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[2001] VSC 5
Supreme Court of Victoria
2001-01-31
Eames J
Original judgment source is linked above.
GROUND 3: PERMITTING MR REID TO FURTHER PARTICIPATE IN THE HEARING.
"The rule of necessity gives expression to the principle that the rules of natural justice cannot be invoked to frustrate the intended operation of a statute which sets up a tribunal and requires it to perform the statutory functions entrusted to it. Or, to put the matter another way, the statutory requirement that the tribunal perform the functions assigned to it must prevail over and displace the application of the rules of natural justice. Those rules may be excluded by statute: Twist v Randwick Municipal Council[5]; Salemi v Mackellar [No 2][6]; FAI Insurances Ltd v Winneke.".[7]
"That rule operates to qualify the effect of what would otherwise be actual or ostensible disqualifying bias so as to enable the discharge of public functions in circumstances where, but for its operation, the discharge of those functions would be frustrated with consequent public or private detriment. There are, however, two prima facie qualifications of the rule. First, the rule will not apply in circumstances where its application would involve positive and substantial injustice since it cannot be presumed that the policy of either the legislature or the law is that the rule of necessity should represent an instrument of injustice. Second, when the rule does apply, it applies only to the extent that necessity justifies[8]."
GROUNDS 1 AND 4: SHOULD ALL MEMBERS HAVE DISQUALIFIED THEMSELVES?
"6. Where, in the absence of any suggestion of actual bias, a question arises as to the independence or impartiality of a judge (or other judicial officer or juror), as here, the governing principle is that, subject to qualifications relating to waiver (which is not presently relevant) or necessity (which may be relevant to the second appeal), a judge is disqualified if a fair-minded lay observer might reasonably apprehend that the judge might not bring an impartial mind to the resolution of the question the judge is required to decide. That principle gives effect to the requirement that justice should both be done and be seen to be done, a requirement which reflects the fundamental importance of the principle that the tribunal be independent and impartial. It is convenient to refer to it as the apprehension of bias principle.
"7. The apprehension of bias principle may be thought to find its justification in the importance of the basic principle, that the tribunal be independent and impartial. So important is the principle that even the appearance of departure from it is prohibited lest the integrity of the judicial system be undermined. There are, however, some other aspects of the apprehension of bias principle which should be recognised. Deciding whether a judicial officer (or juror) might not bring an impartial mind to the resolution of a question that has not been determined requires no prediction about how the judge or juror will in fact approach the matter. The question is one of possibility (real and not remote), not probability. Similarly, if the matter has already been decided, the test is one which requires no conclusion about what factors actually influenced the outcome. No attempt need be made to inquire into the actual thought processes of the judge or juror.
"8. The apprehension of bias principle admits of the possibility of human frailty. Its application is as diverse as human frailty. Its application requires two steps. First, it requires the identification of what it is said might lead a judge (or juror) to decide a case other than on its legal and factual merits. The second step is no less important. There must be an articulation of the logical connection between the matter and the feared deviation from the course of deciding the case on its merits. The bare assertion that the judge (or juror) has an "interest" in litigation, or an interest in a party to it, will be of no assistance until the nature of the interest, and the asserted connection with the possibility of departure from impartial decision making, is articulated. Only then can the reasonableness of the asserted apprehension of bias be assessed".
"Again, the test in Livesey cannot be pressed too far when the qualifications for membership of the tribunal are such that the members are likely to have some prior knowledge of the circumstances which give rise to the issues for determination or to have formed an attitude about the way in which such issues should be determined or the tribunal's powers exercised. Qualification for membership cannot disqualify a member from sitting[26]."
