Body Corporate and Community Management (Standard Module) Regulation 2020 (Standard Module)

INTERIM ORDER - whether an interim order is warranted.

1. The application for an interim order is dismissed.

• [1] This application is about body corporate gardening works purportedly proposed to be carried out in common areas adjacent to Lot 3 (the applicant's lot). The applicant says that the proposed work includes the planting of 5 gardenia shrubs along the rear boundary fence of the scheme and gazanias in the garden.
• [2] The applicant is seeking a variety of final orders, including an order that the committee's decision about the gardening works is invalid. The applicant asserts that the works were approved without proper authority and would interfere with the applicant's access, privacy, and safety.
• [3] Pending the determination of the final orders sought, the applicant is seeking an interim order to restrain the body corporate from carrying out the proposed gardening works.
• [4] At this stage, I will only consider whether an interim order is warranted in the circumstances.

• [5] The application seeks the following interim outcome:

That the Body Corporate, Committee members, or any agents, contractors, or residents acting under their instruction be restrained from carrying out or authorising any planting, landscaping, or alteration works in the common property area immediately adjacent to my lot and along narrow grassed strip along the rear boundary fence, until this dispute is resolved by a final order.

• [6] The application then seeks the following final outcomes:
  1. (To put a stop to the current dispute in its entirety): That the committee's purported decision to approve the planting of gardenias or any other shrubs along the rear boundary fence of the scheme is declared invalid and of no effect; and that no such planting or landscaping works may be undertaken in that location without a properly convened body corporate meeting and the prior written agreement of the owner of Lot 3.
  2. An order that no planting, removal, or landscaping works be carried out in the common property garden adjoining (lot 3) without prior agreement and input.
  3. An order that each lot owner may communicate directly with the gardener regarding the maintenance and appearance of the garden adjoining their lot, according to their individual preferences.
  4. An order that all existing plantings along the internal driveway be removed and replaced, at body corporate expense Gardenias, Hibiscus rosa-sinensis, and Ixora chinensis 'Prince of Orange'.
  5. An order that all existing plantings along the internal driveway directly opposite Lot 3 be removed and replaced, at body corporate expense, with four Gardenias, four Hibiscus rosa-sinensis, and four Ixora chinensis 'Prince of Orange'.
  6. An order that the engagement of Shane's Gardens and Maintenance as the scheme's gardener and lawn contractor, is terminated and that no further work be assigned to him within the scheme.
  7. An order that a new, suitably qualified and independent gardener is engaged on an ongoing basis.
  8. An order that the owner of Lot 3 be the primary point of contact for, and may give reasonable instructions to, the gardener regarding the maintenance of the garden and lawn areas within the complex.
  9. An order that owners of Lot 1 (Sharon and Paul Buckland) be removed from office as committee members.

• [7] 216 Cypress Street community titles scheme 54382 (216 Cypress Street) is a 3-lot scheme in Urangan. The community management statement (CMS) indicates the Standard Module applies. The scheme is registered as survey plan 323913.

• [8] An adjudicator may make an order that is just and equitable in the circumstances to resolve a dispute about a claimed or anticipated contravention of the Act or the CMS, or the exercise of rights or powers or the performance of duties under the Act or CMS.[1] Relevantly, an adjudicator may make an interim order if satisfied, on reasonable grounds, that an interim order is necessary due to the nature or urgency of the circumstances.[2] Prima facie, I have jurisdiction to determine the subject matter of this application under the dispute resolution provisions in the Act.[3] But, as I will discuss below, there is a question as to whether the applicant has yet demonstrated the existence of a dispute on some of the issues on which orders are sought which would enliven my jurisdiction.

• [9] This application was lodged on 13 October 2025. The Commissioner sought further clarification from the applicant about the application.[4] The application was then amended.[5]
• [10] I have been tasked with deciding whether the circumstances warrant an interim order.[6] There is no legislative requirement to give notice of an interim order application to a respondent or affected party.[7] In the circumstances, I gave the owners and the body corporate manager a limited opportunity to respond to the interim order application. The chairperson requested an extension, as the chairperson and the other owner (who is the secretary and treasurer) were unavailable. I granted the extension based on the chairperson's written undertaking that no new planting would be undertaken in the common areas until the matter is resolved.

