pty Limited, Carotino (Australia) Pty Limited, Pharm-a-Care Laboratories Pty Ltd and Minister for Health and Aged Care [2022] AATA 1254 at [94]; Boardman and Secretary, Department of Social Services (Social services second review) [2021] AATA 3144; Re Sheepskin and Opal Exporters and Export Development Grants Board (1984) 6 ALD 594.Third, as submitted by the respondent, the mere potential for damage to the applicant's reputation and employment prospects alone is not a sufficient justification for the making of a non-publication order. In purportedly refuting this submission, the applicant referred to material suggesting that reputational harm can cause mental health issues, that unfair termination can be a breach of confidence and that embarrassment is an injury resulting from privacy violations.Essentially, the applicant appeared to be contending that the potential for reputational damage is of itself a sufficient justification for a non-publication order, given the nature of the harm that might be suffered by a person whose reputation is affected.I reject that contention. Indeed, reputational harm can be an inevitable consequence of open justice.[10] The risk of it, and how it might adversely affect a person’s prospects of being involved in a particular industry,[11] is usually insufficient justification for the making of a suppression or non-publication order.[12][10] Lee v Deputy Commissioner of Taxation [2023] FCAFC 22 at [90], where it is said that the “…fact that a person will suffer reputational or commercial harm from publication of evidence relied upon in open court does not have the necessary consequence that the proper administration of justice is or will be prejudiced. Such harm can be an inevitable part of open justice.” In KPTT v Commissioner of Taxation [2021] FCA 464 at [7], it was said that “parties must accept the damage to their reputation, and the possibility of consequential loss, which may be inherent in being involved in litigation”.[11] Catena v Australian Securities and Investment Commission [2010] FCA 598 at [24].[12] Poidevin and Australian Securities and Investments Commission [2018] AATA 124 at [17], where it is said that “Reputational damage will generally not be enough and it is for the applicant to satisfy the Tribunal that there should be a departure from the ‘norm’”. In Panganiban v Australian Securities & Investments Commission [2016] AATA 703 at [12], SM Taylor stated that “…mere apprehension about the potential for reputational harm directly resulting from the reviewable decision will usually not provide a persuasive basis for restricting the publicity of review proceedings.”Fourth, while the grant of a prohibition or suppression order is not precluded by the fact that the decision in this case and the reasons for it have been in the public domain for some time (and were in the public domain for more than a month before the applicant sought a non-publication order), that fact does weigh against such a grant.[13][13] De Pyle v Commonwealth [2023] FCA 597 at [29], where it was said that the information the publication of which was sought to be suppressed “…had been in the public domain for almost one month before the application was foreshadowed and it must be reasonably supposed that any confidentiality has been lost once and for all.” See also Ogawa (formerly Ms PD) v President of the Australian Human Rights Commission (Pseudonym) [2022] FCAFC 160 at [37]-[38].DecisionThe applicant has applied to the Tribunal for “…a suppression or non-publication order to stop my records of the case… from being published anywhere on your website or any accessible for public viewing” and for “…the removal of my files from your database.”Insofar as it has power to make a decision with respect to those applications, the Tribunal refuses to grant them.In particular, the Tribunal refuses to grant a suppression or non-publication order with respect to its decision, and the reasons for its decision, in this proceeding. I certify that the preceding 27 (twenty-seven) paragraphs are a true copy of the reasons for the decision herein of Senior Member C. J. Furnell ............................[SGD]............................................AssociateDated: 28 August 2023 Interlocutory hearing: On the papers Applicant: Self-represented Solicitors for the Respondent: HWL Ebsworth Lawyers

Evidence

Evidence Before The Court

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Decision

Reasons for decision

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Ratio Decidendi

Legal Principle Established

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