Tarlka Matuwa Piarku Aboriginal Corporation RNTBC v Rachlan Holdings Pty Ltd
[2019] NNTTA 52
•16 July 2019
NATIONAL NATIVE TITLE TRIBUNAL
Tarlka Matuwa Piarku Aboriginal Corporation RNTBC v Rachlan Holdings Pty Ltd and Another [2019] NNTTA 52 (16 July 2019)
Application No: | WO2018/0268 |
IN THE MATTER of the Native Title Act 1993 (Cth)
- and -
IN THE MATTER of an inquiry into an expedited procedure objection application
Tarlka Matuwa Piarku Aboriginal Corporation RNTBC (WCD2013/004)
(native title party)
- and -
Rachlan Holdings Pty Ltd
(grantee party)
- and -
State of Western Australia
(Government party)
DETERMINATION THAT THE ACT IS NOT AN ACT ATTRACTING THE EXPEDITED PROCEDURE
Tribunal: | Ms H Shurven |
Place: | Perth |
Date: | 16 July 2019 |
Catchwords: | Native title – future act – proposed grant of exploration licence – expedited procedure objection application – whether act likely to interfere directly with the carrying on of community or social activities – whether act likely to interfere with sites or areas of particular significance – whether act likely to involve major disturbance to land or waters – expedited procedure – non-disclosure directions – the act is not an act attracting the expedited procedure |
Legislation: | Native Title Act 1993 (Cth) ss 151, 237 |
Cases: | Albert Little & Ors v Lake Moore Gypsum Pty Ltd [2012] NNTTA 56 (Little v Lake Moore Gypsum) Champion v Western Australia and Another [2005] NNTTA 1; (2005) 190 FLR 362 (Champion v Western Australia) Cheinmora v Striker Resources NL [1996] FCA 1147; (1996) 142 ALR 21 (Cheinmora v Striker Resources) Daisy Lungunan and Others on behalf of Nyikina and Mangala/ Western Australia/Geotech International Pty Ltd [2012] NNTTA 24 (Lungunan v Geotech International) Harvey Murray on behalf of the Yilka Native Title Claimants/Western Australia/Drew Griffin Money [2011] NNTTA 91 (Murray v Money) Silver v Northern Territory [2002] NNNTA 18; (2002) 169 FLR 1 (Silver v Northern Territory) Tarlka Matuwa Piarku Aboriginal Corporation RNTBC v Rachlan Holdings Pty Ltd and Another [2018] NNTTA 72 (TMPAC v Rachlan Holdings) Walley v Western Australia [2002] NNTTA 24; (2002) 169 FLR 437 (Walley v Western Australia) Ward v Western Australia [1996] FCA 1452; (1996) 69 FCR 208 (Ward v Western Australia) Western Australia v Smith [2000] NNTTA 239; (2000) 163 FLR 32 (Western Australia v Smith) Western Australia/Winnie McHenry on behalf of the Noongar People [1999] NNTTA 210 (Western Australia v McHenry) WF (Deceased) on behalf of the Wiluna People v State of Western Australia [2013] FCA 755 (Wiluna v Western Australia) Yindjibarndi Aboriginal Corporation RNTBC v FMG Pilbara Pty Ltd and Another [2014] NNTTA 8 (Yindjibarndi v FMG Pilbara) Young v Western Australia (2001) 164 FLR 1; [2001] NNTTA 42 (Young v Western Australia) |
| Representative of the native title party: | Ms Sally Raine, Fremantle Law Pty Ltd |
| Representative of the grantee party: | Mr Rhys Davies, DLA Piper Australia |
| Representatives of the Government party: | Mr Tom Ledger, State Solicitor’s Office |
REASONS FOR DETERMINATION
[1] The State of Western Australia gave notice under s 29 of the Native Title Act 1993 (Cth) (the Act) of its intention to grant exploration licence E69/3528 to Rachlan Holdings Pty Ltd (Rachlan Holdings). The notice included a statement that the grant of the licence is an act attracting the expedited procedure (see s 32 of the Act). This is a decision about whether the expedited procedure applies to the proposed grant of E69/3528 (the licence).
