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

IMPROVEMENT TO COMMON PROPERTY - REASONABLENESS - whether a proposal to install power points in a common property car park for the purpose of electric vehicle charging was a restricted issue for the committee - whether the committee's refusal was reasonable in the circumstances.

Act, ss 94(2), 100(5); Standard Module, ss 187, 193.

• [1] This application is brought by the owner of Lot 3105 against the body corporate. The applicant disputes the body corporate's refusal to allow them and owners of Lot 3003 (who are listed as affected persons) to install power points in common property car parks they have exclusive use of. The power points would be specifically designed and used to charge their electric vehicles (EVs) via a 'trickle charger'.
• [2] The applicant says the body corporate has acted unreasonably in refusing the request. In response, the body corporate says the committee did not have the power to approve the request. Alternatively, even if the committee did have the power, it is argued the refusal was reasonable.
• [3] While I have not found that the proposal was a restricted issue for the committee, I have dismissed the application. I have found the body corporate has acted reasonably in its refusal due to fire safety concerns in circumstances where:
  1. Submissions opposing the application have provided evidence to suggest EV fires, while rare, can take place during charging. The applicant has not provided sufficient evidence that there is no risk of thermal runaway with the type of charger they intend to use.
  2. With the above in mind, the body corporate has provided evidence that a fire involving an EV lithium battery, though rare, is a special hazard that can require specific fire suppression and intervention infrastructure. The applicant has not provided evidence that the body corporate's current fire suppression systems are sufficient in addressing such a hazard.
• [4] Notably, the evidence provided to me suggests thermal runaway events of EV batteries are not limited to charging. This decision does not stop EVs being on scheme land. If the body corporate has genuine concerns about its fire suppression system, it may like to seek expert advice and take any necessary steps to reduce those concerns, regardless of this application.

• [5] The community management statement (CMS) shows the Standard Module applies. The scheme is also subject to a building management statement (BMS).
• [6] The survey plans for the scheme show it is a building format plan subdivision of 43 levels comprised of 214 lots. There are several levels at the bottom of the building dedicated to a common property car park, with car parking spaces subject to exclusive use grants. Lots 3105 and 3003 both have exclusive use over one car space each on Level G of the building.

• [7] The applicant says that from around October 2023, discussions were had with the committee about installing 10amp lockable power points with meters to be used in the exclusive use parking bays of Lots 3003 and 3105 for the purpose of charging their electric vehicles (the Proposed Improvements).
• [8] On 17 May 2024, the following motion was considered at a meeting of the committee (Motion 10.6):

Motion: Approval of Standard Power Point Installation in Carpark Bays 67 and 70 > > Moved By: Zane Grant, Owner of Carpark Bay 67, and Bruce and Margaret Grant, Owners of Carpark Bay 70 > > Motion Details: > > 1. Approval for Installation: The Body Corporate Committee is requested to approve the installation of standard 10amp lockable power points in Carpark > > Bays 67 and 70 for the purpose of electric vehicle (EV) trickle charging. > > 2. Financial Commitment: The cost of installation, totalling $1,100 plus GST, > > will be solely borne by the owners of Carpark Bays 67 and 70. Additionally, all maintenance and repair costs will be the responsibility of the bay owners. > > 3. Usage and Billing: Power usage for EV charging will be monitored by smart KWH meters installed in the bays. The owners will remit payments monthly to the Body Corporate based on actual consumption rates. > > 4. Usage Restrictions: The power points are designated exclusively for EV charging via the vehicles' internal chargers and will be locked when not in use. > > 5. Compliance and Safety: The installation will adhere to all relevant electrical safety and building regulations in Queensland. > > 6. Future Considerations: This installation will not impede any future EV charging infrastructure projects that the Body Corporate may undertake.

• [9] The motion failed to pass with 1 yes and 6 no votes. The applicant requested reasons for the refusal but says they did not receive a 'satisfactory' response.

• [10] The applicant disputes the body corporate's refusal to pass Motion 10.6. Conciliation was attempted, however the dispute did not resolve.
• [11] The applicant now seeks the following final orders:

1. That Motion Number 10.6, being the decision made by the Body Corporate Committee on May 17, 2024, to refuse the installation of standard 10amp lockable power points in Carpark Bays 67 and 70, be declared void and of no effect. > > 2. That Motion Number 10.6 for the installation of standard 10amp lockable power points in Carpark Bays 67 and 70 be deemed passed, subject to the conditions of the motion.

