REAL ESTATE AND BUSINESS AGENTS SUPERVISORY BOARD and KAMIL
[2008] WASAT 189
•22 AUGUST 2008
REAL ESTATE AND BUSINESS AGENTS SUPERVISORY BOARD and KAMIL [2008] WASAT 189
| STATE ADMINISTRATIVE TRIBUNAL | Citation No: | [2008] WASAT 189 | |
| REAL ESTATE AND BUSINESS AGENTS ACT 1978 (WA) | |||
| Case No: | VR:110/2008 | 14 AUGUST 2008 | |
| Coram: | JUSTICE M L BARKER (PRESIDENT) MR D LIGGINS (SENIOR SESSIONAL MEMBER) MS V O'TOOLE (SENIOR SESSIONAL MEMBER) | 22/08/08 | |
| 16 | Judgment Part: | 1 of 1 | |
| Result: | Proper cause for disciplinary action found Respondent unfit to hold a certificate of registration Certificate of registration cancelled Respondent disqualified from holding certificate of registration for 10 years Respondent to pay Board's costs | ||
| B | |||
| PDF Version |
| Parties: | REAL ESTATE AND BUSINESS AGENTS SUPERVISORY BOARD AHMED EDDIE KAMIL |
Catchwords: | Vocational Regulation Real estate agent Fraud Forgery Breaches of the Code of Conduct Unfit to hold a certificate of registration Penalty Disqualification from holding a certificate of registration |
Legislation: | Criminal Code Act Compilation Act 1913 (WA), s 409, s 473 Real Estate and Business Agents Act 1978 (WA), s 29, s 31, s 103(4)(c)(iii), s 103(4)(d) |
Case References: | Banning v Wakka [2007] WADC 17 Grljusich v Andrews [2003] WASCA 206 Jemelita v Medical Board of Western Australia (unreported, WASC, Library No 920584, 13 November 1992, per Owen J) NSW Bar Association v Evatt (1968) 117 CLR 177 Real Estate and Business Agents Supervisory Board v Landa [2008] WASAT 114 |
Orders | 1. As of the date of this order, Ahmed Eddie Kamil's certificate of registration as a Real Estate and Business Sales Representative (no 31707) is cancelled and Ahmed Eddie Kamil is disqualified from holding such a certificate of registration for a period of ten years.,2. Ahmed Eddie Kamil is to return his certificate of registration to the Board forthwith.,3. Ahmed Eddie Kamil is to pay the costs of the Board in bringing and maintaining this application in the sum to be agreed by the parties or, in the absence of agreement, to be fixed by the President of the Tribunal. |
Summary | The Real Estate and Business Agents Supervisory Board commenced disciplinary proceedings in the Tribunal alleging that there was proper cause for disciplinary action against the respondent due to a number of breaches of the Code of Conduct for Agents and Sales Representatives, and that he was unfit to hold a certificate of registration.,The agent admitted the allegations.,At a hearing on the issue of penalty, the Tribunal considered its disciplinary powers, including the power to permanently disqualify the agent from holding a certificate of registration. ,The Tribunal considered that the appropriate penalty was cancellation of the respondent's certificate of registration and disqualification from being registered as a sales representative or agent for a period of 10 years. |
JURISDICTION : STATE ADMINISTRATIVE TRIBUNAL STREAM : VOCATIONAL REGULATION ACT : REAL ESTATE AND BUSINESS AGENTS ACT 1978 (WA) CITATION : REAL ESTATE AND BUSINESS AGENTS SUPERVISORY BOARD and KAMIL [2008] WASAT 189 MEMBER : JUSTICE M L BARKER (PRESIDENT)
- MR D LIGGINS (SENIOR SESSIONAL MEMBER)
MS V O'TOOLE (SENIOR SESSIONAL MEMBER)
- Applicant
AND
AHMED EDDIE KAMIL
Respondent
Catchwords:
Vocational Regulation - Real estate agent - Fraud - Forgery - Breaches of the Code of Conduct - Unfit to hold a certificate of registration - Penalty - Disqualification from holding a certificate of registration
(Page 2)
Legislation:
Criminal Code Act Compilation Act 1913 (WA), s 409, s 473
Real Estate and Business Agents Act 1978 (WA), s 29, s 31, s 103(4)(c)(iii), s 103(4)(d)
Result:
Proper cause for disciplinary action found
Respondent unfit to hold a certificate of registration
Certificate of registration cancelled
Respondent disqualified from holding certificate of registration for 10 years
Respondent to pay Board's costs
Category: B
Representation:
Counsel:
Applicant : Julia King
Respondent : Self-represented
Solicitors:
Applicant : Julia King
Respondent : Self-represented
Case(s) referred to in decision(s):
Banning v Wakka [2007] WADC 17
Grljusich v Andrews [2003] WASCA 206
Jemelita v Medical Board of Western Australia (unreported, WASC, Library No 920584, 13 November 1992, per Owen J)
NSW Bar Association v Evatt (1968) 117 CLR 177
Real Estate and Business Agents Supervisory Board v Landa [2008] WASAT 114
(Page 3)
Summary of Tribunal's decision
1 The Real Estate and Business Agents Supervisory Board commenced disciplinary proceedings in the Tribunal alleging that there was proper cause for disciplinary action against the respondent due to a number of breaches of the Code of Conduct for Agents and Sales Representatives, and that he was unfit to hold a certificate of registration.
