Scrutiny of Acts and Regulations Committee

Discussion Paper No. 1
On the Operation of Section 85 of the Constitution Act 1975
Chapter Five - Reports by the Committee in 1995 on Bills Containing
Section 85 Provisions

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5.1 Bills considered by the Committee so far in 1995 which contain Section 85 provisions

1995

  1. Land (Revocation of Reservations) Bill

  2. Fisheries Bill

  3. Australian Food Industry Science Centre Bill

5.2

Following are extracts from the Bills considered by the Committee so far in 1995 which contain Section 85 provisions.

(1) LAND (REVOCATION OF RESERVATIONS) BILL

The Committee reported on the Land (Revocation of Reservations) Bill in Alert Digest No.3 of 1995.

"This Bill was introduced into the Legislative Assembly on 8 March 1995 by the Honourable Geoff Coleman MP with The Honourable Bill McGrath MP.

This Bill removes several reservations over land described in the Schedules to the Bill. It also makes other minor amendments.

Clause 3 revokes the reservation of land in Maryborough. The Committee notes the comments in the Second Reading Speech:

"Clause 3 of the Bill deals with an area of land at Maryborough reserved as a public park in 1863 under the control of the city of Maryborough by virtue of a crown grant. Maryborough golf club occupies an area of approximately 50 hectares at this location; 16.4 hectares of which is freehold land and the remainder crown land. Maryborough golf club has occupied the land for approximately 85 years and has expressed interest in acquiring the crown land portion of the golf course. The Bill provides for the revocation of the permanent reservation to facilitate the sale of the land.

The City of Maryborough supports the application by the golf club and has agreed to the surrender of the Crown grant, revocation of the public park reservation and sale of the land provided its use as a public golf course continues. The sale will be subject to a section 173 agreement under the Planning and Environment Act 1987, restricting use of the land to golf club purposes and controlling land use."

Clause 4 revokes the reservation of land in Ballarat. The Committee notes the comments in the Second Reading Speech:

"Clause 4 deals with an area of land located to the North of Ballarat. The land is part of the Ballarat general cemetery. This land was permanently reserved as a site for a cemetery in 1879 and a Crown grant issued to the Ballarat general cemetery trust. The Roads Corporation as part of its upgrade of roads associated with the Western Freeway proposes to establish a roundabout at this location. A small area of 572.8 square metres of the cemetery reserve is required to accommodate the new intersection.

The Department of Health and Community Services and the Ballarat General Cemetery Trust have agreed to the excision of this small portion of the reserve which has not been used for burials. The Bill revokes the permanent reservation and the crown Grant in order to facilitate its use by the roads corporation."

Clause 5 revokes the reservation of land in Bendigo. The Committee notes the comments in the Second Reading Speech:

"Clause 5 deals with an area of land located in Bendigo which was permanently reserved for market purposes in 1878, 1889 and 1890. The area has been reduced by a number of excisions and now covers approximately 8 hectares. The land is controlled by the City of Greater Bendigo by virtue of a Crown grant. The grant contains conditions that restrict the use of the land to the purpose of the reservation and prohibit the sale of the land unless authorised by a law enacted after the date of the grant. The land remains in use as stockyards.

The land has been assessed as surplus to government requirements. The Bill revokes the permanent reservations and the Crown grant to enable the site to be sold to the City of Greater Bendigo for future re-development."

Clause 6 deems the land to be unalienated land of the Crown freed and discharged from all trusts and encumbrances and revokes the appointment of any committee of management. Clause 7 gives the Registrar-General and Registrar of Titles the power to make any necessary amendments to any records.

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

Clause 8 provides that no compensation is payable by the Crown in respect of anything done or arising under the Act. Clause 9 declares 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 respect of anything done under or arising out of this Act. The Committee notes the comments in the Second Reading Speech:

"Clause 9 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 from awarding compensation in respect of anything done or under or arising out of the Bill. 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 and 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 future use of some of the land to which this Bill applies, it is also necessary to revoke or excise from several Crown Grants."

The Committee wrote to the Minister on 16 March 1995 seeking his advice as to the following matters:

  • Are there any private legal interests which may be affected?

  • If there are no private legal interests which may be affected, is it necessary to use the clause in its current form in the first instance/

  • Alternately, is it appropriate to insert a clause which allows for clear title so that the Government can deal with the land but allows for compensation if there are any interests which may be affected?

