NSWNSWLEC

Burwood Council v Alam

[2025] NSWLEC 2

Land and Environment Court (NSW)|2024-12-16|Before: Duggan J

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At a glance

Source facts

Court

Land and Environment Court (NSW)

Decision date

2024-12-16

Before

Duggan J

Catchwords

(1993) 82 LGERA 21 Chief Executive Office of Environment and Heritage v Clarence Valley Council (2018) 236 LGERA 291
[2018] NSWLEC 205 Cooper v Coffs Harbour City Council (1997) 97 LGERA 125
(1997) 98 A Crim R 340 Environment Protection Authority v Baiada Poultry Pty Ltd (2008) 163 LGERA 71
[2006] NSWLEC 419 Great Lakes Council v Spalding [2011] NSWLEC 257 Markarian v The Queen (2005) 228 CLR 357

Source

Original judgment source is linked above.

Catchwords

(1993) 82 LGERA 21 Chief Executive Office of Environment and Heritage v Clarence Valley Council (2018) 236 LGERA 291[2018] NSWLEC 205 Cooper v Coffs Harbour City Council (1997) 97 LGERA 125(1997) 98 A Crim R 340 Environment Protection Authority v Baiada Poultry Pty Ltd (2008) 163 LGERA 71[2006] NSWLEC 419 Great Lakes Council v Spalding [2011] NSWLEC 257 Markarian v The Queen (2005) 228 CLR 357[2005] HCA 25 Pearce v The Queen (1998) 194 CLR 610[1998] HCA 57 Plath v Rawson (2009) 170 LGERA 253

Judgment (39 paragraphs)

[1]

Nature of proceedings

In this matter, Radwan Alam (the Defendant) has pleaded guilty to two charges that he breached s 4.2(1)(b) of the Environmental Planning and Assessment Act 1979 (NSW) (EP&A Act) in that he carried out development otherwise than in accordance with a development consent. The two charges relate to demolition works undertaken by the Defendant at a residential premise in Burwood NSW.
These proceedings are to sentence the Defendant with respect to the two offences.

[2]

[4]

Development Application and Consent

On or around 15 February 2021, ES Design lodged a development application with Burwood Council (the Council or the Prosecutor) in respect of the Land on behalf of the Defendant, with various documents including, inter alia, architectural plans, a Statement of Environment Effects and Heritage Impact Statement (HIS).
On 13 September 2021, Council granted development consent 11/2021 in respect of the Land, for the "[p]artial demolition of rear ground floor, internal alterations to existing two storey dwelling and removal of trees" (the Consent).
Condition 1 of the Consent, under the heading "Conditions of Approval", provided as follows: (1) The development being carried out in accordance with the approved stamped Architectural Plans, Schedule of External Materials, Colours and Finishes, Landscape Plans, Tree Protection Plan and Specifications, Arboricultural Impact Assessment Report and Elemental Cost Estimate Report submitted on 28/07/2021, Statement of Environmental Effects submitted on 4/03/2021, Heritage Impact Statement and Waste Management Plan submitted on 15/02/2021, except where amended by the conditions of consent.
Conditions 6-7 of the Consent, under the heading "HERITAGE", provided as follows (with emphasis in original): (6) A Schedule of Conservation Works detailing all proposed works to the building fabric, including the manner of change, materials, finishes, etc shall be submitted to Council for approval, prior to the issuing of a Construction Certificate. The Schedule shall include such matters as changes to the proposed bathroom floor/s, painting, any changes to windows/doors and alterations or removal of other joinery. The Schedule should identify where original fabric is to be removed and how that fabric is to be salvaged and/or stored. The Schedule must also identify any repair and/or maintenance required on the building (including roof tiles). Identified repairs/maintenance is required to be undertaken as part of the development of the property. The Schedule of Conservation Works is to also include elements relating to original fabric raised within "Section 6.1 - Design Recommendations" of the submitted Heritage Impact Statement (Project Code P0027288, Report Number 02 Final Copy 02.02.2021) prepared by Urbis Pty Ltd dated February 2021. (7) Work to the exterior and interior shall be undertaken under the guidance of a suitably qualified Heritage professional. All work shall be undertaken in accordance with the approved Schedule of Conservation Works. The work shall be inspected by a qualified heritage professional/consultant or Burwood Council.