2 The agent admitted the allegations.
3 At a hearing on the issue of penalty, the Tribunal considered its disciplinary powers, including the power to permanently disqualify the agent from holding a certificate of registration.
4 The Tribunal considered that the appropriate penalty was cancellation of the respondent's certificate of registration and disqualification from being registered as a sales representative or agent for a period of 10 years.
Issue
5 The Real Estate and Business Agents Supervisory Board (Board) made a number of allegations against Ahmed Eddie Kamil (respondent), which he agreed with, to the following effect:
• That there is proper cause for disciplinary action against him pursuant to s 103(4)(c)(iii) of the Real Estate and Business Agents Act 1978 (WA) (REBA Act) in relation to his misconduct in relation to a real estate transaction.
• That there is proper cause for disciplinary action against him pursuant to s 103(4)(d) of the REBA Act in that cause exists that he is unfit to hold a certificate of registration.
6 The sole issue at the hearing of this proceeding was as to the appropriate penalty that should be imposed on the respondent.
Orders made 14 August 2008
7 On 14 August 2008, the Tribunal, after considering written and oral submissions made by counsel for the Board and by the respondent, decided that it was appropriate for the respondent's certificate of registration to be cancelled
(Page 4)
- and for him to be disqualified from holding a certificate of registration for a period of ten years.
8 The Tribunal indicated written reasons would be provided in due course. These are those written reasons.
Agreed facts
9 The Board supported its application for disciplinary orders to be made against the respondent with a statement of facts, which were agreed by the respondent in writing and orally before the Tribunal at the hearing. The statement of facts provided, in substance, as follows.
10 At all material times the respondent:
• Was registered as a real estate and business sales representative under the REBA Act;
• Held a certificate of registration as a real estate and business sales representative (no 31707) which expires on 26 February 2009;
• Was employed by Eftos Group Pty Ltd trading as Eftos Estates (Eftos) as a real estate and business sales representative acting as a sales representative.
11 At all material times the Eftos Group Pty Ltd:
• Conducted a real estate agency business under the name of Eftos Estate and conducted that business at 220 Carr Place, Leederville, Western Australia;
• Held a real estate and business agent's licence 47726 first granted on 14 March 2003 pursuant to s 29 of the REBA Act;
• Held triennial certificate no 47726 granted pursuant to s 31 of the REBA Act which expires on 13 March 2009.
12 On 1 September 2004, the owner of Lot 32, 333 Charles Street, North Perth entered into a 'Selling Agency Agreement Residential: Exclusive Agency' (agreement) with Eftos for the sale of the property.
13 Under the terms of the agreement, Eftos had exclusive selling rights for the property until 17 August 2005.
(Page 5)
14 The property is comprised of a number of residential units, including Unit 7.
15 On 9 December 2005, an offer was made for Unit 7 in the name of a real person, who for present purposes may simply be referred to as Ms L.
16 The offer included information and contained terms, including the following:
• The purchaser's address in South Perth;
• The purchase price was $313,000;
• A deposit of $500.00 was to be paid within 10 days of acceptance to be held by Eftos as stakeholder;
• The offer was conditional upon finance being obtained in the sum of $250,000 from National Australia Bank within 30 working days of acceptance; and
• West End Settlements were nominated to be the purchaser's representative.
