RRS Holdings Aust Pty Ltd v Cumberland Council

[2023] NSWLEC 1627

Land and Environment Court

New South Wales

Medium Neutral Citation:

RRS Holdings Aust Pty Ltd v Cumberland Council [2023] NSWLEC 1627

Hearing dates:

Conciliation conference 19 July, 14 September 2023

Date of orders:

24 October 2023

Decision date:

24 October 2023

Jurisdiction:

Class 1

Before:

Dickson C

Decision:

The Court orders that:

(1) The Applicant is to pay the Respondent’s costs thrown away as a result of the amendment of the application for development consent pursuant to s 8.15(3) of the Environmental Planning and Assessment Act 1979 in the amount of $4,000 within 28 days.

(2) The appeal is upheld.

(3) Development application DA2022/0643 for the demolition of existing structures and construction of a mixed use development comprising of an eighty (80) place child care centre, four (4) residential apartments for National Disability Insurance Scheme rental and an indoor recreation facility (swimming pool/school) at 31 Mary Street, Lidcombe NSW 2141, is determined by the grant of development consent subject to the conditions in the annexure marked A.

Catchwords:

DEVELOPMENT APPLICATION – construction of a mixed use development – conciliation conference – amended plans and documents – agreement between the parties – orders made.

Legislation Cited:

Cumberland Local Environmental Plan 2021, cll 2.7, 4.3, 4.4, 4.6, 5.21, 6.1, 6.2, 6.4, 6.7

Education and Care Services National Regulations 2011, regs 107, 108

Environmental Planning and Assessment Act 1979, ss 4.15, 8.7

Environmental Planning and Assessment Regulation 2021, ss 23, 29

Fisheries Management Act 1994

Land and Environment Court Act 1979, s 34

State Environment Planning Policy (Building Sustainability Index: BASIX) 2004

State Environmental Planning Policy (Biodiversity and Conservation) 2021, ss 6.5, 6.6, 6.7, 6.8, 6.9, 6.10, 6.11, 6.12, 6.13, 6.14 6.65

State Environmental Planning Policy (Resilience and Hazards) 2021, s 4.6

State Environmental Planning Policy (Transport and Infrastructure) 2021, ss 3.3, 3.22, 3.23, 3.26

State Environmental Planning Policy No 65 – Design Quality of Residential Apartment Development, cll 4, 30

Water Management Act 2000

Cases Cited:

Initial Action Pty Ltd v Woollahra Municipal Council (2018) 236 LGERA 256; [2018] NSWLEC 118.

RebelMH Neutral Bay Pty Ltd v North Sydney Council [2019] NSWCA 130

Texts Cited:

Department of Planning, Industry and Environment, Child Care Planning Guideline, September 2021

NSW Department of Planning and Environment, Apartment Design Guide, July 2015

Category:

Principal judgment

Parties:

RRS Holdings Aust Pty Ltd (Applicant)
Cumberland Council (Respondent)

Representation:

Counsel:
J Farrell (Applicant)
C McFadzean (Solicitor) (Respondent)

Solicitors:
Fortis Law (Applicant)
Cumberland Council (Respondent)

File Number(s):

2023/37161

Publication restriction:

No

JUDGMENT

1. COMMISSIONER This appeal is brought pursuant to s 8.7(1) of the Environmental Planning and Assessment Act 1979 (the EPA Act). The Applicant appeals the deemed refusal of their development application DA2022/0643 by the Respondent Cumberland Council. The development application, as amended, seeks consent for the demolition of existing structures and construction of a mixed use development comprising of an 80 place child care centre, 4 residential apartments for National Disability Insurance Scheme rental and an indoor recreation facility (swimming pool/school). The development is proposed at 31 Mary Street, Lidcombe (Lot 1 in DP 12000).

2. A conciliation conference was held between the parties pursuant to s 34 of the Land and Environment Court Act 1979 (LEC Act) on 19 July 2023. I presided over the conciliation conference. Following the conciliation, the parties continued discussions and reached an agreement based on amended plans and documents. The parties’ agreement is for the grant of consent to the application, as amended, subject to the conditions in Annexure A.

