Waiba and Minister for Immigration and Multicultural and Indigeno Us Affairs
[2003] AATA 668
•16 July 2003
Administrative
Appeals
Tribunal
DECISION AND REASONS FOR DECISION [2003] AATA 668
ADMINISTRATIVE APPEALS TRIBUNAL )
) No N2002/1829
GENERAL ADMINISTRATIVE DIVISION ) Re Durgay WAIBA Applicant
And
Minister for Immigration and Multicultural and Indigenous Affairs
Respondent
DECISION
Tribunal Ms. N Isenberg, Member Date16 July 2003
PlaceSydney
Decision The Tribunal affirms the decision under review.
[Sgd] Ms. N Isenberg, Member
CATCHWORDS
IMMIGRATION AND CITIZENSHIP - citizenship - refusal to grant - residential requirements - permanent resident less than two years - delay in processing of application for permanent residency - whether amounted to "administrative error" within meaning of section 13(4)(b)(v) - whether applicant refused employment because of lack of citizenship - whether amounted to "significant hardship or disadvantage" within meaning of section 13(4)(b)(iv) – decision affirmed
LEGISLATION
Australian Citizenship Act 1948 section 13
CASE LAW
Al- Mughrabi and Secretary, Department of Immigration and Multicultural Affairs [1999] AATA 164
Drake v Minister for Immigration and Ethnic Affairs (1979) 2 ALD 60
Re Drake and Minister for Immigration and Ethnic Affairs (No 2) (1979) 2 ALD 634
Liu and Others v Department of Immigration and Ethnic Affairs (1996) 41 ALD 589
REASONS FOR DECISION
16 July 2003
Ms. N Isenberg, Member
DECISION UNDER REVIEW
1. This is an application by Mr. Durgay Waiba (“the Applicant”) for review of the decision of the Minister for Immigration and Multicultural and Indigenous Affairs ("the Respondent”) dated 25 November 2002 (T2 p5), that refused an application by the Applicant of a grant of Australian citizenship under section 13(1)(d) and (e) of the Australian Citizenship Act 1948 ("the Act").
BACKGROUND
2. The Applicant was born in Tibet on 14 September 1965 and arrived in Australia on 10 March 1995. On 4 August 1995 he departed Australia for Nepal but returned on 1 October 1996 on a student visa. The student visa was extended to 3 April 1999.
3. On 31 March 1999 the Applicant lodged an application for a Protection (Class AZ) visa. (T5 p22) which was refused by a delegate of the Respondent on 15 April 1999. (T5 p22)
4. On 20 May 1999, the Applicant applied to the Refugee Review Tribunal ("RRT") for review of the delegate's decision. (T5 p22) but it was not until 26 March 2002 that the RRT handed down its decision (T5 p21). On 7 August 2002 the Applicant was granted a Protection visa which entitled him to permanent residence from that date. (T6 p43)
5. 17 days later, on 23 August 2002 the Applicant completed an application for grant of Australian Citizenship (Form 124). (T8 p46) On 25 November 2002 a delegate of the Respondent notified the Applicant of the decision to refuse the application for grant of Australian citizenship on the basis that the Applicant did not meet the residency requirements of the Act. ( T12 p62)
6. On 2 December 2002 the Applicant lodged an Application for Review of Decision with the Administrative Appeals Tribunal (“the Tribunal”).
APPEARANCES
7. At the hearing before the Tribunal held on 14 May 2003, the Applicant appeared without representation and the Respondent was represented by Ms Louise Stone of Blake Dawson Waldron, solicitors.
LEGISLATION
8. Australian citizenship is granted in accordance with the provisions of Part 3, Division 2 of the Act. In particular, section 13 of the Act relevantly provides:
“13 Grant of Australian citizenship
13(1) Subject to this section, the Minister may, in the Minister's discretion, upon application in accordance with the approved form, grant a certificate of Australian citizenship to a person who satisfies the Minister that:
(a) the person is a permanent resident;
(b) the person has attained the age of 18 years;
(c) the person understands the nature of the application;
(d) the person has been present in Australia as a permanent resident for a period of, or for periods amounting in the aggregate to, not less than one year during the period of 2 years immediately preceding the date of the furnishing of the application;
(e) the person has been present in Australia as a permanent resident for a period of, or for periods amounting in the aggregate to, not less than 2 years during the period of 5 years immediately preceding the date of the furnishing of the application;
(f) the person is of good character;
(g) the person possesses a basic knowledge of the English language;
(h) the person has an adequate knowledge of the responsibilities and privileges of Australian citizenship; and
(j) if granted a certificate of Australian citizenship, the person is likely to reside, or to continue to reside, in Australia, or to maintain a close and continuing association with Australia.
