NSW Civil and Administrative Tribunal
New South Wales
- Amendment notes
Medium Neutral Citation: NSM [2020] NSWCATGD 84 Hearing dates: 04 August 2020 Date of orders: 04 August 2020 Decision date: 04 August 2020 Jurisdiction: Guardianship Division Before: C P Fougere, Principal Member Decision: The guardianship order for NSM made on 1 August 2019 has been reviewed. The order now is as follows:
1. The Public Guardian is appointed as the guardian.
2. This is a continuing guardianship order for a period of two years from 4 August 2020.
3. This is a limited guardianship order giving the guardian(s) custody of NSM to the extent necessary to carry out the functions below.
FUNCTIONS:
4. The guardian has the following functions:
a) Access
To decide what access NSM has to others and the conditions of access.
b) Accommodation
To decide where NSM may reside.
c) Health care
To decide what health care NSM may receive.
d) Medical/Dental consent
To make substitute decisions about proposed minor or major medical or dental treatment, where NSM is not capable of giving a valid consent.
CONDITION:
5. The condition of this order is:
a) Standard Condition
In exercising this role the guardian shall take all reasonable steps to bring NSM to an understanding of the issues and to obtain and consider their views before making significant decisions.
Catchwords: GUARDIANSHIP – review of guardianship order – permanent resident of aged care facility – unsupported allegations of neglect and abuse by Public Guardian – concerns over separation of subject person and spouse – service needs met by aged care facility – suitability of proposed guardian – supporting material not received – no evidence on ability to meet statutory criteria – family conflict – separate representative and family member oppose proposed guardian – Public Guardian reappointed
PROCEDURE – rejection of adjournment request – guiding principle in Tribunal proceedings – non-compliance with evidence timetable – hearing proceeded in absence of certain evidence – reasonable opportunity to be heard – limits on presentation time of parties – unsupported allegations of actual bias of Tribunal Member – no evidence to support recusal
Legislation Cited: Civil and Administrative Tribunal Act 2013 (NSW), ss 36, 36(1), 38, 38(5)(c), 38(6)(a)-(c)
Guardianship Act 1987 (NSW), ss 3(1)-(2), 4, 4(a)-(e), 4(g), 14, 14(1)-(2), 14(2)(a)(i), 15(3), 16(3), 17(1), 17(1)(a)-(c), 25(2)(a)-(b), 25C, Pt 5
Cases Cited: Chi v Roger Fuller Pty Limited [2018] NSWCATAP 95
Michael Wilson & Partners Limited v Nicholls & Others [2011] HCA 48; 244 CLR 427
P v NSW Trustee and Guardian [2015] NSWSC 579
Reid v Commercial Club (Albury) Ltd [2014] NSWCA 98
Texts Cited: NSW Civil and Administrative Tribunal, Message from the President, “Temporary changes to NCAT operations”, 10 July 2020, accessed 3 November 2021
Category: Principal judgment Parties: 007: Review of Guardianship Order
NSM (the person)
Public Guardian (appointed guardian)
BYM (joined…
Continue reading NSM
Sign in free to access the full text
- AGLC
- NSM [2020] NSWCATGD 84
- Case
- [2020] NSWCATGD 84
- Decision Date
CaseChat Overview and Summary
The court had to determine whether the Public Guardian should continue as the guardian of NSM, given the allegations and the evidence presented. The court also had to assess the appropriateness of the adjournment request and whether the evidence timetable was adhered to. The court needed to consider the claims of actual bias against a Tribunal member, which were ultimately unsupported. The court was required to weigh the evidence on the ability of the proposed guardian to meet statutory criteria and the impact of family conflict on the decision-making process.
In its reasoning, the court noted that the allegations of neglect and abuse were unsupported and that the aged care facility was meeting NSM's service needs. The court also found that the proposed guardian was suitable for the role, despite opposition from a separate representative and a family member. The court rejected the adjournment request, emphasising the importance of compliance with the evidence timetable in Tribunal proceedings. The court found that the hearing could proceed in the absence of certain evidence, as long as parties had a reasonable opportunity to be heard within the limits of presentation time. The unsupported allegations of actual bias against a Tribunal member were dismissed due to a lack of evidence. Consequently, the Public Guardian was reappointed as the guardian of NSM, with a continuing guardianship order for two years, including specific functions and conditions.
The final order appointed the Public Guardian as NSM's guardian, with a limited guardianship order for two years. The guardian was granted functions related to access, accommodation, health care, and medical/dental consent. The condition of the order required the guardian to take reasonable steps to ensure NSM understood the issues and considered their views before making significant decisions.
Orders
Orders of the court
The guardianship order for NSM made on 1 August 2019 has been reviewed. The order now is as follows:
1. The Public Guardian is appointed as the guardian.
2. This is a continuing guardianship order for a period of two years from 4 August 2020.
3. This is a limited guardianship order giving the guardian(s) custody of NSM to the extent necessary to carry out the functions below.
FUNCTIONS:
4. The guardian has the following functions:
a) Access
To decide what access NSM has to others and the conditions of access.
b) Accommodation
To decide where NSM may reside.
c) Health care
To decide what health care NSM may receive.
d) Medical/Dental consent
To make substitute decisions about proposed minor or major medical or dental treatment, where NSM is not capable of giving a valid consent.
CONDITION:
5. The condition of this order is:
a) Standard Condition
In exercising this role the guardian shall take all reasonable steps to bring NSM to an understanding of the issues and to obtain and consider their views before making significant decisions.
Background
Background to the litigation
Full text does not contain this section.
Evidence
Evidence Before The Court
Full text does not contain this section.
Decision
Reasons for decision
Full text does not contain this section.
Ratio Decidendi
Legal Principle Established
Full text does not contain this section.