• [11] The owners of Lot 1 and Lot 2, in a joint submission, oppose the interim order application. Most relevantly, they say:
  1. There has been no decision about future plantings in the common area. Therefore, there is no need for an interim or permanent order.
  2. As the applicant objected to the planting proposal, it was subsequently withdrawn. The applicant was advised of this in writing on 20 July 2025.
  3. The applicant has been advised several times that a committee meeting will be held when all parties are available.
  4. On several occasions, the chairperson has told the applicant that until a committee meeting is held, no new planting will be undertaken.
  5. Any plans to meet have been put on hold pending the outcome of the adjudication application. No new work will be undertaken until the matter is resolved.
  6. Prior written agreement of the owner of Lot 3 is not a requirement for a committee decision.

• [12] From the submitted material, it is apparent that a significant amount of interpersonal conflict exists within 216 Cypress Street. While I appreciate that this type of conflict can be especially challenging in a smaller scheme, it will have no bearing upon my determination of the interim order application.
• [13] The sole issue for me to determine at this stage is whether an interim order is warranted. However, to make this determination, I must consider the substantive issues in dispute.

• [14] An interim order is intended to protect rights and interests temporarily, or maintain the status quo, until the substantive issues in dispute are finally determined.
• [15] The Act stipulates that an adjudicator may make an interim order if they are satisfied, on reasonable grounds, that an interim order is necessary due to the nature or urgency of the circumstances.[8]
• [16] In determining whether it is just and equitable to make an interim order, an adjudicator must consider whether the application raises serious legal questions. Although I am not making any final decisions as to the merit of the substantive issues at this time, I must consider whether the applicant has made a prima facie case on genuine legal issues.
• [17] An adjudicator must also weigh the impact of refusing to make an interim order if the final orders are ultimately granted, against the impact of granting the interim order if the final orders are ultimately refused (referred to as the 'balance of convenience'). It is particularly important to consider whether an interim order is necessary to prevent serious or irreparable harm.

• [18] I will turn now to consider the legal basis for the application and whether there is an arguable case.
• [19] The first final order sought by the applicant is intended to resolve the current dispute about the purportedly approved gardening works. I will therefore focus primarily on whether there are any genuine legal issues raised in relation to the first order. However, in view of the broad nature of the interim order sought - specifically, that it refers to any planting, landscaping or alteration works in the disputed areas - I will also consider the legal basis for final orders 2 to 8, which appear to relate, albeit more indirectly, to the interim order application.
• [20] From the outset, I note that for several of the final orders sought, the applicant has cited various provisions which, at this stage, appear to have little relevance. It is insufficient to simply list provisions without going further to demonstrate how they have allegedly been contravened.
• [21] For the first 5 final orders sought, the applicant has referred to alleged breaches of the code of conduct for committee voting members (the code) in Schedule 1A of the Act. However, its application is limited to individual committee members.[9] The code does not apply to the committee collectively.[10] Relevantly, the body corporate (and not the committee or individual committee members) has been named as the respondent in this application.
• [22] The applicant also relies on section 167 of the Act pertaining to nuisances for the first 5 final orders sought. Again, the application of this provision does not extend to the body corporate or its committee. Its application is limited to an individual occupier of a lot in the scheme.

Validity of committee's decision about the gardening works (order 1)