3. As the presiding Commissioner, I am satisfied that the decision is one that the Court could have made in the proper exercise of its functions (this being the test applied by s 34(3) of the LEC Act). I form this state of satisfaction on the basis that:

1. The development application was lodged on 6 December 2022, as such the Environmental Planning and Assessment Regulation 2021 (EPA Regulation) applies. The development application was lodged with the consent of the owner of the land satisfying s 23 of the EPA Regulation.

2. The development application was notified from 12 to 26 January 2023. Three letters of objection were received in response to the notification of the development application. As required by s 4.15(1)(d) of the EPA Act, I am satisfied that the issues raised have been considered by the parties and where appropriate are addressed in either amendments to the development application or conditions of consent.

3. The amended development application is accompanied by a BASIX certificate, complying with the requirements of State Environment Planning Policy (Building Sustainability Index: BASIX) 2004.

4. State Environmental Planning Policy No 65 – Design Quality of Residential Apartment Development (SEPP 65) applies as the development application comprises, in part, a residential flat building: cl 4(1) SEPP 65. The amended development application is accompanied by a statement that confirms that:

1. first, the qualified designer designed or directed the design of the development; and

2. second how the design quality principles are achieved;

3. finally, how the objectives in Parts 3 and 4 of the Apartment Design Guide (ADG) have been achieved. The statement satisfies s 29 of the EPA Regulation.

5. Further, as required by cl 30(2) of SEPP 65 I am satisfied that the proposed development demonstrates that adequate regard has been given to the design quality principles, and the objectives specified in the ADG for the relevant design criteria. On the basis of the architect’s statement demonstrating how the objectives of Parts 3 and 4 of the ADG have been achieved, I am satisfied that adequate regard has been given to the ADG.

6. Section 4.6(1) of State Environmental Planning Policy (Resilience and Hazards) 2021 (SEPP RH) precludes the granting of development consent unless the consent authority has considered whether the land is contaminated. The development application is accompanied by a Preliminary Site Investigation, a Detailed Site Investigation and a Remedial Action Plan (RAP) which detail the management and remediation of the site. The site investigations and the RAP conclude that the site can be made suitable for the proposed development and intended use of the site subject to the implementation and completion of the measures outlined in the RAP. Compliance with these documents is included in the conditions of consent. The parties agree, and I accept, that the Court can be satisfied that the RAP and the consent conditions together establish that the site will be suitable, post remediation, for the proposed uses pursuant to s 4.6(1) of SEPP RH.

7. Chapter 6 of State Environmental Planning Policy (Biodiversity and Conservation) 2021 (SEPP BC) applies as the site is located within the Sydney Harbour Catchment. The Development Application was lodged under the provisions of the SEPP BC, as they applied on 6 December 2022. At that time, Ch 6 of the SEPP BC contained provisions relating to the Sydney Harbour Catchment. Those provisions continue to apply: s 6.65 SEPP BC. In relation to the provisions of Chapter 6, I find as follows:

1. The site is not mapped by Council as being susceptible to the probable maximum flood event and is not identified in an environmental planning instrument as flood liable land: s 6.5 of SEPP BC

2. In relation to s 6.6(1) ‘Water quality and quantity’ of SEPP BC:

• subsection (a) does not apply by virtue of s 6.6(3) as the site is located within the Sydney Drinking Water Catchment.

• the development will not have an adverse impact on water flow in a natural waterbody,

• the development will not increase the amount of stormwater run-off from the site.

• the development does not require on-site stormwater retention, infiltration or reuse.

• the development will have no impact on the level and quality of the water table.

• cumulative environmental impacts of the development on the regulated catchment are negligible.

• the development has no impact on the quality and quantity of ground water.

3. In relation to s 6.6(2) ‘Water quality and quantity’ of SEPP BC I am satisfied, firstly, that subs (a) does not apply by virtue of s 6.6(3) as the site is located within the Sydney Drinking Water Catchment. Secondly that the effect of the development on the quality of water entering a natural waterbody will be as close as possible to neutral or beneficial.

4. In relation to the matters for consideration at s 6.7(1) Aquatic Ecology:

• to the extent of any direct, indirect or cumulative adverse impact on terrestrial, aquatic, or migratory animals or vegetation, the impact is minor and not determinative of the application.

• the development does not involve the clearing of riparian vegetation.

• the development will not involve sedimentation of a natural waterbody or erosion of land abutting a natural waterway.

• the development will not have an adverse impact on wetlands.

• the development will not impact aquatic ecology and therefore does not require safeguards and rehabilitation measures.

