Beneficiary AP v Chief Executive of the Ministry of Social Development
[2019] NZHC 2208
•6 September 2019
ORDER PROHIBITING PUBLICATION OF NAME OR IDENTIFYING PARTICULARS OF THE APPELLANT. IN THE HIGH COURT OF NEW ZEALAND WELLINGTON REGISTRY
I TE KŌTI MATUA O AOTEAROA TE WHANGANUI-A-TARA ROHE
CIV-2019-485-213
[2019] NZHC 2208
IN THE MATTER OF an appeal by way of Case Stated from the determination of the Social Security Appeal Authority under section 12Q of the Social Security Act 1964 BETWEEN
BENEFICIARY AP
Appellant
AND
THE CHIEF EXECUTIVE OF THE MINISTRY OF SOCIAL DEVELOPMENT
Respondent
Hearing: 6 August 2019 Appearances:
W L Aldred for Appellant
K Hutchinson for Respondent
Judgment:
6 September 2019
JUDGMENT OF COOKE J
[1] The appellant appeals by way of case stated from a decision of the Social Security Appeal Authority (the Authority) pursuant to s 12Q of the Social Security Act 1964 (the Act).1
[2] The appellant is a single parent. Over the years she has needed assistance from the Ministry of Social Development (the Ministry) from time to time, including a need for emergency assistance. Such assistance is effectively treated as a loan advanced by
1 The Social Security Act 1964 has since been repealed by the Social Security Act 2018.
BENEFICIARY AP v THE CHIEF EXECUTIVE OF THE MINISTRY OF SOCIAL DEVELOPMENT [2019]
NZHC 2208 [6 September 2019]
the Ministry, which is then repaid by taking deductions for benefits otherwise payable in accordance with determinations made under the Act. She sought confirmation from the Ministry as to the extent of the amounts that she was required to repay according to the Ministry, and then with the assistance of an advocate she contested what the Ministry had done in relation to her case in accordance with her review and appeal rights under the Act.
[3] In a decision dated 31 March 2017 the Authority decided that the scope of her appeal was limited to the calculation of her indebtedness from 3 October 2008 only. But she had wanted to challenge determinations by the Ministry prior to that date. In effect what the appeal concerns is a dispute about the scope of her appeal rights.
[4] On 16 April 2019 the Authority formulated a case stated for the appeal pursuant to s 12Q of the Act. The two questions of law formulated are:
(a)Did the Authority err in its characterisation of the decision under review as being money owed by [AP] from 3 October 2008 only?
(b)Did the Authority wrongfully limit the scope of [AP’s] appeal when it held that the Benefits Review Committee report put [AP] “on notice” as to that scope?
[5] Written submissions were provided both by Ms Aldred on behalf of the appellant, and Ms Hutchinson on behalf of the Chief Executive on these questions.
[6] As I indicated at the hearing, however, it seems to me that the review and appeal processes have been adversely affected by a degree of confusion as to how the appellant’s initial request for a review of the decisions affecting her should have been addressed. Rather than recording, and then addressing, the submissions that counsel have advanced in relation to the case stated questions, it seems more appropriate to address the background, explaining where I think the matter has gone wrong. I will then address the consequence for questions formulated by way of case stated.
General approach
[7] It is appropriate to identify the general approach to the interpretation and application of the provisions of the Act.
[8] In Brosnahan v Chief Executive of the Ministry of Social Development Kós J referred to the adoption of a “generous unniggardly interpretation” to ACC legislation.
He then held:2
[33] I do not think that interpretative approach should be confined to that Act, as if it were sui generis. In my respectful opinion it is applicable to social policy legislation generally. The reason for that is obvious. In a context such as the present Act, Parliament is dealing with the expectations of the poor and disadvantaged. Small individual sums of money may have very significant personal consequences. Where those expectations are the fair and reasonable product of statutory language, and are consistent with the overall statutory purpose, they are not, I think, to be read down except by language of the clearest kind. Lines of exclusion in a welfare context need to be drawn clearly.
[9] It seems to me that this involves interpreting the text of the enactment in light of its purpose in the usual way.3 I accept Ms Aldred’s submission that such an approach not only applies to statutory interpretation, but also to the application of the provisions once interpreted.