• [12] The applicant says the committee did not act reasonably when it refused to pass Motion 10.6 in circumstances where:
  1. The committee did not provide a coherent and evidence-based reason for refusal.
  2. If the committee believes the matter needed to be proposed at a general meeting, it should have been referred to a general meeting rather than voted against.
  3. The safety risks the committee raises do not apply to the 10amp trickle charger they are proposing.
  4. There is no evidence to suggest the body corporate's fire suppression system is inadequate.
  5. The committee scrutinized minimal safety risks associated with the proposed installation while ignoring greater risks posed by unregulated charging of scooters and bikes within the building.
  6. The committee failed to consider imposing reasonable conditions that could mitigate concerns.
  7. The committee disregarded advice from insurance brokers and other third parties.
  8. The committee is inconsistently applying the by-laws by refusing the installation, as the exclusive use by-law states the grant is for the purpose of car parking only[1] yet many car parks are used for storage or caravan parking.
  9. The committee failed to consider that the Proposed Improvements would allow EV charging, which is in line with environmentally sustainable practices and would enhance the building's appeal to prospective residents.
  10. The Proposed Improvements would come at no cost to the body corporate.
• [13] The applicant also discusses and disputes elements of the conciliation session. Anything said or done in a conciliation is inadmissible in an adjudication application.[2] For the avoidance of any doubt, I have not had regard to those matters.

• [14] The body corporate says Motion 10.6 and the Proposed Improvements are a restricted issue for the committee. Alternatively, the committee's refusal to pass Motion 10.6 was reasonable where the applicant has not addressed the special hazards EV battery fires pose.

• [15] Nine submissions were received from lot owners. Three submissions supported the application citing an upward trend in EV use, protracted processes and exhausting demands by the committee, as well as concern that occupiers will simply run leads from other common property power points. Six submissions opposed the application, raising many of the same concerns as the body corporate. The applicant exercised their right of reply to submissions opposing the application.

• [16] First, I will consider the body corporate's argument that Motion 10.6, which sought approval for the Proposed Improvements, was a restricted issue for the committee.
• [17] Second, I will consider the applicant's argument that the body corporate did not act reasonably in its refusal. I only need to find that the body corporate acted reasonably in considering one factor for the application to fail. To assist the parties and avoid risk of future dispute, I will consider all factors argued.

• [18] It is not disputed that Motion 10.6 sought to make improvements to common property. Generally, improvements to common property require approval of the body corporate. While other sections of the legislation may impact this requirement, typically approval must be by ordinary resolution of the body corporate, unless the improvement:
  1. has an installed value of $3,000 or less,

1. does not detract from the appearance of any lot or common property, and
2. the use and enjoyment of the improvement is not likely to promote a breach of the owner's duties as an occupier.[3]

• [19] There are slightly different rules for improvements made to exclusive use areas, where the lot owner does not need approval if the by-law authorises the improvements. Otherwise, body corporate approval is needed and that must be given by ordinary resolution if the value of the improvement is more than $3,000.[4]The Proposed Improvements do not appear to be limited to the exclusive use area, as the wiring would impact other areas of common property (such as walls and common property utility infrastructure). Regardless, both sections of the legislation do not appear alter the type of resolution needed in the circumstances of this application.
• [20] The applicant provides a quote that the installed value is $1,210, evidencing the Proposed Improvements can be approved by the committee.
• [21] On the other hand, it is argued the committee does not have the authority to resolve Motion 10.6 for reasons I will discuss below. I have not been persuaded by these arguments and I am satisfied the Motion 10.6 and the Proposed Improvements are not a restricted issue for the committee, based on the material in front of me.

• [22] The by-law that grants Lots 3003 and 3105 exclusive use of car parks provides that the owner or occupier 'shall use the [area] only for the purpose of car parking'. The body corporate interprets this by-law to not allow the charging of vehicles, as it says charging is different to the purpose of parking. The body corporate argues that electric vehicle charging, and the associated risks, could not have been contemplated when the by-law was registered.
• [23] The applicant says the body corporate is interpreting the purpose of the by-law too narrowly. The applicant argues Motion 10.6 does not fundamentally change the use of a car space, it merely facilities the use of a modern vehicle.
• [24] The body corporate relies on the decision of Westside Business Estate.[5] That decision relevantly states:

... unless the exclusive use by-law or the terms of another by-law or the legislation, limit the rights given to the occupier who benefits from that by-laws, those rights are not limited...[6] > > There are many previous adjudication decisions that have determined that exclusive use areas allocated for the specified purpose of car parking could only be used for car parking... these determinations have been made in cases where the terms of the exclusive use by-law itself specifically stated that the area was allocated only for the purpose of car parking or only...[7]

• [25] I agree that exclusive use rights given to an occupier are not limited unless the by-law expressly limits that right. However, I do not agree that the statement 'only for the purpose of car parking' means that incidental, minor, or routine uses typical of residential car parking are not permitted. I find that charging an electric vehicle is incidental to modern day residential parking, and I am not satisfied the Proposed Improvements are a restricted issue for the committee on this basis.