[10]

Defendant's Remedial Building Action Plan

The Defendant obtained a Remedial Building Action Plan from the firm Weir Phillips Heritage and Planning, dated September 2023 (the RAP).
The RAP notes (at [2.1]) that the only dwelling walls remaining intact on the Land were the masonry wall on the street front northern elevation, the masonry walls on the western elevation, and the northern half of the masonry walls on the eastern elevation.
The following sketch contained in the RAP depicts: (i) the masonry walls of low heritage significance that were removed (dotted green lines); (ii) the masonry walls, two verandahs and one bay window of high heritage significance that were removed (dotted orange lines); and (iii) the masonry walls that were not removed (black solid lines).
Attached to the RAP is a Schedule of Conservation Works for the Land (the SCW), which the Defendant obtained from Heritage 21 in March 2022 in accordance with condition 6 of the Consent.
In relation to the heritage significance of the masonry walls, the SCW records that "Original masonry is to be retained and made good as instructed", and where a structural engineer has determined that cracks and deformations are impacting the structural integrity of the building, such that bricks needed replacing, the mason undertaking the work is to inspect the rear face of the brick for damage. If the rear face is deemed to be in good condition, the brick is to be re-laid using the rear face at the façade. Further, that existing masonry is to be made good where the masonry poses a risk to the structural integrity of the building users, under the direction of a structural engineer and in collaboration with Heritage 21. The SCW also records that internal walls within the area of high significance should be restored sympathetically, employing traditional techniques and materials.
In addition to masonry walls, the SCW lists the following relevant items as having been demolished and/or removed from the Dwelling on the Land: terracotta Marseille roof tiles, rafters and associated roof timbers had been completely removed; ceiling joists and associated timbers had been completely removed; the bay window in the street elevation had been removed; the high significance street front and eastern front verandahs had been completely removed; all the timber windows had been completely or partially removed with the exception of the portal window in the street elevation; and all the doors had been completely removed with the exception of the French doors in the street elevation.

[13]

Defendant's Admissions

On 16 October 2023, Council wrote to the Defendant asking questions in respect of the offending conduct as part of its investigation (Council's Questions).
The Defendant advised that he would assist Council with its investigation and provide answers to Council's Questions following receipt of legal advice.
On 21 December 2023, the Defendant provided responses to Council's Questions.
In the responses, the Defendant made various admissions in writing as to his involvement in the offence, including the following: I understood the DA approved some demolition of the building and alteration to it. While I was carrying out the works, I noticed that a lot of walls had cracks and defects within them while I was doing the work to the building. These showed when I was doing works next to or near walls and when paint began to crack off from walls. Because the building was to be my family home I was worried about this and organised for a structural engineer to review the walls and building generally. I received advice from a structural engineer that many walls and footings were not stable to support the proposed works. When I heard this and the engineer's recommendations my response was to focus on resolving the problem. I honestly always intended to replace every bit of wall which was removed, exactly where it was located just with proper structure and footing to make it safe. When I started the work I was completely focused on resolving the structural problem which the engineer had identified and because I was simply going to replace the wall, just with footings underneath it I didn't focus on stopping and talking to council about it or getting someone to seek approval for me. I was worried about the structure and removed the roof above the walls which were not structurally sound. Once I started removing the walls which were shown as not structurally sound this made the wall next to it less stable and come down [sic]. I removed all the walls which were shown as structurally not sound but made sure that I retained all of the walls the engineers report showed as being stable and structurally sound. I understand now that the work I did went well beyond what the approval allowed me to do with demolition. I have been shown plans and agree that the demolition I did was beyond what the approved plans allowed for. My intention was not to demolish the building but simply rebuild it in a safe way on footings so that my family could live there. I kept the materials and bricks to rebuild the walls on site. I removed the roof because I was worried it was unstable and needed to come done [sic] to allow me to rebuild the walls and attach it to it.
The Defendant also admitted to undertaking all the unlawful works himself, including "the demolition works of the roof and walls" using his own machinery.

