Psychologists Registration Board of Victoria v Pallini

Psychologists Registration Board of Victoria v Pallini - [2008] VCAT 2632 - VCAT 2008 case summary — Zoe

[6]

The registration of Mr Pallini be suspended for a period of six months, beginning one month from the date of these orders, or earlier as agreed between Mr Pallini and the Board. This delay will enable Mr Pallini to conclude current professional activities with his current clients.
Mr Pallini whilst suspended commence as soon as possible further education in the form of mentoring with a mentor approved by the Board, for a period of six months, in relation to boundary issues which might include guidance, through the utilisation of any or all of the following:
- (a) review of previous Board determinations involving boundary issues
- (b) role plays
- (c) discussion of various scenarios
- (d) reading of relevant literature
- (e) attendance at relevant professional development activities.
Mr Pallini undertake counselling at least monthly for a period of 12 months, from the date of this determination, or such longer period as his counsellor directs, whichever is longer, at his own expense from a mental health professional approved by the Board in relation to the personal factors that contributed toward his boundary transgressions and creation of inappropriate dual relationships.
Mr Pallini take those steps that are reasonably open to him to facilitate the counsellor referred to in Order 3 providing to the Board a brief report at six monthly intervals confirming Mr Pallini's attendances with the counsellor and confirming that issues relating to relevant personal issues have been addressed in the counselling process.
On resumption of his registration, the following conditions apply :
- (a) that Mr Pallini obtain supervision of his practice as a psychologist at his own expense from a senior psychologist approved by the Board for a period of at least three years, at least weekly for the first year after resumption and at least fortnightly after that**,** and that the supervisor provide six-monthly reports to the Board, assessing Mr Pallini's progress in each of the areas specified in the initial agreement_;_

[35]

It will be seen then, that the conduct in the HPR Act is equivalent to the conduct in the old Act. "Unprofessional conduct" for the purposes of this hearing is the same whether you look at (a) and (b) together in the old Act or its definition in (a) in the HPR Act; and "professional misconduct" at common law equates to definitions (a) and (b) in the HPR Act.
The allegations were referred to this Tribunal by the Board under s 59(2)(g) of the new Act for the Tribunal to conduct a hearing in relation to them. The allegations were framed by reference to the HPR Act, and were that Mr Pallini had engaged in unprofessional conduct and/or professional misconduct within the meaning of s 3 of the HPR Act.
As we understand Ms Stynes' submissions, they are that the allegations as well as any findings we make should be framed with reference to the old Act.
We accept that whichever approach is taken, the practical consequences in this case would be the same. For the avoidance of doubt, we made findings on the day of "unprofessional conduct" and "professional misconduct" without specific reference to either Act.
The Supreme Court of Victoria has had occasion to consider similar difficulties in a number of cases.
These are McGrath v Medical Practitioners Board of Victoria [1960] 10 VAR 454; Qx v The Medical Practitioners Board of Victoria, unreported, 11 June 1997 and Chen v Chiropractors Registration Board of Victoria [2000] VSC 480. The approach taken however has not been uniform. More recently, and since submissions were made, our attention has been drawn to a decision of Kaye J in Gertrude Kennedy v Medical Practitioners Board of Victoria [2008] VSC 507 delivered on 26 November 2008. We understand the parties are aware of this decision.
The case was about what provisions the Medical Practitioners Board was bound to apply, the provisions of the 1970 Act or the 1994 Act when the conduct occurred before the 1994 Act commenced. Critically, in that case, the standard of conduct in the 1970 Act and the 1994 Act was different, a matter of real substance, unlike this case.
The conclusion reached by the Court was that the proper construction of s 102A(1) of the 1994 Act (which is in similar terms to s 169(2) of the HPR Act in the current case) militated against the implication of any legislative intention that the Act operate retrospectively in the absence of any clear legislative intention expressed to the contrary.
Ms Stynes stressed similar points in her submissions to us about which legislative regime to apply to the findings we should make. The better view, even though the findings in this case under both Acts are equivalent, is that they should be findings under the old Act. Given that determinations must be in accordance with the old Act, it would be preferable, if not essential, to frame allegations and findings in accordance with the language of the old Act.