3.1.2 Changing the rights, privileges or obligations of the owners

• [26] The body corporate argues that Motion 10.6 is a restricted issue as the Proposed Improvements implements a new way of charging for electricity use that impacts all lot owners. I do not agree. It is open to the body corporate to enter into agreements with some owners or occupiers for the supply of utility services.[8] There is nothing before me suggesting a fundamental change to billing practices across the scheme as result of Motion 10.6.

• [27] Submissions from the owner who is the chairperson argue that a further exclusive use grant would be needed to install the improvement. I do not agree. The owner would not be excluding other owners or occupiers from the common property wall or infrastructure the cabling attaches to that is not already subject to an exclusive use grant.[9] The proposal aligns with being an improvement to common property by a lot owner, which there is specific and distinct provision for in the legislation.[10]
• [28] The same submission argues Motion 10.6 is also a restricted issue as the committee was being asked to determine issues around insurance obligations, but the submission does not adequately articulate how and why this is beyond the committee's power. In any event, I do not agree that Motion 10.6 is proposing a change to insurance obligations at the scheme. The arguments about whether the improvement will impact the premium ignore the section of the legislation that deals with this issue.[11]
• [29] The submission also argues that Motion 10.6 is restricted because the Proposed Improvements would alter maintenance responsibilities in relation to the improvement. Again, the submission lacks detail as to how or why this would be a restricted issue, and ignores the sections of the legislation that already set out maintenance obligations of improvements to common property and exclusive use areas.[12]
• [30] I note that submissions from the owner who is the chairperson argue that the applicant has not adequately attempted internal dispute resolution before lodging for adjudication as required,[13] as the applicant did not submit a motion to a general meeting. I do not agree. Internal dispute resolution is defined as informal processes to resolve a dispute, and the submission of a motion to a general meeting is just one example of this. I have not been satisfied Motion 10.6 involved a restricted issue for the committee and I find the submission of a motion to the committee for its consideration was satisfactory internal dispute resolution. The Commissioner also had discretion to reject the application for lack of internal dispute resolution and did not do so.[14]

• [31] It is not disputed that the body corporate has an obligation to act reasonably, including when making decisions.[15] The dispute concerns whether the body corporate has acted reasonably in its refusal.
• [32] Reasonable decision-making involves adequate consideration of all relevant facts in the circumstances, and disregarding irrelevant ones.[16] Notably, there may be more than one decision that can reasonably be made on the same set of facts.[17]
• [33] The general law also requires the body corporate to make a legally reasonable decision.[18] This means that even where the body corporate has acted reasonably in the decision-making process, the outcome must not be absurd or be unjust in its practical effect.[19] If it is absurd or unjust, then it is invalid as a legally unreasonable decision.
• [34] In determining questions of reasonable decision making, I am not called to simply supplant the body corporate's decision with my own.[20] I am also not called to weigh up which option is best. My role is to assess the decision-making process and the relevance of the facts that were, or otherwise should have been, considered by the body corporate. If I am satisfied with this process, then body corporate's decision will remain, unless the outcome of the decision lacks an intelligible justification or is unjust.
• [35] The onus is on the applicant to satisfy me that the body corporate acted unreasonably or made a legally unreasonable decision.

• [36] The body corporate also refers me to a passage from La Joya[21] which suggests it is not unreasonable for a committee to prefer a matter be determined by owners at a general meeting even if it is within the committee's authority to decide the matter. I do not disagree with the point, but the body corporate has not expressly said that this formed part of the committee's decision. In any event the point is inconsistent with the fact that the committee did in fact make a decision. Ultimately, in this case nothing really turns on this issue.

