Zablotsky and Secretary, Department of Social Services (Social services second review)

Zablotsky and Secretary, Department of Social Services (Social services second review) [2020] AATA 3131 (26 August 2020)
Reviewnumber: 2019/0362 and 2019/0383
Division:GENERAL DIVISION
File Number(s): 2019/0362
2019/0383

Re:Elena Zablotsky
APPLICANT

AndSecretary, Department of Social Services
RESPONDENT

DECISION
Tribunal:Senior Member A Poljak
Date:26 August 2020
Place:Sydney

The decision under review is set aside, and in substitution, the Tribunal decides that:
(a)the applicant was a member of a couple with Mr Zablotsky during the period 15 October 2013 to 27 March 2017;
(b)the applicant has a debt to the Commonwealth for the overpayment of Disability Support Pension in the amount of $61,528.19; and
(c)the debt is recoverable in full.

...............................[SGD]........................................
Senior Member A Poljak
CATCHWORDS
SOCIAL SECURITY – Disability Support Pension – rate of payment – whether applicant was a member of a couple – financial aspects of relationship – nature of commitment – social aspects of relationship – sexual relationship – nature of household – recoverable debt – whether debt can be written off – whether debt can be waived – sole administrative error – special circumstances – decision under review set aside and substituted
LEGISLATION
Social Security (Administration) Act 1999 (Cth) s 68
Social Security Act 1991 (Cth) ss 4, 1223, 1236, 1237A, 1237AAD
CASES
Beadle and the Director-General of Social Security (1984) 6 ALD 1
Boskoski v Secretary, Department of Social Services [2014] AATA 915
Pelka v Secretary, Department of Family and Community Services (2006) 151 FCR 546
Re Callaghan and Secretary, Department of Social Security (1996) 45 ALD 435
Re Cullinane and Secretary, Department of Family and Community Services [2004] AATA 789
Secretary, Department of Family and Community Services and Jonauskas [2001] AATA 72
Sekhon v Secretary, Department of Family and Community Services (2003) 132 FCR 126
Skinner and Secretary, Department of Social Services [2015] AATA 569
REASONS FOR DECISION
Senior Member A Poljak
26 August 2020