[44]

In May 2003, Ms M commenced employment at W as an administrative assistant.
Ms M says that as part of her role at W, she was responsible for receiving the mail and job applications sent to W via email. Ms M says that in approximately October 2003, around six months after she commenced employment with W, she became aware that Mr Pallini had applied for a position at W, as a psychologist. Ms M says that she first became aware of this when she received Mr Pallini's job application via email at W. Mr Pallini does not accept that he sent his application via email. Mr Pallini says that he sent his application by ordinary post to Ms J.
Ms M says that prior to applying for a position at W, Mr Pallini was aware that she worked there. Ms M says that she had spoken to Mr Pallini during numerous clinical sessions about working at W. Mr Pallini says that he applied for the position at W in August 2003, after he had returned from overseas where he had been travelling since May 2003.
Mr Pallini says that he did not know that Ms M worked at W when he applied for the position. However, prior to accepting the position, he did know. He found out when he told Ms M, as he did his other clients, that he had applied for a job and that if he got it, it may impact on the days he would be available at the .... Medical Centre. He says that Ms M asked him where he had applied and he told her he had applied to W. At that time she told him that she worked at W.
Ms M says that after she had seen Mr Pallini's application for a position at W, Mr Pallini discussed his application with Ms M at her next therapeutic session.
Mr Pallini says that he did not know that Ms M had seen his application. However, he agrees that it was during a counselling session that they discussed how they would manage their relationship in the workplace.
Mr Pallini asked Ms M whether she would feel comfortable working with him. Ms M told Mr Pallini that she did not have a problem working with him at W. The conversation between Mr Pallini and Ms M regarding Mr Pallini's employment at W was quite brief.
Mr Pallini commenced employment with W in September 2003, working two to three days per week. Ms M was employed full-time. No other employees at W were aware that Mr Pallini was Ms M's treating psychologist.
In general, Ms M's administration role at W did not require a significant amount of interpersonal contact with the psychologists. Ms M says her role did involve making bookings for the psychologists and speaking with their clients. She says that as part of her role, she was responsible for managing Mr Pallini's diary and was also required to contact Mr Pallini to manage his appointments and put telephone calls through to him. Mr Pallini says that Ms M did not manage his diary or his appointments. He says he managed an electronic diary. If someone wanted to make an entry in his diary they sent him an email notifying him of an appointment. Most appointments came from reception. He says Ms M did spend some time on reception and that he may have received a small number of appointment notifications from her. He says she may have also put some calls through to him but not very often.
Although Ms M and Mr Pallini did not have constant contact at work, their contact was reasonably frequent.
Mr Pallini and Ms M were both employed at W for approximately five months. Throughout this period, Mr Pallini and Ms M remained professional at the work place. They continued to have fortnightly counselling sessions.
During counselling sessions with Mr Pallini, Ms M often discussed work issues. This included during the period that both Mr Pallini and Ms M were working at W. As a result, there were a number of occasions when Ms M spoke to Mr Pallini about issues that she had with work colleagues, who were also work colleagues of Mr Pallini.
During the period that Ms M was employed at W, she also dated a male colleague from the company. Whilst Mr Pallini was employed with W, Ms M spoke to Mr Pallini about this during sessions. Ms M says that during one of her counselling sessions with Mr Pallini, while discussing her relationship with the male colleague at W, Mr Pallini suggested that she should point him out while at work. Mr Pallini says that Ms M did inform him who she was dating at W, but denies that he suggested that she should point him out.

[45]

During the period in which Mr Pallini and Ms M were both employed at W, W provided drinks evenings for employees once a month. This was a social occasion for all W employees. Mr Pallini attended them infrequently, perhaps once every three months. On one, perhaps two occasions, Ms M and Mr Pallini attended on the same evening. Neither Mr Pallini nor Ms M approached each other on these occasions.
Prior to Christmas 2003, W also arranged an office Christmas party. Ms M did not attend it and instead went out with friends for birthday drinks. Ms M invited a group of W employees (including Mr Pallini) to join her for drinks after the Christmas party. Ms M says that following the Christmas party, Mr Pallini sent Ms M a text message asking whether she was out and where she was. Mr Pallini cannot remember whether he sent a text message or whether it was another employee whom he was with. However, he agrees that a text message was sent and that Ms M replied with details of where she was. Mr Pallini and a number of W employees then attended the club that Ms M was at. Mr Pallini says that at the club, he wished Ms M a happy birthday, had a drink in her company, and left the venue after approximately 30 minutes. Ms M says that she left the club at the same time as Mr Pallini and one of his friends. Ms M says that this was after Mr Pallini had been at the club for at least an hour.
During their employment at W, Mr Pallini also sent Ms M a small number of 'joke' emails. Ms M says that on one occasion, Mr Pallini sent her an email of a cartoon of a semi-naked man with a joke attached. Ms M says that this was a generic type of email likely to be sent amongst friends. However, Ms M says that she thought it was inappropriate given the nature of her relationship with Mr Pallini. Mr Pallini says that the email is likely to have been sent as a group email.
In around April 2004, Ms M ceased employment with W. She says she decided to leave partly because she felt uncomfortable working with Mr Pallini, but also because she was ready for a change and was experiencing a number of other issues working at W.

