The Bell Group Ltd (In Liq) v Westpac Banking Corporation
[2001] WASC 315 (S)
•19 DECEMBER 2001
THE BELL GROUP LTD (In Liq) & ORS -v- WESTPAC BANKING CORPORATION & ORS [2001] WASC 315 (S)
| SUPREME COURT OF WESTERN AUSTRALIA | Citation No: | [2001] WASC 315 (S) | |
| Case No: | CIV:1464/2000 | 22 NOVEMBER 2001 | |
| Coram: | OWEN J | 19/12/01 | |
| 19/12/01 | |||
| 14 | Judgment Part: | 1 of 1 | |
| Result: | Leave to amend granted | ||
| B | |||
| PDF Version |
| Parties: | THE BELL GROUP LTD (In Liquidation) (ACN 008 666 993) THE BELL GROUP LTD (In Liquidation) AS TRUSTEE FOR DOLFINNE PTY LTD (In Liquidation) THE BELL GROUP LTD (In Liquidation) AS TRUSTEE FOR INDUSTRIAL SECURITIES PTY LTD THE BELL GROUP LTD (In Liquidation) AS TRUSTEE FOR MARANOA TRANSPORT PTY LTD THE BELL GROUP LTD (In Liquidation) AS TRUSTEE FOR NEOMA INVESTMENTS PTY LTD BELL GROUP FINANCE (In Liquidation) (RECEIVER AND MANAGER APPOINTED) BELL GROUP (UK) HOLDINGS LTD (In Liquidation) (IN ADMINISTRATIVE RECEIVERSHIP) BELL PUBLISHING GROUP PTY LTD (In Liquidation) BELL GROUP NV (In Liquidation) AMBASSADOR NOMINEES PTY LTD (In Liquidation) and OTHERS GEOFFREY FRANK TOTTERDELL AS LIQUIDATOR OF FIRST PLAINTIFF AND OF FIRST, SECOND, THIRD, FIFTH, NINTH, TENTH, ELEVENTH, THIRTEENTH, FOURTEENTH, SIXTEENTH, SEVENTEENTH AND NINETEENTH NAMED SEVENTH PLAINTIFFS ANTONY LESLIE JOHN WOODINGS AS LIQUIDATOR OF THE THIRD PLAINTIFF, FIFTH PLAINTIFF AND OF THE FOURTH, SIXTH, SEVENTH, EIGHTH, TWELFTH, FIFTEENTH, EIGHTEENTH NAMED SEVENTH PLAINTIFFS GARRY JOHN TREVOR AS LIQUIDATOR OF THE SIXTH PLAINTIFF WESTPAC BANKING CORPORATION (ACN 007 457 141) SOCIETE GENERALE AUSTRALIA LTD NATIONAL AUSTRALIA BANK LTD HONGKONGBANK OF AUSTRALIA LTD STANDARD CHARTERED BANK AUSTRALIA LTD COMMONWEALTH BANK OF AUSTRALIA LLOYDS BANK PLC BANCO ESPIRITO SANTO E COMERCIAL DE LISBOA BANK FUR GEMEINWIRTSCHAFT AG THE GOVERNOR AND COMPANYOF THE BANK OF SCOTLAND CAISSE NATIONALE DE CREDIT AGRICOLE CREDITANSTALT-BANKVEREIN CREDIT LYONNAIS DRESDNER BANK AG KREDIETBANK NV SKOPBANK DG BANK DEUTSCHE GENOSSENSCHAFTSBANK THE GULF BANK KSC GENTRA LTD (FORMERLY ROYAL TRUST BANK) BANQUE INDOSEUZ EQUITY TRUST (CURACAO) NV COMMONWEALTH BANK OF AUSTRALIA (ACN 123 123 124) NATIONAL AUSTRALIA BANK LTD (ACN 004 044 937) SOCIETE GENERALE AUSTRALIA LTD (ACN 002 093 021) STANDARD CHARTERED BANK AUSTRALIA LTD WESTPAC BANKING CORPORATION (ARBN 007 457 141) HONGKONGBANK OF AUSTRALIA LTD (ACN 006 434 162) THE GOVERNOR AND COMPANY OF THE BANK OF SCOTLAND CREDITANSTALT-BANK VEREIN CAISEE NATIONALE DE CREDIT AGRICOLE GULF BANK KSC DG BANK DEUTSCHE GENOSSENSCHAFTBANK THE LAW DEBENTURE TRUST CORPORATION PLC THE BELL GROUP LTD (ACN 008 666 993) GEOFFREY FRANK TOTTERDELL BELL GROUP FINANCE PTY LTD (In Liquidation) (RECEIVER AND MANAGER APPOINTED) (ACN 009 165 182) ANTONY LESLIE JOHN WOODINGS STATE GOVERNMENT INSURANCE COMMISSION OF WESTERN AUSTRALIA AUSTRALIAN CONSOLIDATED INVESTMENTS LTD (ACN 008 670 924) GODINE DEVELOPMENTS PTY LTD (ACN 009 237 307) BELL RESOURCES DEVELOPMENTS PTY LTD (ACN 009 152 569) W.A. GLENDINNING & ASSOCIATES PTY LTD (ACN 008 762 721) W.U. INVESTMENTS PTY LTD EXPECTATION PTY LTD COMMONWEALTH OF AUSTRALIA WESTPAC BANKING CORPORATION |
