WHETHER LEGISLATION IN FORCE BEFORE 15 JANUARY 2015 APPLIES
- The Tribunal is required to make the correct and preferable decision having regard to the material then before it, including any relevant factual material and any applicable written or unwritten law (Administrative Decisions Review Act 1997, s 63(1)). This generally requires the Tribunal to make a decision on the material before it at the time it makes its decision (see Drake v Minister for Immigration and Ethnic Affairs [1979] AATA 179; (1979) 46 FLR 409; Mattar v Roads and Maritime Services [2012] NSWADT 274 at [10]; Shi v Migration Agents Registration Authority (2008) 235 CLR 286).
- In Foley v Commissioner of Police [2005] NSWADT 12 at [5], Hennessy DP summarised the relevant principles as follows:
At common law, a tribunal conducting a merits review must apply the law in force when it considers the matter, unless the decision involves a consideration of accrued rights and liabilities at an anterior date: Re Smith and Defence Force Retirement and Death Benefits Authority (1978) 1 ALD 374; Re Costello and Secretary, Dept of Transport (1979) 2 ALD 934; Commonwealth of Australia v Esber [1991] FCA 223; (1991) 101 ALR 35.
- The respondent submitted that the Home Building Amendment Act 2014 has no effect, and that the application is to be determined under the Home Building Act 1989 as it stood prior to the January 2015 amendments, due to the operation of savings and transitional provisions. The applicant submitted that the amendments "should not have an effect on the final decision made by the Tribunal".
- Item 121(2)(a) of Sch 4 to the Home Building Act 1989 provides that an amendment made by the Home Building Amendment Act 2014 does not apply to or in respect of proceedings commenced in a court or tribunal before the commencement of the amendment.
- I am satisfied that, as the respondent submits, these proceedings are to be determined by applying the provisions of the Home Building Act 1989 as it stood prior to the amendments made by the Home Building Amendment Act 2014.
- The respondent also submitted that the application was not affected by the Home Building Regulation 2014. No explanation was provided for adopting this position.
- Item 121 of Sch 4 to the Home Building Act 1989 does not have the effect of continuing the operation of the Home Building Regulation 2004 in respect of these proceedings. That is because the making of the Home Building Regulation 2014 is not an "an amendment made by the" Home Building Amendment Act 2014 within item 121.
- Clause 75(2) of the Home Building Regulation 2014 provides that any act, matter or thing that, immediately before the repeal of the Home Building Regulation 2004, had effect under that Regulation continues to have effect under the Home Building Regulation 2014. There are no other savings and transitional provisions in the Home Building Regulation 2014.
- Clause 75(2) does not, in my view, have the effect that the provisions of the Home Building Regulation 2004 are continued in respect of the present proceedings. The provisions applicable to the applicant's application to vary his licence are not an "act, matter or thing" that "had effect" under the Home Building Regulation 2004.
- It is necessary, in addition, to consider the effect of s 30(1) of the Interpretation Act 1987 (NSW), which provides for the effect of the repeal of a statutory rule. A "statutory rule" includes a regulation made by the Governor: Interpretation Act 1987, s 21(1), such as the Home Building Regulation 2014. Section 30(1) of the Interpretation Act 1987 provides:
30 Effect of amendment or repeal of Acts and statutory rules
(1) The amendment or repeal of an Act or statutory rule does not:
(a) revive anything not in force or existing at the time at which the amendment or repeal takes effect, or
(b) affect the previous operation of the Act or statutory rule or anything duly suffered, done or commenced under the Act or statutory rule, or
(c) affect any right, privilege, obligation or liability acquired, accrued or incurred under the Act or statutory rule, or
(d) affect any penalty incurred in respect of any offence arising under the Act or statutory rule, or
(e) affect any investigation, legal proceeding or remedy in respect of any such right, privilege, obligation, liability or penalty,
and any such penalty may be imposed and enforced, and any such investigation, legal proceeding or remedy may be instituted, continued or enforced, as if the Act or statutory rule had not been amended or repealed.
- The repeal of a statutory rule does not affect the operation of any savings or transitional provision contained in the statutory rule: Interpretation Act 1987, s 30(2)(d).
- Section 5(2) of the Interpretation Act 1987 relevantly provides that that Act applies to an instrument except in so far as the contrary intention appears in the instrument concerned. The inclusion of cl 75(2) in the Home Building Regulation 2014 does not evince an intention to generally exclude the operation of s 30 of the Interpretation Act 1987. Accordingly, s 30 of the Interpretation Act 1987 applies.
- Section 30(1) of the Interpretation Act 1987 was considered by Judicial Member Molony (as he then was) in Esber v Commissioner of Police, NSW Police Force [2009] NSWADT 208, in the context of an application to review a decision to revoke the applicant's firearms licence, and in Duncan v Commissioner of Fair Trading, New South Wales Office of Fair Trading [2008] NSWADT 121 ("Duncan"), in the context of an application for review of a decision to refuse to grant a real estate agent's licence. I respectfully adopt Judicial Member Molony's analysis of the relevant legal principles in Duncan at [17]-[35].
- One situation in which s 30 of the Interpretation Act 1987 could have the effect of applying the Home Building Regulation 2004 to the present application is if the applicant had an accrued "right" or "privilege" under that regulation (see Interpretation Act 1987, s 30(1)(c)). An analysis of the provisions of the Home Building Regulation 2004 is necessary to determine whether the applicant had an accrued right to have his application for variation of his licence considered under that regulation. Where the legislative scheme does not leave any discretion to the administrator (here, the Tribunal) to determine whether a decision is to be made in the applicant's favour, the applicant will have an "accrued right" for the purposes of s 30(1) of the Interpretation Act 1987 (see Duncan at [23]-[33] and the cases there cited). Where, on the other hand, the decision is at least partly discretionary, no rights will accrue.
