Scrutiny of Acts and Regulations Committee

Discussion Paper No. 1 on the Operation of Section 85 of the Constitution Act 1975
Chapter Four - Adverse Reports by the Committee in 1993 and 1994
Part C

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(2) LOCAL GOVERNMENT (AMENDMENT) BILL

"This Bill was introduced into the Legislative Assembly on 5 October 1994 by The Honourable Rob Maclellan MP with The Honourable Phil Gude.

This Bill amends various Acts. Its purposes are: -

  • to alter the dates of the municipal financial year and the date of Council elections;

  • to alter its provisions concerning the creation and operation of regional corporations;

  • to transfer provisions concerning regional waste management groups from the Local Government (Miscellaneous) Act 1958 to the Environment Protection Act 1970;

  • to repeal the Local Government (Miscellaneous) Act 1958 and the Prahran Market Act 1979.

Variation of section 85 of the Constitution Act 1975 (section 4D(b)(i) and (ii) of the Parliamentary Committees Act 1968)

Clause 27, new section 50QB declares its intention to alter or vary section 85 of the Constitution Act 1975 to the extent necessary to prevent the Supreme Court from entertaining any appeal or challenge from the decision of the Minister, or an arbitrator or panel of arbitrators appointed by the Minister made under section 50QA. The Committee notes the comments in the Second Reading Speech: -

"Clause 27 of the Bill inserts a new section 50QB which is intended to vary or alter section 85(5) of the Constitution Act 1975 to the extent necessary to prevent the Supreme Court from entertaining any appeal or challenge from the decision of the Minister, or an arbitrator or panel of arbitrators appointed by the Minister under section 50QA.

The reason for limiting the jurisdiction of the Supreme Court is that is not appropriate for a body with a local interest to be able to bring an action in relation to a decision made by independent persons in the regional interest. It is not appropriate that a municipal council or governing body of a regional waste management group with a local interest in the outcome of a dispute should be able to challenge a decision of the Minister, or an arbitrator or panel of arbitrators appointed by the Minister which gives precedence to the interests of the region as a whole. A regional perspective is critical to conserve existing and potential landfill space, cover the costs incurred in managing suitable landfill sites for the disposal of wastes, and manage waste cost-effectively and with minimal impact on the environment."

In its current form, the Committee cannot say that the provision is appropriate and desirable in all the circumstances. The Committee has written to the Minister.

Chairman's Note:

After discussions between the Chairman and the Minister, the Committee has been advised that a House Amendment will be made to ensure that there will be an avenue of appeal to the Supreme Court on questions of law. The exclusion of the jurisdiction of the Supreme Court will only apply to issues of fact."

(3) LAND (MISCELLANEOUS MATTERS) AND NATIONAL TENNIS CENTRE (AMENDMENT) BILL

"This Bill was introduced into the Legislative Assembly on 12 October 1994 by The Honourable Geoff Coleman MP with The Honourable Phil Gude MP.

The purposes of this Act are to: -

  • amend the National Tennis Centre Act 1985 to make further provision for national tennis centre land;

  • amend the Land (Revocation of Reservations) Act 1994 to continue leases over the Eastern Market Site at Melbourne despite the revocation of the reservation and Crown grant of that land;

  • remove several reservations over land including land set aside for the Janefield Colony for the Treatment of Mental Defectives;

  • amend the Land (Further Miscellaneous Matters) Act 1994, repeal various other Acts and make other related provisions.

Variation of section 85 of the Constitution Act 1975 (Section 4D(b)(i)(ii) and (iii) of the Parliamentary Committees Act 1968)

Clause 5 amends section 26 of the National Tennis Centre Act 1985 to provides that no compensation is payable by the Crown in respect of anything done or arising out of new sections 25A, 25B, 25C and 25D. Clause 6 declares its intention to alter or vary section 85 of the Constitution Act 1975 to the extent necessary to prevent the Supreme Court awarding compensation in respect of anything done under or arising out of sections 25A, 25B, 25C, 25D and 26. The Committee notes the comments in the Second Reading Speech: -

"The reason for preventing the Supreme Court from awarding compensation is as follows:

To enable the Crown to change the use or status of land, it is necessary to ensure that the land is no longer subject to any interests or rights arising out of the former use. The existence of these interests and rights and claims for compensation based on them or on the former use of the land could delay or prevent a change in the use or status of the land that is for the benefit of the community as a whole. To facilitate use of the land to which this Part applies, it is also necessary to provide a mechanism to divest and excise land shown on the plans proposed to be inserted in Parts 3 and 4 of the Schedule to the National Tennis Centre Act 1985."