After the letter was written, the Chairman consulted with the Minister. That consultation led to the Committee writing a further letter to the Minister and letters to the Attorney-General, Crown Counsel and Chief Parliamentary Counsel with specific suggestions as to possible methods of dealing with the issues raised by Section 85 clauses in general. The Committee received a response from Mr Greg Craven, Crown Counsel dated 4 April 1995. The relevant extract is set out:

"Thank you for your letter concerning the use of privative clauses in connection with legislation dealing with reserved land.

As I indicated to you in our telephone conversation yesterday, I believe that there is something to be said for an approach which secures the ability of Government to deal freely with land by extinguishing all interests in that land, while preserving a right to compensation in any affected person.

However, I make this comment subject to the following strict reservations:

1. A section 85 clause would still be required if the effect outlined above were to be achieved;

2. It would be imperative for the workability of such a legislative approach that the relevant legislation did in fact extinguish all interests in the land in question, and prevented the taking of interlocutory and other proceedings with a view to frustrating the Government dealing with the land;

3 . It would be highly desirable that practice in relation to such clauses was, so far as possible, uniform across Government. Nevertheless, such practice would have to recognise that there would be certain circumstances (for example, where extraordinary complexities of title were involved) where a no-compensation clause would be the only responsible course.

4. Finally, and most importantly, any such legislative practice should not be instituted without full and careful inquiry by SARC. You will recall that amendments to section 32 of the Interpretation of Legislation Act some years ago were made without proper consideration of their full impact, and most unfortunate consequences ensued. The potential for such unforseen consequences clearly would arise in connection with the present proposal."

Following informal consultation, the Committee has resolved to adopt the approach outlined by Crown Counsel. This will be communicated to all Ministers in respect of Section 85 clauses and enable the development of a Government approach.

The Committee received a letter from the Minister in respect of its original letter to him dated 16 March 1995. The relevant extract from the Minister's letter is set out:

"I refer to your letter dated 16 March 1995.

The provisions referred to are common to all Bills of this type and are included to ensure that no actions for compensation arise over changes in the status of reserved land. I am not aware of private legal interests which are likely to be infringed by the limitation of the Supreme Court's jurisdiction contained in the Bill.

The provisions are based on a desire to achieve sound administrative practices and are not intended to unduly interfere with the rights of any private person with an interest in the land."

The Committee concedes that it is unlikely that there are any private legal interests which may be affected. Nevertheless, the Committee has some difficulty with a provision which may inadvertently remove existing private legal interests. The Committee notes that Governments of both persuasions have adopted the policy of using these type of provisions.

However the Committee is required under Section 4D(b)(i)(ii) and (iii) of the Parliamentary Committees Act 1968 to examine each Section 85 provision and assess whether it is "appropriate and desirable" in all the circumstances. The Committee has a responsibility to determine whether there may be more appropriate or better ways of achieving the same ends. The Committee does not find that the provision is appropriate and desirable in all the circumstances."

(2) FISHERIES BILL

The Committee reported on the Fisheries Bill in Alert Digest No.3 of 1995 on 11 April 1995. The relevant extract is set out:

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

Clause 128 provides that no compensation is payable to any person for any loss or damage as a result of the enactment and the repeal of the Fisheries Act 1968. In particular it includes the following:

  • the conversion of a licence or permit;

  • the failure of licensees to achieve their quotas or otherwise take fish in accordance with any licence or permit;

  • the seizure, detention or forfeiture of any fish, protected aquatic biota, declared noxious aquatic species, equipment or property in accordance with this Act;

  • the making and carrying out of an order under section 79(4),ie: the authorised seizure and removal of noxious aquatic species;

  • the suspension, cancellation or refusal to issue or renew any licence or permit in accordance with the Act;

Clause 129 declares its intention to alter or vary section 85 of the Constitution Act 1975 to the extent necessary to prevent the Supreme Court entertaining actions of a kind to which section 128 applies. The Committee notes the Minister's explanation in the Second Reading Speech:

"Clause 129 provides that it is intended to alter or vary the Constitution Act to the extent necessary to prevent the Supreme Court from awarding compensation for any loss or damage as a result of the enactment of this Act and the repeal of the Fisheries Act 1968. The reason for preventing the Supreme Court from awarding compensation is as follows: The Crown intends to change the nature of various types of fishing licences and permits but does not intent thereby to affect unfairly the rights and interests of individual licence and permit holders. The existence of these interests and rights and claims for compensation based on them could delay or prevent a change in the types of licence that are intended to benefit the community as a whole and in particular the commercial fishing industry."