Catchwords: | Practice and procedure Pleadings Amendment to statement of claim Turns on own facts |
Legislation: | Nil |
Case References: | The Bell Group Limited (In Liq) & Ors v Westpac Banking Corporation & Ors [2001] WASC 315 Banque Commerciale SA (In Liq) v Akhil Holdings Ltd (1990) 169 CLR 279 BCCI v Akindele [2001] Ch 437 Commercial Bank of Australia Ltd v Amadio (1983) 151 CLR 447 Commonwealth Bank of Australia v Ridout Nominees Pty Ltd [2000] WASC 37 Kinsela v Russell Kinsela Pty Ltd (In Liq) (1986) 4 NSWLR 722 Koorootang Nominees Pty Ltd v Australian and New Zealand Banking Group Ltd [1998] 3 VR 16 Manifest Shipping Co Ltd v Uni-Polaris Shipping Co Ltd [2001] 2 WLR 170 Nicholson v Permakraft (NZ) Ltd (In Liq) (1985) 3 ACLC 453 Pyramid Building Society (In Liq) v Scorpion Hotels Pty Ltd [1998] 1 VR 188 Royal Brunei Airlines Sdn Bhd v Tan [1995] 2 AC 378 Spies v R (2000) 201 CLR 603 Sycotex Ltd v Baseler (1994) 122 ALR 531 |
JURISDICTION : SUPREME COURT OF WESTERN AUSTRALIA
- IN CHAMBERS
DECISION : 19 DECEMBER 2001 FILE NO/S : CIV 1464 of 2000 BETWEEN : THE BELL GROUP LTD (In Liq) (ACN 008 666 993)
- First Plaintiff
THE BELL GROUP LTD (In Liq) AS TRUSTEE FOR DOLFINNE PTY LTD (In Liq)
THE BELL GROUP LTD (In Liq) AS TRUSTEE FOR INDUSTRIAL SECURITIES PTY LTD
THE BELL GROUP LTD (In Liq) AS TRUSTEE FOR MARANOA TRANSPORT PTY LTD
THE BELL GROUP LTD (In Liq) AS TRUSTEE FOR NEOMA INVESTMENTS PTY LTD
Second Plaintiffs
BELL GROUP FINANCE (In Liq) (RECEIVER AND MANAGER APPOINTED)
Third Plaintiff
BELL GROUP (UK) HOLDINGS LTD (In Liq) (IN ADMINISTRATIVE RECEIVERSHIP)
Fourth Plaintiff
BELL PUBLISHING GROUP PTY LTD (In Liq)
Fifth Plaintiff
(Page 2)
BELL GROUP NV (In Liq)
Sixth Plaintiff
AMBASSADOR NOMINEES PTY LTD (In Liq) and OTHERS
Seventh Plaintiffs
GEOFFREY FRANK TOTTERDELL AS LIQUIDATOR OF FIRST PLAINTIFF AND OF FIRST, SECOND, THIRD, FIFTH, NINTH, TENTH, ELEVENTH, THIRTEENTH, FOURTEENTH, SIXTEENTH, SEVENTEENTH AND NINETEENTH NAMED SEVENTH PLAINTIFFS
Eighth Plaintiff
ANTONY LESLIE JOHN WOODINGS AS LIQUIDATOR OF THE THIRD PLAINTIFF, FIFTH PLAINTIFF AND OF THE FOURTH, SIXTH, SEVENTH, EIGHTH, TWELFTH, FIFTEENTH, EIGHTEENTH NAMED SEVENTH PLAINTIFFS
Ninth Plaintiff
GARRY JOHN TREVOR AS LIQUIDATOR OF THE SIXTH PLAINTIFF
Tenth Plaintiff
AND
WESTPAC BANKING CORPORATION (ACN 007 457 141)
First Defendant
SOCIETE GENERALE AUSTRALIA LTD
NATIONAL AUSTRALIA BANK LTD
HONGKONGBANK OF AUSTRALIA LTD
STANDARD CHARTERED BANK AUSTRALIA LTD
COMMONWEALTH BANK OF AUSTRALIA
Second Defendants
(Page 3)
- LLOYDS BANK PLC
BANCO ESPIRITO SANTO E COMERCIAL DE LISBOA
BANK FUR GEMEINWIRTSCHAFT AG
THE GOVERNOR AND COMPANYOF THE BANK OF SCOTLAND
CAISSE NATIONALE DE CREDIT AGRICOLE
CREDITANSTALT-BANKVEREIN
CREDIT LYONNAIS
DRESDNER BANK AG
KREDIETBANK NV
SKOPBANK
DG BANK DEUTSCHE GENOSSENSCHAFTSBANK
THE GULF BANK KSC
GENTRA LTD (FORMERLY ROYAL TRUST BANK)
BANQUE INDOSEUZ
Third Defendants
