Strange and Secretary, Department of Employment and Workplace Relations
[2006] AATA 239
•23 January 2006
Administrative
Appeals
Tribunal
DECISION AND REASONS FOR DECISION [2006] AATA 239
ADMINISTRATIVE APPEALS TRIBUNAL )
) No Q2005/688
GENERAL ADMINISTRATIVE DIVISION ) Re GAYE STRANGE Applicant
And
SECRETARY, DEPARTMENT OF EMPLOYMENT AND WORKPLACE RELATIONS
Respondent
DECISION
Tribunal Mr S C Fisher, Member Date23 January 2006
PlaceBrisbane
Decision The Tribunal affirms the decision under review.
....................Sgn......................
Member
CATCHWORDS
SOCIAL SECURITY – disability support pension – increase in assets – share in property – notification of change in circumstances – income and assets review – overpayment
Social Security Act 1991 ss 1223, 1236, 1237, 1237A, 1237AAD
Collins v Minister for Immigration and Ethnic Affairs (1981) 36 ALR 598
Dranichnikov v Centrelink (2003) 75 ALD 134
Beadle v Director-General of Social Security (1985) 60 ALR 225
Secretary, Department of Social Security (1998) 153 ALR 259
Re Gerhardt and Department of Employment, Education and Training (AAT 10941, 17 May 1996)
March v E & MH Stramare Pty Ltd (1991) 171 CLR 506
Groth v Department of Social Security (1995) 40 ALD 541WRITTEN REASONS FOR ORAL DECISION
14 March 2006 Mr S C Fisher, Member 1. This is a hearing involving Miss Gaye Strange as the applicant, and the Secretary of Department of Employment and Workplace Relations as respondent. At all material times, Miss Strange – I will refer to her as the applicant – was in receipt of a Disability Support Pension payable by the Department of Family and Community Services through its agent – if I can call it that – the Secretary, Department of Employment and Workplace Relations.
2. The applicant asked for the oral reasons for decision to be reduced to writing within the scope and effect of section 43(2A) of the Administrative Appeals Tribunal Act 1975. These Reasons for Decision are the reasons given orally at the 29 August 2005 hearing. They have been edited to correct minor errors only and do not incorporate any changes of substance. These Reasons for Decision reflect an extemporaneous account of the decision made on 23 January 2006, and do not have the benefit of considered post-hearing analysis and research of the facts, law and issues that a reserved decision would have.
3. The history of this matter is as follows: the applicant inherited a part share in three properties in Brisbane by way of an inheritance, and this, of course, ultimately had implications for the level of her Disability Support Pension (“DSP”). On 20 December 2002, the applicant advised Centrelink that the properties had been sold and that she had received an interim distribution of nearly $197,000. After a small amount of this was spent repaying a loan, the balance of $191,208 was deposited into a Commonwealth Bank Cash Management Account.
4. On the same day, Centrelink advised the applicant to notify Centrelink when the balance of the monies from the sale of the proceeds were paid to her, remembering, of course, that that was an interim distribution. On 20 December 2002, Centrelink also wrote to the applicant advising her that her pension was being calculated on the basis of total assets of an amount of about $205,000, and that particular advice contained the sentence: “Your DSP has been reduced because the value of your assets has increased”. That letter went on to notify the applicant of her responsibility or obligation to notify Centrelink within 14 days if the value of her financial investments went above a threshold of $192,529.
5. In July 2003, Centrelink undertook an income and assets review, and in that review form, the applicant properly disclosed that the balance of her Commonwealth Bank Cash Management Account was $262,718. After some correspondence between the applicant and the respondent about how this figure was comprised, on 27 August 2003, the applicant provided the respondent with bank statements spanning the period 18 January to 16 July of 2003.
6. Based on the increased asset level disclosed by the applicant, Centrelink raised a debt in an amount of $2402.98 on 24 February 2005, and the basis for the debt was that Centrelink had determined that because the asset levels of the applicant had increased, effectively, she had been overpaid DSP because they did not take into account her increased asset level during a “debt period” of 18 January to 12 August 2003 (for the sake of brevity I will refer to that period of time as the debt period in these reasons). Following internal and external review, the applicant applied to this Tribunal for review on 28 October 2005.