17 The respondent presented the offer to the owners of the property.
18 The owners of the property accepted the offer on 10 January 2006 and settlement on the contract took place on 23 June 2006.
19 On and between the date of the offer and the date of settlement, without the knowledge or consent of Ms L, the respondent:
• Drafted the offer in the name of Ms L;
• Applied a signature that appeared to be the signature of Ms L (signature) to the offer and then himself signed as a witness to the signature;
• Applied the signature to various annexures, attachments, plans, diagrams and documents comprising and attached to the offer;
• On or about 11 January 2006, prepared a standard form 'Settlement Instruction Sheet' that included an instruction that all correspondence for the purchaser, Ms L, was to be sent to 220 Carr Place, Leederville, being the respondent's workplace at Eftos;
(Page 6)
- • Drafted and sent a letter dated 17 January 2006 to West End Settlements enclosing the contract and the instructions;
• Received and retained a letter dated 27 January 2006 sent from West End Settlements to Ms L;
• Paid the $500.00 deposit on the contract to Eftos;
• On 22 February 2006 received a facsimile transmission from the owner of Unit 7 advising that the contact was terminated given that finance approval had not been provided;
• In or about February 2006, drafted a 'waiver of finance' letter dated 21 February 2006 from Ms L to himself (waiver letter);
• Applied the signature to the waiver letter and then himself signed that letter as a witness;
• On or about 23 February 2006, sent the waiver letter to West End Settlements;
• On or about 24 February 2006 sent the waiver letter to the owners of Unit 7 and further advised that it had been received from Ms L within the time allowed under the contract;
• From time to time spoke with West End Settlement staff representing that he was receiving instructions from Ms L;
• In or about March 2006, occupied Unit 7 without the owner's knowledge or consent until he vacated at the owner's direction on 25 March 2006;
• On 13 March 2006, corresponded with West End Settlements in relation to settlement;
• In or about May 2006, applied the signature to;
- Form 1 - Appointment of Settlement Agent for Buyer, and dated it 27 June 2006;
- - A form - 'Identification of Certificate of Title for Buyer';
- A form 'Certification/identification of Strata Plan 47665/Lot 7'; and
- A form 'Identification of Notification of J693409'.
- • On or about 27 May 2006, sent those documents to West End Settlements;
• Applied the signature to the Transfer of Land for Unit 7, at the same time obtaining a witness to the signature, and thereafter forwarded the transfer to West End Settlements;
• In or about June 2006, drafted a letter from Ms L to himself requesting the keys to Unit 7 at settlement;
• On or about 20 June 2006, sent that request to West End Settlements; and
• On or about 21 June 2006 caused the sum of $323,554.37 to be forwarded to West End Settlements for the purposes of settlement.
20 At or about settlement, without the knowledge or consent of Ms L:
• Ms L was registered on the title as the owner of Unit 7;
• The respondent received the federal first home owners grant in the sum of $7,000, having applied for the grant in the name of Ms L; and
• The respondent received the first home owners rate of stamp duty and obtained a relief having applied to the Commissioner of State Revenue for that relief in the name of Ms L.
21 At and after settlement, without the knowledge or consent of Ms L, the respondent:
• Obtained the keys to and took possession of Unit 7; and
(Page 8)
- • On or about 26 June 2006, received and retained a letter from West End Settlements to Ms L, which letter included a refund cheque for $977.67 payable to Ms L.
22 The Western Australian Police Service (Major Fraud Squad) subsequently laid the charges identified below in relation to various of the material facts as follows:
• As to documents identified in paragraphs above, offences of forging and uttering pursuant to s 473(1)(a) and s 473(1)(b) of the Criminal Code Act Compilation Act 1913 (WA) (Criminal Code); and
• As to other matters, offences of obtaining a benefit by deceit pursuant to s 409(1)(c) and s 409(1)(f) of the Criminal Code.