The Committee has written to the Minister to ensure that there are no legal private interests which are adversely affected before forming a conclusion.

Clause 21 provides that no compensation is payable by the Crown in respect of any thing done under or arising out of this Part. Clause 22 declares its intention to alter or vary section 85 of the Constitution Act 1975 to the extent necessary to prevent the Supreme Court awarding compensation in respect of anything done under or arising out of this Part. The Committee notes the comments in the Second Reading Speech: -

"The reason for preventing the Supreme Court from awarding compensation is as follows: -

To enable the Crown to change the status of reserved land, it is necessary to ensure that the land is no longer subject to any interests or rights arising out of the former use. The existence of these interests and rights and claims for compensation based on them or on the former use of the land could delay or prevent a change in the use or status of the land that is for the benefit of the community as a whole. To facilitate use of some of the land to which this Bill applies it is also necessary to revoke several Crown grants."

The Committee has written to the Minister to ensure that there are no legal private interests which are adversely affected before forming a conclusion."

(4) CROWN LANDS ACTS (AMENDMENT) BILL

"The Committee reported on the Crown Lands Acts (Amendment) Bill in Alert Digest No. 13 on 15 November 1994. The Committee made the following comments in respect of clause 17 in the Alert Digest : -

"Variation of Section 85 of the Constitution Act 1975 (Section 4D(b)(i)(ii) and (iii) of the Parliamentary Committees Act 1968)

Clause 17 of the Bill amends section 412 of the Land Act 1958 to declare its intention to alter or vary section 85 of the Constitution Act 1975 to the extent necessary to prevent the Supreme Court from awarding compensation in the circumstances where section 133C(4) or 133F(3) provides that no compensation is payable.

Clause 11 of the Bill inserts new sections 133C and 133F(3). The Committee notes the comments in the Second Reading Speech: -

"The Land Act as proposed to be amended by clause 11 of the Bill will include compensation provisions and it is for this reason that the ability of the Supreme Court to award compensation is restricted. In the case of termination of a lease, the Land Acquisition and Compensation Act will apply. In the case of termination of a licence, there will be a pro rata refund of the licence fee. Where a lease or licence is terminated because of non-compliance with its terms, compensation would not be appropriate and will not be payable. However, a lessee or licensee will be entitled to remove improvements which he or she owns whether the lease or licence is terminated because of non-compliance or otherwise."

The Committee is of the view that clause 17 together with new sections 133C(4) and 133F(3), (clause 11) may contravene section 4D(a)(i)(ii) and (iii) of the Committee's Terms of Reference. The Committee has made inquiries and confirmed that although the Minister's decision in respect of new 133C is reviewable in the Supreme Court, no compensation is payable in respect of the vesting of improvements in the Crown, the forfeiture of money to the Crown or the extinguishment of any interest, right or privilege. A lessee or licensee is only entitled to remove improvements which he or she owns.

In respect of new section 133F(3), where a licence may be cancelled even if there is no breach, the only compensation payable is the amount of the licence fee refunded by the Minister. The decision to cancel the licence may be reviewed in the Supreme Court but not the compensation which is payable under the provision. "

The Committee wrote to the Minister. The Minister responded by way of a letter dated 21 November 1994. The relevant extract is set out:

"Clause 17 of the Bill

In light of the comments made by the Committee, clause 17 was deleted by house amendment in the Legislative Assembly on 17 November. During the debate, Mr Coghill asked that consideration be given to enabling appeals to be taken to the Administrative Appeals Tribunal in the first instance rather than the Supreme Court. I am advised that the AAT does not presently have any jurisdiction in relation to either commercial or residential tenancies. It seems, therefore, that the Supreme Court is the appropriate forum.

I hope the above comments are of assistance to the Committee."

The Committee notes that the Minister introduced a House Amendment into the Parliament which deleted clause 17 in its entirety. The Committee's concerns have been resolved."

(5) CORRECTIONS (AMENDMENT) BILL

The Committee reported on the Corrections (Amendment) Bill in Alert Digest No. 11 on 8 November 1994. The Committee made the following comments in the Alert Digest in respect of new section 9CB. The relevant extract is set out: -

"Variation of Section 85 of the Constitution Act 1975 (Section 4D(b)(i)(ii) and (iii) of the Parliamentary Committees Act 1968)

(b) New section 9CB provides that an authorised person who uses reasonable force whilst minding prisoners in custody is not liable for injury caused by that use of force. The Committee notes the comments in the Second Reading Speech:

"Section 9CB will provide where a person employed by a contractor to manage a police gaol and it is necessary to use reasonable force in the performance of their duties that the person does not incur any liability for acting in accordance with that clause.