EQUITY TRUST (CURACAO) NV
Fourth Defendant
- First Plaintiff
NATIONAL AUSTRALIA BANK LTD (ACN 004 044 937)
Second Plaintiff
SOCIETE GENERALE AUSTRALIA LTD (ACN 002 093 021)
Third Plaintiff
STANDARD CHARTERED BANK AUSTRALIA LTD
Fourth Plaintiff
(Page 4)
- WESTPAC BANKING CORPORATION (ARBN 007 457 141)
Fifth Plaintiff
HONGKONGBANK OF AUSTRALIA LTD (ACN 006 434 162)
Sixth Plaintiff
BANCO ESPIRITO SANTO E COMERCIAL DE LISBOA
BANK FUR GEMEINWIRTSCHAFT AG
THE GOVERNOR AND COMPANY OF THE BANK OF SCOTLAND
CREDITANSTALT-BANK VEREIN
CREDIT LYONNAIS
DRESDNER BANK AG
BANQUE INDOSEUZ
Seventh Plaintiffs
LLOYDS BANK PLC
CAISEE NATIONALE DE CREDIT AGRICOLE
GENTRA LTD (FORMERLY ROYAL TRUST BANK)
KREDIETBANK NV
GULF BANK KSC
DG BANK DEUTSCHE GENOSSENSCHAFTBANK
Eighth Plaintiffs
AND
THE LAW DEBENTURE TRUST CORPORATION PLC
First Defendant
THE BELL GROUP LTD (ACN 008 666 993)
Second Defendant
GEOFFREY FRANK TOTTERDELL
Third Defendant
(Page 5)
- BELL GROUP FINANCE PTY LTD (In Liq) (RECEIVER AND MANAGER APPOINTED) (ACN 009 165 182)
Fourth Defendant
ANTONY LESLIE JOHN WOODINGS
Fifth Defendant
STATE GOVERNMENT INSURANCE COMMISSION OF WESTERN AUSTRALIA
Sixth Defendant
(BY ORIGINAL ACTION)
THE LAW DEBENTURE TRUST CORPORATION PLC
STATE GOVERNMENT INSURANCE COMMISSION OF WESTERN AUSTRALIA
Plaintiffs
AND
AUSTRALIAN CONSOLIDATED INVESTMENTS LTD (ACN 008 670 924)
GODINE DEVELOPMENTS PTY LTD (ACN 009 237 307)
BELL RESOURCES DEVELOPMENTS PTY LTD (ACN 009 152 569)
First Defendants
LLOYDS BANK PLC
Second Defendant
W A GLENDINNING & ASSOCIATES PTY LTD (ACN 008 762 721)
W U INVESTMENTS PTY LTD
EXPECTATION PTY LTD
Third Defendants
COMMONWEALTH OF AUSTRALIA
Fourth Defendant
(Page 6)
- WESTPAC BANKING CORPORATION
Fifth Defendant
(BY COUNTERCLAIM)
Catchwords:
Practice and procedure - Pleadings - Amendment to statement of claim - Turns on own facts
Legislation:
Nil
Result:
Leave to amend granted
Category: B
Representation:
CIV 1464 of 2000
Counsel:
First Plaintiff : Mr R M Robson QC & Mr J T Svehla
Second Plaintiffs : Mr R M Robson QC & Mr J T Svehla
Third Plaintiff : Mr R M Robson QC & Mr J T Svehla
Fourth Plaintiff : Mr R M Robson QC & Mr J T Svehla
Fifth Plaintiff : Mr R M Robson QC & Mr J T Svehla
Sixth Plaintiff : Mr R M Robson QC & Mr J T Svehla
Seventh Plaintiffs : Mr R M Robson QC & Mr J T Svehla
Eighth Plaintiff : Mr R M Robson QC & Mr J T Svehla
Ninth Plaintiff : Mr R M Robson QC & Mr J T Svehla
Tenth Plaintiff : Mr R M Robson QC & Mr J T Svehla
(Page 7)
- First Defendant : Mr T M Jucovic QC, Mr J L B Allsop QC &
Mr A V McCarthy
Second Defendants : Mr T M Jucovic QC, Mr J L B Allsop QC &
Mr A V McCarthy
Third Defendants : Mr T M Jucovic QC, Mr J L B Allsop QC &
Mr A V McCarthy
Fourth Defendant : No appearance
Solicitors:
First Plaintiff : Blake Dawson Waldron
Second Plaintiffs : Blake Dawson Waldron
Third Plaintiff : Blake Dawson Waldron
Fourth Plaintiff : Blake Dawson Waldron
Fifth Plaintiff : Blake Dawson Waldron
Sixth Plaintiff : Blake Dawson Waldron
Seventh Plaintiffs : Blake Dawson Waldron
Eighth Plaintiff : Blake Dawson Waldron