• [37] The applicant makes complaint that a lack of timeliness in the committee making its decision as well as a failure to communicate reasons for refusal. The applicant says this demonstrates arbitrary decision making which is not in line with reasonable decision making. This is despite there being no express provision in legislation requiring the committee to provide its reasons or record same in the minutes.[22]
• [38] I am not satisfied this argument justifies the final orders. Generally, the remedy for not providing reasons is for reasons to be provided, or for the decision to be remade with reasons. It will not necessarily mean the decision is overturned.
• [39] Further, the information in front of me shows the committee did communicate its reasons. While I have not been provided copies of all communications between the parties, the applicant acknowledges several instances of committee members raising concerns in writing prior to Motion 10.6 being formally submitted and voted on. On 12 April 2025, the body corporate manager advised the applicant of the outcome of Motion 10.6 and stated it was 'due to compliance concerns previously communicated'.

• [40] The committee and several owners hold concerns over fire and safety risks of EV chargers. The committee has doubts that its fire safety infrastructure is adequately equipped to deal with a lithium battery fire from an EV. To support its concerns, the committee relies on a position statement from the Queensland Fire Department dated April 2022 (QFD Position Statement) which states:

[Queensland Fire Department] consider the electrical distribution installations for EV and the allocation of dedicated EV carpark spaces within a building represent a special hazard for Firefighters under National Construction Code (NCC) Part E1.10 Provision for special hazards.

• [41] The QFD Position Statement goes on to describe challenges in firefighter intervention of EV battery fires including:
  1. toxic smoke production
  2. rapid rate of fire spread
  3. heat release rate
  4. proximity to other vehicles with fuel loads, and
  5. the proximity of suppression resources.
• [42] The QFD Position Statement requests building certifiers to consider whether there are suitable levels of protections when dealing with building development approvals, such as fire detection and early warning systems, smoke management systems, fire hydrants and sprinklers, and fire resistance of construction. For EV chargers within buildings, QFD requests building certifiers consider the following items under the National Construction Code E1D17:
  1. emergency shutdown controls for EV charging stations
  2. block plans for building to include location of EV charging stations
  3. block plans to include location of EV distribution boards and EV emergency shutdown controls, and
  4. vehicle impact protection (e.g., bollards) for EV charging stations.
• [43] Based on the above, I accept that thermal runaway from an EV battery is a special hazard. When acknowledging the increased difficulty in addressing an EV fire, there is an argument that fire safety risks of EV batteries are inherent and not limited to the act of charging the EV. The body corporate is not mandating that owners do not own EVs or that they cannot be parked in the scheme at all. Therefore, it could be said that to refuse the installation of a power point that will be used for charging is an irrelevant factor as EV fire risks continue regardless. There is logic in this argument, and there is evidence in front of me that risk of EV battery fires are not solely tied to charging.[23] I would agree that if the body corporate had a genuine concern regarding the increased difficulty in controlling lithium battery fires, it would be ideal for it to take steps to ensure the scheme's fire safety systems are suited to addressing such a situation, as EVs are likely being parked within the scheme.
• [44] However, those in opposition to the Proposed Improvements have also provided evidence that some EV fires have taken place during charging of the battery,[24] suggesting an increased risk of thermal runaway during charging. Based on this, I accept that fire safety is a genuinely held and relevant factor in the committee's refusal of Motion 10.6. The applicant does argue that the QFD Position Statement relates to 'EV charging stations' which they say typically includes high-power fast charging installations. The applicant says this is different to their Improvement Proposal which is for a 'trickle charger', and thermal runaway incidents are less likely to occur with this type of charging. The applicant, however, supplies no evidence in support this claim.
• [45] Additionally, the applicant has not provided any evidence that would suggest the body corporate's current fire safety suppression systems are adequate in addressing an EV fire. The applicant says there is no evidence the infrastructure is insufficient, but the onus is on the applicant to show this is a baseless concern. Consequently, I cannot be satisfied that objections to the Proposed Improvements are completely unfounded.
• [46] I am not satisfied that the committee acted unreasonably in its refusal on the basis that it was concerned that there is increased risk of fire during charging, and it is not clear whether the scheme's fire response system is adequate to address an EV's lithium battery fire.

• [47] Submissions from the owner who is the chairperson argue that the quote for the Proposed Improvements was not 'proper' as it was a copy of an email from the contractor with attachments. I find this is an irrelevant consideration. The committee should be concerned with the contents of the quote, not the presentation.