[2] To decide whether or not the licence should be granted under the expedited procedure, I must examine the criteria in s 237 of the Act. The issues I need to determine in relation to these criteria are, in summary:
a.(a) is the grant of the licence likely to interfere directly with community or social activities carried on by members of the native title claimants or native title holders?
b.(b) is the grant of the licence likely to interfere with areas or sites of particular significance in accordance with the traditions of the native title claimants or holders?
c.(c) is the grant of the licence likely to involve, or create rights whose exercise is likely to involve, major disturbance to the land or waters concerned?
d.[3] The licence covers approximately 339.49 square kilometres in the Shire of Wiluna. A large portion of the licence is located on Lake Nabberu, particularly the western area of the licence, and the lake is the focal point of much of the material provided in this inquiry.
e.[4] The Tarlka Matuwa Piarku Aboriginal Corporation (TMPAC) hold native title rights and interests in the whole of E69/3528, on behalf of members of the Wiluna and Tarlpa native title holders. The determination of native title was made by the Federal Court in Wiluna v Western Australia. I note, based on evidence presented in this inquiry, those determined native title claims share many of the same members, who identify as Martu People, belonging to a Western Desert Cultural Bloc. The evidence provided in this matter refers to the native title holders at various points as the Wiluna People, Tarlpa People, and Martu People.
f.[5] TMPAC exercised their right to lodge an objection against the State’s assertion that the expedited procedure applies to the grant of licence, and argue the expedited procedure should not apply, as interference or disturbance with one or more of the criteria in s 237 of the Act is likely. Rachlan Holdings and the State argue the expedited procedure should apply.
g.[6] In determining whether the expedited procedure applies or not, I must make a predictive assessment (see FMG v Yindjibarndi at [39]). I must look at what is likely to occur as a result of the grant and decide whether there is real chance or risk of interference. I must have regard to the rights conferred by the grant of the licence, the nature of the proposed grant, and the applicable regulatory regime (see Walley v Western Australia at [8]-[9]).
h.[7] If I find the expedited procedure applies, the licence can be granted without parties being required to negotiate with each other. If I find it does not apply, Rachlan Holdings and the State must negotiate in good faith with a view to reaching an agreement with TMPAC about the proposed grant of the licence. In this inquiry, I have concluded the expedited procedure should not apply.
Preliminary matters
TMPAC material
Non-disclosure directions
a.[8] TMPAC applied for non-disclosure directions under s 155 of the Act in relation to some of this material. I was satisfied the material is sensitive and gender restricted. I made directions restricting parties’ use of that information, following consultation and submissions from all parties on the nature and extent of those directions. The directions were cast so that I was able to read and consider all of the materials. While I have considered that evidence, I refer to it specifically in this decision only to the extent I need to make my reasons clear, given the cultural sensitivities.
Material provided for previous Tribunal inquiries, for use in the present inquiry
a.[9] TMPAC provided a statement of contentions, and rely on material that it lodged in support of its expedited procedure objections to the grant of exploration licences E69/3487 and E69/3494 (see TMPAC v Rachlan Holdings). Both licences in that matter overlapped Lake Nabberu, as does the licence in this current inquiry. The licence in this current inquiry is at the eastern end of Lake Nabberu and the licences from the previous inquiry were at the western end of the lake.
b.[10] That previous material on which TMPAC seek to rely comprises statements of evidence made by Dr Lee Sackett, Mr Geoffrey Stewart and Mr Paul Morgan, and a map of sites and areas of particular significance within the Wiluna v Western Australia determination and the licence areas. Mr Stewart and Mr Morgan are senior native title holders and knowledge holders for Lake Nabberu. Dr Sackett is an anthropologist who outlines his qualifications and experience working with the native title holders.
Other material provided for the present inquiry
a.[11] TMPAC also rely on a statement of evidence made for this present inquiry by Mr Victor Ashwin and maps depicting the exploration licences from TMPAC v RachlanHoldings respective to the licence in this current inquiry. Mr Ashwin is a native title holder and knowledge holder from Wiluna. I accept Mr Ashwin’s authority to speak about the licence area.