23 The charges against the respondent, more particularly, are that the respondent:
• With intent to defraud, forged a record, namely the contract of the sale of land or strata title by offer and acceptance in the name of Ms L;
• With intent to defraud, uttered a forged record, namely a contract for sale of land by offer and acceptance for property in the name of Ms L to the Proud Property Group Pty Ltd;
• With intent to defraud, forged a record, namely a transfer of land document for Lot 7 on Strata Plan 47665 in the name of Ms L;
• With intent to defraud, uttered a forged record, namely a transfer of land document for Lot 7 on Strata Plan 47665 in the name of Ms L to the Department of Land Information;
• With intent to defraud, forged a record, namely a letter dated 21 February 2006, allegedly written by Ms L;
• With intent to defraud, uttered a forged record, namely a letter dated 21 February 2006, allegedly written by Ms L to Proud Property Group;
(Page 9)
- • With intent to defraud, by deceit, induced Kenneth Wayne McFarlane of Proud Property Group to do and act, namely offer for sale the property situated at Lot 7, 333 Charles Street, North Perth, that Kenneth Wayne McFarlane of Proud Property Group was lawfully entitled to do;
• With intent to defraud by deceit gained a benefit, namely a first home owners grant of $7,000; and
• With intent to defraud by deceit gained a benefit, namely a reduction of stamp duty on a first home owners grant property, valued at $3,034.00.
24 The respondent plead guilty to the above charges and the criminal proceedings were listed for a pre-sentence report in the District Court on 15 August 2008.
Respondent's explanation for conduct
25 In a written submission to the Tribunal the respondent set out a number of matters he considered relevant to penalty.
26 At the hearing in relation to penalty, which the respondent attended by telephone due to illness, the respondent also indicated that he had initially put a proposal to the owner of the property to put the purchased property in his own name, which proposal was rejected. He said it was only following a rejection and a deterioration in the relationship between him and Mr McFarlane that he took these steps to acquire the property in the name of Ms L.
27 In the submission of the respondent, the respondent considered that he should be subject to a penalty whereby he was prevented from working as a sales representative for 12 months.
28 The respondent made the following points;
• He did not jeopardise the vendors sale price - the vendor received the sale price he was seeking. The position of the vendor had not changed. The vendor still had not paid the respondent's previous employer or the respondent any of the commissions for 16 units that were otherwise sold;
(Page 10)
- • He did not put Ms L through any form of hardship. Her position or circumstances have not changed. (It seems that, at material times, Ms L and the respondent were in a relationship);
• The first home owners grant has been paid back plus penalty;
• The respondent does believe that he should be punished for the things he has done wrong however, the following matters have occurred as a result of his actions:
- His former partner has stopped him from having any contact with his son;
- His current relationship has ended because of the pressure it has brought on the relationship;
- He has been receiving counselling for 15 months to help him through these circumstances. He has felt guilty since it happened and this has created a lot of internal pressure which he is slowly working through;
- He has a sentencing trial on 15 August 2008 and he awaits his fate there; and
- He fears he may go to prison;
• All this has been a great lesson for him. He has learned a lot and will never put himself through this sort of thing again. Everyone in life goes through a bad patch now and then and sometimes steps over the line. Everybody deserves a second chance. The community would not need to be worried about his actions in the future. It will never happen again;
• Once he has been counselled through his actions he believes that, in light of his 16 years in real estate, he can come back and work in the industry and prove himself as a worthy representative or licensee. He believes that the penalty after all this has occurred should be no more than 12 months restriction from practice.
(Page 11)
Board's submissions
29 The Board notes that between 9 December 2005 until in or about June 2006 the respondent:
• Used another person's name to purchase property without the other person's knowledge or consent;
• Forged the other person's signature as required throughout the purchase and settlement of the transaction;
• Gained a benefit of the first home owners grant of $7,000 and a reduction in stamp duty valued at $3,034 by fraud; and
• Misled or deceived the owners as to the identity of the purchaser of the property.
30 The Board says that on or about 21 - 24 February 2006 the respondent falsely represented to the owners that finance approval had been received within the time under the contract for the purchase of the property.
31 The Board says that it is clear that the misconduct of the respondent can be couched in a number of different ways. The first set of allegations of the Board (set out in full in paragraph 1 and paragraph 2 of the application) reflect part of the misconduct of the respondent in the property transaction. The further allegation (set out in full in paragraph 3 of the application) adheres that the respondent is unfit to hold a certificate of registration. The Board says this unfitness results from the entirety of the respondent's misconduct in the property transaction. The Board submits that in determining the disciplinary outcome, the Tribunal shall have regard to whether the disciplinary outcome is appropriate in all of the circumstances: Real Estate and Business Agents Supervisory Board v Landa [2008] WASAT 114 at [154].