...
13(4) For the purposes of the application of subsection (1) in relation to an applicant for the grant of a certificate of Australian citizenship:
...
(b) subject to paragraph (a), the Minister may, in the Minister's discretion:
...
(iv) if the Minister considers that the applicant would suffer significant hardship or disadvantage if a certificate of Australian citizenship were not granted to the applicant—treat a period during which the applicant was present in Australia otherwise than as a prohibited immigrant, as a prohibited non-citizen, as an illegal entrant, as an unlawful non-citizen, or in contravention of a law of a prescribed Territory, as a period during which the applicant was present in Australia as a permanent resident; or
…”
9. The Respondent's policy in relation to section 13 of the Act is contained in the Australian Citizenship Instructions ("ACI"), relevantly as follows
“Residence discretion: Residence earlier than 5 years before application (s 13(4)(b)(ii))
4.3.32There is a discretion to count permanent residence earlier than 5 years before application towards the “2 years in 5” residence requirement. This discretion does not apply to the “1 year in 2” residence requirement.
4.3.33As a matter of policy, this discretion would usually only be exercised in one of the following situations of hardship or disadvantage:
· the applicant can demonstrate that he/she has been refused employment solely on the grounds that the employment is restricted to Australian citizens and that alternative sources of employment are not reasonably available to him/her;
· the applicant would be excluded from travelling internationally because he/she cannot obtain a passport or because he/she s excluded from travelling with immediate Australian family; or
· The applicant would not otherwise be eligible to represent Australia in an international forum or be selected to represent Australia in a national representative team/group.
-An applicant should be of international standard to satisfy this criterion.
-If citizenship is a prerequisite to selection for a national team, the applicant should be able to demonstrate that their selection depends solely upon being granted citizenship.
Residence discretion: Residence other than permanent residence
(s 13(4)(b)(iv)
4.3.34This discretion enables periods of temporary residence in Australia to be counted as periods of permanent residence if the applicant would otherwise suffer significant hardship or disadvantage.
· The applicant still has to satisfy the normal residence requirements of “2 years in 5” and “1 year in 2” and must be a permanent resident at the time of application.
· The discretion would normally only be exercised if the applicant has 12 months continuous permanent residence in Australia prior to the date of application.
· The discretion is only available for periods spent lawfully in Australia.
· The discretion is not available for periods when the applicant was in contravention of a law of a “prescribed Territory”.
· See 4.3.33 for guidance on hardship or disadvantage.
4.3.35Use of this discretion may be appropriate for people who have become permanent residents of Norfolk Island. If an applicant satisfies all the requirements under s 13(1) except the residence requirements, but has spent the appropriate periods of time in Norfolk Island as a temporary resident prior to being granted permanent residence of Norfolk Island, use of this provision would be appropriate.
4.3.36Some clients, particularly refugees, seek the exercise of this discretion on the grounds of difficulties in obtaining non-Australian travel documents or a preference to travel with the ‘protection’ of a Australian passport. This would not, however, normally justify use of the discretion , particularly given the following:
· Being the holder of Australian passport does not prevent arrest in a foreign country. An Australian citizen is required to obey local laws.
· Dual citizens may remain liable for military service in their country of other citizenship and offences under that country’s law that are committed outside that country.
· Although Australian citizenship does not permit the Australian Government to provide certain consular services (such as representations on behalf of an arrested person), if the person is also a citizen of the country they visit, and are treated as such, consular access may be denied.
· DFAT will consider granting an Australian Certificate of Identity ifa person is unable to obtain another passport.
· In the case of refugees, DFAT can issue a Convention Travel Document with validity of up to two years to allow the person to travel overseas.
4.3.37However, decision makers will need to continue to assess each application under s 13(4)(b)(iv) on its own merits, as there may be other circumstances which warrant use of the discretion within or outside of normal policy.
Residence discretion: Cases of administrative error (s 13(4)(b)(v))
4.3.38This provision enables a period spent in Australia to be treated as a period of permanent residence when it was not permanent residence because of an administrative error.