• [23] The applicant says they did not receive any information about a committee meeting being held in relation to the motion about the gardening works. They submit that the owners of Lot 1 and Lot 2 met privately with the gardener and approved gardening works adjacent to the applicant's lot (specifically, the planting of 5 gardenia shrubs along the rear boundary fence and gazanias in the garden). The applicant claims the decision is invalid and of no lawful effect, as it was made without a formal meeting, recorded vote, minutes, or their input as a committee member.
• [24] In their joint response to the interim order application, the other owners assert that despite the body corporate manager's email to the applicant stating that the gardening works were approved by the majority of the committee and scheduled to commence in the coming weeks, there has in fact been no committee decision about the gardening works and no new planting will be undertaken until a committee meeting is held. They also submit that there will not be a committee meeting until the matter is resolved.
• [25] The submission casts some doubt over whether there is a current dispute about any approved gardening works. Nonetheless, I will consider whether the applicant has raised genuine legal issues in relation to the first order sought in the event that the committee has purported to make a decision approving the gardening works.
• [26] Significantly, there is no statutory requirement for a committee decision to be made at a committee meeting. The legislation enables committee decisions to be made either at a committee meeting,[11] or by a vote outside a committee meeting (VOCM).[12] If a committee meeting is called, all committee members must be notified.[13] Similarly, for a VOCM, all committee members must be notified of the motion to be decided, except in an emergency.[14] Consequently, if the relevant gardening works in the disputed area were approved by a VOCM, the applicant should have been notified of the motion to be decided, notwithstanding that their vote would not have changed the outcome. The committee is also required to take full and accurate minutes for its meetings, or for a VOCM, keep a full and accurate record of motions.[15]
• [27] The applicant alleges that the body corporate breached sections 104 and 111 of the Act. Section 104 of the Act requires the body corporate to conduct meetings in the way prescribed under the regulation module. However, this provision relates to general meetings (specifically, an annual general meeting or an extraordinary general meeting of owners), not committee meetings. As explained above, the committee is not limited to making its decisions at committee meetings.
• [28] Section 111 of the Act, regarding a vote outside a general meeting, specifies that every lot owner must exercise a vote in favour of the motion for it to succeed. The applicant's repeated reliance on this provision (in relation to this order and for several of the other final orders sought) appears to be misconceived, as it does not apply to committee decisions or to schemes registered under the Standard Module.[16]
• [29] It is also alleged that the body corporate and its committee breached sections 94 and 100 of the Act pertaining to acting reasonably when making decisions. Although the applicant bears the onus of proof, they have not yet clearly explained how these provisions have been contravened. The applicant says that their written objections about the proposed gardening works sent via email on 20 July 2025 were ignored.
• [30] The applicant submits that maintaining the area as open grass is the safest option and that there are more appropriate areas in the scheme for beautification. The applicant lists various concerns, including that:
  • the disputed area provides the only access for moving their household bins, lawn mower, and other items
  • the area becomes muddy and slippery after rain
  • introducing shrubs will obstruct functional access and increase the risk of falls or injuries
  • the body corporate will be exposed to insurance and personal injury claims, as the area is common property
  • the area would become a 'high-maintenance zone', repeatedly bringing contractors and other residents into the area, interfering within the applicant's peace, quiet enjoyment, and privacy
  • the applicant has a reasonable expectation of seclusion in this area directly beside their lot.
• [31] In my preliminary view, the applicant's claims about the safety risks, the body corporate's potential exposure to insurance and personal injury claims, and the obstruction of functional access appear to be largely speculative at this stage. The photographs included with the application material confirm that the gate entrance leading to the relevant common area is narrow. But aside from some photographs and plans roughly marked by the applicant to indicate the alleged location of the proposed changes, there is currently little evidence which demonstrates how the relevant gardening works would further obstruct the applicant's access through the already narrow gate or pose an increased safety risk to the applicant or others in the area.
• [32] If the relevant gardening proposal is implemented and additional maintenance such as routine watering and pruning of shrubs is required, this is not in itself evidence of a loss of the applicant's peace, quiet enjoyment, or privacy. In the absence of specific evidence about the type of maintenance that would be required or its alleged adverse impacts on the applicant, these concerns seem largely speculative at this stage.
• [33] It is also not clear what is meant by a 'reasonable expectation of seclusion'. The disputed area is general common property. It is not part of the applicant's lot, or an exclusive use area designated to their lot. Accordingly, owners and occupiers are entitled to use the disputed area, regardless of its proximity to Lot 3,[17] provided they are not breaching a legislative provision or any of the scheme's registered by-laws in the process.
• [34] In view of these considerations, there appears to be little at this stage to establish that the body corporate or its committee have breached sections 94 or 100 of the Act (if the works were in fact approved).
• [35] As part of the order, the applicant also wants a body corporate meeting to be held and for their prior written agreement to be obtained before any such gardening works can be undertaken in the relevant location. The legislation expressly enables the body corporate to make improvements to common property.[18] The Act provides that an 'improvement' can include the erection of a building, a structural change, or a non-structural change (such as the installation of air conditioning).[19] The cost of an improvement determines whether it can be approved by the committee or whether a general meeting resolution is required (specifically, an ordinary resolution or a special resolution).[20]
• [36] At a committee meeting, a motion is passed by a majority of the voting members present and entitled to vote on the motion who are voting.[21] Similarly, for a VOCM, a motion is passed if the majority of the voting members entitled to vote on the motion agree to the motion.[22] A committee decision does not need to be unanimous. Therefore, if the committee has the authority to approve the contested gardening works, the applicant has not yet provided a legal basis which would oblige the committee to first obtain their prior written agreement (notwithstanding that any notice of a committee meeting or a motion for a VOCM must still be given to the applicant).
• [37] If the committee does not have the authority to approve the relevant gardening works and a general meeting is required instead, the votes cast would be counted in accordance with the required resolution type to determine whether the motion passes or fails.[23] There is no additional legislative requirement for the body corporate to obtain the applicant's prior written agreement.
• [38] In my preliminary view, the applicant has not yet established that the legal issues raised have a sufficient likelihood of success in relation the first order sought.