32 The Board submits that it is well established that powers of this kind exercised by the Tribunal under the REBA Act are entirely protective, and notwithstanding that the exercise may involve a great deprivation of the person disciplined, there is no element of punishment involved: NSW Bar Association v Evatt (1968) 117 CLR 177. As well as the protection of the public, sanctions in vocational matters serve to maintain a high standard and good reputation of a profession generally in the eyes of the community. It is also necessary to deter others who may be of a like mind
(Page 12)
- to transgress in the future: Jemelita v Medical Board of Western Australia (unreported, WASC, Library No 920584, 13 November 1992, per Owen J)
33 The Board made the point that honesty and trustworthiness are the stock in trade of licensed real estate agents and sales representatives under the REBA Act. The conduct of the respondent in respect of the property transaction represents serious deficiencies in his standards of conduct which the applicant submits makes him unfit to be registered as a sales representative.
34 The Board says where it has been demonstrated that a person is presently unfit to be licensed or registered for a relevant vocation, if the public is to be protected, then disqualification is the obvious and necessary sanction: Grljusich v Andrews [2003] WASCA 206, at [154] (Grljusich).
35 The Board says once determination has been made to cancel a relevant licence or registration, the question arises as to the extent of disqualification that may be necessary, that is, whether a disqualification must be permanent or for some lesser period.
36 The Board points out that in Grljusich, the Full Court varied a permanent disqualification made by the Board to one of disqualification for a period of five years. In that case, the agent had on three occasions diverted commissions due to his principal totalling $4,750.
37 In Banning v Wakka [2007] WADC 17 (Banning) the permanent disqualification of an agent was varied on appeal to disqualification for seven and a half years. In that case the agent was found to have been a party to re-documentation of various transactions at prices that were falsely inflated by $300,000. The object of the false representation was to ensure that the parties were able to obtain sufficient finance to allow the transactions to be completed. This decision is currently on appeal by both parties.
38 The Board submits that the seriousness of the conduct of the respondent in this case is more significant than that of the respondents in Grljusich and Banning. To take just one example, the respondent in this case, motivated by self-interest, intentionally misled and deceived the owners of the property throughout the property transaction. The conduct in this case was not primarily directed at deceiving his employer, as in Grljusich, or the finance providers as in Banning, but was designed to deceive the client of the employer. The Board says it is primarily the
(Page 13)
- protection of the public that the REBA Act seeks to achieve. It should also be noted that through the respondent's fraudulent conduct he attempted to gain various financial benefits including the increase in value of the property, the first home owners grant and a reduction in stamp duty.
39 The Board also note that the respondent has a previous disciplinary history from 1999. The respondent then pleaded guilty to breaches the Code of Conduct for Agents and Sales Representatives as a result of which he was suspended from registration for three months and ordered to pay $250 costs. The findings concerned representations made to purchasers regarding a bore and electrical wiring on a property.
40 The Board also seeks an order for costs in these proceedings against the respondent.
Tribunal's decision on penalty
41 The Tribunal having read the written submissions of the parties and having heard from the parties or their representatives orally at the final hearing, decided that the appropriate penalty in this case was cancellation of the respondent's certificate of registration and disqualification from being registered as a sales representative or agent for a period of 10 years.
42 The Tribunal accepts the primary submissions of the Board concerning the significant departure from professional conduct expected of a sales representative in this case.
43 The explanation by the respondent for his conduct given to the Tribunal at the hearing is specious. It was, however, not really offered by the respondent as an excuse for his conduct. He simply explained that he had tried to negotiate to purchase Unit 7 from the owner of the property at an earlier stage. The information concerning those negotiations, however, suggest that the respondent proposed the purchase of the property at a low price. The owners were advised by their accountants that the proposal might involve a failure to meet GST requirements. The owner did not proceed with negotiations, but for one reason or another, according to the respondent, differences arose between the representative of the owner and himself. As a result of this the respondent then developed the ruse of buying the property under a different name, details of which have been set out above.
44 The fact that, for whatever reason, the respondent decided to engage in a ruse to purchase the property and keep the true facts and circumstances from the owner, is utterly inimical to the obligations that the respondent has as a
(Page 14)
- sales representative to his employer's clients.