4.3.39Examples of administrative error could be, depending on the circumstances of the case:
· unlawful cancellation of a visa;
· grant of a temporary visa to permanent visa holder;
· double processing of a visa application.
4.3.40Administrative error does not occur just because a client has been successful at merits review.
4.3.41Decision makers must be satisfied that actual error on the part of administration has occurred and it is recommended that they contact the Migration Advising Help Desk in Central Office. For instance, it cannot be assumed that grant of a temporary visa to a permanent visa holder was as a result of administrative error.”
EVIDENCE: DOCUMENTS
10. The Tribunal had before it documents lodged pursuant to section 37 of the Administrative Appeals Tribunals Act 1975 ("the T-documents"), which the Tribunal took into evidence. In addition, the Respondent tendered Exhibit R1, a Statement of Facts and Contentions dated 17 March 2003.
APPLICANT’S EVIDENCE AND SUBMISSIONS
11. The Applicant gave sworn evidence and was cross-examined on behalf of the Respondent. Questions were also put to the Applicant by the Tribunal.
12. The Applicant drew the Tribunal’s attention to a letter from the Respondent advising him that his application for a Protection visa had been successful (T6 p43). The Applicant identified that the letter encouraged him to apply for Australian citizenship. He told the Tribunal he had seen a media campaign that encouraged permanent residents to become citizens. The Applicant told the Tribunal that he wanted to be a citizen, so applied almost as soon as his permanent residence was granted. He had, by that time, been here 8 or 9 years.. The Applicant said that when he contacted the Respondent he believed he met all the criteria for citizenship.
13. The Applicant told the Tribunal that when he first came to Australia he worked for an education college and, when asked to go overseas in his capacity as employee to promote the college he did not think he could refuse. The Applicant was only overseas for about 2 months.
14. Since his return the Applicant has applied for about 50 or 60 jobs. In India he studied accountancy for 3 years and worked as an accountant. However he does not have any documents verifying his qualifications and was unsuccessful in applications for bookkeeper-type roles here. The Applicant attended some interviews before he achieved permanent residency but was unsuccessful in obtaining employment. The Applicant told the Tribunal that he understood his unresolved status was not the only reason he failed to attain a job: “Employers do not tell you the reason you are unsuccessful in job applications.” He acknowledged, in this context, that he had no documentary evidence of his qualifications.
15. The Applicant then accepted labouring roles, and presently does this 1-2 days per week on a casual basis. He is also studying full time at TAFE for a Diploma of Advanced Accounting to renew his skills as there has been a long break since he did accounting type work. The Applicant saw a job with the Australia Army that he would have applied for but as there was a requirement that he be an Australia citizen, he chose not to proceed with the application. He made another inquiry about a job with the Department of Foreign Affairs and Trade (“DFAT”) but when he found out more information about it he felt discouraged from applying.
16. The Applicant considers that his current position is affected by competition in the market, the fact that his qualifications are not recognised in Australia and that he can only work part time because of his studies.
17. The Applicant said he had never applied for a Convention Travel document (CTD). When he had enquired about citizenship he had been asked why he wanted to be a citizen. He said that he understood one of the benefits was getting an Australia passport upon which he could travel, but this was not his reason for applying. He informed the Tribunal that he thought after being here for 8 or 9 years it might be nice to go to New Zealand or Bali one day because they were so close by.
18. Notwithstanding the fact that he had been granted refugee status he said he was told by the Respondent to go to the Chinese Embassy for a passport. In his statement dated 11 November 2002 (T10 p59) he said he had been refused ‘instantly’.
19. In summarising his position, the Applicant said he was proud to be a permanent resident of Australia and wanted to be an Australian citizen.
SUBMISSION: RESPONDENT
20. The solicitor for the Respondent referred the Tribunal to section 13(1) of the Act. Under that section a decision-maker, in considering an application for a grant of citizenship, cannot grant citizenship unless all the criteria set out in sub-sections (a) to (j) of section 13(1) have been satisfied. The Respondent contended that the Applicant does not meet the provisions of section 13(1)(d) and (e) because he was only a permanent resident for 17 days before the date of his application (T6 p43, T8 p46).
21. Nonetheless, section 13(4)(b)(iv) provides a discretion for the Respondent to take into account periods of residence other than that as a permanent resident. The discretion can be exercised if an Applicant would otherwise suffer significant hardship or disadvantage.