Ms Elena Zablotsky, the applicant, married Mr Igor Zablotsky in Russia on 15 November 2003. The applicant has a daughter, Victoria, from a previous relationship. On 28 November 2003 Mr Zablotsky returned to Australia. The applicant came to Australia on 27 September 2005 on a Subclass 309 Partner (Provisional) visa. The applicant, Mr Zablotsky and Victoria lived together in Sydney from that time.
On 4 July 2006 the applicant was injured in a motor vehicle accident (MVA) and on 3 October 2007 the applicant was granted Disability Support Pension (DSP) at the single rate on account of the injuries she sustained. On 26 March 2009, the applicant was awarded a lump sum compensation payment of $600,000 for the MVA and as a result was subject to a DSP preclusion period from 4 July 2006 to 14 October 2013 (preclusion period). At the end of the preclusion period the applicant claimed and was granted DSP. She received DSP payments from 15 October 2013.
On 3 May 2017 the respondent assessed the applicant as a member of a couple for the purposes of determining her entitlement to DSP from 15 October 2013. This decision was affirmed by an authorised review officer (ARO) on 26 June 2017. On 5 October 2017 the respondent raised a debt against the applicant for $62,211.69 for the overpayment of DSP for the period 15 October 2013 to 27 March 2017 (relevant period). On 9 November 2017 the ARO recalculated the applicant’s debt for the relevant period to be $61,528.19.
In these proceedings, the applicant seeks review of decisions by the Social Services and Child Support Division of the Administrative Appeals Tribunal (SSCSD) made on 10 December 2018, which determined, inter alia, the following regarding the applicant:
(a)the applicant was not a member of a couple from 15 October 2013 to 25 August 2014 but that she was a member of a couple with Mr Igor Zablotsky from 26 August 2014 to 27 March 2017; and
(b)the debt remaining after recalculation of the applicant’s entitlement to DSP by Centrelink is to be written off pursuant to section 1236 of the Social Security Act 1991 (Cth) (the Act) until 30 June 2019 or until the applicant starts receiving social security payments, whichever comes first.
The issues for determination in these proceedings are:
(a)whether the applicant was a member of a couple during the relevant period;
(b)whether the applicant was overpaid DSP during the relevant period; and
(c)whether an overpayment of DSP can be waived of written off.
RELEVANT LEGISLATIVE PROVISIONS
Subsection 4(2) of the Act provides that a person is a member of a couple for the purposes of the Act if the person is legally married to another person and is not, in the Secretary’s opinion (formed as mentioned in subsection 4(3)), living separately and apart from the other person on a permanent or indefinite basis; or all of the conditions in paragraph 4(2)(b) are met.
“Partner” is defined to mean in relation to a person who is a member of a couple and means the other member of the couple. The term “member of a couple” has the meaning given by subsections 4(2), 4(3), 4(3A), 4(6) and 4(6A).
Relevantly, in forming an opinion about the relationship between two people, the Secretary is to have regard to all the circumstances of the relationship including the following matters, pursuant to subsection 4(3) of the Act:
(a) the financial aspects of the relationship, including:
(i) any joint ownership of real estate or other major assets and any joint liabilities; and
(ii) any significant pooling of financial resources especially in relation to major financial commitments; and
(iii) any legal obligations owed by one person in respect of the other person; and
(iv) the basis of any sharing of day‑to‑day household expenses;
(b) the nature of the household, including:
(i) any joint responsibility for providing care or support of children; and
(ii) the living arrangements of the people; and
(iii) the basis on which responsibility for housework is distributed;
(c) the social aspects of the relationship, including:
(i) whether the people hold themselves out as married to, or in a de facto relationship with, each other; and
(ii) the assessment of friends and regular associates of the people about the nature of their relationship; and
(iii) the basis on which the people make plans for, or engage in, joint social activities;
(d) any sexual relationship between the people;
(e) the nature of the people’s commitment to each other, including:
(i) the length of the relationship; and
(ii) the nature of any companionship and emotional support that the people provide to each other; and
(iii) whether the people consider that the relationship is likely to continue indefinitely; and
(iv) whether the people see their relationship as a marriage‑like relationship or a de facto relationship.
When deciding whether a person is in a relationship, I must have regard to the interpersonal relationship as a whole, not limited by the factors listed in subsection 4(3). The decision-maker must specifically consider the “total picture of the relationship created by all of those factors”; Pelka v Secretary, Department of Family and Community Services (2006) 151 FCR 546.
Whilst all aspects of the relationship must be considered, differently structured relationships may satisfy different criteria set out in subsection 4(3). As the Tribunal observed in Re Cullinane and Secretary, Department of Family and Community Services [2004] AATA 789 at [16]:
People must be free to structure their domestic relationships as they please. But it is still necessary to attempt to characterise the relationship where the decision whether or not to take into account the other person’s income depends on whether they are members of a couple, or merely share a common address. The criteria offer common-sense indicators. One need not satisfy them all; indeed, one may satisfy few of them but still be considered to be a member of a couple if the decision-maker forms the view that the applicant is in fact a member of a couple.
Deputy President J W Constance said in Boskoski v Secretary, Department of Social Services [2014] AATA 915 at [63]:
In considering the various criteria set out in subsection 4(3) it is necessary to take an objective view of the facts. However, the subjective views of the parties may be relevant in considering aspects of the relationship, such as the commitment of each party to the other.
THE APPLICANT’S RELATIONSHIP STATUS
Financial Aspects
The applicant has filed with the Tribunal large amounts of evidence regarding past assets and liabilities that she shared with Mr Zablotsky, with emphasis on how funds were contributed by each party. For the purposes of these proceedings, I am only concerned with the financial aspects of the relationship as it was during the relevant period. I will not be detailing all the assets and liabilities of the applicant and Mr Zablotsky since they were married unless they go to the relevant period because, firstly, it will not assist me in resolving the relevant issues in this matter and secondly, there are Supreme Court of NSW proceedings on foot dealing with the division of property.
During the relevant period, the financial aspects of the applicant’s relationship with Mr Zablotsky are detailed below.
On 15 October 2013 the applicant was the owner of Unit 19. Mr Zablotsky was the owner of Unit 20. At hearing, the applicant said that despite owning and living in separate adjacent units for a short period of time, Mr Zablotsky supported her and her daughter financially and continued to buy her groceries.
On 20 June 2007 the applicant opened a savings account with St George Bank which was current as at 19 July 2017. Mr Zablotsky was a joint signatory on the account during the relevant period. On 11 April 2011 Mr Zablotsky opened a Visa credit bank account with St George Bank which was still open at the dates of hearing. The applicant is a signatory for the card and advised at hearing that she still uses the card to pay for her medical expenses and groceries. The applicant and Mr Zablotsky also held a joint account with ANZ from 7 December 2004 to 27 March 2017.
On 18 October 2013 Mr Zablotsky successfully applied for a personal loan from St George Bank. In his application form he listed his address as Unit 20. On 1 August 2014 Mr Zablotsky updated his address with Citibank as Unit 19 and on 8 August 2014, he updated his address with the Roads and Maritime Services (RMS) as Unit 19.
On 26 August 2014 Mr Zablotsky sold Unit 20.
On 30 August 2014 Mr Zablotsky updated his address with Citigroup Pty Limited as Unit 19 and on 11 September 2014, he updated his address as Unit 19 with St George Bank.
Mr Zablotsky declared in his income tax return for the 2013/2014 financial year that the applicant was his spouse and relevantly claimed a spousal rebate. In his 2014/2015 income tax return Mr Zablotsky, although not claiming a spousal rebate, declared the applicant as his spouse. The applicant also lodged an income tax return for the 2014/2015 financial year and declared Mr Zablotsky as her spouse.
On 11 February 2015 the applicant and Mr Zablotsky entered into a contract for sale for an “off the plan” purchase of a property in Miranda NSW (Miranda Property) as joint tenants. In the contract for sale, the applicant and Mr Zablotsky gave their address as Unit 19. In their updated “Declaration of “Off the Plan” Purchase” form for the Office of State Revenue, the applicant and Mr Zablotsky gave their address as Unit 20.
On 19 February 2015 the applicant and Mr Zablotsky opened an investment account with Stephen Sredoje Malesev, the vendor of the Miranda Property.
On 11 December 2015 the applicant sold Unit 19. The net proceeds from the sale were paid to Mr Zablotsky. The applicant entered a license agreement with the purchaser of Unit 19 to retain possession of the property after completion of the sale. The applicant licensed Unit 19 for $500 a week until 1 July 2016. Payment of the weekly license fee was from Mr Zablotsky’s account. At hearing, the applicant said she didn’t know what money Mr Zablotsky used to pay the license fee, but she gave Mr Zablotsky her pension in cash.
Mr Zablotsky lodged an income tax return for the 2015/2016 financial year in which he declared the applicant was his spouse. The applicant also lodged an income tax return for the same financial year declaring that Mr Zablotsky was her spouse.
On 28 November 2016 the purchase of the Miranda Property was completed. The applicant and Mr Zablotsky lived at the property until 20 August 2019.
Both the applicant and Mr Zablotsky updated their address to the Miranda Property with the RMS (on 6 December 2016) and Centrelink (on 25 January 2017). On 20 March 2017 the applicant and Mr Zablotsky each lodged a Centrelink “Relationship Details” form stating, inter alia, that they were not in a relationship with each other but were both sharing the Miranda Property as of 25 January 2017. Both stated that they were making monthly mortgage repayments.
I am satisfied that during the relevant period the applicant and Mr Zablotsky shared financial resources and benefits. The financial aspects of the applicant’s relationship with Mr Zablotsky is a strong indicator that they were in a relationship during the relevant period.
Nature of Commitment
The applicant and Mr Zablotsky were married in November 2003. Mr Zablotsky filed for a divorce in 2007 which was granted on 16 March 2007. At hearing, the applicant said that she was not aware of the divorce until June 2019. She said she was very surprised by the divorce because she believed they had a happy marriage and that the marriage was not over in 2007. The applicant claims that the signature on the application for divorce was not her signature.
Detective Senior Constable Paul Baglin gave evidence at hearing that a current investigation was underway over the allegedly fraudulent divorce application. He said that the applicant’s signature was in question, as was the signature of the Justice of the Peace (JP) who witnessed the applicant’s signature. Detective Senior Constable Baglin was directed to file and serve any witness statements or evidence obtained. On 24 September 2019, Mr Tarek Elsawi, the JP who allegedly witnessed the divorce application, gave a statement to the NSW Police. In his statement he confirmed that the handwriting of his name on the form and the signature were not his. He said he did not witness the divorce application or the other signatures. The date of signing listed on the divorce application was 22 December 2006, two weeks after Mr Elsawi’s appointment as a JP ended.