[10] I also accept that it is not appropriate to place unwarranted administrative burdens on the Ministry given the nature and scope of decision-making that must be undertaken under the Act, including in relation to the review and appeal functions. This was addressed by the Supreme Court in Arbuthnot v Chief Executive of the Department of Work and Income where Blanchard J said for the Court:4
[18] We consider first the scheme of the review/appeal provisions of the Act. The Department administers many thousands of social welfare benefits. Naturally, its officials will make many decisions with which a beneficiary or someone claiming entitlement to a benefit will disagree. It would not be sensible for all of them to have to go immediately to a formal appeal process without the decision first being reviewed at a more senior level within the Department. Plainly, it would simply not be possible for the Chief Executive personally to undertake reviews on this scale. Furthermore, it has seemed
2 Brosnahan v The Chief Executive of the Ministry of Social Development [2013] NZHC 2618, [2014] NZAR 284 (footnote omitted).
3 See McKeefry v Accident Compensation Corporation [2019] NZHC 612 at [8].
4 Arbuthnot v Chief Executive of the Department of Work and Income [2007] NZSC 55, [2008] 1 NZLR 13.
appropriate to have some input into the review process from a person from outside the Department. The Act therefore provides for the mechanism of the BRC, which consists of two departmental officials with no involvement in the decision under review and a third person appointed by the Minister “to represent the interests of the community”. But even that third person must be someone who is “resident in or closely connected with” the relevant office of the Department.
[11] It was this very factor that led to the establishment of reviews by committees as part of the review/appeal structure.5
[12] I approach the relevant circumstances of the present case, and the interpretation issues against that background.
The relevant circumstances
[13] Prior to formally complaining about her case the appellant had spent some time engaging with the Ministry seeking to understand the level of her indebtedness. She encountered some difficulty in receiving clear advice on that issue. Ultimately by letter dated 27 November 2014 Ms Linda Coffin, the Service Centre Manager, sent her a letter commencing as follows:
As requested, attached is a copy of the full breakdown of your debt as actioned by National Office for the period August 1996 – June 2014.
[14] As suggested there was a full schedule attached to that letter showing the then indebtedness at the figure of $16,868.90 and the steps that had been taken leading to that total going back to 1996. The schedule recorded that the debt was currently being offset from sole person support payments being made to the appellant.
[15] By that stage the appellant had an advocate, Mr Graham Howell, to assist her. The appellant and Mr Howell met with an Assistant Service Centre Manager on 1 December 2014. It was explained that the appellant wanted to advance her statutory review rights to the Benefits Review Committee (the BRC) under the Act. Under the scheme of the Act, a person can have decisions reviewed by the BRC, and then there is a right of appeal from decisions of the BRC to the Authority.
5 See Bocxe v The Chief Executive of the Ministry of Social Development, HC Auckland, CIV-2008- 485-1122, 1 October 2008 at [29]–[30].
[16] It is important to understand the rights of review the appellant had. Section 10A of the Act provides:
10A Review of decisions of chief executive made under delegation by other decision makers
(1)This section applies to a person and a decision both of which are specified in any 1 of the rows of the following table, but only if the decision is made by a decision maker in the exercise of any power, function, or discretion conferred on the decision maker by delegation:
Row Person Decision 1 An applicant or a beneficiary A decision of the chief executive made in relation to the applicant or beneficiary under any enactment
referred to in any of the paragraphs of section 12J(1) (other than a decision referred to in section 12J(2) or (3))
… (1A) A person to whom this section applies may apply in writing for a review of the decision to the appropriate benefits review committee established under this section.
(1B) The application must be made—
(a)within 3 months after receiving notification of the decision; or
(b)if the committee considers there is good reason for the delay, within such further period as the committee may allow on application made either before or after the expiration of that period of 3 months.
…
[17] Following the meeting with the Assistant Service Centre Manager, Mr Howell sent an email dated 2 December 2014 to the Ministry confirming the extent of the requested review. It stated:
Thanks David for the break-down of advances and RAP provided since 1996 and the debt recovery that took place to 20 September 2009 when the debt was only $281, and that this amount has been fully re-paid as well. The review is into the entire outstanding debt of $16,868. This means each individual amount is under review.