7. Now in terms of jurisdiction, in a procedural sense, this Tribunal has jurisdiction because of Part 4 Division 5 of the Social Security (Administration) Act 1999, but, in a substantive sense, the merits of the appeal are governed by the Social Security Act 1991.
8. I have already identified before the decision under review which, to encapsulate it again, is the decision made by the respondent on 24 February last year to raise and recover a DSP debt in an amount of $2402.98 spanning the debt period 18 January to 12 August 2003, and that decision had been affirmed by the Social Security Appeals Tribunal below on 19 October 2005.
9. In terms of the issues to be determined, they are as follows: the first is, in a factual sense, did the applicant notify the respondent about increases in her assets between 18 January and 12 August 2003? The second issue is, if you answer “yes” to that, did the applicant receive payments of DSP in good faith, which payment levels were not modified from the levels that were in place before 20 December 2002? And, if you answer no to that issue, should the debt be waived in reliance on Section 1237AAD or written off under Section 1236 of the Social Security Act, in short, the waiver provisions that were at issue in this case. In terms of the central issue in this case, it is a factual issue, and that is did the applicant notify the respondent about increases in her assets during the debt period?
10. I want to say something about the role of this Tribunal. The role of this Tribunal is to review the merits of decisions before it, and that is under Section 43 of the Administrative Appeals Tribunal Act 1975. The Tribunal is guided by the norm or standard that it should reach the correct or preferable decision on the basis of the material before it. The job of this Tribunal is to stand in the shoes of the original or substituted decision makers and to consider all evidence afresh, bearing in mind any relevant statutory provisions, such as the few I have referred to earlier, and any significant legal precedents.
11. The Tribunal must base its decision on the material that is logically probative of the existence of facts that emerge from the evidence before it, and in that regard, I refer to the decision in Collins v Minister for Immigration and Ethnic Affairs (1981) 36 ALR 598 at 601. Also equally importantly, this Tribunal does not have a general jurisdiction to circumvent, override, side-step, or supplant the otherwise very clear terms of legislation that determines the income support entitlements such as DSP; or to put it another way: we still have to follow the law and the precedents that the courts have set in order to properly apply the provisions before us.
12. The material before the Tribunal was as follows: exhibit 1 were the T documents; exhibit 2 was a Commonwealth Bank of Australia deposit receipt of 17 January 2003 recording a deposit of $39,407.87 to the credit of the applicant; exhibit 3 was a list of Centrelink file notes; exhibit 4 was Centrelink asset limit brochures;, and exhibit 5, was an annotated envelope to which was annexed a Centrelink letter of 7 October 2003 to the applicant. Exhibits 1 to 4 were lodged on behalf of the respondent, and exhibit 5 was lodged by the applicant.
13. In terms of the evidence it is as follows. The applicant gave evidence in person. The applicant represented herself. I accept that the applicant was honest and did her best to assist the Tribunal in reaching its decision. There was a single issue of credit in this appeal, namely whether the Tribunal accepted the version of the applicant that she notified the respondent about increases in her assets in the debt period which, to recap, was between 18 January and 12 August 2003. So that is the central issue of credit.
14. In terms of the evidence of the applicant to the Tribunal, I can summarise it in these terms. First, the applicant accepted that the summary of factual history contained in paragraphs 3 to 15 of the statement of facts and contentions lodged by the respondent was basically accurate. The applicant said that Centrelink made an administrative error in not recording the transactions involving two large deposits of money she received during the debt period. The applicant said that she went into Centrelink on or about 30 April 2003 in relation to the deposit of $58,560.97. The applicant said that she either showed a Centrelink officer, whom she identified as a male, a cheque for that sum, or a completed duly stamped deposit slip and she asked Centrelink to update her records.
15. The applicant said that the officer who handled that 30 April 2003 notification showed the document to another officer who was also a male, and placed it on a desk behind them without recording electronically or otherwise the relevant notification or giving her a photocopy of any document with a Centrelink stamp on it. The applicant said she did not diarise that particular event, because probably she did not see the need to at the time.
16. In cross-examination, the applicant denied that she was mistaken in believing she had notified Centrelink of the two additional deposits during the debt period, and she also denied during cross-examination of being confused about dates in terms of the notification. The applicant admitted in cross-examination that after July 2003, she had been diligent in notifying Centrelink of her bank balances, and in cross-examination, the applicant also explained that the $39,000 deposit represented the proceeds of a litigation settlement involving an action against a former solicitor related to the administration of her late father's estate.