• [39] This order appears to be in a similar vein to the second part of the first order sought, except that it seems to include any future planting or gardening works to be carried out in the common property garden adjacent to Lot 3.
• [40] The body corporate is under no specific legislative obligation to obtain the prior agreement of the applicant before any planting or other gardening work is carried out in the common property garden adjoining Lot 3. As I outlined earlier, the legislation stipulates how motions are passed by the committee and how, for general meetings, the votes cast for a motion are counted according to the required resolution type. If the body corporate wants to make any improvements to the common property, they must be approved in accordance with section 186 of the Standard Module. The cost of an improvement will determine the requisite body corporate approval.
• [41] For clarity, I also note that if any work to be done in the common property garden adjoining Lot 3 is classed as maintenance instead of an improvement, committee approval will suffice if the work does not exceed the committee's spending limit. Otherwise, an ordinary resolution at a general meeting may be necessary to approve common property maintenance.[24]
• [42] It is not clear what the applicant means by obtaining their 'input' in addition to their agreement. As clarified earlier, the applicant must be notified of any motions to be voted on, whether at a committee meeting, by a VOCM, or if the committee does not have the authority to vote on the motion, at a general meeting. It is then for the applicant to choose whether to provide 'input' to the other committee members or owners.
• [43] Even though this order appears to be about any potential works in the common property garden (distinct from the first order regarding specific gardening works which were allegedly approved), the applicant simply relists all the same provisions relied on for the first order sought without any clear explanation as to how they have been contravened.
• [44] At this stage, the applicant has not yet demonstrated a prima facie case for the body corporate to obtain their prior agreement before carrying out any future planting, removal, or landscaping works in the common property garden adjoining Lot 3.
• [45] However, if at some future time the body corporate resolves to do certain planting or landscaping works in the common property garden adjoining Lot 3, it is open to the applicant to lodge a separate application about that decision if internal efforts to resolve the matter are unsuccessful. The onus would then be on the applicant to demonstrate how the body corporate has acted unreasonably in making its decision or how its decision is otherwise invalid.

• [46] The body corporate legislation does not specifically regulate communications between individual owners and service contractors or external contractors.
• [47] Again, the applicant has listed multiple provisions without any clear explanation as to how the body corporate has allegedly breached them.
• [48] The legislation enables an owner to submit a written motion to the committee or to a general meeting of owners for a decision.[25] I can see nothing in the application material to suggest that the applicant has previously submitted a written motion asking for each owner to liaise directly with the gardener regarding the maintenance and appearance of the common property gardens adjoining their lots. The applicant only mentions communicating verbally with the chairperson. Until the applicant has submitted a motion seeking this outcome and been refused, there does not yet appear to be a current dispute with the body corporate within the jurisdiction of an adjudicator.[26] If the applicant's motion is refused, they could then consider whether the body corporate has acted reasonably when making its decision (as opposed to now when a decision is yet to be made).[27]
• [49] Irrespective of the applicant's claim about past practices at the scheme which allowed for direct liaison with the gardener, the legislation does not provide for an individual owner making decisions unilaterally about general common property, even if the area is adjacent to an owner's lot. Body corporate decisions are made either by the committee (provided it is not a restricted issue) or at a general meeting.[28] Moreover, the Act does not permit the body corporate to delegate its decision-making power.[29]
• [50] In my preliminary view, the applicant has not yet made an arguable case for each owner to communicate directly with the gardener regarding their individual preferences for the maintenance and appearance of the common property garden adjoining their lot.

Removal and replacement of existing plantings along the internal driveway (orders 4 and 5)

• [51] The applicant has again cited various provisions without any explanation as to how they have been contravened.
• [52] The applicant says they raised the issue of replacement planting along the internal driveway verbally with the chairperson and in writing to the committee on 20 July 2025. However, I note that in the email of 20 July 2025, the applicant only recommends 'addressing the inconsistent and deteriorating plants along the driveway' in very general terms. No mention is made of removing all existing plantings and replacing them with the specific plantings sought in orders 4 and 5.
• [53] Until the applicant has submitted a written motion to the body corporate seeking these specific outcomes and the motions are rejected, there does not yet appear to be a current dispute with the body corporate within the jurisdiction of an adjudicator.[30] At this stage, the applicant has not yet made a prima facie case for the removal and replacement of existing plantings along the internal driveway.