• the development does not adjoin a natural waterbody.

5. In considering the preceding matters, I accept the agreed position of the parties that I can be satisfied of the matters at s 6.7(2) Aquatic Ecology as:

• any direct, indirect or cumulative adverse impact on terrestrial, aquatic or migratory animals or vegetation will be kept to the minimum necessary for the carrying out of the development,

• the development will not have a direct, indirect or cumulative adverse impact on aquatic reserves,

• an approval under the Water Management Act 2000 and a permit under the Fisheries Management Act 1994 are not required,

• the erosion of land abutting a natural waterbody or the sedimentation of a natural waterbody will be minimised,

• there will be no adverse impact on wetlands.

6. Pursuant to s 6.8 Flooding, consistent with the findings at [19], I have considered the likely impact of the development on periodic flooding that benefits wetlands and other riverine ecosystems. I am satisfied that likely impacts of the development on periodic flooding that benefits wetlands and other riverine ecosystems are negligible to non-existent and satisfactory.

7. Pursuant to s 6.9, Recreation and Public Access, in determining the development application I have given consideration to the matters listed at subs (1) and I accept the agreed position of the parties that I can be satisfied that:

• the development has no impact on public access to and from natural waterbodies for recreational purposes.

• the development does not involve new or existing points of public access to natural waterbodies.

• the land does not form part of a foreshore of a natural waterbody.

8. I accept that there is no likely adverse environmental impact to downstream local government areas: s 6.10 Total Catchment Management. Finally, the site is not within 100m of a natural waterbody (s 6.11), is not within a riverine scenic area (s 6.12), a Hawkesbury-Nepean conservation area sub-catchment (s 6.13) and Sydney Drinking Water Catchment (s 6.60) and does not involve temporary use of land (s 6.14).

8. The proposed development relates, amongst other things, to a centre-based child care facility under s 3.3 of State Environmental Planning Policy (Transport and Infrastructure) 2021 (SEPP TI). Part 3.3 of SEPP TI contains provisions which apply to centre based childcare facilities, in particular, ss 3.22 and 3.23.

9. Section 3.22(2) of SEPP TI provides that the consent authority must not grant development consent to development to which this section applies except with the concurrence of the Regulatory Authority. Section 3.22(1) sets out the circumstances for when the section applies as follows:

(1)   This section applies to development for the purpose of a centre-based child care facility if—

(a) the floor area of the building or place does not comply with regulation 107 (indoor unencumbered space requirements) of the Education and Care Services National Regulations, or

(b)  the outdoor space requirements for the building or place do not comply with regulation 108 (outdoor unencumbered space requirements) of those Regulations.

10. The development application demonstrates compliance with reg 107 of the Education and Care Services National Regulations 2011 (Education Regulations) in that the architectural plans indicate provision of space in excess of the required indoor space per child.

11. The development application demonstrates compliance with reg 108 of the Education Regulations in that the architectural plans indicate provision of space in excess of the required outdoor space per child. Thus, I am satisfied that as compliance with regs 107 and 108 has been achieved and s 3.22 of SEPP TI does not apply and therefore concurrence of the Regulatory Authority is not required.

12. Section 3.23 of SEPP TI provides that before determining a development application for development for the purpose of a centre-based childcare facility, the consent authority must take into consideration any applicable provisions of the Child Care Planning Guideline (the Guidelines), in relation to development. As the guidelines have been addressed in the Statement of Environmental Effects accompanying the development application, I can be satisfied the Guidelines have been considered.

13. The development application is compliant with the non discretionary development standards at s 3.26 of SEPP TI.

14. The Cumberland Local Environmental Plan 2021 (LEP 2021) is the relevant environmental planning instrument that applies to the site. The site is zoned R4 High Density Residential, and the proposed development is permitted with consent as follows:

1. The childcare centre is defined as a centre-based childcare facility

2. The residential apartments are defined as a residential flat building, and

3. The swimming pool is defined as a recreational facility (indoor).

15. In determining the development application I have given consideration to the objectives of the zone, which are:

•  To provide for the housing needs of the community within a high density residential environment.

•  To provide a variety of housing types within a high density residential environment.

•  To enable other land uses that provide facilities or services to meet the day to day needs of residents.

•  To ensure that non-residential land uses are located in a setting that minimises impacts on the amenity of a high density residential environment.