[73]

Dr Freckelton highlighted a number of cases which had considered the test to be applied at common law to determine what conduct might amount to "professional misconduct". He submitted that the essence of "professional misconduct" is assessment of serious impropriety by reference to the evaluation of professional peers. In summary, those cases, he submitted, would indicate the test is :
- whether the practitioner was in such breach of the written or unwritten rules of the profession as would reasonably incur the strong reprobation of professional brethren of good repute and competence (see Qidwai v Brown [1984] 1 NSWLR 100);
- whether it is conduct which would reasonably be regarded as disgraceful or dishonourable by peers (in this case solicitors) of good repute and competency (see Myers v Eman [1940] AC 282 at 288-289 citing Re a Solicitor; Ex parte Law Society [1912] 1 KB 302);
- whether the conduct would encompass conduct which included a 'deliberate departure from accepted standards or such serious negligence as, although not deliberate, to portray indifference and an abuse of the privileges which accompany registration as a medical practitioner' per Kirby P in Pillai v Messiter (No 2) [1989] 16 NSWLR 197 at 200 (see McGrath v Medical Practitioners Board, unreported, Supreme Court of Victoria, Eames J, 1 November 1996);
- whether the conduct violates or falls short of, to a substantial degree, the standard of professional conduct observed or approved by members of the profession of good repute and competency (see Mandie J in Campbell v The Dental Board of Victoria [1999] VSC 113 at [23]- [24].
Ms Stynes, in her submissions, essentially referred to the same cases. Additionally, she drew our attention to the fact that there was not a substantial body of law dealing with the notion of "unprofessional conduct". She referred to the following paragraph in Vissenga v Medical Practitioners Board of Victoria [2004] VCAT 1044 at paragraph 33 in which President Morris said :

[80]

It was not agreed that Mr Pallini knew Ms M was employed at W when he applied for a position there. He maintains he did not. Ms Stynes took us through a chronology of events. At the end of April 2003, Mr Pallini took a three month holiday overseas. It was several weeks before he left, that Ms M started work at W. Mr Pallini's clinical notes only refer to the fact she had got a new job and was excited and saw it as a challenge. The company offering the new job was not identified, nor indeed was it ever nominated in the notes. Ms M apparently started there in May 2003. The next consultation occurred on 27 August 2003. Mr Pallini told the Tribunal he applied for the position at W in August after returning from overseas and commenced there in September. Given that chronology, Mr Pallini's version of events is more likely to be correct compared with Ms M's recollections which refer to October. In those circumstances, we were not satisfied that the allegation that he applied for the position, knowing Ms M worked there, is proven. However, he conceded he was aware of her employment prior to his commencement at the same employer.
Mr Pallini agreed he discussed with Ms M "how they would manage their relationship in the workplace". He agreed he asked her "whether she would feel comfortable working with him" and that they should keep their psychologist/client relationship confidential. He agreed these were brief conversations. Mr Pallini accepted that his conduct was unprofessional. We are fortified in our conclusion, by evidence which emerged during the determination phase of the hearing to the effect that Mr Pallini conceded that he had only discussed his employment with Ms M following the commencement of his employment, that they had a very brief conversation, and that she was not offered alternatives and effectively had to "make the best of it".
As Ms Stynes conceded, in any therapeutic relationship there is a power imbalance between the parties exposing the client to potential exploitation. She conceded that dual relationships should be avoided because they can impair the psychologist's professional judgment or increase the risk of exploitation.
In our view, this conduct in the spectrum of impropriety falls short of being disgraceful or dishonourable such as to constitute professional misconduct. We agree with Ms Stynes that it is unprofessional conduct of a serious nature; conduct of a lesser standard than the public or peers would expect.
The problem with the conduct was that whilst he was counselling Ms M, he took a job in the same workplace as his client. What makes it unprofessional is that he should have foreseen that he could be causing adverse consequences to the therapeutic relationship and the psychological well-being of his client.
It is conduct which violates proper professional boundaries that should exist between a psychologist and their client. It created an unnecessary and counter-therapeutic dual relationship.
Mr Pallini placed his own needs before those of his particularly vulnerable client. He was aware when he took the job that (as he described her) Ms M had a range of depressive symptoms, amounting to major depression; constant mood swings; irritability; anger; dependency; low self-esteem and attachment and abandonment concerns. From the outset of counselling, she was being prescribed anti-depressant medication. A year into the counselling, she had been diagnosed with bipolar disorder and prescribed a mood stabiliser.
In addition, and a critical aspect of her presentation, was that Mr Pallini reported that Ms M has complained to him of previous employment in which sexual boundaries had been breached by a male co-worker.
These vulnerabilities should have clearly signalled to Mr Pallini that clear boundary demarcation was required. He should never have mixed his therapeutic and working roles as he did when he commenced work at W.