17. The applicant said she could not recall if she notified Centrelink of bank balances. Now that is distinct from whether the applicant did or did not notify of the particular deposits, but the applicant said she did notify Centrelink of the deposits during the debt period.
18. The applicant said that she had auto-teller receipts relating to deposits and payments made because there was a lag in getting bank statements from the Commonwealth Bank, which would either issue them monthly or quarterly, depending on the relevant account.
19. In cross-examination, the applicant accepted she received a 20 December 2002 letter from the respondent, and that that letter stipulated the asset level in question that represented the top end of her entitlements before it would, in fact, affect her rate of DSP. The applicant said she did not always pay close attention to some other details of Centrelink letters, and that she did not monitor her bank balances in order to determine how that might affect the payment of DSP to her. To sum up her evidence, the applicant said that she told Centrelink "everything" about changes to her bank account balances. So that is the gist of the evidence from the applicant.
20. The respondent lodged documents T1 to T36 under section 37 of the Administrative Appeals Tribunal Act 1975, and I took those documents into evidence as exhibit 1. I note that the respondent was represented by Ms Sarah Oliver, a departmental advocate, and the respondent's advocate provided the statement of facts and contentions to the Tribunal.
21. The respondent called evidence from Mr Ian Edwards, a Centrelink officer with reception experience at the Toowong branch of Centrelink, and Mr Edwards gave evidence to the Tribunal by telephone, and the gist of his evidence was to the following effect: Mr Edwards described his experience as spanning four years at this particular Centrelink office where he said he had a lot of experience of the reception desk and area.
22. Secondly, Mr Edwards said that the standard invariable practice at the reception desk was that if a customer had to notify changes in circumstances, the reception officer dealing with that particular customer would always open up that customer's electronic record in order to make sure that they were dealing with the right person or the authorised nominee, and so that they would know how to deal with the subject matter of the change in circumstances notification by referring any documentation on to other areas of Centrelink for proper assistance. Mr Edwards then gave the illustration or example that if somebody was a DSP customer and they notified something, a record would be opened; it would be saved on the main frame system and that the relevant piece of paper, if there was one produced, would be put on the mail desk behind the reception area and that someone ultimately from “Disabilities” would go along to the mail desk, pick up the batch of documents that were there and go away and process them further, because the reception was really only a clearing house to get information and documents into the Centrelink system.
23. Mr Edwards said it was a management directive at his particular branch that the customer's electronic record must be accessed. Mr Edwards said that it was his standard practice, from which he did not depart, to access the electronic records of customers and that he would not have ever transacted any business on behalf of a customer without doing so.
24. In response to a question from myself, Mr Edwards conceded he did know of colleagues who would access electronic records for customers, but would not, at that time, record the transaction for which the customer came into Centrelink to report or tell about. Mr Edwards said he would never allow a gap in time to arise between accessing the electronic record and recording the transaction.
25. In response to questions from both the advocate for the respondent and from the Tribunal, Mr Edwards said that if a customer notified a change in circumstances involving an increased or changed bank balance, his practice was that he would photocopy any documentation produced; he would date stamp it with the office stamp, but he would only give a duplicate copy to the customer if the customer requested it, but he would always record the transaction in the electronic record, which he would have accessed once he dealt the customer.
26. Mr Edwards said that he was well aware that if a bank balance was being notified by a customer to Centrelink, it was important for that change to be notified and recorded properly because of the adverse financial consequences that would happen for a customer if there was no timely recording of that change in circumstances or other data.
27. Mr Edwards said, in response to a question from me, that the procedures he had outlined had been followed in 2003 during the debt period. Mr Edwards was questioned by the applicant in cross-examination about whether he had the relevant experience, or had he departed from those procedures. Mr Edwards said no, he had not departed from them, and that even though he had probably only had about one year's experience at the time the events surrounding the applicant took place, if he had any doubts about what to do, he would have checked with a supervisor - a reception team leader - and that person would have given him, or any other staff, appropriate guidance about what to do if there was any uncertainty. Mr Edwards said that even for an officer of his low Centrelink seniority in 2003, had he dealt with the applicant he would have documented the transactions; it would not have been too complicated for him.