Accepting statements and material from previous inquiries
a.[12] Throughout their materials, the State and Rachlan Holdings argue I should give Dr Sackett’s evidence little weight, largely because they assert the statements of Mr Stewart and Mr Morgan do not explain why any relevant places are of more than ordinary significance in accordance with their laws and customs, and so the explanations provided by Dr Sackett are of limited value. I adopt my findings in TMPAC v Rachlan Holdings (at [9] – [14]) where I accepted and gave appropriate weight to Dr Sackett’s opinion and evidence regarding Lake Nabberu and the issues of significance and interference. I believe Dr Sackett’s statement to be an impartial assessment of the questions he was asked to address, and that he has outlined the grounds upon which he relied to provide his views.
a.[13] Similarly, I accept the statements of Mr Stewart and Mr Morgan relate to the licence area in this current inquiry because they both address the significance of Lake Nabberu to the native title holders, and the proposed licence in this current inquiry is located largely on Lake Nabberu. Mr Ashwin (at 6) says the statements by Mr Morgan and Mr Stewart are ‘wholly relevant and applicable’ to the land subject of the licence area E69/3528. I accept TMPAC’s explanation of why these statements are ‘wholly relevant and applicable’ is that those statements concern the significance of Lake Nabberu to the native title holders. That is, the significance of the geographical feature known as Lake Nabberu to the native title holders.
b.[14] In TMPAC v Rachlan Holdings Mr Morgan and Mr Stewart provided details of the creation of Lake Nabberu in the Dreaming which I do not repeat here due to cultural sensitivities. TMPAC state the accounts appear to, in parts, have their differences to which Dr Sackett provides information to reconcile these differences. TMPAC say Dr Sackett does not express an opinion that one account is wrong and the other is right. Based on his work in the area dating back to 1974, Dr Sackett expresses (at 18) that Mr Stewart’s account is ‘the more rounded and complete of the two’. TMPAC contend Mr Stewart’s account can be understood as ‘being more complete’ as his account covers an area much larger than the licence areas, and the difference between the statements is ‘in their scope, the details related and the details emphasised’.
c.[15] I accept this explanation, and that evidence provided by Indigenous witnesses can differ in part, depending on which areas of country can be spoken for by each person, and their respective traditional rights, responsibilities and knowledge. I do not find the evidence of Mr Stewart and Mr Morgan contradictory – rather, I find both statements cogent and clear in their description of the relevant areas and why those areas are important or of significance to the native title holders. I also accept Mr Ashwin’s evidence in this matter for the same reason.
Considering the argument the licence area is ‘site rich’
a.[16] In an exchange between TMPAC and Rachlan Holdings from 17 to 21 May 2019, it is TMPAC’s submission that there have been numerous cases where, despite the acceptance of a presumption of regularity that a grantee will comply with the Aboriginal Heritage Act 1972 (WA) (AHA) and the State’s regulatory regime in general, the Tribunal has found, based on the evidence, that there is likely to be interference with relevant sites (see Murray v Money at [57]). They explain that such a conclusion has often been based on the relevant area being rich in sites. Rachlan Holdings contend there is a material distinction between cases involving ‘site rich’ areas and the present case.
b.[17] In the email exchange with TMPAC, Rachlan Holdings outlined that:
…there is a material distinction between cases involving 'site rich' areas and the present case.
In 'site rich' cases, the likelihood of interference arises from the fact of a multiplicity of sites and resulting uncertainty as to the precise location and boundaries of each site - it is this uncertainty that gives rise to the prospect of inadvertent interference.
This stands in stark contrast to the current case, where it is asserted that there is a single known site, which the Native Title Party contends encompasses the entirety of the relevant area. In such a case, there is no uncertainty and therefore no prospect of inadvertent interference. On the Native Title Party's contention any activity would require consent under the Aboriginal Heritage Act 1972 (WA) - far from being inadvertent, interference would only flow from the exercise of Ministerial discretion in the manner described in WA v Smith…
This was in response to TMPAC’s assertion that:
…the native title party submits that there have been numerous cases where despite the acceptance of a presumption of regularity that the government party and the grantee party will comply with the Aboriginal Heritage Act 1972 (WA), the Tribunal has found, based on the evidence (usually that the area is rich in sites), that there is likely to be interference with the sites (see Harvey Murray on behalf of the Yilka Native Title Claimants/State of Western Australia/Drew Griffin Money [2011] NNTTA 91; (2011) 257 FLR 450 at [57]).