[16]

Statutory matters required to be taken into account in sentencing

For the purposes of sentencing in these matters the following factors as provided for in s 21A of the CSP Act have been identified as relevant: 21A Aggravating, mitigating and other factors in sentencing (1) General In determining the appropriate sentence for an offence, the court is to take into account the following matters - (a) the aggravating factors referred to in subsection (2) that are relevant and known to the court, (b) the mitigating factors referred to in subsection (3) that are relevant and known to the court, (c) any other objective or subjective factor that affects the relative seriousness of the offence. The matters referred to in this subsection are in addition to any other matters that are required or permitted to be taken into account by the court under any Act or rule of law. (2) Aggravating factors The aggravating factors to be taken into account in determining the appropriate sentence for an offence are as follows - … (g) the injury, emotional harm, loss or damage caused by the offence was substantial, The court is not to have additional regard to any such aggravating factor in sentencing if it is an element of the offence. … (3) Mitigating factors The mitigating factors to be taken into account in determining the appropriate sentence for an offence are as follows - … (e) the offender does not have any record (or any significant record) of previous convictions, (f) the offender was a person of good character, (g) the offender is unlikely to re-offend, (h) the offender has good prospects of rehabilitation, whether by reason of the offender's age or otherwise, (i) the remorse shown by the offender for the offence, but only if - (i) the offender has provided evidence that he or she has accepted responsibility for his or her actions, and (ii) the offender has acknowledged any injury, loss or damage caused by his or her actions or made reparation for such injury, loss or damage (or both), (k) a plea of guilty by the offender (as provided by section 22 or Division 1A), (m) assistance by the offender to law enforcement authorities (as provided by section 23), … (4) The court is not to have regard to any such aggravating or mitigating factor in sentencing if it would be contrary to any Act or rule of law to do so. (5) The fact that any such aggravating or mitigating factor is relevant and known to the court does not require the court to increase or reduce the sentence for the offence.
It is to be noted that where a prosecutor contends that a particular sentencing consideration should be treated as an aggravating feature it must establish by evidence, beyond reasonable doubt the presence of such aggravating factor. Where a Defendant contends for the presence of a mitigating factor in sentencing it must establish the presence of such factor on the balance of probabilities: Environment Protection Authority v Sydney Water Corporation [2019] NSWLEC 100 at [131].

[17]

Objective seriousness of offences

The determination of an appropriate sentence is to be undertaken bearing in mind that: A sentence should never exceed that which can be justified as appropriate or proportionate to the gravity of the crime considered in light of its subjective circumstances: Bentley v BGP Properties Pty Ltd (2006) 145 LGERA 234 at [162].
The primary factor to be considered in sentencing is the objective seriousness of the offences. The objective seriousness of the offences fixes both the upper and lower limits of proportionate punishment: the upper, as a sentence should never exceed that which can be identified as proportionate to the gravity of the particular crime; and the lower, as an allowance for the subjective considerations can never produce a punishment that does not reflect the objective seriousness of the offence: Environment Protection Authority v Waste Recycling and Processing Corporation (2006) 148 LGERA 299; [2006] NSWLEC 419 at [139]-[140].
The objective gravity of the offence is to be judged by two principal components: the precise acts or omissions of the offender; and the consequences of those acts or omissions: Environment Protection Authority v Baiada Poultry Pty Ltd (2008) 163 LGERA 71; [2008] NSWLEC 280 at [22].
The Defendant accepted that in an environmental offence (such as the cases before me) in determining objective seriousness the factors to be taken into account may include those outlined in Plath v Rawson Plath v Rawson (2009) 170 LGERA 253; [2009] NSWLEC 178 at [48] (per Preston CJ of LEC). Such factors, though not exhaustive, include: 1. The nature of the offences; 2. The maximum penalties for the offences; 3. The harm caused to the environment by the commission of the offences; 4. The state mind of the offender in committing the offences; 5. The offender's reasons for committing the offences; 6. The foreseeable risk of harm to the environment by commission of the offences; 7. The practical measures to avoid harm to the environment; and 8. The offender's control over the causes of harm to the environment.

[19]