[82]

On the day we made a finding that this conduct was "professional misconduct". We were satisfied that the conduct was unprofessional conduct of a serious nature (s 48(1) of the old Act) being professional misconduct (s3(c) of the old Act).
The socialisation involved attending office drinks; attending a nightclub to celebrate Ms M's birthday, responding to her invitation; sending a tasteless joke email to work colleagues and including Ms M.
Dr Freckelton submitted that this allegation amounted to professional misconduct.
Ms Stynes submitted that it was unprofessional conduct but not of a serious nature. She referred to the matters as being trivial in nature. She submitted that such interactions as sending a cartoon or conducting a brief visit to a nightclub were matters that should not be tainted in any way by the subsequent text messaging.
We did not agree with Ms Stynes that we should find the behaviour to be unprofessional conduct not of a serious nature.
In addition to what we have said above about boundary violations, a psychologist should not be mixing socially with their client. What makes the conduct more heinous is that it happened where there were already boundary issues crossed, and, more disturbingly, where the psychologist had assessed his client as vulnerable and dependent upon his approval. In addition, she had raised issues about their joint workplace where boundaries had been crossed, and had a history of previous unresolved issues about sexualised behaviour in the workplace.
We agree with Professor Love that any reasonable psychologist would, referring to the socialising within and outside the workplace, on reflection, consider this behaviour to be a boundary crossing that in itself was a violation of the appropriate relationship between psychologist and client and that it would severely increase the risk of possible further boundary violation in the future.
The vice in the behaviour is that the client may receive mixed messages and might misconstrue the nature of the relationship. Assuming that the client is comfortable with the development, which Mr Pallini did, is no defence to boundary transgressions.
Again, we are fortified in our conclusion by evidence which emerged in the determination phase, that satisfied us that Mr Pallini appeared oblivious to the risks of such transgressions, and did not consult, seek supervision, or in any other way act in a manner consistent with appropriate self-examination.

[106]

Dr Freckelton made extensive submissions about Mr Pallini's and Dr Farhall's evidence in support of his submissions as to the determinations we should make.
As indicated, Mr Pallini gave evidence and was cross-examined. He also answered questions put to him by the Tribunal.
In his evidence in chief, Mr Pallini gave us to understand that he now well understood that his conduct was unprofessional and inappropriate and that he understood the risks associated with dual relationships. We viewed such assertions as superficial and of questionable substance.
What struck us about his evidence in chief was that he used phrases like "we hoped", "we discussed", when referring to conversations he and Ms M had had. It was clear to us that even in retrospect he still regarded that therapeutic relationship as a "friendship". We accepted that the proven imbalance in the therapeutic relationship is one of the matters that he was beginning to work through with Dr Farhall.
The general tenor of his evidence about his embarrassment about his conduct sending the text messages, his expressed guilt since, and his reflections on the difficulty and hurt to Ms M gave us the impression that he was embarrassed particularly because of the position he now found himself in, rather than for what he had done to Ms M.
Repeatedly, he referred to the fact that his reflection since and his work with Dr Farhall has given him a better understanding of the impact of his behaviour, and his ability not to find himself in the same situation again.
We accept that Mr Pallini thinks that he is a good practitioner in that he genuinely cares for his clients. He accepts that one of his key difficulties is that he tries to fix up all his clients' issues himself, without seeking assistance elsewhere as he should, and it is of some reassurance that Mr Pallini accepts the necessity for him to learn the skills of consultation and supervision for himself as a practitioner.
Therefore, having heard Mr Pallini's evidence and Dr Farhall's evidence, we accept that Mr Pallini has gained some understanding of the seriousness of his conduct and the effects it has had on Ms M. But what was also clear is that Mr Pallini was starting from a very low base. As Dr Farhall made clear in his evidence, in his opinion, Mr Pallini still has some way to go.
How low a base Mr Pallini started from is apparent from the response he made to the Board about the complaint in October 2007.
The following extracts speak for themselves :