The reason for preventing the entertaining of these proceedings is that without the protection provided in clause 22 that clause would not be effective to enable persons required to manage police gaols to ensure the security and welfare of all detainees."

The Committee questions the need to limit the jurisdiction of the Supreme Court in this instance. The Committee is of the view that the same end could be achieved by the insertion of a provision which enables a defence of reasonable force to a charge brought by a prisoner. The Committee has written to the Minister."

The Minister responded by way of a letter dated 14 November 1994. The relevant extract is set out:

"2. New Section 9CB - Variation of Section 85 of the Constitution Act 1975

Prison officers and contractors responsible for the management of prisoners and police officers currently supervising persons detained in police gaols are exempt from legal proceedings in the Supreme Court arising from the use of reasonable force, the former by virtue of section 23 of the Corrections Act 1986 and the latter according the common law. Contractors who are engaged to supervise persons detained in police gaols should be afforded the same protection for the use of reasonable force that is given to prison officers and police officers.

A defence of reasonable force to a claim brought by a prisoner will have the undesirable effect of reversing the onus of proof on the defendant contractor, requiring the contractor to prove that reasonable force was used. There is no reason why the burden of proof should be imposed on the contractor, when no such burden of proof lies against prison officers or police members in actions brought by prisoners for the use of unreasonable force.

The defence will also have the effect of limiting the ability of the Supreme Court to consider the issue of force used at the expense of proceedings being issued. Any limitation on the jurisdiction of the Supreme Court to consider the issue of reasonable force should avoid the necessity for legal proceedings to be issued, and this requires a statement to be made regarding section 85 of the Constitution Act 1975.

I trust the above advice is of assistance."

(6) VICTORIAN PLANTATIONS CORPORATION (AMENDMENT) BILL

"The Committee reported on this Bill in Alert Digest No. 13 of 1994 on 15 November 1994. The relevant extract is set out:-

Variation of Section 85 of the Constitution Act 1975 (Section 4D(b)(i)(ii) and (iii) of the Parliamentary Committees Act 1968.

Clause 13 provides that no compensation is payable by the Crown in respect of anything done under or arising out of this Act. Clause 14 declares its intention to alter or vary section 85 of the Constitution Act 1975 to the extent necessary to prevent the Supreme Court awarding compensation in respect of anything done under or arising out of this Act. The Committee notes the comments in the Second Reading Speech:

"Clause 14 of the Bill provides that it is intended to alter or vary the Constitution Act 1975 to the extent necessary to prevent the Supreme Court awarding compensation in respect of anything done under or arising out of this Act. The reason for preventing the Supreme Court from awarding compensation is as follows:

To enable the Crown to change the status of land to a status more appropriate to its current use, it is necessary to ensure that the land is no longer subject to any interests or rights arising out of the former use, other than those specifically provided for by the principal act. The existence of these interests and rights and claims for compensation based on them could delay or prevent a change in the use or status of the land."

The Committee has written to the Minister to ensure that there are no private legal interests which are adversely affected before forming a conclusion."

The Minister responded by way of a letter dated 18 November 1994. The relevant extract is set out:

"I refer to your letter of 16 November 1994 concerning clauses 13 and 14 of the above-mentioned Bill and the intention of those clauses to limit the jurisdiction of the Supreme Court in relation to anything done under or arising out of the Act.

Sections 27 and 33 of the Victorian Plantations Corporation Act 1993 prevent the Supreme Court from awarding compensation in respect of anything done under or arising out of the Act. That Act provided for the vesting and divesting of land, revocation of reservations and road closures, in order to facilitate the formal transfer of management of plantations to the Corporation. In order to ensure that those processes were not impeded or delayed by claims for compensation arising out of the former use of the land, the Act contained provisions to limit the jurisdiction of the Supreme Court.

The Victorian Plantations Corporation (Amendment) Bill merely provides for the further vesting and divesting of land to and from the Corporation, to facilitate more efficient management of the plantation estate. Inclusion of a provision in this Bill to limit the jurisdiction of the Supreme Court was considered necessary as it was unclear whether the scope of sections 27 and 33 of the Principal Act would extend to the further vesting and divesting actions provided for by the Bill. I am not aware of any rights which are likely to be infringed by the limitation of the Supreme Court's jurisdiction in the case of the matters provided for by this Bill.