That is, for example, the outstanding advance of $861 (the original amount provided was $870 in regards “bond and rent” to the Serbian Church on 3 October 2008) and $406 (the original amount provided was $800 in regards assistance provided on 7 November 2008 for accommodation purposes where the assistance was paid to the Serbian Church) and so on ending with the debt of $297.50 (the original amount provided was $350 in regards assistance
provided on 16 June 2014 for accommodation purposes where the assistance was paid to Quinovic Property Management).
Without going into detail, it is submitted that most, if not all of the debts between 2008 and February 2013 have been re-paid In full, and that the advances provided since have been re-paid either in full or by more than the mount Wk&I say.
The claim being made we believe will be proven by evidence of the difference between the income support our client was entitled to (main benefit, accommodation supplement, disability allowance, child care subsidy and another income support she was eligible for and that which was issued. The difference being debt recovery unless other offsets can be proven. Should in the course of the proof of entitlement it be discovered our client was under- paid then we believe the chief executive has the ability under section 80AA to rectify any under-payments.
It is also very possible advances paid direct to landlords may have been refunded to the Crown account by landlords in situations where she shifted and the bond was redeemable.
The BRS case sheets indicate a review of decision lodged by BRS on 3 March of this year, but our client advises she has been challenging the debt for some considerable time and UCVII notes dated 14 February 2013 indicate this. Can we be provided with the HIYA for the 14 February 2013 application as I presume due diligence lodged this with HIYA and a number exists.
[18] I accept Ms Aldred’s submission that on the face of the email exchange, the appellant was seeking to have considered all of the underlying decisions that were evidenced in the entries in the schedule to the letter leading to the calculation of the debt that she owed. The examples referred to in the email post-dated October 2008, but there was nothing in the email that suggested a limitation, and the statement that “each individual amount is under review” must include the amounts in the schedule that pre-dated October 2008. What was being sought was a full review of her case and the resulting balance.
[19] It may be that most, if not all, of the underlying statutory decisions reflected in the entries in the schedule to s 10A may have been formally advised to the appellant more than three months previously so that any review of the underlying decision might have to be addressed under the power in s 10A(1B)(b).
Scope of the requested review
[20] In terms of the ability to challenge statutory decisions of the kind referred to in s 10A(1), there are two ways of viewing the appellant’s request for a full review:
(a)the request could be treated as a request for a review of all the underlying statutory decisions that have led to the ultimate balance, including if necessary a review of such decisions out of time under s 10A(1B)(b); or
(b)the request could be treated as seeking a review of a new statutory decision made by the Ministry in relation to the calculation of the amount owing by the appellant, and/or a new decision to recover that balance from her under the statutory provisions (such as the recovery decisions under s 86A).
[21] The Ministry proceeded on the basis described in [20](b). By letter dated 13 January 2015 the Ministry wrote to the appellant. The first line stated:
We have received your application for a review of our decision to seek recovery of the balance of $16768.90 owed to the Ministry.
[22] In an internal review document, the Ministry described the decision being reviewed in the following terms:
The decision to seek recovery of an amount of $16768.90 owed to the Ministry. The decision was made on 27 November 2014.
[23] I do not read the letter of 27 November 2014 as a letter communicating a new statutory decision. All it did was advise what the current balance was and provide schedules to indicate how that was calculated. The schedules recorded that the debt was being recovered by deductions from the benefit, but no fresh decision had been made or communicated. In Arbuthnot the Supreme Court said:6
[25] It is fundamental that an appeal must be against the result to which a decision-maker has come, namely the order or declaration made or other relief given, not directly against the conclusions reached by the decision-maker which led to that result, although of course any flaws in those conclusions may provide the means of impeaching the result. A litigant cannot therefore, save perhaps in very exceptional circumstances, bring an appeal when they have been entirely successful and do not wish to alter the result. The successful litigant cannot seek to have the appeal body overturn unfavourable factual or legal conclusions made on the journey to that result which have had no significant impact on where the decision-maker ultimately arrived. In short,
6 Arbuthnot, above n 4 (footnote omitted).
there is no right of appeal against the reasons for a judgment, only against the judgment itself.
[24]That is true of the review of a decision as well.
[25] It is important not to take an unduly narrow or formal approach to review requests of this kind, however. Previous practice appears to indicate, appropriately, that no particular form is required to make such an application.7 The letter of 27 November might legitimately be treated as a formal letter of advice communicating what the Ministry had decided recover in the exercise of its statutory powers. That may have been an acceptable interpretation in accordance with the principles outlined at [7]–[10] above.