Termination of the current gardener and engagement of a new gardener (orders 6 and 7)

• [54] From the information provided, it is not clear whether the gardener has been engaged as a service contractor for 216 Cypress Street. The Act defines a 'service contractor' as a person engaged by the body corporate (other than as an employee) for a term of at least 1 year to supply services (other than administrative services) to the body corporate for the benefit of the common property or lots.[31]
• [55] I also note that the applicant has referred to Schedule 2 of the Act, which is the code of conduct for caretaking service contractors and body corporate managers. Relevantly, a 'caretaking service contractor' is distinct from a 'service contractor'. The Act defines a 'caretaking service contractor' as a service contractor who is also a letting agent for the scheme or an associate of a letting agent.[32] As the parties have only been referring to gardening services, the applicant may be mistaken in their reference to Schedule 2 of the Act.
• [56] If the current gardener has been engaged as a service contractor,[33] the Standard Module sets out the grounds on which the body corporate may terminate a person's engagement as a service contractor and the steps the body corporate must follow.[34] The applicant alleges that there has been repeated non-performance and unresponsiveness by the gardener. At this stage, these claims appear to be based on nothing more than the applicant's bare assertions.
• [57] The Standard Module provides that if a service contractor fails to carry out duties under their engagement, the body corporate may issue a remedial action notice.[35] If the gardener has been engaged as a service contractor, I can see nothing in the submitted material to indicate that the applicant has previously submitted a written motion to the committee or to a general meeting seeking that a remedial action notice is issued. Alternatively, if the gardener is not a service contractor, I can see nothing in the application material to suggest that the applicant has previously submitted a written motion seeking another action. Merely raising concerns about alleged non-performance with the body corporate manager is not adequate self-resolution and does not evidence a current dispute with the body corporate on this issue.[36]
• [58] Furthermore, the applicant has not yet identified any legal basis for requiring the body corporate to engage a new gardener. It is open to the applicant to submit a motion to the body corporate at an appropriate time.[37] Again, verbal communication with the body corporate manager is not appropriate self-resolution. Even if the body corporate chooses not to continue with the services of the current gardener, the body corporate is under no specific legal obligation to engage a replacement gardener. The legislation simply requires the body corporate to maintain the common property in a good and structurally sound condition.[38] How the body corporate fulfils its statutory maintenance obligations is a question for the body corporate.
• [59] The applicant has not yet demonstrated any genuine legal issues in relation to orders 6 or 7 at this stage.

• [60] I can see nothing in the submitted material to suggest that the applicant has submitted a written motion to the body corporate asking them to vote on making the applicant the primary point of contact for the gardener. The applicant has only referred to their 'earlier communications'. As there is nothing to suggest that the applicant has asked and been refused, there does not appear to be a current dispute with the body corporate within the jurisdiction of an adjudicator at this stage.[39]
• [61] In addition to being made the primary point of contact for the gardener, the order is also asking for the applicant to be able to give reasonable instructions to the gardener regarding the maintenance of the garden and lawn areas within the complex. It is not immediately clear what the applicant means by giving 'reasonable instructions' to the gardener. As I have outlined earlier, the legislation does not provide for an owner making decisions unilaterally in relation to the general common property. Moreover, the body corporate cannot delegate its decision-making power.[40]
• [62] If such a motion is submitted to the body corporate in the future and it fails, the onus will ultimately be on the applicant to demonstrate how the body corporate has acted unreasonably in refusing to the make the applicant the primary point of contact.
• [63] At this stage, the applicant has not yet made a prima facie case in relation to order 8.

• [64] Order 9, which seeks that both owners from Lot 1 are removed from the committee, appears to be the only final order sought that is not connected to gardening works within the scheme and is therefore not relevant to my determination of the interim order application. However, I will make some brief comments regarding order 9 for the information of the parties moving forward.
• [65] First, the minutes from the annual general meeting held on 1 May 2025 indicate that Sharon Buckland is not a committee member. Only Paul Buckland, who holds the positions of secretary and treasurer, is currently a committee member.
• [66] The legislation provides 2 distinct ways to remove a committee member from office - specifically, by ordinary resolution at a general meeting,[41] or alternatively, if the removal is for a breach of the code, pursuant to a more protracted process prescribed in the applicable regulation module.[42]
• [67] Relevantly, the applicant has cited section 101B of the Act regarding the code. I can find nothing in the submitted material to suggest that the applicant has previously attempted to remove Paul Buckland from the committee at a general meeting in accordance with section 45 of the Standard Module. Until the applicant has tried to remove this committee member from office using this procedure and failed, there does not appear to be a current dispute within the jurisdiction of an adjudicator.[43] The applicant should also bear in mind that committees under the Standard Module must generally consist of at least 3 voting members.[44]
• [68] However, as 216 Cypress Street is only a 3-lot scheme, it is arguable that a representative of each lot must be on the committee.[45]