[118]

We agree with Dr Freckelton that these views display a very primitive understanding of a psychologist's professional obligations, the nature of transference and counter-transference, the issues of boundary transgressions and multiple relationships and the need to place the client's interests ahead of one's own, as well as of the repercussions to clients and the profession if ethical obligations are not adhered to.
Dr Farhall's supervisory role has been limited to protecting the community from risks in the period leading to the hearing, and not rehabilitative in nature. In that context he made it clear to us that his focus had been on assisting Mr Pallini with issues arising with current clients and in the limited context of Mr Pallini's current role. He provided supervision, support and learning with Mr Pallini's current clientele. As he said himself, he was appointed to "protect the public in the interim". For that reason, not all issues relevant to Mr Pallini's past conduct had been fully explored. Despite that limited role, it emerged Dr Farhall was conscious there were still many gaps in Mr Pallini's level of true understanding and insight. He thought Mr Pallini had some understanding of the problem with dual relationships but still had some way to go. For example, Dr Farhall thought that Mr Pallini did not see socialising with clients as particularly risky or problematic. He considered that Mr Pallini was "on the way" to having a competent understanding of why his conduct was wrongful but did not have a full understanding; that his understanding had grown significantly but that there were many aspects they had not yet discussed.
It was of considerable concern to us that Dr Farhall viewed Mr Pallini, virtually one year following the imposition of supervision, as still significantly removed from an appropriate understanding of boundary issues, and that he could not be assured that Mr Pallini would, even with continuing supervision, achieve the requisite understanding.
In addition, Dr Farhall described his role as "containing", rather than rehabilitative, in nature. He acknowledged, in that context, that he did not have a full understanding of the dynamics of treatment through its course, and that there had been limited discussion with Mr Pallini about the relevant professional standards.
Dr Farhall agreed, when it was put to him, there were many things still to be followed up; that Mr Pallini had rationalised and minimised things and was very self-centred; had no understanding of the fundamental dynamics of a power relationship and continued to rationalise and minimise the sexual relationship with Ms M.
In his opinion, Mr Pallini needed to continue with his own counselling for some time and to maintain a supervisor for a considerable period of time.
These observations were reinforced by much of what emerged in cross-examination of Mr Pallini.
Mr Pallini, in contrast to his supervisor, reported having made considerable inroads into the lacunae impairing his professional judgment. In that context, we were not satisfied that Mr Pallini had achieved the results he claimed. In that regard, we viewed Mr Pallini's evidence as self-serving and lacking credit.
In general terms, while he acknowledged and expressed substantial contrition for his misdeeds in general terms, he continued to minimise and deny his culpability in specific terms.
For example, what greatly troubled us was Mr Pallini's persistent categorisation of the text messages he sent as something other than what they plainly were, a sexual proposition to Ms M. He did not seem to be able to accept that. He described it as the "banter of friends about life events".
In addition, notwithstanding repeated questioning about it, he refused to acknowledge that in his letter to the Board of October 2007, he was blaming Ms M for having "lured" him with her charms; nor, would he acknowledge that he was blaming his client, when he appeared to question her motives in taking two years to complain.
In so doing, he showed little insight into his responsibilities as a treating professional, and the way in which his own emotions and impulses had acted to corrode those responsibilities. In that light, he showed little understanding of the concepts of transference and counter-transference as directly applicable to the therapeutic dynamic.
In the larger sense, in defining his therapeutic approach as a combination of cognitive behavioural therapy and psychodynamic therapy in the statement of agreed facts, Mr Pallini showed little understanding of the basic theory base of the latter, and instead indicated that his "therapy" consisted of the establishment of rapport and non-directive counselling.
In so doing, he exaggerated the nature of his professional competencies and the nature of his professional authority, beyond the scope of either his training or experience. As a result, he overstated the treatment provided to Ms M in the statement of agreed facts for the Tribunal.
It was apparent to us that he had not perceived his shortcomings at several critical points. These include when the issue of employment became live, when he began socialising with his client, when he submitted the text message, when she discontinued therapy, and when the complaint was made. He could not explain why he had done nothing to pursue supervision himself at any time point during and after the debacle with his client. He only commenced supervision as part of the agreement with the Board in order to avoid suspension.
These matters reinforce, in our view, his abject lack of insight into his conduct or reflectiveness on that professional relationship. Our impression was that Mr Pallini was conceding, but not actually comprehending to an acceptable standard, his culpability and poor judgement.
The need for psychologists to have a full and proper understanding of their ethical obligations is fundamental to the practice of the profession. It is imperative that psychologists know the basic steps that a psychologist in a position such as Mr Pallini must take to safeguard the interests of the client and to ensure no harm or exploitation occurs. The knowledge of these basic steps we found abjectly lacking in Mr Pallini.
In so saying, we found that Mr Pallini continued to demonstrate a troubling low level of insight into his own behaviour or the impact of his actions upon his vulnerable client.
On that basis, we received little comfort from Mr Pallini's remorse, and could not be satisfied that the community's safety could be ensured without substantial improvement in his understanding of the relevant standards.
In our view, Mr Pallini developed a continuing, escalating pattern of errant conduct rather than a number of connected but discrete incidents, comprising "bad behaviour"; it is about fundamental lacunae in his capacities not only to maintain appropriate boundaries but to recognise and respond effectively to the challenges and risks posed to the integrity of the professional relationship by the dynamics of that relationship and his own internal impulses; we do not view him as having made meaningful (even within the narrow confines of the evidence of Dr Farhall) progress in addressing that pattern.
In so saying, it is our intention to respond to that pattern with a coherent framework of determinative orders designed to address Mr Pallini's deficits and assist him towards the construction and maintenance of appropriate professional standards.