45 For that reason there is no doubt the respondent should have findings made against him that there is a proper cause for disciplinary action pursuant to s 103(4)(c)(iii) of the REBA Act and there should also be a finding against him that there is proper cause for disciplinary action pursuant to s 103(4)(d) of the REBA Act in that he is not fit to hold a certificate of registration.
46 The finding that the respondent is unfit to hold a certificate of registration is also bolstered by the related conduct of the respondent that he made false representations to persons other than the owner of the property, namely, the authorities concerning the payment of the first home owners grant and reduction of stamp duty. The conduct of the respondent at all material times is properly described as fraudulent. He has plead guilty to the charges listed above in the District Court of Western Australia brought against him under the Criminal Code.
47 The question in this case is whether the respondent should be permanently disqualified from holding a sales representative licence, or whether some long term disqualification from being registered should be imposed.
48 The guiding consideration in a case such as this, as the Board submits by reference to authority, is the proper protection of the public. What then is required in order to uphold professional standards and give the public confidence that persons they deal with as real estate agents or representatives will comply with the legal and ethical obligations imposed on them?
49 In Grljusich, the Full Court of the Supreme Court found that, in the circumstances of that case, a penalty of the permanent disqualification of an agent was a manifestly excessive penalty.
50 Ultimately the Full Court in Grljusich concluded at [162]:
In our view, the nature and extent of the appellant's misconduct revealed by the inquiry before the Board, taken with the findings of untruthfulness concerning his evidence before the Board, as we have said, require that his current registration be cancelled. However, this misconduct does not involve such a breach of public trust that it should be thought the appellant is incapable of reestablishing himself over a period of time. The many professional and character references supplied to the Board strongly support the view that the appellant is, indeed, capable of re-establishing himself over a period of time.
(Page 15)
51 In the present case, the Tribunal considers that the misconduct revealed does not suggest that the appellant is totally incapable of re-establishing himself over a period of time. This is due to his age and apparent level of experience in the industry.
52 However, the Tribunal considers that the period of time over which the respondent should have the opportunity of re-establishing himself needs to be lengthy and for that reason the Tribunal considers that disqualification for a period of 10 years is appropriate. In this period the respondent will not be entitled to practise in any form under the REBA Act as a real estate agent or a sales representative.
53 A disqualification of 10 years carries with it the clear message to all persons within the industry that fraudulent misconduct of the kind involved in this case, notwithstanding the fact that it may be argued that the owner of the property did not suffer any apparent financial loss, will result in a heavy disciplinary penalty being imposed.
Conclusion and Orders
54 For these reasons, on 14 August 2008, following submissions by the parties, the Tribunal made the following findings and orders:
The Tribunal finds and the parties agree:
A. There is proper cause for disciplinary action against Ahmed Eddie Kamil pursuant to s 103(4)(c)(iii) of the Real Estate and Business Agents Act 1978 (Act) in that from on or about 9 December 2005 until about June 2006, by failing to advise the owners of the property that he was the actual purchaser of that property, Ahmed Eddie Kamil:
(a) knowingly mislead or deceived a party in a transaction contrary to article 5(2) of the Code of Conduct for Agents and Sales Representatives (Code);
(b) failed to act fairly and honestly contrary to article 5(1) of the Code;
(c) continued to act where to do so would place his interest in conflict with that of his principal contrary to article 10(1) of the Code; and
(d) indirectly purchased an interest in real estate which he was engaged to sell, without obtaining the prior written consent of his principal, contrary to article 10(2) of the Code.
B. There is proper cause for disciplinary action against Ahmed Eddie Kamil pursuant to s 103(4)(d) of the Act in that he is unfit to hold a certificate of registration.
(Page 16)
The Tribunal orders:
1. As of the date of this order, Ahmed Eddie Kamil's certificate of registration as a Real Estate and Business Sales Representative (no 31707) is cancelled and Ahmed Eddie Kamil is disqualified from holding such a certificate of registration for a period of ten years.
2. Ahmed Eddie Kamil is to return his certificate of registration to the Board forthwith.
3. Ahmed Eddie Kamil is to pay the costs of the Board in bringing and maintaining this application in the sum to be agreed by the parties or, in the absence of agreement, to be fixed by the President of the Tribunal.
I certify that this and the preceding [54] paragraphs comprise the reasons for decision of the State Administrative Tribunal.
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JUSTICE M L BARKER, PRESIDENT
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