The removal or alteration of land tenure is a decision which properly rests with the Parliament with any beneficial interests taken into account during the development of the legislation. The provisions are required to prevent unnecessary impediments to or delays in, the change of land status and are not intended to unduly interfere with the rights of any private person with an interest in the land."

The Committee notes the Minister's response. The Committee believes that there is a distinction to be drawn between the Government's understandable and proper concern to ensure clear title and the removal of the right for compensation. The Committee believes that the Government's concern could have been met with a section 85 provision which guaranteed clear title. In these particular circumstances, the Committee is of the view that the proposed section 85 provision is not appropriate and desirable in all the circumstances."

(7) LAND (FURTHER MISCELLANEOUS MATTERS) BILL

"This Bill was introduced into the Legislative Assembly on 9 March 1994 by The Honourable Geoff Coleman with The Honourable Phil Gude.

This Bill amends various Acts which relate to Crown land and land transactions. More specifically, it provides for:

  • the revocation of reservations of land which are described in the Schedules to the Bill;

  • the surrender of land to the Crown to enable the sale of the land;

  • the amendment of the Melbourne Lands Act 1987 to correct errors to the Schedule;

  • the issue of a lease over a small portion of a wildlife reserve for shellgrit extraction purposes;

  • other enabling provisions with the various land transactions proposed by the Bill;

Supreme Court - Limitation of Jurisdiction (section 4d(b)(i) and (ii) of the Parliamentary Committees Act 1968)

Clause 20 declares its intention to alter or vary section 85 of the Constitution Act 1975 to the extent necessary to prevent the Supreme Court awarding compensation in respect of anything done under this Act.

This effectively means that actions for compensation cannot be brought in respect of any alterations made to the title of any piece of land dealt with by this Act. In the Second Reading Notes, the Minister States:

"The reason for preventing the Supreme Court from awarding compensation is as follows:

To enable the Crown to change the use or status of reserved land, it is necessary to ensure that the land is no longer subject to any interests or rights arising out of the former use. The existence of these interests and rights, and claims for compensation based on them or on the former use of the land, could delay or prevent a change in the use or status of the land that is for the benefit of the community as a whole. To facilitate use of some of the land to which this Bill applies, it is also necessary to revoke a Crown Grant to enable the surrender of certain land to the Crown...."

The Committee notes the explanation. The Committee wrote to the Minister to request his advice as to whether he was aware of any rights which may be removed as a result of Clause 20. The Minister responded in a letter which is set out:

"I refer to your letter of 17 March 1994, regarding Clause 20 of the above Bill and the intention of that clause to limit the jurisdiction of the Supreme Court.

The provision referred to is common to all Bills of this type and is required to ensure that no action arises over changes in status of reserved land. I am not aware of any rights which are likely to be infringed by the limitation of the Supreme Court's jurisdiction in this case.

The removal or alteration of permanent reservations of land is a decision which properly rests with Parliament, with any beneficial interests affected taken into account during the development of the legislation. The provision is required to prevent the unnecessary impeding of changes of and status in the courts and is not intended to unduly interfere with the rights of any individual with an interest in the land."

(8) CITY OF GREATER BENDIGO BILL

"The Committee reported on this Bill in Alert Digest No. 4 on 19 April 1994. The Committee made the following comments in respect of certain provisions in the Bill:-

Variation of section 85 of the Constitution Act 1975 (Section 4D(b)(i) and (ii) of the Parliamentary Committees Act 1968)

Clause 23 of the Bill prevents proceedings being brought in the Supreme Court against any person in respect of any action taken or purported to have been taken or proposed to be taken to sections 7(1), 7(2), 7(3), 7(4), 13(3), 14(3) or 15 of the Bill.

Clause 24 declares its intention to alter or vary section 85 of the Constitution Act 1975 to prevent the Supreme Court entertaining the applications referred to in section 23.

Sections 7(1), 7(2), 7(3) and 7(4) relate to the appointment of the Commissioners for the new Council. Section 13(3) provides for orders in council to be made in relation to the first election of the Councillors. Section 14(3) relates to the first meeting of the elected Council. Section 15 is the general enabling provision which enables orders to be made for a range of purposes associated with the implementation of the Act.