[26] But treating the request for review in this way could cause difficulties if there were any suggestion of a limitation on the scope of the review — for example, if it was later said that the underlying statutory decisions could not be considered in that process. And there was such a limitation imposed here. The Ministry said that anything that happened prior to 3 October 2008 was not within the scope of the requested review, as at that date the appellant’s recorded balance was zero. In other words, the Ministry was proceeding on the basis that the review would not consider anything that occurred prior to that time. As a result, the appellant’s request was not being properly responded to. She was asking for her balance, and then saying the balance was not correct, indicating that all inputs into it were part of her request for review. That request for review needed to be dealt with on its merits and should not be defeated by procedural formalism. In my view this is where this case has first gone wrong.
Decisions on scope of review
[27] The appellant and Mr Howell were sent the Ministry’s internal report dated 27 January 2015 to the BRC which stated that the decision being reviewed was the decision to seek recovery of the outstanding balance, limited to the steps that had taken place after 3 October 2008.
7 See, for example, Daniels v Chief Executive Officer of the Department of Work and Income [2002] NZFLR 998, [2002] NZAR 615 (HC) at [6(c)].
[28] By letter dated 20 May 2016 Mr Howell subsequently objected to the characterisation of the review. He said that the review was of the overall debt, and the only time that it could legitimately be considered at zero was at the outset (on 8 October 1996). He itemised in detail the steps that had been erroneously taken to determine the overall size of the debt, including as a consequence of decisions taken before 3 October 2008.
[29] The BRC decision was nevertheless limited to what had occurred before October 2008. It also said it was only reviewing “the decision to seek recovery of an amount of $16,768.90 owed to the Ministry” said to have been made on 27 November 2014. This introduced a further possible limitation on the review to the extent it was suggested that the appellant could not challenge the underlying decisions themselves. The BRC appeared to address the accuracy of the calculation of the debt, and not just the decision to recover it, however. The BRC said:
Advance payments of benefits and Special Needs Grants are payments made on specific application by the Applicant. The making of such payment does not normally in the Committee’s view amount to an error. The Applicant did not provide evidence to suggest that these payments were made in error and the Applicant had not applied for these.
…
In relation to Overpayments established against the Applicants various benefits, the Applicant was unable to point to any error on part of the Ministry in establishing these overpayments therefore no grounds for any debt write- off.
[30] On this basis the BRC agreed to uphold the decision, albeit with one adjustment to the calculation, leading to the calculation of the total owing being $651.27 so that the total debt was said to be $16,117.63. The $651.27 was written off.8 That decision was sent to the appellant and Mr Howell by letter dated 25 May 2016.
[31] On 11 August 2016 an amended version of the decision appears to have been released by the BRC. An additional paragraph was added to the decision stating:
The Committee acknowledges that the Applicant had an expectation the Committee would review each individual debt incurred with the Ministry, including debts already repaid as the Applicant believed some of the
8 Before the Authority the amount said to be owing by the Ministry was further reduced to
$15,339.62.
recoverable assistance should have been non-recoverable. The Committee advised the Applicant that this hearing was to establish whether the Ministry was correct in seeking recovery of the existing debts. The Committee advised the Applicant that in order to review each individual debt ever established, the Review of Decision process is to be followed for each individual decision requiring review.
[32] As previously indicated, as a matter of substance that had actually been what the appellant and Mr Howell originally sought. The letter of 27 November 2014 had provided advice on what was calculated as owing as a consequence of earlier decisions, following which the appellant had advised that she wanted to review all of the underlying inputs.
[33] I accept that a calculation by the Ministry of the total amount owing by a beneficiary could result in a statutory decision to recover that amount under the provisions of the Act, and that decision could by itself be subject to a right of review. It might be possible to see the Ministry’s letter of 27 November 2014 in that way. But even if it was treated in that way there were two problems with the Ministry’s approach:
(a)First, the assessment of what is owing goes back no further than 3 October 2008 simply on the basis that, on the Ministry’s calculations, the appellant had a zero balance at that stage. But the appellant was contending that that was wrong, as decisions prior to that date had involved over-recovery by the Ministry. If the 27 November 2014 letter is treated as a calculation of the amount owing, and a fresh statutory decision to recover that amount, then a request to review the balance would incorporate all calculation errors alleged.