The harm caused to the environment by the commission of the offences

A factor that is relevant in the consideration of the environmental harm caused by the commission of the offences in these cases is that the Consent related to a dwelling that had been identified as an item of environmental heritage. Section 3.1 of the EP&A Act sets out the objects of that Act and relevantly for the purposes of the consideration of sentence in these proceedings, includes as one of its stated objects: (f) To promote the sustainable management of built and cultural heritage (including Aboriginal cultural heritage).
Such an object makes apparent that the process of requiring the proper assessment of heritage impact prior to the undertaking of any development that is likely to affect the heritage significance of any relevant item. Absent such assessment the ability to sustainably manage such resources is undermined and the integrity of the system provided for in the EP&A Act to manage such impacts is diminished: Great Lakes Council v Spalding [2011] NSWLEC 257 at [35]. The facts of the cases before me disclose that the nature of the offences related to a heritage item and that the demolition of parts of the building that had heritage value had not been authorised nor had such impacts been assessed. Further, identified as part of the heritage value of the individual building was its relationship as part of an intact group of heritage buildings. The carrying out of the unauthorised work impacted not only the heritage value of the individual building but also diminished the heritage value of the group of buildings.
Affidavit evidence of Ms Trueman, heritage consultant was adduced by the Prosecutor. This evidence was not contested by the Defendant. She summarised the environmental impact of the unauthorised works at pars 18-19 and 21-23 as follow: 18 The near complete demolition of the house has had a major adverse material impact on the significance of the heritage item. The significance of the house has been fundamentally lost. Its significance under criterion a), c) and g) has been lost. This amounts to major environmental harm. 19 The reconstruction of the house in accordance with the Land and Environment Court approved Development Control Order No. 10 (Radwan Alam v Burwood Council LEC Proceedings 2023/166071) will result in the construction of a facsimile of the original cottage. This would mitigate some of the harm. … 21 In addition, the significance and integrity of the group of cottages form 48-54 Fitzroy Street has been diminished by the loss of one of the four original cottages. This amounts to a moderate to high amount of environmental harm. 22 The photographs below, taken on 7 November 2024, show the group of significant houses and demonstrate the impact of the loss of the house at 48 Fitzroy Street, which previously formed the western 'bookend' of the group. The loss of the roof and front verandah, elements that are consistent across the group, has eroded the cohesion and integrity of the historic streetscape. 23 Furthermore, the significance and integrity of the Wallace and Brady Streets Heritage Conservation Area has been diminished by the loss of a building that had a strong contribution to the heritage values of the HCA. This also amounts to a moderate to high amount of environmental harm.
The Defendant submitted that it was also appropriate for consideration to be given to the heritage report obtained by him in connection with the RAP. In that report the author considers the individual elements of the building and attributes a heritage value to each element, from high to low heritage significance. I have taken that report into account. However, that report was not commissioned to express an opinion on the totality of the harm caused by the offending, but to identify a means to remedy or mitigate the harm that the work had caused. Whilst each element of the building may have had differing heritage significance when viewed in isolation, the offending works were not isolated or limited to a particular item of a particular heritage value. Rather, the works when viewed as a whole, represent a loss of heritage value as described by Ms Trueman. Whilst I have taken the RAP report into account, I do not consider that it permits of a finding that the harm was not substantial.
Having regard to the evidence adduced, I am satisfied beyond reasonable doubt that the offending conduct caused environmental harm to the heritage item itself and the integrity of the group of which it forms part, which harm was substantial. I therefore consider this an aggravating factor to be taken into account in the sentencing for each matter under s 21A(2)(g) of the CSP Act.

[21]

The offender's reasons for committing the offences

Each of these offences are strict liability offences and therefore do not require, as an element of the offence, intention to commit the offence. However, the offender's state of mind or reasons for committing an offence may nonetheless be relevant in determining the degree of criminality in assessing the objective seriousness of the offending.
In this case, as is outlined at [42] in his response to the Council's Questions the Defendant indicated that he acted to demolish those parts of the building that he considered were structurally unsound. His assessment of the structural adequacy of the building was supported by an inspection (and later written advice) of a qualified structural engineer (see [20] and [21]).
On the evidence adduced in this matter there is no reasonable basis not to accept that the reason the Defendant committed the offending conduct was to remedy what he believed to be a structural defect.
I also take into account the fact that the Defendant must have known that development consent was required for any demolition, as is evidenced from his application to the Council for the Consent where the scope of the demolition was clearly defined. Further, the conditions imposed upon the development consent clearly prescribed the extent of work that was authorised. Any casual reading of the development consent would have made it apparent that the demolition works the subject of these proceedings was not authorised by Council.
In addition, the heritage impacts of the demolition must also have been known to the Defendant. The development application lodged by him was accompanied by a HIS. The conditions of the Consent required the carrying out of the development in accordance with that HIS (condition 1). Specific conditions were also imposed upon the Consent to manage the impact upon the heritage values of the Dwelling (conditions 6-9). Each of these factors, on any view, were sufficient to bring the risks of environmental harm to the attention of the Defendant.
The Defendant's state of mind and reasons for committing the offences, from the evidence available, is that the Defendant did not turn his mind to whether the development consent authorised the further demolition works. The failure to even contemplate the scope of the Consent in deciding to carry out the offending works is a matter that increases the seriousness of the offending conduct, as it is an essential part of the scheme of the EP&A Act that a person authorised to carry out development do so within the confines of that for which they have sought and obtained consent. I accept that there is no evidence that the Defendant committed the offences intentionally in so far as he had the intention to breach the law. However, the failure to turn his mind to whether further consent was required, whilst an explanation, does not reduce the criminality of the offending conduct, it is a matter that increases the objective seriousness of the offending in the circumstances of each of these cases.