28. I considered carefully all the documentary and oral evidence before me. I had regard to what the applicant said, what was said by Mr Edwards on the respondent's behalf, and also the documentary records before me.
29. In terms of discussing the evidence, I say this: essentially the reason for the debt against the applicant was because Centrelink maintained that she had not notified Centrelink of two key deposits during the debt period. I note that the respondent did not assert or allege that the applicant was dishonest in not notifying Centrelink of the deposits during the debt period. The respondent submitted that the applicant was mistaken in that regard, but certainly not dishonest. I accept that the applicant is an honest person who subjectively believes she has done everything she needed to in order to satisfy her notification obligations with Centrelink in order to discharge her share of mutual responsibilities relating to DSP.
30. I have no reason to discount anything that Mr Edwards said in evidence before me. Now what to make of all this? Well, I accept the evidence of the applicant in all respects except the issue of the notification of the two deposits during the debt period. I have evidence before me, which I accept, that the electronic records would have been accessed had someone in the position of the applicant presented to the reception area and said that she, or he for that matter, wanted to notify a change of circumstances.
31. The evidence in exhibits 1 and 2 show extensively the dealings between the parties before, during, and after the debt period. During the debt period, there is a conspicuous absence of contact by the applicant with the respondent, and certainly no contact relating to notification of these two particular deposits. I am talking about the accessing of the electronic records, which would have been a way of corroborating what the applicant said she did and said to the respondent.
32. Certainly after the debt period, there is an extensive record in the electronic registers of dealings between the applicant and the respondent, which showed that she certainly was making efforts to comply with her notification responsibilities to the respondent. But that, of course, was really after the end of the debt period, and in particular, leading up to the income and asset review conducted in July 2003.
33. In terms of what the applicant's submissions were, they were as follows: the first thing is the applicant said she had done everything she could to notify Centrelink of the deposits during the debt period. The applicant said that Centrelink made an error in her case, even if she could not get to the bottom of it, particularly having regard to and having heard Mr Edwards evidence. The applicant said she was not at fault in any respect, and the applicant asked for the debt to be waived by this Tribunal. The applicant submitted that being on DSP in and of itself is a special circumstance that justifies waiver.
34. The applicant complained about the delay in raising the debt, some 18 months after she produced her passport to Centrelink in order to comply with other responsibilities she had. The applicant also has some other legitimate concerns about aspects of the legal system, but they are not relevant to this appeal that I am deciding.
35. What did the respondent submit? The submissions for the respondent were as follows: firstly, that I should affirm the decision below. The respondent conceded and said quite categorically that the applicant was honest, but in this submission, the applicant was mistaken. The respondent contended that there was a debt owed by the applicant to the Commonwealth under section 1223(1) of the Social Security Act.
36. The respondent said there was no record of the applicant contacting the respondent between 21 December 2002 and 30 July 2003 to notify the respondent of bank account balances in order to calculate properly the level of DSP payable to the applicant. The respondent pointed to the state of the electronic records as indicating an absence of contact during the debt period. The respondent said that the evidence given by Mr Edwards indicated it was highly unlikely that a contact by a customer such as the applicant, who presented to Centrelink to report material changes such as changes to bank account balances, would not have caused a customer services officer to have not accessed the electronic record, and even if the processing of the transaction was done by another section, there would still be an electronic record of the initial contact made by that customer.
37. The respondent submitted that the applicant must have been mistaken in saying she had notified Centrelink of those two deposits or distribution she received in January and April 2003.
38. In terms of the substantive law, that really was not at issue, and the respondent cited various decisions on what good faith means, including Prince's case, Haggerty's case, Jazazievska's case, and Jonauskas' case, and I won't give the citations.
39. The respondent contended that when these decisions are properly applied and understood to the present case, it meant that good faith means that the person cannot turn a blind eye to circumstances in which he or she knows there is a doubt about the entitlement to a Disability Support Pension payment.
40. The respondent contended that when the applicant knew on 20 December 2002 that if her asset limit increased above the nominated amount of approximately $192,000, she subsequently had to notify Centrelink of any increase. The respondent said that the better view of the evidence was that the applicant did not so notify Centrelink, despite her protestations to the contrary, and the respondent said that the decision of the Full Court of the Federal Court in Dranichnikov v Centrelink (2003) 75 ALD 134, when properly understood and applied, reinforced the time-honoured formulation in Beadle v Director-General of Social Security (1985) 60 ALR 225 that special circumstances represent a range of circumstances in the case of a particular person, such as Miss Strange in the present case, which takes their case out of the ordinary run of cases. So you need something - although the words "uncommon," "exceptional" "unusual" are often used - you really had to have something that took this case out of the ordinary range of cases before the special circumstances waiver could be applied.