(b)Secondly, the review seems to have been limited to the exercise of the statutory powers of recovery rather than those exercised to establish the debt in the first place. It is apparent that the appellant wanted to challenge the underlying decision as part of her review.
Decision by Authority
[34] An appeal to the Social Security Appeal Authority was then lodged by the appellant. There are such rights of appeal under s 12J(1)(a) of the Act in relation to “any decision or determination” of the Chief Executive of Part 1A of the Act.9
[35] An issue of the scope of the requested review, and accordingly of the appeal, was then raised. The appellant and Mr Howell said she was challenging all the underlying decisions that had led to the calculation of the amount owing. The Ministry did not agree. The Appeal Authority decided to deal with that by way of a preliminary decision. It described the issue in the following way:10
[1] At the hearing on 17 March 2017 the subject of this appeal was disputed by the parties. [AP] says that she appeals all decisions made by the Ministry since 1998.
[2] The Ministry submit that the appeal is limited to the calculation of debt incurred by [AP] since 2008.
[36]The Authority determined the matter in the Ministry’s favour. It held:
[17] For the following reasons we conclude that the subject of the application to the Benefits Review Committee, and therefore the subject of this appeal, is the decision issued on 27 November 2014, that is, the calculation of the debt that the Ministry states [AP] owes from 3 October 2008.
…
[37]The Authority then went on to provide the reasons for that view.
[38] The appeal proceeded with this limitation. By decision dated 22 November 2017 the Authority, after hearing from the parties, dismissed the appeal.11 During the course of its reasoning it reiterated the limits on the scope of the appeal. It addressed particular grants made to the appellant, and accepted the Ministry’s position on those grants.
9 In Arbuthnot, the Supreme Court held there was no material significance in the use of the word determination as well at decision: above n 4, at [24].
10 Re P [2017] NZSSAA 011.
11 Re P [2017] NZSSAA 066.
Analysis
[39] As indicated it seems to me that both the review by the BRC, and the appeal by the Authority have been limited by a misinterpretation of the rights the appellant had, and what she was seeking. At the very least there has been a misunderstanding.
[40] The rights of review under s 10A are only in relation to decisions. The correspondence informing the appellant of the calculation of the balance said to be owing is not necessarily a statutory decision, but the extent to which it was, there was nothing about 3 October 2008 that created a cut-off point to any challenge to the calculations. The calculations are the product of underlying decisions in relation to the appellant’s case. As I have found, the appellant wished to have these reviewed. The Ministry’s internal approach was to suggest that the letter of 27 November 2014 involved a fresh statutory decision to seek recovery of that amount, but even if that approach is taken, it cannot be presumed that everything done before October 2008 was accurate simply because the Ministry said there was a nil balance at that date. The appellant did not accept that, and this was the very issue she wanted to have reviewed, and then appealed.
[41] The correct position was that the appellant had effectively sought a review of all the decisions/calculations made leading to the suggested calculation of a debt owing by her in the amount of $16,868.90. To the extent that involved a request to review decisions out of time, she had the right to have that request considered on its merits under s 10A(1B)(b). That sub-section was not applied by the BRC. Neither was the position clarified. The consequence is that her rights of review, and subsequent rights of appeal have been curtailed. It is the person seeking review that determines the intended scope of it. It is not for the BRC, or indeed the Authority to itself decide what the scope of the review will be.
Case stated questions
[42]The first question of law in the Case Stated Appeal is:
(a)Did the Authority err in its characterisation of its decision under review as being money owed by [AP] from 3 October 2008 only?
[43] The Authority did so err. What the appellant had sought to have reviewed, and then to have appealed, were all decisions made by the Chief Executive leading to the calculation of her total indebtedness. That was so whether or not the decisions were made before or after 3 October 2008. That may well have encompassed a request for the review of decisions out of time under s 10A(1B)(b) which should have been, but was not, considered on its merits.
[44] In any event, to the extent that the 27 November 2014 letter was a fresh statutory decision to recover a particular balance, the request for the review covered all inputs into that balance, whether or not that encompassed matters that occurred before 3 October 2008.
[45] On either approach, the appellant’s rights of review, and then appeal, were misinterpreted by both the BRC and the Authority.