Ninth Plaintiff : Blake Dawson Waldron
Tenth Plaintiff : Blake Dawson Waldron
First Defendant : Freehills
Second Defendants : Freehills
Third Defendants : Freehills
Fourth Defendant : No appearance
CIV 2061 of 1996
Counsel:
First Plaintiff : Mr T M Jucovic QC, Mr J L B Allsop QC &
Mr A V McCarthy
Second Plaintiff : Mr T M Jucovic QC, Mr J L B Allsop QC &
Mr A V McCarthy
Third Plaintiff : Mr T M Jucovic QC, Mr J L B Allsop QC &
Mr A V McCarthy
Fourth Plaintiff : Mr T M Jucovic QC, Mr J L B Allsop QC &
Mr A V McCarthy
Fifth Plaintiff : Mr T M Jucovic QC, Mr J L B Allsop QC &
Mr A V McCarthy
Sixth Plaintiff : Mr T M Jucovic QC, Mr J L B Allsop QC &
Mr A V McCarthy
Seventh Plaintiffs : Mr T M Jucovic QC, Mr J L B Allsop QC &
Mr A V McCarthy
(Page 8)
- Eighth Plaintiffs : Mr T M Jucovic QC, Mr J L B Allsop QC &
Mr A V McCarthy
First Defendant : Mr A R Beech & Ms A Hamersley
Second Defendant : Mr R M Robson QC & Mr J T Svehla
Third Defendant : Mr R M Robson QC & Mr J T Svehla
Fourth Defendant : Mr R M Robson QC & Mr J T Svehla
Fifth Defendant : Mr R M Robson QC & Mr J T Svehla
Sixth Defendant : Mr A R Beech & Ms A Hamersley
Solicitors:
First Plaintiff : Freehills
Second Plaintiff : Freehills
Third Plaintiff : Freehills
Fourth Plaintiff : Freehills
Fifth Plaintiff : Freehills
Sixth Plaintiff : Freehills
Seventh Plaintiffs : Freehills
Eighth Plaintiffs : Freehills
First Defendant : Edgar & Co
Second Defendant : Blake Dawson Waldron
Third Defendant : Blake Dawson Waldron
Fourth Defendant : Blake Dawson Waldron
Fifth Defendant : Blake Dawson Waldron
Sixth Defendant : Edgar & Co
Case(s) referred to in judgment(s):
The Bell Group Limited (In Liq) & Ors v Westpac Banking Corporation & Ors [2001] WASC 315
Case(s) also cited:
Banque Commerciale SA (In Liq) v Akhil Holdings Ltd (1990) 169 CLR 279
BCCI v Akindele [2001] Ch 437
Commercial Bank of Australia Ltd v Amadio (1983) 151 CLR 447
Commonwealth Bank of Australia v Ridout Nominees Pty Ltd [2000] WASC 37
Kinsela v Russell Kinsela Pty Ltd (In Liq) (1986) 4 NSWLR 722
Koorootang Nominees Pty Ltd v Australian and New Zealand Banking Group Ltd [1998] 3 VR 16
(Page 9)
Manifest Shipping Co Ltd v Uni-Polaris Shipping Co Ltd [2001] 2 WLR 170
Nicholson v Permakraft (NZ) Ltd (In Liq) (1985) 3 ACLC 453
Pyramid Building Society (In Liq) v Scorpion Hotels Pty Ltd [1998] 1 VR 188
Royal Brunei Airlines Sdn Bhd v Tan [1995] 2 AC 378
Spies v R (2000) 201 CLR 603
Sycotex Ltd v Baseler (1994) 122 ALR 531
(Page 10)
1 OWEN J: The reasons in The Bell Group Limited (In Liq) & Ors v Westpac Banking Corporation & Ors [2001] WASC 315 ("the earlier reasons") disclose my general approach to the application by the plaintiffs for leave to amend the writ and the statement of claim. At a directions hearing on 22 November 2001 I requested the plaintiffs to bring in a fresh minute of proposed amended statement of claim:
(a) incorporating changes that counsel had indicated the plaintiffs were prepared to make to accommodate some of the objections raised by the defendants; and
(b) to bring the pleading in line with the earlier reasons.