The Committee notes the comments in the Second Reading Speech: -

"This Bill is a critical element of the Government's reform program for restructuring local government. It establishes a Greater Bendigo City Council.......The proposal before the House follows closely the recommendations of the Local Government Board in its final report on the structure of local government in the Bendigo region.....The Minister for local government has considered the recommendations of the Board's final report, the Act provides for a new local structure to be put in place by order of the Governor-in-Council.

.....Because of the attempt of the rural city of Marong to halt that process, the matter has been brought back to the Parliament to ensure the smooth implementation of the restructure. The proceeding initiated by the rural city of Marong is being opposed in the Supreme Court but legislation is being introduced now to ensure that the benefits of restructure can be implemented without delay.........

The orders which can be made under each of the provisions listed deal with critical aspects of the municipal restructuring proposed in the Bill. It is essential for the successful implementation of the restructuring that the matters addressed in such orders proceed smoothly without challenge.

Councils have resorted to litigation in the past as a means of frustrating proposals for boundary change. The provisions will ensure that the Courts cannot be used to delay and frustrate the implementation of the restructuring."

The Committee is still deliberating as to whether the proposed provisions in respect of section 85 of the Constitution Act 1975 are in all the circumstances appropriate and desirable."

The Minister replied to the Committee in a letter dated 29 April 1994, the contents of which are set out:

"Thank you for your letter of 14 April 1994 which raises concerns regarding several provisions of the City of Greater Bendigo Bill.

It is not my intention to proceed with the Bill and arrangements will be made to withdraw the Bill at the appropriate time. However, I offer the following in response to your concerns you have raised in your letter -

Clause 15 - Orders in Council

Clause 15 is identical to clause 21 of the City of Melbourne Act 1993 on which the Committee raised similar concerns. It remains my view that it is not possible to anticipate and deal with all the implementation issues that may arise in relation to primary legislation. The ability for the Governor in Council to make Orders in relation to the implementation of the Bendigo area restructuring is critical to the success of the proposal.

There has traditionally been an ability to deal with the implementation issues through Orders in Council. This was the approach adopted in the Local Government Act 1958 and , more recently, in the Local Government (General Amendment) Act 1993 and the City of Greater Geelong Act 1993.

Each restructuring throws up its own unique issues to be resolved and the Government must be in a position to act promptly. An ability to act through Orders in Council is essential.

Clause 23 - Legal Proceedings excluded (from jurisdiction of the Supreme Court)

Your letter requests that I justify each clause and subclause to which section 23 applies.

Subclauses 7(1), (2), (3) and (4) all deal with the appointment of Commissioners. As with the City of Melbourne, the appointment of Commissioners is clearly a critical element of restructuring. The existing councillors would go out of office upon the Bill receiving Royal Assent and it is imperative that there be a smooth change over to the Commissioners. It would be most improper that challenges could be brought in relation to the initial or to any subsequent appointments as a means of frustrating the changes being proposed.

Subclause 13(3) relates to the holding of the first elections. I note your concern that an Order could be made creating wards which had differences in voters of greater than 10%. As in all cases of setting ward boundaries by Order, the general principles spelt out in s.220 of the Local Government Act 1989 must be applied. It is clear from s.220 of the Act that ward boundaries must be fair and equitable and the number of voters should not vary by more than 10% from the average number of voters for the entire municipal district. It is important that the first election be able to proceed smoothly and without challenge. It remains my view that the courts are clearly not an appropriate place for settling differences in relation to such matters as new ward boundaries.

Subclause 14(3) provides that the Governor in Council may give directions to provide for any matters in relation to the first meeting of the elected council. The transition from the Commissioners to the newly elected councillors is also a critical period and the process should not be frustrated by challenges.

Clause 15 contains general provisions for the Governor in Council to make any necessary Orders to enable the implementation of the Bill. The restructuring of the Bendigo area should not be frustrated by challenges to matters, which while important to the smooth implementation of the restructure, are essentially housekeeping matters.

Councils have resorted to litigation in the past as a means of frustrating proposals for boundary change as demonstrated recently by the Rural City of Marong in relation to the proposed Order to restructure the Bendigo region and the Cities of South Melbourne and Port Melbourne in relation to the City of Melbourne Act 1993. Clause 23 ensures, as far as possible, that the courts cannot be used to delay and frustrate the implementation of the restructuring of the Bendigo area by bringing proceedings in relation to the matters specified.

I trust my comments will be of assistance."


Scrutiny of Acts and Regulations Committee
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