22. The ACI, in particular paragraphs 4.3.33 and 4.3.34 to 4.3.37 (T4 p18), provide guidance on the exercise of the Respondent's discretion, including that the discretion would usually only be exercised where:
·the Applicant had 12 months continuous permanent residence in Australia prior to the date of application; and
·in one of the following situations of hardship or disadvantage;
- exclusion from overseas travel;
- refusal of employment due to it being restricted to Australian citizens; or
ineligibility to represent Australia in an international forum.
In addition, paragraph 4.3.37 notes that there may be other circumstances, which warrant use of the discretion outside the normal policy guidelines.
23. The solicitor for the Respondent addressed each of the relevant provisions in the ACI as follows:
· Twelve months continuous permanent residence prior to application
The Applicant does not meet this policy guideline.
· Exclusion from overseas travel
On 7 August 2002 the Applicant was granted a Protection visa, and therefore accepted as a refugee to whom Australia has protection obligations. As such he was entitled to a UN Convention travel document, or Titre de Voyage, which can be issued to recognised refugees with validity of up to two years to allow the person to travel overseas (T11 p61)
· Refusal of employment due to it being restricted to Australian citizens
The Applicant claimed in his statement (T10 p59) that he has an interest in becoming a public servant. However, the Applicant provided no evidence that he had been refused employment solely on the grounds that the employment was restricted to Australian citizens or that alternative sources of employment were not reasonably available to him.
The Respondent contended that the Applicant does not meet this policy guideline for the exercise of the discretion.
· Ineligibility to represent Australia in an international forum.
The Applicant does not meet this policy guideline, nor was there any contention made in this regard.
· Other Circumstances
The solicitor for the Respondent submitted that there do not appear to be any other circumstances to warrant exercise of the discretion in accordance with paragraph 4.3.37 of the ACI (T4 p20).
24. The Tribunal discussed with the solicitor for the Respondent whether it was bound by the ACI. The solicitor referred the Tribunal to Drake v Minister for Immigration and Ethnic Affairs (1979) 2 ALD 60 where it was held that there were no cogent reasons for the Tribunal not to apply the ACI.
25. The Tribunal observed that if the Applicant had been granted refugee status at the time of application or if the RRT had been able to make orders rather than remit the matter to the Respondent, then the Applicant may have met the residency requirements. In this regard the solicitor for the Respondent referred the Tribunal to Al- Mughrabi and Secretary, Department of Immigration and Multicultural Affairs [1999] AATA 164 which addressed both whether the delay could be regarded as an administrative error for the purposes of section 13(5) of the Act, and the issue of backdating permanent residency status.
26. In conclusion, the solicitor for the Respondent contended that the Applicant failed to satisfy both the residence requirements under section 13(1) of the Act. She also submitted that the Applicant’s circumstances do not come within the policy guidelines for the exercise of the discretion under section 13(4)(b)(iv) and hence the discretion in section 13(4)(b)(iv) should not be exercised in his favour.
27. The Tribunal discussed with the solicitor for the Respondent the ‘practical differences’ between citizenship and permanent residence. Other than the right to a passport and some jobs that are limited, largely for security purpose, to Australian citizens, the solicitor could provide no other assistance. The Tribunal enquired about entitlement to vote and the Applicant told the tribunal he had been sent forms to register to vote.
FINDINGS
28. In coming to the correct and preferable decision, the Tribunal took into account all the evidence, submissions, case law and relevant legislation.
29. The RRT provided information relating to the Applicant’s experiences previous to his life in Australia (T5 p22):
“[h]e has suffered and fears persecution in India, Nepal, and Peoples Republic of China (PRC) because of political views which may be imputed to him and because of his race (Tibetan ethnicity) and religion (Christian).”
30. The Applicant commenced life in Australia, alone in 1996 and this has been his adopted home ever since.
31. Soon after his arrival the Applicant obtained a job and in recent times has worked as a labourer. He is studying and trying to improve his credentials. He has applied for many professional jobs without success and has subsequently accepted menial work disproportionate to his background skills. He is presently working as his studies permit and impressed the Tribunal as hardworking.
32. From his evidence the Applicant appeared to have competent English speaking skills. He experienced the ignominy of evidently being sent to the Chinese embassy to seek a passport.