[27]

Character of the Defendant, unlikely to reoffend, and prospects for rehabilitation - s 21A(3)(f), (g) and (h) of the CSP Act

The Defendant provided two character references.
The first from Mr Dakhoul. Mr Dakhoul's reference was addressed to the Court and it indicated in that he had been provided with a copy of the Agreed Facts. On that basis, I am satisfied that Mr Dakhoul provided the reference with full knowledge of the circumstances surrounding the offending and the purpose to which his reference was to be directed. Mr Dakhoul stated: I have known Radwan in both a personal and professional capacity. In my dealings with him, I have found him to be an individual of integrity, responsibility, and a strong sense of moral accountability. In the years I have known Radwan I have had the time to observe him work. I also work in the construction industry. It is important to acknowledge that, while the offence in question is serious, Radwan has shown sincere remorse and taken full responsibility for his actions. From my perspective, he has been forthcoming about the mistake he made and has expressed genuine regret over the consequences of his decisions. I have seen how deeply this situation has affected him, and I believe that it has given him the opportunity to reflect on his actions and to learn from this experience. Radwan's character outside of this incident speaks to a person who is committed to his family, his community, and his professional life. He has always been someone who values honesty and fairness, and I have witnessed these traits in both his personal and professional relationships. In the time I have known him, he has been consistently respectful, kind, and considerate of others. I have no doubt that this unfortunate incident does not reflect his overall character or the type of person he is.
The second reference was from Mr Rufo who has known the Defendant for some 24 months in a professional capacity. Mr Rufo's reference was addressed to the Defendant's solicitor (and the presiding magistrate) and whilst he commented that he understood that the Defendant was required to attend court "about development actions" at the relevant premises I am less certain that Mr Rufo fully understood the nature and context of the offending. To the extent that Mr Rufo expresses his opinion as to why the Defendant engaged in the offending, I give such expression little weight. However, I accept his reference in so far as he attests to his knowledge of the Defendant and where he states: I safely attest to have found Mr Alam to be of good character, respectful to those of his employ and with very close ties to his immediate family and children.
I am satisfied on the basis of these references that the Defendant is of good character and I will take that factor into account as a mitigating factor in the sentence for each proceeding.
For the reasons I outline in connection with the considerations relating to remorse and specific deterrence I also consider that the Defendant has good prospects of rehabilitation and is unlikely to reoffend. As the consideration overlaps with the relevant factors identified I will not separately take this matter into account as a mitigating factor but will consider it as part of my considerations on remorse and specific deterrence.

[31]