a.[18] My view of this argument is that that the concept 'site rich' is not helpful in this present inquiry. The central issue remains whether there are any areas or sites of particular significance likely to be interfered with under s 237(b) by the activities of Rachlan Holdings. I adopt the following reasoning from Member O’Dea in Lungunan v Geotech International at [43]:
In certain circumstances it may be, depending on the evidence, appropriate to describe an area which contains numerous sites of particular significance as being rich in sites. However, in my opinion, it is unhelpful to the predictive assessment that I am required to undertake to introduce a term of art such as ‘site rich’, because it may imply a range of assumptions which are not necessarily the case in any particular evidentiary situation. In circumstances where the evidence suggests there are sites of particular significance, particularly where there are a number of such sites, the intentions of the grantee party relating to the manner in which it intends to conduct its exploration activities will be of pivotal importance in the predictive assessment as to whether or not it is likely that such sites will be interfered with during the course of those activities. To the extent that the grantee party seeks to persuade the Tribunal that the risks of interference are not likely, it is incumbent upon them to provide evidence as to how such interference, including inadvertent interference, can be avoided. In those circumstances, in the absence of such evidence from the grantee party, it is likely to prove difficult to persuade the Tribunal that interference with sites of particular significance is not likely.
Rachlan Holdings material
a.[19] Rachlan Holdings submitted their statement of contentions, and a copy of the draft agreement currently the subject of ongoing discussions between the parties. Rachlan Holdings statement accompanying their application for the licence, provided in the State’s materials, indicates Rachlan Holdings will be targeting a potential Paleo Channel containing a brine aquifer that may contain various commodities. It is stated that the salt lakes in the licence area may be linked to a potential Paleo Channel. Rachlan Holdings exploration program states it will aim to confirm the above theory and test the economic recovery of the commodities. Field based activities will include:
•• access to the areas by pastoral station tracks and helicopters
•• geological and hydrological mapping and interpretation
•• geophysical surveying
•• surface and near surface water sampling
•• heritage surveys
•• planned exploration drilling programs
•• porosity testing
•• water drawdown testing of the aquifer
•• further work based on the initial drilling and survey results
•• environmental surveys
The State’s material
a.[20] The State lodged: a statement of contentions; Rachlan Holding’s licence application with the accompanying work program statement; mapping; a Tengraph Quick Appraisal; search results and mapping from the Department of Planning, Lands and Heritage Aboriginal Heritage Inquiry System (AHIS); and a list of proposed endorsements and conditions intended to be imposed on the grant of the licence. The State also outline a condition will be placed on the licence where the native title party may request, and the grantee party shall execute, a Regional Standard Heritage Agreement (RSHA) within certain timeframes.
Considering the matter ‘on the papers’ – no need for an oral hearing
a.[21] Having considered all of the material before me, I am satisfied it is appropriate to determine the matter ‘on the papers’ as permitted by s 151 of the Act, without the need for an oral hearing. All parties indicated they were content to proceed on the papers.
Section 237(a): is the grant of the licence likely to interfere directly with the native title holders’ community or social activities?
a.[22] To find s 237(a) interference is likely, there must be evidence supporting direct and substantial interference with social or community activities (Yindjibarndi v FMG at [16]). TMPAC state they do not make any contentions in relation to s 237(a) and do not submit evidence on this issue. Applying the common sense approach to evidence required by administrative tribunals (Ward v Western Australia at [26]), there is nothing before me which indicates the grant of the licence is likely to interfere directly with the carrying on of the native title holder’s community or social activities. Therefore, I find disturbance under s 237(a) is unlikely.
Section 237(b): is the grant of the licence likely to interfere with areas or sites of particular significance to the native title holders?
a.[23] An area or site of ‘particular significance’ is one of special or more than ordinary significance to the native title holders in accordance with their traditions (Cheinmora v Striker Resources at 34–35). If an area or site is one of particular significance, it must be known and able to be located, and the nature of its significance explained (Silver v Northern Territory at [91]). Silver v Northern Territory (at [88]) is also authority for the importance of the focus of an expedited procedure objection inquiry on ‘areas or sites of particular significance, in accordance with their traditions, to the persons who are the holders of native title’.
What areas or sites are identified by TMPAC on the licence?
a.[24] TMPAC state Lake Nabberu, a complex of dry saline lakes, is a site of particular significance to the native title holders. Mapping shows Lake Nabberu overlaps the licence area. TMPAC contend that E69/3528 is a large area that almost wholly overlaps part of Lake Nabberu. That is consistent with mapping provided by parties.