33. The Applicant’s evidence was simply that he wants to be an Australian citizen.
34. There was no dispute that the Applicant did not meet the residence requirements under section 13(1) of the Act in that, at the time he lodged his application for citizenship, he had been a permanent resident for only 17 days.
35. However if an Applicant would suffer significant hardship or disadvantage if the application were not granted, section 13(4)(b)(iv) provides a discretion to take into account lawful periods of residence other than that as a permanent resident.
36. Guidance on the exercise of the discretion is provide by the ACI, in particular paragraphs 4.3.33 and 4.3.34 to 4.3.37 (T4 p18) These paragraphs provide that the discretion would usually (Tribunal’s emphasis) only be exercised where the Applicant had 12 months continuous permanent residence in Australia prior to the date of application. There is no doubt that the Applicant does not meet this criteria but the Tribunal notes that this is not an essential pre-requisite to the exercise of the discretion.
37. Before the discretion can be exercised there must be evidence of hardship or disadvantage. Examples of hardship or disadvantage are outlined in the ACI.
Exclusion from overseas travel
· “the applicant would be excluded from travelling internationally because he/she cannot obtain a passport because he/she is excluded from travelling with immediate Australian family; …”
38. The Respondent referred to the e-mail dated 15 November 2002 (T11 p61) containing information provided by DFAT about the UN Convention travel document, or Titre de Voyage. This information is consistent with that included in paragraph 4.3.36 of the ACI. The Tribunal accepts that the Applicant may be eligible for such a travel document and could therefore travel overseas. For that reason the Tribunal finds that the Applicant does not meet this policy guideline for the exercise of the discretion.
Refusal of Employment
· “the applicant can demonstrate that he/she has been refused employment solely on the grounds that the employment is restricted to Australian citizens and that alternative sources of employment are not reasonably available to him/her;”
…
39. The Applicant expressed an interest in becoming a public servant (T10 p59) and gave evidence that he was also interested in jobs with the Australia Army and DFAT. However he felt discouraged from actually applying for either because of what he understood as being citizenship requirements. His evidence was that his employment position is affected by competition in the market, that his qualifications are not recognised in Australia and that he can only work part time because of his studies. No prospective employer has specifically told him he was unsuccessful because he was not an Australia citizen.
40. The Tribunal therefore found that there was no evidence that the Applicant had been refused employment solely on the grounds that the employment is restricted to Australian citizens. Furthermore, alternative sources of employment such as labouring are available to him, to the extent that his studies permit.
The Tribunal therefore finds that the Applicant does not meet this policy guideline.Ineligibility to represent Australia in an international forum
· “The applicant would not otherwise be eligible to represent Australia in an international forum or be selected to represent Australia in a national representative team/group.
- An applicant should be of international standard to satisfy this criterion.
- If citizenship is a prerequisite to selection for a national team, the applicant should be able to demonstrate that their selection depends solely upon being granted citizenship.
…”
41. This paragraph is not applicable in this matter.
42. The Tribunal then turned to paragraph 4.3.37 (T4 p20) to consider if there may be other circumstances which warrant use of the discretion outside the normal policy guidelines, or whether it could be said that there had been an administrative error under section 13(b)(v).
43. Turning first to the question of administrative error, the only material which might be said to amount to administrative error was the delay between the Applicant’s application for permanent residence and the ultimate granting of that status.
44. One problem for the Applicant is that the Act contains no provision for the commencement date of a person’s permanent residency to be backdated. ‘Permanent residence’ commences from the date on which the Applicant obtained permanent residency, in this case 7 August 2002. Therefore notwithstanding that he had been in fact permanently resident in Australia since 1996 he was not a ‘permanent resident’ for the purposes of the Act. Had there been no delay in granting refugee status at the time of application or had the RRT been able to make orders rather than remit the matter to the Respondent, then the Applicant would have easily met the residency requirements as to time.