[119]

On the basis of these considerations and having found that Mr Pallini has engaged in unprofessional conduct of a serious nature, we determine to suspend Mr Pallini's registration, to require him to undergo counselling and to impose conditions on his registration. We makes these determinations to ensure the protection of the community, to give him time to contemplate and receive assistance in the development of appropriate professional standards, and to convey to the profession and the public the importance of maintaining appropriate professional boundaries.
We therefore order pursuant to s 48(2) of the Psychologists Registration Act 2000 that
1. The registration of Mr Pallini be suspended for a period of six months, beginning one month from the date of these orders, or earlier as agreed between Mr Pallini and the Board. This delay will enable Mr Pallini to conclude current professional activities with his current clients.
2. Mr Pallini whilst suspended commence as soon as possible further education in the form of mentoring with a mentor approved by the Board, for a period of six months, in relation to boundary issues which might include guidance, through the utilisation of any or all of the following:
  - (a) review of previous Board determinations involving boundary issues
  - (b) role plays
  - (c) discussion of various scenarios
  - (d) reading of relevant literature
  - (e) attendance at relevant professional development activities.
3. Mr Pallini undertake counselling at least monthly for a period of 12 months, from the date of this determination, or such longer period as his counsellor directs, whichever is longer, at his own expense from a mental health professional approved by the Board in relation to the personal factors that contributed toward his boundary transgressions and creation of inappropriate dual relationships.
4. Mr Pallini take those steps that are reasonably open to him to facilitate the counsellor referred to in Order 3 providing to the Board a brief report at six monthly intervals confirming Mr Pallini's attendances with the counsellor and confirming that issues relating to relevant personal issues have been addressed in the counselling process.
5. On resumption of his registration, the following conditions apply :

At a glance

Court

Decision date

Source

Judgment (123 paragraphs)

Psychologists Registration Board of Victoria v Pallini (Occupational and Business Regulation) [2008] VCAT 2632 (19 December 2008)

Psychologists Registration Board of Victoria v Pallini (Occupational and Business Regulation) [2008] VCAT 2632 (19 December 2008)

Parties

Cases Cited (2)