2 I made this request so that I could satisfy myself that the Eighth Amended Statement of Claim (as the pleading will become) would be in accord with what I had intended to convey in the reasons. I also wished to give the defendants an opportunity to consider the final form of the proposed pleading.
3 The plaintiffs have filed a document entitled "Minute of Plaintiffs' Eighth Amended Statement of Claim" dated 7 December 2001 ("the Minute"). The document was accompanied by two lever arch files constituting the particulars to the statement of claim. The defendants filed a memorandum dated 14 December 2001 in which they raised four matters which were of concern to them. The plaintiffs filed a memorandum dated 7 December 2001 in which they responded to the defendants' concerns.
4 I have considered the Minute, the particulars and the memoranda. These reasons, which are supplementary to those contained in [2001] WASC 315, deal with the four matters of concern raised by the defendants. My reading of the materials did not alert me to other areas in which the Minute is not consistent with the earlier reasons. These reasons constitute the finalisation of the application for leave to amend the writ and the statement of claim.
The State of Mind of the Directors
5 I made it clear in the earlier reasons and at the November 2001 directions hearing that I understood the plaintiffs not to be alleging conscious wrongdoing on the part of the directors. In my view pars 39A, 39C and 39D and the particulars accord with that understanding.
(Page 11)
6 One of the defendants' concerns is the reference in the particulars to a "lack of a genuine belief" in a state of affairs. My recollection is that the Seventh Amended Statement of Claim (a document that I do not have available at the moment) contained similar references. As I understand it there was no suggestion that it imported an element of conscious wrongdoing into that version of the pleading. I see no reason why the Minute should be differently interpreted.
7 The problem is exemplified by the allegation that the directors exercised powers for an improper purpose. This can arise in a number of ways. For example, an objector may allege the power was exercised for purpose "A" (which on any view of it is improper) while the directors may say that it was done for purpose "B", a totally legitimate purpose. A different argument may arise if the claimant and the directors are of one mind as to what the purpose was but they part company on the question whether it was improper. In that case the purpose may be found to be improper, in which case the directors may be liable. But this does not mean that they have pursued an improper purpose knowing the purpose to be improper. That would involve conscious wrongdoing. There may be other possibilities and combinations.
8 All that need be said is that I interpret the pleading as not involving an allegation of conscious wrongdoing in the sense that I have outlined. I will hold the plaintiffs to that interpretation.