Is there evidence these areas or sites are of particular significance in accordance with TMPAC’s traditions?
a.[25] Results from the State’s AHIS show there are no registered sites or other heritage places within the licence area. It is well established that a site or area may be of particular significance without being recorded on the AHIS (see Little v Lake Moore Gypsum at [67]). The word ‘particular’ in s 237(b) not only means ‘special or more than ordinary’ but that the particularity of the significance must be capable of identification (Western Australia v McHenry at 14-15).
b.[26] TMPAC contends Mr Morgan and Mr Stewart establish that, according to the native title holders, the complex of lakes comprising Lake Nabberu were created in the dreaming and is highly significant within their traditional laws and customs. Mr Morgan explains access to the lake is gender restricted, and there are severe consequences for others who access the lake or interfere with it. Dr Sackett supports these contentions in his statement and outlines why Lake Nabberu is of more than ordinary significance to the native title holders. I do not repeat that information here due to sensitivities.
c.[27] Dr Sackett further explains, in his opinion, the lake and certain surrounding places are not like other areas where ‘mundane activities’ are permitted. The lake and known sites around it are places that are marked off by their creation and important to the native title holders belief system. Dr Sackett states (at 25) ‘they exist as places to be avoided, skirted around, approached with caution…’ and he goes on to outline their gender sensitivity.
d.[28] Rachlan Holdings and the State contend there is insufficient evidence to establish the precise location of the ‘site of particular significance’ and insufficient evidence to explain the nature of the significance of Lake Nabberu to the native title holders. In particular, Rachlan Holdings assert the materials filed by TMPAC do not lead to location or significance of any area or site of particular significance.
e.[29] Rachlan Holdings responded, asserting the nature or significance of the relevance is not explained either by Mr Ashwin’s statement or the accompanying maps, which ‘serve only to demonstrate that the Application is, at its nearest point, approximately 55 km removed from the land subject of applications for mining tenements to which the Morgan statement and Stewart statement are directed.’ (This is dealt with at [9] above). In reply to Rachlan Holdings contentions, TMPAC stated it is not necessary to indicate on the map the restricted locations to establish the location of Lake Nabberu, as the whole of the lake is a site of particular significance. When referring to certain Jukurrpa (dreaming), TMPAC assert Mr Stewart and Mr Morgan gave an account of the creation of the whole area of Lake Nabberu as indicated on the map.
f.[30] As with my conclusion in TMPAC v Rachlan Holdings, I conclude that Lake Nabberu, as marked on mapping provided by parties, is itself a site of particular significance for the purposes of s 237(b).
Is interference with this site of particular significance likely?
a.[31] TMPAC contends access to Lake Nabberu by people who are not senior native title holders and knowledge holders for Lake Nabberu, and of the appropriate gender, constitutes interference with the lake in accordance with the native title holders’ law and customs. For example, Mr Morgan states (at 23) ‘Whitefella come in and digging round there and I have to get in trouble for breaking the Law.’ Dr Sackett explains it is not relevant that exploration activities of Rachlan Holdings might be non-ground disturbing, it is the presence on the lake by an inappropriate person that is breaking the law, ‘virtually any activity would constitute interference with it’ (at 28). TMPAC assert any disturbance created by Rachlan Holdings might result in harm to its personnel who venture onto the lake and may result in serious consequences for the native title holders.
b.[32] The State and Rachlan Holdings do not agree. The State outline that even if Lake Nabberu is a site of particular significance, ‘interference with the sites of particular significance is not likely’. The State and Rachlan Holdings assert this is because of the regulatory regime, and the grantees willingness ‘to recognise and work with the NTP [native title party] to take into account cultural or heritage issues’.
c.[33] In Rachlan Holdings contentions (at 34 to 46), and in an email exchange between TMPAC and Rachlan Holdings between 17 to 21 May 2019, they argue that the points pressed by TMPAC prevent a finding that the act is likely to interfere with areas or sites of particular significance for reasons such as:
• • if, as is contended by TMPAC, Rachlan Holdings will need to apply for consent under the Aboriginal Heritage Act 1972 (WA) in order to conduct any exploration activity (emphasis added), then - applying the presumption of regularity - there is no prospect of inadvertent interference; and
• • it is not possible to assess how or the likelihood of how the Minister will exercise direction and, in any event, if the Minister were to grant consent, any interference would flow from the discretionary decision and not directly from the act (see Western Australia v Smith at [37]).