Deterrence, retribution and denunciation

As to specific deterrence I am satisfied, for the reasons outlined above in connection with his expressions of remorse, that the Defendant is now fully aware that demolition of the type he undertook cannot be undertaken without the necessary consent. In light of that understanding, I do not consider that there is a need for the sentence to reflect a specific deterrence.
It has been observed that there must be an element of general deterrence in dealing with significant breaches of the planning laws: Cooper v Coffs Harbour City Council (1997) 97 LGERA 125; (1997) 98 A Crim R 340 at 143. As was observed Chief Executive Office of Environment and Heritage v Clarence Valley Council (2018) 236 LGERA 291; [2018] NSWLEC 205 at [98]-[99] (per Preston CJ of LEC): …The sentence of the Court needs to operate as a powerful factor in preventing the commission of similar offences by other persons who might be tempted to do so by the prospect that, if they are caught, only light punishment will be imposed. Courts have repeatedly stated, when sentencing for environmental offences, that the sentence of the Court needs to be of such magnitude as to change the economic calculus of persons in determining whether to comply with or to contravene environmental laws. It should not be cheaper to offend than to prevent the commission of the offence. Environmental crime will remain profitable until the financial cost to offenders outweighs the likely gains by offending. [case citation omitted] Where a fine or other monetary penalty is determined to be appropriate, the amount needs to be such as will make it worthwhile to incur the cost of complying with the law and undertaking the necessary precautions. The amount of the monetary penalty must be substantial enough so as not to appear as a mere licence fee for illegal activity. The sentence of the Court changes the economic calculus of persons who might be tempted not to comply with environmental laws or not to undertake the necessary precautions. Compliance with the law becomes cheaper than offending. Environmental crimes become economically irrational. [case citation omitted]
It is often the case that once development commences defects relating to an existing building become apparent. However, the identification of such defects and the necessity to undertake some action to address such matters do not overcome the legal necessity to obtain approval to undertake work not otherwise authorised by a development consent. The EP&A Act makes statutory provision for the modification of development consents in such circumstances. The EP&A Act also mandates that any such work be critically assessed prior to any approval being granted. Such a process ensures that all relevant factors, including, as arose in this case, the questions of heritage are addressed and considered.
In this case, such circumstances are central to the environmental harm that was occasioned by the offending conduct. For that reason, I consider it appropriate to consider the need for general deterrence in the determination of the relevant penalty for the offending conduct.

[36]

Totality principle

The principle of totality is a relevant sentencing principle in the present case where both offences with which the Defendant has been charged and which it has pleaded guilty arise from the same identical facts and circumstances.
The principle has been concisely described by the majority of the High Court in Pearce v The Queen (1998) 194 CLR 610; [1998] HCA 57 at [40] as: To the extent to which two offences of which an offender stands convicted contain common elements, it would be wrong to punish that offender twice for the commission of the elements that are common. No doubt that general principle must yield to any contrary legislative intention, but the punishment to be exacted should reflect what an offender has done; it should not be affected by the way in which the boundaries of particular offences are drawn. Often those boundaries will be drawn in a way that means that offences overlap. To punish an offender twice if conduct falls in that area of overlap would be to punish offenders according to the accidents of legislative history, rather than according to their just deserts.
It is appropriate to leave questions of totality to the end of the sentencing process and apply a final check of the aggregate sum of the fines proposed to be imposed against whether it is a just and appropriate penalty for the entire criminality: ACE Demolition & Excavation Pty Ltd v Environment Protection Authority (2024) 260 LGERA 358; [2024] NSWCCA 4 at [111].
In this case, the Prosecutor commenced two sets of proceedings in relation to the one course of conduct. The differentiation between the conduct was said to relate to: 1. Demolition using heavy machinery: proceedings 2024/00216164; and 2. Demolition by way of removal without the use of heavy machinery: proceedings 2024/00216165.
When viewed in the context of that distinction, it is apparent that the elements of each offence are co-incident with respect to the conduct and circumstances giving rise to the commission of each offence and the consequence of each offence. The only distinction identified was the means by which the conduct was undertaken. There is no element of the offences before me that distinguishes between the means of demolition.
In considering the two offences I am satisfied that the circumstances are such that the application of the sentencing principle of totality is appropriate to be applied in the circumstances of this case. However, in applying the principle of totality I must also ensure that the specific elements of demolition are taken into account, as each proceeding particularises a different element of the building demolished. In those circumstances, I consider it appropriate that the appropriate sentence in each matter be reduced by 50% to reflect the differing elements demolished whilst recognising that the offending was a single course of conduct giving rise to the same offence under the EP&A Act. A fine of such amount would represent the aggregate sum reflecting the just and appropriate fine for the entire criminality.
Accordingly, in applying the principle of totality to the fine I determined at [96] above, the fine to be imposed as an appropriate sentence in each proceeding is: 1. In proceedings 2024/00216164, a fine in the amount of $93,750 reduced by 50% for totality resulting in a fine of $46,875; and 2. In proceedings 2024/00216165, a fine in the amount of $93,750 reduced by 50% for totality resulting in a fine of $46,875.

Burwood Council v Alam - [2025] NSWLEC 2 - NSWLEC 2024 case summary — Zoe

Burwood Council v Alam

At a glance

Court

Decision date

Before

Catchwords

Source

Catchwords

Judgment (39 paragraphs)

Parties

Legislation Cited (5)

Cases Cited (23)