[46]The second question of law in the Case Stated Appeal is:
(a)Did the Authority wrongfully limit the scope of [AP’s] appeal when it held that the BRC report put [AP] “on notice” as to that scope?
[47] Amongst the reasons outlined for the Authority taking the view that the scope of the review before the BRC was limited was that the BRC had sent a report dated 27 January 2015 to Mr Howell and the appellant putting them notice that “the scope of this review was post 3 October 2008”.12 The Authority said that neither the appellant or Mr Howell disputed the scope of the review before 20 May 2016. The Authority then said:
[18] We do not consider it reasonable for Mr Howell to consider that he can extend the scope of a BRC review through submissions, particularly when they are sent some 18 months after the Report to the BRC.
[48] In my view this approach was misconceived. The real issue was the scope of the review originally requested, which turns on what the appellant said at the first meeting, and what Mr Howell said in his follow up email of 2 December 2014. That
12 Re P, above n 10, at [17](c).
was not analysed by the Authority. The fact that the appellant and Mr Howell were sent documents by the Ministry/BRC which stated that they were limited what was being reviewed is beside the point if they had misinterpreted what had been sought. Moreover a person in the appellant’s position always has the ability to apply for a review out of time under s 10A(1B)(b), so even the submission of 20 May 2016 could have been treated as such a request.
[49] Further, and in any event, if both the Ministry and the BRC had decided to proceed on the basis that the appellant was entitled to have reviewed the calculation of her debt, and the recovery of the debt as advised in the letter of 27 November 2014, then she was entitled to have reviewed all of the inputs into that calculation, and that recovery. If she wanted to say that it was wrong to say she had a nil balance as at 3 October 2008, then that was within the scope of the review.
[50] On any view of it the approach was inappropriate and failed to recognise the review and appeal rights established under the Act. The process has become distracted by a formalistic question on the scope of the review, rather than getting on and addressing any issues on the merits.
[51] I am mindful of not reaching decisions creating an undue burden in the administration of the Act. But the amount of time and energy taken up by the formalistic question on the scope of the review (including this very appeal) would have been far better spent on the merits of the appellant’s case.
Result and relief
[52] Given that I have concluded that both of the questions in this case stated should be answered in the appellant’s favour, I then need to decide on the appropriate form of any remedy this Court should grant. Rule 21.14 of the High Court Rules 2016 provides as follows:
21.14Determination of questions
After hearing and determining the question of law or fact (or both) in a case stated, the court must do 1 or more of the following things:
(a)in the case of an appeal, reverse, confirm, or amend the decision in respect of which the case was stated:
(b)in the case of an appeal, remit the matter to the tribunal for reconsideration and decision in accordance with the opinion of the court on the question of law or fact (or both):
(c)in every other case, remit the matter to the tribunal with the opinion of the court:
(d)in any case, make any other order that is just.
[53] At the hearing I discussed with counsel whether the true error in the current case was that the BRC had failed to consider the appellant’s application as an application for a review out of time under s 10A(1B)(b). If so the appropriate order might need to remit the case to the BRC under r 24.14(d) in order for it to make that determination.
[54] For a series of reasons I have decided not to do that. First it is not the conventional relief that the Court would give, which would usually be to remit the matter to the Authority under r 21.14(b). Secondly the Ministry and the BRC treated the appellant’s review request as a review of a fresh decision — the decision supposedly indicated in the letter of 27 November 2014 encompassing the calculation of the amount owing, and the recovery of that amount. They then illegitimately confined any dispute about the calculation to the inputs after 3 October 2008 only. The process has thereby become procedurally confused. To remit the matter back to the BRC to start all over again, with the potential that leave to review after out of time would not be granted, would have the potential to create yet further legal formalism.
[55] What now needs to happen is for the appellant’s arguments on appeal to be considered on their merits. That would encompass all arguments she makes relating to the Ministry’s decisions before 3 October 2008. That includes all the criticisms set out in Mr Howell’s letter to the BRC coordinator dated 20 May 2016. That may encompass a review of decisions out of time under s 10A(1B)(b), but it seems to me that the case needs now to be treated on the basis that good reason to do so has been established.
[56] Accordingly I remit the matter to the Authority with the direction that they consider the appeal in light of this judgment.
Cooke J
Solicitors:
O’Regan Arndt Peters & Evans Solicitors, Wellington for Appellant Crown Law, Wellington for Respondent
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