a.[34] Rachlan Holdings contend there is insufficient evidence to establish the precise location and nature of any area or site of particular significance within the land subject to the licence area. It asserts the proposed exploration activities are flexible and can be relocated to avoid areas of significance to the extent possible. In the event that areas of significance cannot be avoided, and Rachlan Holdings seeks the consent of the Minister, it states the grantee party will not necessarily be granted consent under the AHA. Rachlan Holdings have offered additional protections to TMPAC in the form of an alternative heritage agreement, including in relation to identification and avoidance of areas of sensitivity or significance, and state it continues to pursue reaching agreement with TMPAC.
b.[35] I accept Rachlan Holdings intends to act lawfully and in accordance within the AHA and the State’s regulatory regime. I also note their positive attitude to reaching agreement with TMPAC. However, the Tribunal has previously found that the concept of ‘interference’ in s 237(b) is of a potentially wider scope than the proscribed activities in s 17 of the AHA (see for example Young v Western Australia). Depending on the circumstances, activities permitted under s 17 of the AHA or under the RSHA (for example activities which may be considered non-ground disturbing, on the surface of Lake Nabberu) may constitute interference pursuant to s 237(b) of the Act. Rachlan Holdings contends the Tribunal cannot, on the evidence before it, be satisfied as to the location of any area or site of particular significance within the land subject of the licence area. However, as noted above, it does acknowledge if an area of significance cannot be avoided, the grantee party would need to seek the consent of the Minister.
c.[36] The State notes the licence area has been the subject of historical exploration licences and current pastoral leases. It contends there is a sufficient basis for the Tribunal to infer there has been ground disturbance due to prior mining and/or pastoral activity in the licence area, and the grant of this the licence is unlikely to cause substantial further disturbance. TMPAC assert there is nothing in the information provided by the State from which it can be inferred what (if any) activities have taken place on the licence area, or where those activities have taken place. TMPAC contends the inference there has been ground disturbance should not be drawn. In addition, owing to the native title holders’ beliefs about the creation and consequences for those who venture Lake Nabberu, TMPAC say the likelihood of interference remains, irrespective of prior ground disturbance.
Conclusion
a.[37] I must consider, based on the facts presented in an inquiry and the nature and extent of sites of particular significance, whether the States protective regime is sufficient to make it unlikely there will be interference with sites of particular significance found to exist. In making the predictive assessment for s 237(b) of the Act, the Tribunal can have regard to the grantee party’s attitude to the RSHA (Champion v Western Australia [30]-[34]). I note some of the parties submissions also related to the negotiations and content of a draft agreement between parties. However, it is not my role in an expedited procedure inquiry to evaluate those negotiations or draft agreements. My role is to decide whether or not the expedited procedure applies to the grant of the licence in the context of consideration of s 237 of the Act.
b.[38] There is no question the State’s regulatory regime will apply to the licence – the question is whether, in doing lawful exploration activities, Rachlan Holdings is likely to interfere with the site of particular significance which has been identified by TMPAC. As with my conclusion in TMPAC v Rachlan Holdings I find the evidence as it relates to this inquiry compelling, and that evidence is supported by Mr Ashwin.
c.[39] I have accepted Lake Nabberu is a site of particular significance in accordance with the native title party traditions. The activities Rachlan Holdings have proposed (as outlined at [18]) are likely to cause interference. There is nothing in the endorsements and conditions to be imposed by the State which is likely to mitigate the interference. In addition, while the RSHA would provide some protection to Lake Nabberu, it allows for non-ground disturbing work to occur on the licence. There is sufficient evidence provided by TMPAC that such non-ground disturbing work would be sufficient to cause interference for the purpose of s 237(b) of the Act.
Section 237(c): is the grant of the licence likely to involve, or create rights whose exercise is likely to involve, major disturbance to any land or waters concerned?
a.[40] TMPAC state they do not make any contentions in relation to s 237(c). Again, applying the common sense approach to evidence required by administrative tribunals (Ward v Western Australia at [26]), there is nothing before me which indicates the grant of the licence is likely to involve major disturbance to the land or waters concerned. Therefore, I find disturbance under s 237(c) is unlikely.
Determination
a.[41] My determination is that the grant of E69/3528 Rachlan Holdings Pty Ltd is not an act that attracts the expedited procedure.
Helen Shurven
Member
16 July 2019
0
14
0