41. Based upon the evidence before me, I make the following findings of fact.
(a)The applicant in this case, Gaye Strange, is in receipt of DSP.
(b)The applicant received payments from the distribution of a deceased estate on 17 January 2003 and 30 April 2003, which caused her asset limits to exceed those previously maintained by Centrelink.
(c)There is insufficient evidence to conclude that the applicant notified Centrelink of the payments she received on 17 January and on 30 April 2003.
42. I want to give you my reasons, having sketched all the background. There is no contest that the legislation that applies is the Social Security Act 1991, and that the debt arose because of the operation of section 1223(1) of the Act. The critical issues really are whether there is really any basis for waiver of the debt of $2402.98.
43. A starting premise, according to the Federal Court in Secretary, Departrment of Social Security v Hales (1998) 153 ALR 259, is that if there is an overpayment of income support payments, taxpayers are entitled to expect that in the ordinary course those sort of payments will be recovered, and that is, of course, what the respondent did in this case, but recovery is not automatic. Whilst it is not automatic, certainly there are exceptions to it, and the main exception that we have seen regarding income support payments has to do with waiver.
44. Now waiver does not happen at large. It is very much conditioned or controlled by specific provisions to the Act, and I said earlier in my reasons that this Tribunal is under a duty to follow the law. We cannot depart from it, because that would, of itself, lead to improper and ineffective administration.
45. Section 1237 of the Act limits or signposts the circumstances under which waiver can take place, and in this case, waiver was considered under Section 1237A, which is administrative error waiver, or Section 1237AAD, which is special circumstances waiver, and particularly the applicant relied on both of those provisions.
46. The general waiver provision based on administrative error is Section 1237A, and essentially, without reading the detail of that provision out in all its gory detail, waiver must take place if an overpayment is attributable solely to an administrative error made by the Commonwealth, so long as the debtor also receives in good faith the payment or payments that give rise to that portion of the debt. And the way it has been interpreted by the courts and this Tribunal is that the administrative error must cause the overpayment, and there is no other causative factor, and, secondly, there has to be good faith receipt, and I note also that the six week limitation period, or certainly the entree rather, under Section 1237A(1A) doesn't apply in this case.
47. So just to sum that part of my decision up, the applicant would have had to satisfy me of two things. First, that the administrative error solely caused the overpayment, and, secondly, there was good faith receipt after that administrative error by Centrelink. Now in the decision of Re Gerhardt and Department of Employment, Education, and Training (AAT 10941, 17 May 1996), this Tribunal said that "solely" means you have to exclude everything else, so we can only take into account sole administrative error. If there was another operative reason that might lead to an overpayment, that has to be ignored, and, in fact, cannot be taken into account because of the way the legislation is set up.
48. Causation is always a question of fact, so it is not a complicated exercise. Causation is taken to be a commonsense notion; you don't have to get side-tracked into the philosophy at all, and the High Court reminded us of that in a range of decisions, including March v E & MH Stramare Pty Ltd (1991) 171 CLR 506. The evidence in this case, which I reviewed carefully, does not disclose that the respondent made an administrative error. That now certainly was the argument of the applicant, but when I look at the evidence that supports that contention, there is nothing before me to enable me to conclude that there was an administrative error.
49. I have heard evidence carefully from the applicant. I have heard evidence on behalf of the respondent as to what the applicant says took place and as to the normal procedures the respondent would have followed, and I simply cannot conclude on the state of the evidence before me that there was an administrative error that caused the overpayment and which properly activates the waiver machinery.
50. Now given that I cannot conclude that there was an administrative error, and I note again that the applicant said there was, but although I do not see any evidence of that - I am not satisfied that there is sufficient evidence of administrative error, it means that I do not really need to go on to consider the good faith receipt, because the two elements: administrative error and good faith receipt are cumulative. So if you do not satisfy administrative error, strictly speaking, I do not need to go on and consider good faith receipt, so I think in the interest of keeping my decision to an absolute bare minimum, I will not go into a consideration of good faith.