9 In my view pars 39A, 39C, 39D of the Minute and the accompanying particulars can stand.
The Equitable Fraud Claim
10 The equitable fraud claim is primarily to be found in pars 65M and 65MA. It is advanced on alternative bases. First, that nominated conduct is a deceit and imposition on Bell Participants and their creditors. This needs no further comment. Secondly, the Scheme and the Transactions constituted an inequitable and unconscientious bargain. This is contentious.
11 The gravamen of the second basis for the unconscionability claim is to be found in the particulars to par 65MA. I have considered carefully the matters raised in pars 22 to 29 of the defendants' memorandum of 14 December 2001. I acknowledge that the pleading is not perfect, although I am not sure how, in relation to pleadings, perfection can ever be assessed. My concern in the earlier reasons was that it was unclear
(Page 12)
- exactly what the plaintiffs were saying about the myriad of material facts which were incorporated by reference and which, on the plaintiffs' case, rendered the bargain inequitable. In my view, that problem has now been cured. The defendants are made aware how it is said various circumstances affected individual or nominated companies.
12 In my view enough is disclosed in the particulars in order for the Banks to know the case they have to meet. I am also satisfied on the matters raised in pars 28 to 30 of the plaintiffs' memorandum, that the proposed plea avoids serious embarrassment or oppression to the defendants. Whether the matters contained in the particulars, if made out, are sufficient to ground a finding that the bargain was inequitable ought to be left for trial.
The Limitation Issues
13 I thought I had made my position on the limitation issues relatively clear in the earlier reasons. I propose to stand over for consideration by the trial Judge all issues relating to limitation defences.
14 These problems can, and probably will, arise in three ways. First, whether some or all of the matters raised in the Eighth Amended Statement of Claim constitute new or fresh causes of action. Secondly, if so, what is the applicable limitation period? In relation to equitable claims, this may involve arguments about analogous causes of action at law. Thirdly, if there is a new or fresh cause of action does it arise out of the same or substantially the same factual matrix as previously pleaded?
15 As I said in the earlier reasons, all of these matters are best left to trial. I have considered carefully the material in pars 30 and 31 of the defendants' memorandum and pars 31 to 34 of the plaintiffs' response. I am afraid I do not fully understand the difference between the approaches advocated by the respective parties. In any event par 31 of the defendants' memorandum accurately reflects what I had in mind as the appropriate order.
Wilful Blindness
16 The defendants are concerned about the particulars to par 59TA(b). That paragraph pleads:
(Page 13)
- "Prior to the February meetings, with the knowledge, belief and suspicion which they held … , the Banks… refrained from seeking any or any adequate information about any schemes to restructure the financial position of the Bell Participants and the position of those companies' creditors, future creditors and shareholders in any such scheme."
17 Particular (b)(i) sets out five areas in which, according to the plaintiffs, the defendants abstained from making inquiries. Particular (b)(ii) sets out what the plaintiffs say inquiries, had they been made, would have revealed. The third particular alleges that the inquiries would have been made by "honest and reasonable persons in the position of" the defendants. In the fourth particular the plaintiffs give notice they will seek to have an inference drawn that the defendants abstained from inquiry because they believed or suspected (not that they knew) that the position was as set out in particular (b)(ii). Finally, there are set out two identified memoranda and an alleged banking practice (known to one of the defendants) as matters on which the plaintiffs wish to rely.
18 I am attracted to the argument raised by the plaintiffs that:
(a) the particulars do not represent a change in the case argued on the amendment application;
(b) they narrow the case by limiting the matters in relation to which it is said the defendants abstained from making inquiry; and
(c) at least to some extent the matters cover what is already in issue in par 62AA of the defence.
19 I do not believe that the particulars raise issues that are not in accord with par 59TA(b) of the Minute or that are not within the confines of the arguments raised during the hearing of the amendment application. Nor do I think they are embarrassing or otherwise defective in form.
Conclusion
20 There will be leave to amend in accordance with the Minute and the particulars as contained in the two lever arch files. The order should be extracted accordingly but it will speak from today. It should provide for the limitation issues to be deferred to the trial Judge.
21 The programme for dealing with the outstanding interlocutory applications was set at the directions hearing on 22 November 2001.
(Page 14)
- Once that programme has been completed the arrangements for management of the action can be reviewed.
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