Clause 128(2)(c) provides that no compensation is payable in respect of the seizure, detention or forfeiture of any fish, protected aquatic biota, declared noxious aquatic species, equipment or other property in accordance with the Act.

If such seizure, detention etc has been done by authorised officers in accordance with the Act, why is it necessary to remove the jurisdiction of the Supreme Court? On the face, it appears to be unnecessary to remove the jurisdiction of the Supreme Court if in fact such seizure, detention etc has been done by authorised officers in accordance with the Act. The Committee wrote to the Minister on 17 March 1995.

Similarly, clause 128(2)(d) provides that no compensation is payable in respect of the making and carrying out of an order under section 79(4). Section 79(4) provides that noxious aquatic species may be destroyed, even though other fish or aquatic species may also be destroyed if the Secretary is satisfied of certain matters. Again the same question may be asked. If such activities are authorised and carried out in accordance with the Act, why is it necessary to remove the jurisdiction of the Supreme Court? On the face, it appears to be unnecessary to remove the jurisdiction of the Supreme Court if in fact such destruction has been done by authorised officers in accordance with the Act and if the Secretary has authorised it.

The reason given by the Minister for the removal of compensation in respect of various matters is that the Crown "intends to change the nature of various types of fishing licences." The Committee does not see how the explanation given relates to the two matters mentioned above. The Committee is of the view that a much more detailed explanation of the particular reasons for the insertion of such clauses would be of great assistance in its deliberations.

The Committee wrote to the Minister on 17 March 1995. The Minister responded by way of letter dated 27 March 1995. The relevant extract is set out:

"Clauses 128 and 129

Virtually all legislation affects certain rights of some persons. It is up to Parliament to determine whether such effects are justified in the wider public interest.

I am advised that even where the actions of an authorised officer are in accordance with valid Acts of Parliament, this may not necessarily prevent the Supreme Court from awarding compensation where property is lawfully damaged or destroyed. The absence of such certainty can inhibit the implementation of legislation and frustrate the will of Parliament. For example, I am advised that the fish disease provisions (Part VIA) of the Fisheries Act 1968, although enacted in 1980, have never been implemented because of this uncertainty with respect to compensation.

Clause 79 of the Bill is a re-enactment of section 43D of the existing Act. If Parliament is still of the opinion that clause 79 is justified, then sub-clauses 128(2)(c) and (d) are also necessary before clause 79 can be implemented. Please note that clause 128(3) does not prevent any action or proceedings for compensation with respect to any loss or damage as a result of negligence."

The Committee wrote a further letter to the Minister on 31 March 1995. The Committee raised continuing concerns as to the need for detailed reasons. The Committee also raised further concerns in relation to clause 128(2)(c). The Committee requested a copy of the original advice which was cited as authority for the proposition that notwithstanding the fact that authorised officers have acted in accordance with the Act, a Supreme Court may award compensation where property is lawfully destroyed.

The Minister responded by way of letter. The relevant extract is set out:

"Your interpretation of my previous letter is correct. Parliamentary Counsel have advised that notwithstanding the fact that authorised officers have acted in accordance with the Act, a Supreme Court could still award compensation where property is lawfully destroyed. Legal advice is being sought on the authorities for this view.

I am advised that sections 105(2) and 138 of the Livestock Disease Control Act 1994 are in fact more restrictive than clauses 128 and 129 of this Bill.

As you are no doubt aware, it is Government policy that where there is a "no compensation" provision in a Bill, there is also to be a Section 85 of the Constitution Act provision. Discussion of this policy is a matter within the Attorney-General's portfolio rather than that of the Minister for Natural Resources.

Whether the risk exposure of the Crown justifies such a "no compensation" provisions in the Bill is a matter my officers would be pleased to discuss in detail with your Committee at the meeting on Monday."