• [48] Submissions from the owner who is the chairperson argue that the body corporate acted reasonably in its refusal as the licences of the proposed contractor were due to expire within the committee's decision period. I find this is an irrelevant consideration. Evidence of valid licences were provided at the time the applicant submitted Motion 10.6, and there was nothing in front of the committee to suggest the licences would not be renewed. If this was a genuine concern of the committee a reasonable act would have been to conduct an online licence search which is free, fast and publicly available. The licence is currently active and there is nothing to suggest it was not renewed.[25]
• [49] The body corporate argues that the applicant did not provide evidence that the proposed meter had a Regulatory Compliance Mark. No explanation is given as to how or why this is required.

3.2.6 Billing practices, private electricity networks and demand charges

• [50] The body corporate argues that a reason for refusal is that the applicant has not provided evidence of a national meter identifier (NMI) for the smart meter they propose to install. Further, submissions from the owner who is the chairperson argue the applicant will be operating a private electronic network and has failed to provide the relevant network exemption, failed to provide any evidence that the Proposed Improvements will not trigger any 'demand change' on the scheme's bulk energy arrangements, and failed to give specifics on how billing would be effected.
• [51] I find that reason cannot support these arguments. First, in relation to network exemptions, it is not the applicant that would be supplying the electricity. It is highly likely the scheme is already subject to a private electricity network. It is not clear to me whether the body corporate is an exempt seller or has an embedded network manager or retailer. What is clear is that the applicant does not need to be an exempt seller. Second, how billing should be performed relies on these specific arrangements that the body corporate will already have in place. Third, if an NMI is required for this meter, the obligation to obtain this would be on whoever operates the private network. Fourth, if the body corporate has a bulk energy arrangement, that is its own and it should be aware of what would and would not increase bulk energy prices. Ultimately, as far as these issues have any relevance, the solutions or answers should be within the body corporate's knowledge or control. Reason cannot support the expectation that the applicant needs to give detailed advice on how the body corporate should operate its electricity network and meet its legal obligations in that respect.

3.2.7 Insurance obligations & third party opinions

• [52] Both the application and submissions in opposition deal with various arguments about insurance and other third party opinions. I have found that all of these arguments are misconceived to some extent.
• [53] Submissions from the owner that is the chairperson argue the body corporate has acted reasonably, as the applicant has not provided evidence of a relevant insurance policy. The submission says Motion 10.6 was proposed on the basis that the lot owner would ensure the car park is adequately insured. However, Motion 10.6 does not actually include such a term of approval. Further, the body corporate is the party with the obligation to insure the building[26] and the common property.[27] The car park itself is common property, and the definition of building includes fixtures and fittings, [28] which would include in Proposed Improvements. If the body corporate reasonably believes that the Proposed Improvements have impacted the premium, it may adjust the contribution payable by the applicant.[29]
• [54] The same submission also argues the body corporate's insurance premium could rise or insurance could be refused in the future, due to the Proposed Improvement's purpose of EV charging. To evidence this, the chairperson relies on a quote in an online publication from an insurance broker.[30] I find general speculation about future decisions of insurance companies should not form part of the body corporate's decision. Again, the argument ignores sections of the legislation that deal with adjustments to insurance premium contributions, and ignores the fact the body corporate can modify or rescind its refusal in the future if it is reasonable to do so.
• [55] In the same vein, the applicant argues the body corporate has acted unreasonably as it has failed to consider advice allegedly given by the Office of the Commissioner for Body Corporate & Community Management (BCCM Office), as well as the scheme's insurer, that they say confirms there is no legislative or insurance barriers to the Proposed Improvements. The BCCM Office provides general and neutral information on the legislation and would not comment on the appropriateness of the Proposed Improvements specifically, nor on such proposals generally. It does not appear that any opinion from the insurer was given in writing or presented to the committee, but the applicant says the committee has acted unreasonably by not seeking 'further verification' to confirm these alleged opinions. I do not agree. The onus is on the applicant to prove their entitlement to the order sought and they bring no persuasive evidence of these claims.

• [56] The applicant argues the committee has been inconsistent with its decision making, as the committee has approved the installation of parking bollards in exclusive use areas. I find this is an irrelevant factor. Each decision should be based on its own merits and what was and was not considered with a parking bollard application is not relevant.
• [57] The applicant also argues that the committee failed to consider that electric scooters and similar devices with lithium batteries are being charged at the scheme with no dispute raised by the body corporate. The body corporate submits, and I agree, that the QFD Position Statement specifically raises concerns with lithium batteries in EVs and arguments about other electric devices are irrelevant.