45.In Al Mughrabi [supra], the Tribunal considered whether the delay could be regarded as an administrative error for the purposes of the equivalent of section 13(b)(v) of the Act. In finding that it could not, Deputy President Purvis referred to Liu and Others v Department of Immigration and Ethnic Affairs (1996) 41 ALD 589, where at paragraph 26, Deputy President Purvis stated:
"... the examples of administrative error given by the Instructions are not comprehensive or exhaustive. They are not intended so to be. An 'error' is defined in the Macquarie Dictionary as a deviation from accuracy or correctness, a mistake, and 'administrative' as pertaining to administration; executive; administrative ability, problems etc. A decision as to status arrived at after considering relevant material, set aside on an application for review pursuant to an appeal process, is not a deviation from accuracy or correctness or a mistake pertaining to administration, to executive, to administrative ability or problems. The Australian Citizenship Instructions further state that 'the delegated officer must in every case be satisfied that actual error on the part of administration has occurred.' The use of the word 'administration' here implies that the purpose of the section is to remedy an error made during the processing of an application in regard to a person's status and does not apply to the result of a complicated assessment decision making process regarding refugee status. It is not appropriate to widen the scope of ”administrative error” to include a decision of the Department regarding refugee status which was set aside on appeal where the Refugee Review Tribunal came to a different conclusion on the facts."
46. In the present case there is no evidence that the lapse of time was attributable to any actual error on the part of the Respondent. It cannot therefore be said that there was any administrative error within the meaning of section 13(b)(v) of the Act. The Tribunal notes, however, that neither was the delay attributable to the Applicant in occasioning the delay.
47. Returning to para 4.3.37 of the ACI (T4 p20), the Tribunal observes that in Al Mughrabi [supra] Deputy President Purvis said, in referring to an earlier version of the ACI:
“It is fair to say that guidelines … are in aid of exercising a discretion conferred by the Act… If circumstances so decree, the decision-maker, in ascertaining whether there is hardship or disadvantage, is to consider such circumstances, be they of a particular or unique nature as are applicable to the particular application.”
Deputy President Purvis went on to say:
“In the exercise of discretion, however, under the Act, the Tribunal, whilst applying guidelines or policies which have been established by the Minister, ought to treat policy as no more than that and not a legislative prescription. There are circumstances where it is not appropriate to decide a matter merely by reference to a policy which has been laid down. ... Each case must be decided on its merits and the discretion cannot be so truncated by policy as to preclude consideration of the merits of a specified class of cases. … The decision-maker must be free to consider any unique circumstances of the particular case and no part of a policy can determine in advance the decision which is to be made in the circumstances of a given case. Whilst appropriate policy providing a guide is apposite, one that attempts to control the making of decisions is not. ….”
48. In Re Drake and Minister for Immigration and Ethnic Affairs (No 2) (1979) 2 ALD 634, at 639 it was stated:
"Inconsistency is not merely inelegant: it brings the process of deciding into disrepute, suggesting an arbitrariness which is incompatible with commonly accepted notions of justice."
The Tribunal agrees that to deviate from the policy should not be done lightly but each case must be examined on its own merits.
49. It might be said that the Applicant is in no different position to that of any other refugee who is determined to get on with his or her life in a new country, having come from difficult circumstances. The delay in the ultimate granting of the Applicant’s permanent resident status also befalls many successful Applicants for refugee status.
50. However, not all new permanent residents are motivated by a sense of patriotism the Tribunal perceives in the Applicant. At the first opportunity he sought Australian citizenship. He understood from the letter of the Respondent dated 7 August 2002 that he was being encouraged to do so. The Applicant had no immediate need to be an Australia citizen: he did not need to travel and was not overly anxious to do so. The evidence in relation to limited employment opportunities was, at best, equivocal. He was motivated by a simple desire to be an Australian citizen.
51. The solicitor for the Respondent could not point to practical differences between citizenship and permanent residence, other than the right to a passport and some specialist jobs. As a permanent resident the Applicant has the entitlement to social security and healthcare benefits as well as the right to vote. Put somewhat inelegantly, there is no disadvantage to him in terms of access to entitlements that he already has.
52. The Tribunal finds that the Applicant would not suffer significant hardship or disadvantage, within the meaning of the statute, if a Certificate of Citizenship is not, at this time, granted to him.
53. The Tribunal is of the strong view, in the light of no apparent material benefit to the Applicant by obtaining citizenship, that his desire to become an Australia citizen should be applauded.
DECISION
54. The Tribunal affirms the decision under review.
I certify that the 54 preceding paragraphs are a true copy of the reasons for the decision herein of Ms N Isenberg, Member
Signed: A. Krilis
AssociateDate of Decision 16 July 2002
Representative for the Applicant Self Represented
Solicitor for the Respondent Ms Louise Stone
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