The Committee held a meeting with officers from the Department of Conservation and Natural Resources on 10 April 1995 to discuss its concerns in respect of the Bill. At that meeting, the Committee discussed the Section 85 provisions in great detail with the officers.

The Committee is of the view that sub-clauses (1), (2)(a)(b)(d) and (e) and (3) are appropriate and desirable in all the circumstances.

Sub-clause (2)(c) provides that no compensation is payable because of the "seizure, detention or forfeiture of any fish, protected aquatic biota, declared noxious aquatic species, equipment or other property in accordance with the Act". The Committee was informed that the provision was inserted as a result of advice from Parliamentary Counsel. The Committee has requested a copy of that original advice. The Committee was advised that the use of the words in the sub-clause " or any other property in accordance with the Act" refers to those actions specified in clause 95, ie; the authorised officers' powers of seizure. In the event that the clause is amended to limit the clause to the actions specified in clause 95, the Committee is of the view that the clause would be appropriate and desirable in all the circumstances."

(3) AUSTRALIAN FOOD INDUSTRY SCIENCE CENTRE BILL

The Committee reported on the Australian Food Industry Science Centre Bill in Alert Digest No.4 of 1995 on 26 April 1995. The relevant extract is set out:

"Part 3 - General

Clause 27 revokes the reservation of specified land at Werribee. On the appointed day the Centre land is deemed to be unalienated Crown land and is deemed to be temporarily reserved for the purposes of research and education. Clause 30 is a transitional provision.

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

Clause 28 provides that no compensation is payable by the Crown in respect of anything done under or arising out of section 27. Clause 29 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 section 27. The Committee notes the explanation in the Second Reading Speech:

"Clause 29 of the Bill is intended to alter or vary section 85(5) of the Constitution Act 1975 to the extent necessary to prevent the Supreme Court from awarding compensation in respect of the change of the status of the reserved land at Werribee which is to be controlled and managed by the Australian Food Industry Science Centre.

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

To enable a change to be made to the status of the reserved land, it is necessary to ensure that the land is no longer subject to any interests and rights arising out of its former use. The existence of such interests and rights and claims for compensation based on them on the former use of the land could delay or prevent a change in the use or status of the land."

It appears that the land being dealt with is in fact Government land and that there are in fact no private legal interests which may be affected. On the face, the Committee believes that there is no need for a Section 85 provision. Again, this appears to reflect an overly cautious drafting practice. The Committee notes that Governments of both persuasions have adopted the policy of using these type of provisions. However the Committee is required under Section 4D(b)(i)(ii) and (iii) of the Parliamentary Committees Act to examine each Section 85 provision and assess whether it is "appropriate and desirable" in all the circumstances. The Committee has a responsibility to determine whether there may be more appropriate or better ways of achieving the same ends. The Committee does not find that the provision is appropriate and desirable in all the circumstances.

The Committee has written to the Minister. The Committee is examining this issue in a Discussion Paper on Section 85 which will be released shortly."

The Minister responded by way of letter dated 2 May 1995. The Committee reported the response in Alert Digest No.5 of 1995 on 9 May 1995. The relevant extract is set out:

"I write in response to your letter of 21 April requesting advice as to the need for Section 85 provisions in the Australian Food Industry Science Centre Bill.

I have been informed by Parliamentary Counsel that the no-compensation provision relating to the change of status of Crown land is there for two reasons.

The first is to ensure that members of the public cannot make any claims on the ground that public privileges have been taken away - for example, the right of access to land, rights of way or any other rights arising from the public nature of Crown land.

The second is to ensure that no private claims are made by persons who may have had leases, licences or other rights over the land that, unknown to the Government have not been revoked.

The absence of a no-compensation provision would imply that the Government would be prepared to accept claims for compensation: but such claims would be uncertain in nature and extent and could expose the Government to unknown liabilities.

In the case of Werribee, the Crown land has been used for many years as a state research farm. I understand that inquiries have not revealed the existence of any interests. That indicates that the Bill is unlikely to affect private rights, but public rights might still be claimed if a section 85 provision were not included.

It must also be remembered that Crown land records do not offer protection of the kind provided under the Transfer of Land Act. It is possible for interests in Crown land to exist despite no formal entries appearing in any of the usual government records.

I note that the Committee is examining this issue in a Discussion Paper on Section 85 which will be released shortly."


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