• [58] The applicants argue that the body corporate has not turned its mind to the benefits the Proposed Improvements would bring. The applicants say the Proposed Improvements would demonstrate desirable community values such as sustainability and being forward-thinking in relation to infrastructure development. The applicant suggests this could increase the market value of lots. The applicant does not bring any evidence of these claims. Even if evidence was provided, I would not be satisfied that this is such an imperative factor there could be no compelling reason for the body corporate to refuse to give its consent.
• [59] The applicant also says the committee previously abandoned plans to install communal EV chargers due to the cost. They say the committee has ignored the benefit that the Proposed Improvements would be installed at no cost to the body corporate. I am not sure how this is relevant where the Proposed Improvements are not to be used communally.

• [60] There were several points raised in the application and submissions that I have found to be irrelevant to my decision. I am only concerned with whether the committee acted reasonably in what factors it considered when making its decision. Arguments about whether the use of artificial intelligence in communications is acceptable, whether any other fire hazards at the scheme have been addressed, whether those members that have objected are currently breaching other by-laws, concerns about the tone and contents of communications and personal disputes between members are all irrelevant to this question.

• [61] While I have found the body corporate considered several irrelevant factors, there was one relevant factor that justified its decision to refuse to pass Motion 10.6. The applicant did not provide sufficient evidence that the type of charger they proposed to plug into the power points had no risk of creating thermal runaway of the EV battery. With this in mind, the applicant also failed to provide sufficient evidence that the body corporate's current fire response and suppression systems are adequate to address the special hazard that an EV lithium battery fire can present. The application must fail.
• [62] This decision does not stop EVs from being on scheme land, and I have been provided with evidence that thermal runaway is not solely linked to charging of the EV batteries. If the body corporate is concerned that its fire suppression infrastructure is inadequate, it may like to consider taking steps to address this.
• [63] Ultimately, thermal runaway of EVs is an evolving issue. Committee members are generally volunteer laypeople, and while they are not expected to be experts, a committee has an obligation to act reasonably. It follows that committee members should make reasonable efforts to inform themselves about issues facing their body corporate. While some aspects of safety concerns may be misconceived, the body corporate has provided some evidence that their concerns are not completely unfounded. This does not mean that every similar application is bound to fail. Other adjudicators' decisions may find that objectors' concerns, while genuinely held, may be objectively unfounded depending on the material in front of them and the unique circumstances of each application.

[1] By-law 44.1(b) of the CMS currently in effect, and the previous CMS that was in effect at the time the application was lodged.

[5] Westside Business Estate [2016] QBCCMCmr 579.

[6] Westside Business Estate [2016] QBCCMCmr 579 at [56].

[7] Westside Business Estate [2016] QBCCMCmr 579 at [58].

[9] Act, s 170; Halcyon Waters [2020] QBCCMCmr 203 at [23]; Pacific Haven - North Caloundra Beach [2018] QBCCMCmr 473 at [38].

[12] Standard Module, ss 187(4)(b), 192(2).

[16] Body Corporate For Beaches Surfers Paradise v Backshall [2016] QCATA 177 at [42] citing McKinnon v Department of Treasury [2006] HCA 45; (2006) 228 CLR 423 at 430.

[17] Body Corporate For Beaches Surfers Paradise v Backshall [2016] QCATA 177 at [47] citing Woden Valley Glass v Psaila (1993) 122 ALR 378, 391.

[18] Body Corporate for Beaches Surfers Paradise v Backshall [2016] QCATA 177 at [34], [47].

[19] Body Corporate For Beaches Surfers Paradise v Backshall [2016] QCATA 177 at [34], [38].

[20] Ainsworth v Albrecht [2016] HCA 40 at [101].

[21] La Joya [2020] QBCCMCmr 153 at [32].

[22] For what needs to be recorded in the minutes, see the definition of 'full and accurate minutes' in Standard Module, s 71.

[23] EV Fire Safe 'Passenger EV lib fire incidents - Global, as of 30th June 2023', which shows other causes of thermal runaway of EV batteries including collision.

[24] EV Fire Safe 'Passenger EV lib fire incidents - Global, as of 30th June 2023', which shows 18% of total EV fire incidents were connected to energised charging.

[25] Electrical contractor licence search conducted via https://www.electricalsafety.qld.gov.au/electrical-license-search

[30] T Shandiman, QLD: Q&A EV Charging in your high rise. What do you need to know? Look Up Strata, October 2023 https://www.lookupstrata.com.au/qld-ev-charging-high-rise/