"In most cases where a statutory tribunal can be validly constituted by some only of its members, the actuality or the appearance of disqualifying bias on the part of a particular member or particular members will affect those members only and will not taint the tribunal as a whole. If, for example, the actuality or appearance of bias on the part of a particular member or particular members results from a relationship or activities unconnected with membership of the relevant tribunal, there is not, without more, any reason in fairness, principle or common sense why the other members of that tribunal or the tribunal itself should be affected or disqualified. Even where the actuality or the appearance of bias on the part of a particular member or particular members has resulted from the discharge of the relevant tribunal's functions, it will ordinarily be possible to say that neither the parties nor a fair minded, informed lay observer would entertain a reasonable apprehension that the tribunal as a whole was affected by the disqualifying bias of the particular member or members. The circumstances of a particular case may, however, be such as to give rise to a reasonable apprehension that the relevant tribunal as an institution is affected by disqualifying bias. One possible example of such a case is where the identity of the members of a tribunal who are involved in prejudgment of issues is effectively shielded by the institutional facade. Another possible example is where the circumstances are such as to give rise to a reasonable apprehension that all members of the tribunal are affected. Ultimately, the central question in the present appeal is whether the Tribunal, as an entity, is itself affected by the actuality or appearance of disqualifying bias in the conduct of the proposed inquiry."
[1] [1980] HCA 13; (1980) 144 CLR 13, at 35
[2] See Vakuata v Kelly [1989] HCA 44; [1989] 167 CLR 568, at 572, per Brennan, Deane and Gaudron JJ; at 577-8, per Dawson J.
[4] [1990] HCA 31; (1990) 170 CLR 70,at 89.
[5] [1976] HCA 58; (1976) 136 CLR 106, at 109-110, 118-119.
[6] [1977] HCA 26; (1977) 137 CLR 396, at 401, 442.
[7] [1982] HCA 26; (1982) 151 CLR 342, at 348-349, 362-363.
[8] Laws v Australian Broadcasting Tribunal, supra, at 96.
[9] City of St Kilda v Evindon Pty Ltd [1990] VicRp 67; [1990] V.R. 771, at 775.
[10] Webb v The Queen [1994] HCA 30; (1994) 181 CLR 41, at 47, per Mason CJ and McHugh J.
[11] Stollery v Greyhound Racing Control Board, [1972] HCA 53; (1972) 128 CLR 509, at 519, per Barwick CJ.; see too Laws v Australian Broadcasting Corporation, supra, at 90, per Deane J, and National Companies and Securities Commission v News Corporation Ltd [1984] HCA 29; (1984) 156 C.L.R. 296, at 311-312, per Gibbs C.J.
[14] [2000] HCA 63, at par [4].
[15] Re J.R.L; Ex parte C.J.L [1986] HCA 39; (1986) 161 C.L.R 342, at 352, per Mason J; adopted in Re Polites; Ex parte Hoyts Corporation Pty Ltd [1991] HCA 25; (1991) 173 C.L.R. 78, at 86.
[16] Re Polites, supra, at 89, per Brennan, Gaudron and McHugh JJ.
[18] R v Sussex Justices; Ex Parte McCarthy [1924] 1 KB 256, at 258-259.
[20] The hearing of evidence resumed on 9 February 2000 - the day following the withdrawal of Reid - and the plaintiff completed his evidence before the newly constituted Tribunal. Amor also gave evidence. Written submissions were filed by counsel for the parties in about June 2000, and the decision was announced on 3 August 2000.
[21] Johnson v Johnson [2000] HCA 48; (2000) 74 ALJR 1380, at 1382, per Gleeson CJ, Gaudron, McHugh, Gummow and Hayne JJ.
[24] Re Polites; Ex Parte Hoyts Corp Pty Ltd, supra, at 87
[25] Livesey v NSW Bar Association [1983] HCA 17; (1983) 151 CLR 288, at 293-294.
[27] [1992] HCA 30; [1992] 66 ALJR 583, at 584.
[28] [1991] HCA 25; (1991) 173 CLR 78, at 87.
[29] [1949] A.C. 134, at 151.
[30] See Laws v Australian Broadcasting Tribunal, at 91, per Deane J.
[35] Johnson v Johnson, at 1391, per Kirby J.
Magazzu
Business Licensing Authority [2001] VSC 5
(1980) 144 CLR 13
(1990) 170 CLR 70
(1976) 136 CLR 106
(1977) 137 CLR 396
(1982) 151 CLR 342
(1994) 181 CLR 41
(1972) 128 CLR 509
(2000) 74 ALJR 1380
(1983) 151 CLR 288
(1991) 173 CLR 78