51. The other ground of excusal, for want of a better of word - or exception - that the applicant relied on was waiver under Section 1237AAD, which is special circumstances waiver. Essentially, a special circumstances waiver applies if this Tribunal is satisfied that (a) the applicant did not make a false statement or false representation, (b) that there are special circumstances other than financial hardship alone that justify or make waiver desirable, and (c) that it is more appropriate to waive than to write off.
52. The interpretation of debt waiver in income support law has been settled for a long, long, time. Waiver on the basis of special circumstances occurs according to the well-known understanding of special circumstances developed in Beadle's case, where special circumstances has been interpreted to mean those circumstances that are unusual, uncommon, or exceptional. Indeed, decisions of decision-makers, the Social Security Appeals Tribunal and this Tribunal, and also the Federal Court reiterate that the common thread to special circumstances is whether somebody's case, or somebody's circumstances take their circumstances out of the ordinary run of cases, and I am mindful that Kiefel J in Groth v Department of Social Security (1995) 40 ALD 541 reiterated the need to compare this case to the ordinary run of cases and see if there is a qualitative difference, and that is really my understanding or gloss.
53. I did carefully consider what the applicant said about waiver on the basis of special circumstances. The applicant argued that simply being on DSP was, of itself, sufficient to justify a waiver of the debt. Although she did not put it in quite these terms, the applicant pointed to various adverse life circumstances that she had suffered, and I don't need to go into those, to the extent they were talked about, in any great detail in this case.
54. Unfortunately, I do not agree with the applicant's contention that simply being on DSP, of itself, justifies waiver. The fact is that all income support recipients are under some form of financial disadvantage, or health disadvantage, or economic disadvantage. So that is the common base line to all Centrelink customers, and really, when you look at the intent and meaning of special circumstances waiver, you have to have somebody whose circumstances are quite bad compared to other income support recipients before we can properly activate the waiver rules.
55. I think that is consistent with what is required when you look at the proper meaning and intent of Section 1237AAD. In other words, simply being in receipt of a Centrelink payment is not a criterion of entitlement to waiver, and indeed, it is not an express element of waiver, in terms of the legislation in Section 1237AAD.
56. So I think, in this case, the evidence simply does not sustain a special circumstances waiver on the part of the applicant. I well recognise the applicant has suffered a series of adverse events in her life. She has suffered the death of her father, a divorce, and probably other things I am not really aware of, which make her feel that her position is out of the ordinary, but, as unfortunate as her circumstances are, in terms of my job as a review decision maker, I am not satisfied that we actually activate the threshold for special circumstances waiver.
57. So my conclusion then is that the correct or preferable decision is that the debt in an amount of $2402.98 was properly raised by the respondent against the applicant and that there are insufficient grounds to justify a waiver or write-off. Accordingly, my decision is that the decision below should be affirmed.
58. I just want to make a couple of observations for the benefit of the parties, in particular, the applicant. The first thing is the applicant may ask for these oral reasons for decision to be reduced to writing, and I think you need to apply within 28 days if you want to get what I have said in a formal written format. The second thing is if you are not happy with this decision, then you can ask not only for a written version of these reasons, but then you can decide whether or not to appeal to the Federal Court of Australia on a question of law using the machinery provided by Section 44 of the Administrative Appeals Tribunal Act 1975.
59. I might just make one further observation. In keeping with the respondent, I accept that the applicant is an honest person. I would conclude that, probably for reasons of mistake, or some other form of oversight, there is no evidence that allows me to conclude that the applicant notified the two deposits that took her asset level over what she had previously notified. I accept that the applicant subjectively believes that she did in fact notify, but there was no objective evidence, no CRAM reports, no electronic records, and as I have indicated, the evidence of the procedures suggests that these records would invariably be generated.
60. So I am unable to agree with the contention of the applicant that she did notify, and that, essentially, is the reason why I have made the decision I have.
I certify that the 60 preceding paragraphs are a true copy of the reasons for the decision herein of Mr SC Fisher, Member
Signed: Mr Robert Hayes
AssociateDate of Hearing 23 January 2006
Date of Oral Decision 23 January 2006
Date of Written Reasons 14 March 2006
The Applicant was unrepresented
For the Respondent Ms S Oliver, Departmental Advocate
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