Melanie Holt, a forensic document examiner, concluded in her report dated 30 August 2019:
Based on the observations, limitations outlined and the materials available, I am of the opinion that there is more support for the alternative hypothesis (H2) i.e., that someone else, other than the writer of the Elena Zablotsky specimen signature, wrote the questioned signature on the original of Item 1 [Application for Divorce], than for the first hypothesis (H1) that Elena Zablotsky wrote the signature on Item 1 either naturally or in such a way as to disguise her signature or by accident. However, the level of that support, while stronger for the alternative, is limited or weak…
Considering the evidence of Ms Holt and Mr Elsawi, it is very likely the divorce granted in 2007 was obtained by fraud.
In Centrelink “Relationship Details” forms dated 20 March 2017, the applicant and Mr Zablotsky both stated, inter alia, that they had not been married to, or in a de facto relationship with each other, had been divorced for ten years, they shared the Miranda Property and Mr Zablotsky was the applicant’s carer.
The applicant said that she gave false evidence before the SSCSD because she “had to obey Mr Zablotsky’s demands”. She said she was completely in his hands as he had access and control of all their financial and related documents. She further said that she did not understand the correspondence between Mr Zablotsky and Centrelink and was pressured to appeal the reviewable decision with this Tribunal.
At hearing, the applicant said she agreed with the debt that she owed Centrelink because she was a member of a couple with Mr Zablotsky up until December 2018. They had joint bank accounts, they lived together, and Mr Zablotsky financially supported the applicant and her daughter. The applicant said she relied on Mr Zablotsky and her daughter for support due to her language and psychological issues resulting from the MVA. Mr Zablotsky helped her with groceries and household duties, accompanied her to the shops and to doctors’ appointments and they saw friends together for coffee. The applicant said that it was not until December 2018 this changed.
The applicant said that in December 2018 Mr Zablotsky’s personality changed and they started fighting a lot about money. She said that she found out Mr Zablotsky was planning to sell the Miranda Property and move to the Gold Coast without her.
As recently as January to February 2019, the applicant said her relationship with Mr Zablotsky was good and they were planning to go to Russia in May. However, she claims she was subject to domestic violence after February 2019 and Mr Zablotsky was subject to a provisional Apprehended Domestic Violence Order (ADVO) as of August 2019. The applicant said Mr Zablotsky moved out of the Miranda Property on 20 August 2019.
Sexual Relationship
The applicant and Mr Zablotsky did not have a sexual relationship during the relevant period. While a sexual relationship is a relevant consideration as to whether the applicant and Mr Zablotsky were members of a couple during the relevant period, it is not determinative. At hearing, the applicant said that despite the lack of a sexual relationship they still acted like spouses.
Nature of Household
As already stated, the applicant owned Unit 19 and Mr Zablotsky owned Unit 20 during the relevant period. At hearing, the applicant said that Mr Zablotsky lived in Unit 20 but visited her often. He helped the applicant clean Unit 19 and bought her groceries. They watched television together and had tea together. The applicant said that despite living separately they acted and communicated with each other like spouses.
When Mr Zablotsky sold Unit 20, he sold it furnished, stored the remaining items and moved into Unit 19 with the applicant and Victoria. She said they shared the living space, kitchen and bathroom. Mr Zablotsky sometimes slept on the sofa and sometimes in the bedroom with the applicant. Mr Zablotsky continued to support the applicant and Victoria financially by maintaining joint bank accounts and by buying groceries.
Despite owning the properties Unit 19 and Unit 20 on separate titles, I am satisfied that there was no break in the continuum of their relationship during the relevant period. Having careful regard of all the circumstances, the two adjoining properties were effectively a single household during the relevant period until 26 August 2014; when Mr Zablotsky sold Unit 20. After which, the applicant and Mr Zablotsky lived together as a couple in Unit 19 and then at the Miranda Property.
Social Aspects
During the relevant period, the applicant and Mr Zablotsky held themselves out as a married couple in bank documents and to the Australian Taxation Office.
Emma Kamensky, a lending manager at St George Bank and a friend of the applicant and Mr Zablotsky, provided a statement in these proceedings dated 14 July 2019. She also gave evidence orally at hearing. In her written statement, Ms Kamensky said she first met Mr Zablotsky in 2011. She described how Mr Zablotsky showed her photos of the applicant and expressed how much he loved her. She said Mr Zablotsky told her the applicant wasn’t well after the MVA so they “decided to separate: sell the unit and buy 2 units separately”. Ms Kamensky said she became friends with Mr Zablotsky when he bought Unit 20. She said at that time, he was “working shift work offshore”. She said sometime after organising a mortgage increase, Mr Zablotsky was thinking of selling Unit 20, as he “is offshore for 6 month [sic] (his work shift) and reconcile with [the applicant]. Soon after he sold his unit and moved into [the applicant’s] unit.” It was at that time that Ms Kamensky met the applicant. She described in her statement that the applicant and Mr Zablotsky used to go to Double Bay together for coffee and a walk late at night; sometimes with the applicant. She said she enjoyed being with the couple.