•  To encourage residential development that maintains the amenity of the surrounding area.

16. Demolition is permitted with consent pursuant to cl 2.7 of LEP 2021.

17. Pursuant to cl 4.3 ‘Height of Buildings’ in LEP 2021 the maximum height limit applicable to the site is 20m. The proposed development does not comply with this standard and relies on cl 4.6 of LEP 2021 to vary the height standard. The variation to the height standard is centred on the exceedance of the lift overrun and structures in the proposed roof top communal open space. The Applicant relies on a written request prepared by Think Planners dated August 2023 in support of the variation to the standard. The written request addresses the matters set out at cl 4.6(3) of LEP 2021 including having regard to the tests set out in Initial Action Pty Ltd v Woollahra Municipal Council (2018) 236 LGERA 256; [2018] NSWLEC 118.

1. Pursuant to cl 4.6(4)(a) of LEP 2021, the Court, in exercising the functions of the consent authority, must be satisfied of both of the matters in subcll 4.6(4)(a)(i) and (ii), being:

(i) the applicant’s written request has adequately addressed the matters required to be demonstrated by subclause (3), and

(ii) the proposed development will be in the public interest because it is consistent with the objectives of the particular standard and the objectives for development within the zone in which the development is proposed to be carried out …

2. Only if the requirements in subcll 4.6(3) and (4) are met will the power in subcl 4.6(2), to grant consent to development that contravenes the development standard, be enlivened: RebelMH Neutral Bay Pty Ltd v North Sydney Council [2019] NSWCA 130 per Preston CJ at [23].

3. I am satisfied, for the reasons outlined in the written request, that it is unreasonable and unnecessary to comply with the height control in the circumstances of this case as the objectives of the standard are met, notwithstanding the non-compliance. Further, I am satisfied that the grounds advanced in the written request are sufficient environmental planning grounds to justify contravening the development standard.

4. I am also satisfied that the proposed development will be in the public interest because it is consistent with the relevant objectives of the development standard and the objectives for development within the R4 High Density Residential Zone in which the development is proposed to be carried out.

5. Finally, I accept, after a consideration of the matters identified in cl 4.6(5) of LEP 2021, that the concurrence of the Planning Secretary is not required having regard to Planning Circular PS 20-002 dated 5 May 2020.

6. Having regard to all of the above matters I am satisfied that I should uphold the cl 4.6 variation request in relation to the maximum height standard in LEP 2021.

18. Pursuant to cl 4.4 Floor space ratio in LEP 2021 the site has a maximum floor space ratio of 2.0: 1. The development is compliant with this standard.

19. The site is identified as being in a flood prone area under cl 5.21 Flood Planning in LEP 2021 as it is affected by flooding in a 1% Annual Exceedance Probability (AEP) event. A Flood Impact Assessment report was prepared by Capital Engineering Consultants which considered flood behaviour and concluded that the impact of the proposed development on flood events was inconsequential. As required by cl 5.21(2) of LEP 2021, in granting consent I am satisfied the development:

1. is compatible with the flood function and behaviour on the land, and

2. will not adversely affect flood behaviour in a way that results in detrimental increases in the potential flood affectation of other development or properties, and

3. will not adversely affect the safe occupation and efficient evacuation of people or exceed the capacity of existing evacuation routes for the surrounding area in the event of a flood, and

4. incorporates appropriate measures to manage risk to life in the event of a flood, and

5. will not adversely affect the environment or cause avoidable erosion, siltation, destruction of riparian vegetation or a reduction in the stability of river banks or watercourses.

20. Pursuant to cl 6.1 of LEP 2021, the site is marked as class 5 land on the Acid Sulfate Soils Map. As the site is more than 500m from class 1, 2, 3 or 4 land and has its basement above 5 metres AHD, development consent is not required under cl 6.1.

21. Pursuant to cl 6.2 of LEP 2021, development consent is required for the proposed earthworks. In relation to required considerations at cl 6.2(3), I accept the agreed position of the parties that:

1. Disruption to and effects on drainage patterns and soil stability are appropriately managed by the development and are satisfactory.

2. The excavation is part of the proposed redevelopment of the site and will not of itself stymie the future use or redevelopment.

3. The quality of soil to be excavated is of de minimis importance and not of determinative weight. The development does not identify proposed fill.