- The respondent contends that cl 26(1)(b) and cl 28(1) of the Home Building Regulation 2004 apply to the applicant's application. I will assume for present purposes that they do.
- Clause 26(1) of the Home Building Regulation 2004 provides:
26 Additional requirements for obtaining contractor licences
(1) Before a contractor licence is issued, the Director-General must be satisfied that:
(a) the applicant has, or proposes to have, such numbers of nominated supervisors for the contractor licence as the Director-General considers are needed to ensure that all work for which the contractor licence is required will be done or supervised by qualified individuals, and
(b) the applicant, if also applying for an endorsement of the contractor licence to show that it is the equivalent of a supervisor certificate:
(i) complies with the requirements prescribed by clause 28 (1), and
(ii) is not disqualified from holding a supervisor certificate or a supervisor certificate of a particular kind, and
(iii) is not the holder of a supervisor certificate that is suspended.
- Clause 28(1) of the Home Building Regulation 2004 is made pursuant to s 20(1) of the Home Building Act 1989, which provides that:
The regulations may fix or provide for the Director-General to determine additional standards or other requirements that must be met before any contractor licence is issued or before a contractor licence of a particular kind is issued.
- Clause 28(1) of the Home Building Regulation 2004 provides:
28 Additional requirements for obtaining certificates
(1) Before a certificate is issued, the Director-General must be satisfied that the applicant:
(a) has such qualifications or has passed such examinations or practical tests, or both, as the Director-General determines to be necessary to enable the applicant to do, or to supervise, the work for which the certificate is required, and
(b) has had experience of such a kind and for such a period, as the Director-General considers would enable the applicant to do, or to supervise, the work for which the certificate is required, and
(c) is capable of doing or supervising work for which the certificate is required.
- The provisions of clauses 26(1) and 28(1) appear on their face to confer a discretion, because they refer to the Director-General's consideration of the kind and duration of experience necessary, and the Director-General's determination of qualifications and examinations.
- The Commissioner made an instrument pursuant to cl 28(1) of the Home Building Regulation 2004 on 3 July 2013, entitled "Qualification Requirements for an Endorsed Contractor Licence or Supervisor Certificate for General Building Work" ("Instrument"). The Instrument states, relevantly, that the Commissioner considers the possession of experience specified in the Instrument to be necessary for an applicant for the issue of a Licence or Certificate.
- Notwithstanding that the Instrument, which was made pursuant to cl 28(1) of the Home Building Regulation 2004, was routinely applied to applications under the Home Building Regulation 2004 by the Commissioner's delegates before its repeal, the Commissioner retained a discretion under cl 28 to determine that different qualifications were necessary in a particular case or that different experience was required in a particular case. This is apparent from the terms of that clause. Further, if the Instrument were to be applied inflexibly, as if the Commissioner did not retain any discretion, that would be an invalid exercise of power: see, for example, NEAT Domestic Trading Pty Ltd v AWB Ltd (2003) 216 CLR 277, Gleeson CJ at [24]; Re Drake and Minister for Immigration & Ethnic Affairs (No 2) (1979) 2 ALD 634 (AAT), Brennan J at 640.
- Accordingly, as the Commissioner retained a discretion as to whether to grant the applicant's application for variation of his licence, the applicant does not have accrued rights under the Home Building Regulation 2004.
- Even if I am wrong about my conclusion that the Commissioner has a discretion under the Home Building Regulation 2004, it is still the case that the applicant does not have an accrued right because, under s 20(1)(a) of the Home Building Act 1989, the Commissioner must refuse an application if he or she is not satisfied that the applicant is a fit and proper person to hold a contractor licence. The determination of whether someone is "fit and proper" involves the exercise of discretion: Duncan at [33].
- The word "privilege" in s 30(1) of the Interpretation Act 1987 captures interests which are not as strong as rights, but the applicant's expectation that his application would be determined under the Home Building Regulation 2004 cannot properly be described as a "privilege". Nor can the requirement that the application be assessed in accordance with those provisions properly be described as a liability.
- Section 30(1)(b) of the Interpretation Act 1987 provides, relevantly, that a repeal of a statutory rule does not affect the previous operation of the statutory rule or anything duly suffered, done or commenced under the statutory rule. This does not assist, as the applicant's application was not "done" or "commenced" under the Home Building Regulation 2004, but was rather commenced under the Home Building Act 1989.
- For these reasons, I conclude that the Home Building Regulation 2004 does not apply to my determination of these proceedings. This creates the anomalous and presumably unintended consequence that the application is to be determined under the Home Building Act 1989, as it stood prior to 15 January 2015, and the Home Building Regulation 2014.
- It is also necessary to consider the effect of another savings and transitional provision, item 143 of Sch 4 to the Home Building Act 1989, as amended by the Home Building Amendment Act 2014, which provides as follows:
An amendment made by the amending Act that imposes a requirement that was a requirement of the regulations before the amendment commenced extends to any contract or other matter to which the requirement was subject under the regulations immediately before the commencement of the amendment.
- It could be argued that this has the effect of requiring the Tribunal to apply, in the present proceedings, provisions in the Home Building Act 1989, as amended, which impose requirements previously contained in the Home Building Regulation 2004. However, item 143 of Sch 4 must be read with the other savings provision referred to above, item 121 of Sch 4, to the effect that the amendments do not apply to proceedings commenced before the amendments took effect. Item 121 is a more specific provision and, in my view, it prevails.