At hearing, Ms Kamensky said that she understood the applicant and Mr Zablotsky to be married. She said that not even in January 2019 did they mention a separation to her. Ms Kamensky described how Mr Zablotsky called the applicant “Bulka”, a term of affection meaning “soft and warm”.
Photographs of the applicant and Mr Zablotsky show them socialising together and with friends. The photos are dated from 28 March 2014 to 1 November 2018.
CONSIDERATION
The applicant and Mr Zablotsky benefited from pooling their resources and responsibilities during the relevant period. This was despite the physical challenges faced by the applicant as a result of the MVA and difficulties encountered in their marital relationship. As already stated, I am not convinced that there was a break in the continuum of their relationship at any stage until December 2018. A couple can structure their domestic relationships as they see fit, including the management of their financial resources and property. The applicant described a happy and loving marriage with Mr Zablotsky that spanned from 2003 until December 2018. Mr Zablotsky supported the applicant and her daughter both financially and emotionally over many years. The nature of their relationship was a spousal relationship.
Having regard to the interpersonal relationship, and the factors listed in subsection 4(3) of the Act, I am satisfied the applicant and Mr Zablotsky were members of a couple with each other during the relevant period within the meaning of paragraph 4(2)(b) of the Act.
The Debt
Subsection 1223(1) of the Act provides that when a social security payment is made and a person who obtains the benefit of the payment was not entitled for any reason to obtain that benefit, the amount of the payment is a debt due to the Commonwealth.
I am satisfied that the applicant’s rate of DSP was not accurately calculated on the basis that she was a member of a couple with Mr Zablotsky during the relevant period. Accordingly, the overpayment of DSP constitutes a legally recoverable debt.
Based on the calculations provided by the respondent I am satisfied that the amount of the overpayment received by the applicant in respect of the relevant period is $61,528.19. She owes this amount to the Commonwealth.
Can the Debt Be Waived or Written Off?
Section 1236 of the Act set out circumstances in which a debt may be written off. There is no evidence that the applicant’s debt is irrecoverable at law or that she has no capacity to repay the debt given that her whereabouts are known.
Subsection 1237A(1) of the Act provides:
Subject to subsection (1A), the Secretary must waive the right to recover the proportion of a debt that is attributable solely to an administrative error made by the Commonwealth if the debtor received in good faith the payment or payments that gave rise to that proportion of the debt.
For the debt to be waived under section 1237A of the Act, it must be found that the debt was caused solely by administrative error; see Sekhon v Secretary, Department of Family and Community Services (2003) 132 FCR 126 at [35]. There is no evidence of administrative error leading to the existence of the debt in this case. The Respondent acted upon the information given to it by the applicant. It was only when the applicant submitted, in a short space of time, competing declarations about her relationship status that the respondent initiated enquiries, which then discovered the relevant facts about the relationship. Accordingly, the debt should not be waived pursuant to section 1237A of the Act.
Section 1237AAD of the Act provides:
The Secretary may waive the right to recover all or part of a debt if the Secretary is satisfied that:
(a) the debt did not result wholly or partly from the debtor or another person knowingly:
(i) making a false statement or a false representation; or
(ii) failing or omitting to comply with a provision of this Act, the Administration Act or the 1947 Act; and
(b) there are special circumstances (other than financial hardship alone) that make it desirable to waive; and
(c) it is more appropriate to waive than to write off the debt or part of the debt.
Each of the three limbs of the section must be satisfied before the debt may be waived.
Despite the Department sending the applicant numerous letters about her reporting obligations, the applicant failed to disclose that she was a member of a couple with Mr Zablotsky during the relevant period as required by subsection 68(2) of the Social Security (Administration) Act1999 (Cth).
In Re Callaghan and Secretary, Department of Social Security (1996) 45 ALD 435, Deputy President Forgie said at [48]:
There is nothing in s 1237AAD which suggests that the word ‘knowingly’ should be given any meaning other than that a person has actual knowledge, rather than constructive knowledge, that he or she is making a false statement or representation or that he or she is failing or omitting to comply with a provision of the Act. That actual knowledge is to be ascertained by reference to the statements of the person as to his or her actual state of knowledge at the time and to events surrounding the false statement or the act or omission.
The applicant alleges that due to her language difficulties, she did not properly understand the correspondence from Centrelink. She claims that Mr Zablotsky handled all the paperwork and communicated with Centrelink on her behalf. However, the onus is on the applicant to meet her obligations as defined in Centrelink correspondence; Secretary, Department of Family and Community Services and Jonauskas [2001] AATA 72. Ignorance of the law is no excuse. During the relevant period, the applicant and Mr Zablotsky knowingly made a false representation, resulting from her failure to disclose and his misrepresentations.
That brings me to consider whether there are special circumstances other than financial hardship alone which make it desirable to waive the debt. Special circumstances are not defined in the Act however the Tribunal is provided some guidance by several Federal Court and Administrative Appeals Tribunal cases. In the decision of Beadle and the Director-General of Social Security (1984) 6 ALD 1 at [3]:
An expression such as “special circumstances” is by its very nature incapable of precise or exhaustive definition. The qualifying adjective looks to circumstances that are unusual, uncommon or exceptional. Whether circumstances answer any of these descriptions must depend upon the context in which they occur. For it is the context which allows one to say that the circumstances in one case are markedly different from the usual run of cases. This is not to say that the circumstances must be unique but they must have a particular quality of unusualness that permits them to be described as special.
(emphasis added)
In a letter dated 30 June 2019, Dr Yuliya Richard, a psychologist, described the applicant’s mental health condition and recorded advice received from the applicant’s former psychologist who had been treating her for several years. The report describes the applicant as able to provide accurate and coherent information in relation to her matter and is capable of making her own decisions. The report also states that the applicant is currently exposed to verbal, emotional and physical abuse from Mr Zablotsky. This was reiterated by the applicant at hearing.
The applicant plainly has issues with her health stemming from the MVA, but the state of her health is not unusual or uncommon for someone in receipt of the DSP. There is nothing in the circumstances described by the applicant, which are unusual or uncommon and would warrant the exercise of the discretion to waive all or part of the applicant debt. Accordingly, I am not satisfied that the applicant’s circumstances are sufficiently special to warrant exercising the discretion to waive all or part of the debt under section 1237AAD of the Act.
It is in the public interest that the applicant’s debt is repaid. In Skinner and Secretary, Department of Social Services [2015] AATA 569 the Tribunal said at [48]:
It is important to recognise the need to ensure the integrity of the social security system and the public interest. This means that those recipients who have received monies to which they are not entitled, are generally expected to repay those monies unless the repayment is in the specific circumstances unjust, unreasonable or inappropriate.
The applicant has not advanced a sound reason as to why the debt should not be repaid.
Neither part nor all of the debt should be written off or waived.
DECISION
The decision under review is set aside and in substitution I find that:
(a)the applicant was a member of a couple with Mr Zablotsky during the period 15 October 2013 to 27 March 2017;
(b)the applicant has a debt to the Commonwealth for the overpayment of DSP in the amount of $61,528.19; and
(c)the debt is recoverable in full.

I certify that the preceding 63 (sixty-three) paragraphs are a true copy of the reasons for the decision herein of Senior Member A Poljak

................................[SGD]........................................
Associate
Dated: 26 August 2020

Date(s) of hearing: 19 July 2019 & 3 October 2019

Date final submissions received: 17 March 2020

Applicant: In person

Solicitors for the Respondent: Services Australia

[2020] AATA 3131

26 August 2020

Key Legal Topics

Areas of Law

Administrative Law

Statutory Interpretation

Legal Concepts

Judicial Review

Jurisdiction

Statutory Construction

Remedies

Standing

Date(s) of hearing:	19 July 2019 & 3 October 2019
Date final submissions received:	17 March 2020
Applicant:	In person
Solicitors for the Respondent:	Services Australia