4. Earthworks do not give rise to amenity impacts for adjoining properties.

5. The likelihood of disturbing relics is low.

6. The site is not proximate to a waterway, drinking water catchment of environmentally sensitive area. The prospect of any adverse impacts of the development can be managed by conditions, including the provision and maintenance of sediment and erosion control measures.

22. I am satisfied pursuant to cl 6.4 of LEP 2021 that essential services are provided to the site.

23. In relation to required considerations at cl 6.7(3) Stormwater in LEP 2021, I accept the agreed position of the parties that:

1. The proportion of water permeable surfaces is within reasonable expectations for this form of development.

2. An onsite stormwater retention system has not been provided and having regard to the nature of the development is not overly practicable and not assessed as being essential.

3. Adverse impacts of stormwater runoff on adjoining properties, native bushland and receiving waters, to the extent they arise, can be minimised and mitigated by conditions, including by the provision of sediment and erosion controls.

24. Further, in determining the development application I have given consideration to the matters listed at cl 5.21(3) of LEP 2021.

4. Having reached the state of satisfaction that the decision is one that the Court could make in the exercise of its functions, s 34(3)(a) of the LEC Act requires me to “dispose of the proceedings in accordance with the decision”. The LEC Act also requires me to “set out in writing the terms of the decision” (s 34(3)(b)).

5. In making the orders to give effect to the agreement between the parties, the parties have not raised, and I am not aware of any jurisdictional impediment to the making of these orders. Further, I was not required to make, and have not made, any assessment of the merits of the development application against the discretionary matters that arise pursuant to an assessment under s 4.15 of the EPA Act.

6. The Court notes that:

1. Cumberland Council has approved the amendment to the development application pursuant to s 37 of the Environmental Planning and Assessment Regulation 2021 as set out below:

Architectural
Site Context	0.1	Advanced Architecture & Construction	C	Aug 2023
Demolition Plan	1.1	Advanced Architecture & Construction	C	Aug 2023
Site Plan/Site Analysis	1.2	Advanced Architecture & Construction	C	Aug 2023
Second Basement	2.1	Advanced Architecture & Construction	C	Aug 2023
First Basement Plan	2.2	Advanced Architecture & Construction	C	Aug 2023
Ground & First Floor Plan and Recommendations	3.1	Advanced Architecture & Construction	C	Aug 2023
Second Floor Plan	3.2	Advanced Architecture & Construction	C	Aug 2023
Third Floor Plan	3.3	Advanced Architecture & Construction	C	Aug 2023
Fourth Floor Plan	3.4	Advanced Architecture & Construction	C	Aug 2023
Fifth Floor Plan	3.5	Advanced Architecture & Construction	C	Aug 2023
Roof Level	3.6	Advanced Architecture & Construction	C	Aug 2023
Roof Plan	3.7	Advanced Architecture & Construction	C	Aug 2023
Gross Floor Area Calculation	3.8	Advanced Architecture & Construction	C	Aug 2023
Elevations	4.1	Advanced Architecture & Construction	C	Aug 2023
Elevations 2	4.2	Advanced Architecture & Construction	C	Aug 2023
Sections	4.3	Advanced Architecture & Construction	C	Aug 2023
Driveway Cross-Section	4.4	Advanced Architecture & Construction	C	Aug 2023
3D Perspectives	4.5	Advanced Architecture & Construction	C	Aug 2023
Streetscape Elevation	4.6	Advanced Architecture & Construction	C	Aug 2023
Shadow Diagrams	5.1	Advanced Architecture & Construction	C	Aug 2023
Landscape
Landscape Concept Plan	1-4	Vision Dynamics	G	16 Aug 2023
Landscape Concept Plan	2-4	Vision Dynamics	G	16 Aug 2023
Landscape Concept Plan	3-4	Vision Dynamics	G	16 Aug 2023
Landscape Concept Plan	4-4	Vision Dynamics	G	16 Aug 2023
Stormwater
Cover Sheet	SW001	CEC	G	21 Aug 2023
Basement Level 2 Plan, Notes & Details	SW010	CEC	G	21 Aug 2023
Basement Level 1 Plan, Notes & Details	SW011	CEC	G	21 Aug 2023
Ground Floor Plan, Notes & Details	SW020	CEC	G	21 Aug 2023
On-Site Detention Section & Details	SW021	CEC	G	21 Aug 2023
OSD Catchment Plan	SW022	CEC	G	21 Aug 2023
Erosion & Sediment Control Plan, Notes & Details	ER001	CEC	G	21 Aug 2023
Drains	-	CEC	-	-
Mechanical
Equipment Selection	M01	RMJ Engineering	2	18 Aug 2023
Basement 2	M02	RMJ Engineering	2	18 Aug 2023
Basement 1	M03	RMJ Engineering	2	18 Aug 2023
Ground Floor	M04	RMJ Engineering	2	18 Aug 2023
First Floor	M05	RMJ Engineering	2	18 Aug 2023
Second Floor	M06	RMJ Engineering	2	18 Aug 2023
Third Floor	M07	RMJ Engineering	2	18 Aug 2023
Forth Floor	M08	RMJ Engineering	2	18 Aug 2023
Fifth Floor	M09	RMJ Engineering	2	18 Aug 2023
Roof	M10	RMJ Engineering	2	18 Aug 2023
Evacuation
Second Basement	-	SPS	-	22 Aug 2023
First Basement	-	SPS	-	22 Aug 2023
Ground Floor	-	SPS	-	22 Aug 2023
First Floor	-	SPS	-	22 Aug 2023
Second Floor	-	SPS	-	22 Aug 2023
Third Floor	-	SPS	-	22 Aug 2023
Fourth Floor	-	SPS	-	22 Aug 2023
Fifth Floor	-	SPS	-	22 Aug 2023
Roof Floor	-	SPS	-	22 Aug 2023
Traffic
Concept Layout - Ground		Stanbury Traffic Planning	01	17 Aug 2023
Concept Layout - Basement 1		Stanbury Traffic Planning	02	17 Aug 2023
Concept Layout - Basement 2		Stanbury Traffic Planning	03	17 Aug 2023
Swept Path Assessment - Ground		Stanbury Traffic Planning	04	17 Aug 2023
Swept Path Assessment - Basement 1		Stanbury Traffic Planning	05	17 Aug 2023
Swept Path Assessment -Basement 1		Stanbury Traffic Planning	06	17 Aug 2023
Swept Path Assessment -Basement 1		Stanbury Traffic Planning	07	17 Aug 2023
Swept Path Assessment - Basement 2		Stanbury Traffic Planning	08	17 Aug 2023
Swept Path Assessment - Basement 2		Stanbury Traffic Planning	09	17 Aug 2023
Swept Path Assessment - Basement 2		Stanbury Traffic Planning	10	17 Aug 2023
Traffic Response to SOFAC		Stanbury Traffic Planning	-	18 Jul 2023
Plan of Management Proposed Child Care Centre		Early Education Solutions	11	17 Aug 2023
Noise Impact Assessment		Rodney Stevens Acoustics	6	21 Aug 2023
Clause 4.6 Variation		Think Planners	-	21 Aug 2023
Supplementary Statement of Environment Effects		Think Planners	-	21 Aug 2023
Plan of Management – Recreational Facility (Swimming Pool)		Think Planners	-	24 Aug 2023
Flood Impact Assessment Report		CEC	C	22 Aug 2023
Memorandum of Advice		Jeremy Farrell	-	24 Aug 2023
Mechanical Design Intent Certification		RMJ Engineering	2	17 Aug 2023
Letter of Response		CEC	02	4 Sep 2023
Arboricultural Impact Assessment of Lilly Pilly Hedge		Arboreport	-	12 Apr 2023

2. The amended development application was filed with the Court on 14 September 2023.

7. The Court orders that:

1. The Applicant is to pay the Respondent’s costs thrown away as a result of the amendment of the application for development consent pursuant to s 8.15(3) of the Environmental Planning and Assessment Act 1979 in the amount of $4,000 within 28 days.

2. The appeal is upheld.

3. Development application DA2022/0643 for the demolition of existing structures and construction of a mixed use development comprising of an eighty (80) place child care centre, four (4) residential apartments for National Disability Insurance Scheme rental and an indoor recreation facility (swimming pool/school) at 31 Mary Street, Lidcombe NSW 2141, is determined by the grant of development consent subject to the conditions in the annexure marked A.

D Dickson

Commissioner of the Court

**********

Annexure A

Decision last updated: 24 October 2023