• [69] The applicant asserts that if the gardening works proceed before the determination of the substantive issues, it will be both difficult and costly to reverse. However, little to no detail or evidence has been provided to support the applicant's claims about the alleged consequences of the gardening works being carried out before the determination of the final orders.
• [70] As discussed earlier, it is not clear whether the works are going to be carried out imminently by the body corporate. The joint submission from the owners asserts that there has been no decision about the relevant gardening works in the disputed areas and that no committee meeting will be held to vote on the work until the matter is resolved.
• [71] In any case, the exact wording of the interim order sought indicates that the applicant is not only seeking to restrain the body corporate from carrying out the specific gardening works which were allegedly approved. Rather, the scope of the interim order is seemingly broad enough to stop the body corporate from carrying out any planting, landscaping, or alteration works in the common property area immediately adjacent to the applicant's lot and in the narrow grassed strip along the rear boundary fence. In my view, this interim order is overly broad and unwarranted.
• [72] The combination of these factors, together with the fact that, at this stage, no genuine legal issues appear to have been raised in relation to 8 of the final orders sought, the applicant has not substantiated that there is any basis to grant the interim relief sought.

• [73] For the reasons outlined above, I have dismissed the interim order application. At this stage, the applicant has not yet established a likelihood of success on genuine legal issues in relation to the final orders currently sought. Even if the applicant had demonstrated a prima facie case on the substantive issues in dispute, they have not satisfied me that granting the broad interim order sought is warranted in the circumstances.
• [74] The application for final orders remains to be determined. Pursuant to the Act, I will refer the application back to the Commissioner to progress.[46]
• [75] If the application is not withdrawn, the applicant may wish to review the basis for the application in light of the matters outlined above.
• [76] While I appreciate that the applicant does not believe the matter to be suitable for conciliation due to alleged rejection, hostility, and exclusion during previous communications, if the application proceeds, I will recommend that the Commissioner refer this application to department conciliation. Having an impartial person facilitating communications may assist the parties to reach their own agreement about the issues still in dispute. Given the interpersonal conflict which clearly exists within the scheme, conciliation may have the additional benefit of improving communications between the parties and their understanding of the legislative requirements for decision-making moving forward.
• [77] I encourage the parties to make use of the ample resources available on the website of the Office of the Commissioner for Body Corporate and Community Management to increase their understanding of body corporate decision-making processes.

[3] Sections 227, 228, 276 and Schedule 5 of the Act

[10] Sandcastles [2025] QBCCMCmr 258 at 61

[12] Section 68 and 69 of the Standard Module

[16] Section 111(1)(b) of the Act. Only schemes under the Commercial or the Small Schemes Module can vote outside a general meeting.

[18] Section 186 of the Standard Module

[19] Schedule 6 (Dictionary) of the Act

[20] Section 186 of the Standard Module

[21] Section 65(2) of the Standard Module

[22] Section 69(2) of the Standard Module

[24] Section 172 of the Standard Module

[25] Section 58 and 86 of the Standard Module

[26] Section 238(1)(b) of the Act; Reef Royale [2023] QBCCCMCmr 258 at 90

[27] Section 94(2) and 100(5) of the Act

[30] Section 238(1)(b) of the Act; Reef Royale [2023] QBCCCMCmr 258 at 90

[32] Schedule 6 (Dictionary) of the Act

[33] Section 135 of the Standard Module

[34] Chapter 6, Part 5 of the Standard Module

[35] Section 152 of the Standard Module

[36] Section 238(1)(b) of the Act; Reef Royale [2023] QBCCCMCmr 258 at 90

[37] Section 135 of the Standard Module

[38] Section 180(1) of the Standard Module

[39] Section 238(1)(b) of the Act; Reef Royale [2023] QBCCCMCmr 258 at 90

[41] Section 44(2)(f) of the Standard Module

[42] Section 44(2)(g) and 45 of the Standard Module and section 101B(3) of the Act

[43] Reef Royale [2023] QBCCCMCmr 258 at 90

[44] Section 9(4) of the Standard Module