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[2001] VSC 276
Supreme Court of Victoria
2001-08-10
Gillard J
Original judgment source is linked above.
JUDICIAL REVIEW - adjustment of premiums payable under employer's insurance
policy - power to do so - power of WorkCover Authority pursuant to statutory instruments. NATURAL JUSTICE - right to be heard - party to review not seeking report - content of fair hearing rule. LEGISLATIVE SCHEME pursuant to Accident Compensation (WorkCover Insurance) Act .
"The audit firm found that succession is applicable to the SBA workplaces, from the predecessor workplaces previously registered against R.J. Gilbertson Pty Ltd (1132650) and R.J. Gilbertson (Southern) Pty Ltd (1132702). The principles of succession have been discussed with you previously, however should you wish to discuss this further, please contact the writer. Acting on the directions of the Victorian WorkCover Authority, HIH Workers Compensation (Vic) Limited has now applied succession with effect from November 1996 and recalculated premiums for all policy periods since that date."
(i) A decision made by the Authority, prior to 13 November 1998, that the principles of succession were to apply to the calculation of the insurance premiums payable by SBA Foods, and a direction by the Authority to HIH to implement the decision, set out in the letter from the Authority to HIH of 13 November 1998.
"In addition, the audit firm has determined that succession should have been applied when the company took over the operations of the business of R.J. Gilbertson Pty Ltd and R.J. Gilbertson (Southern) Pty Ltd on 18 November 1996. The following tables detail the predecessor and successor workplaces: (The tables set out the old and new workplaces with identifying numbers.) Would you please arrange for succession to be applied, as detailed above, effective from 18 November 1996, and adjust remuneration in accordance with the audit result. These amendments are to be made by 30 November 1998 and your advice on completion would be appreciated."
(ii) The alleged decision, made by HIH, whereby it recalculated the premiums pursuant to the direction given by the Authority in its letter of 13 November 1998, conveyed by letter to SBA Foods on 3 December 1998.
"2. The audit firm found that succession is applicable to SBA Foods workplaces, from the predecessor workplaces previously registered against R.J. Gilbertson Pty Ltd (1132650) and R.J. Gilberston (Southern) Pty Ltd (1132702). The principles of succession have been discussed with you previously, however should you wish to discuss this further, please contact the writer. Acting on the directions of the Victorian WorkCover Authority, HIH Workers Compensation (Vic) Limited has now applied succession with effect from November 18 1996 and recalculated premiums for all policies since that date. (A table set out the old and new premiums for the periods 1997, 1997/98 and 1998/99.) For your assistance, we attach a summary of premium details for each individual workplace. An amended premium notice will be issued for each policy period and these will follow shortly. If you wish to object to the audit findings, please lodge your written objection to:- Frank Sanders, Operations Management Division Victorian WorkCover Authority PO 415 Melbourne 3005 This objection must be made within twenty eight (28) days after the date of demand for the revised premium. Should you have any queries or if there is any way in which HIH Workers Compensation (Vic) Limited can be of assistance to you in respect to the audit process, please do not hesitate to contact the writer on (03) 9224 2454". The letter was signed by Miss Caterina Todarello, Premium Supervisor.
(iii) The decision made on the review which was conveyed by a letter, dated 19 July 1999, from the Authority to SBA Foods. The letter relevantly provided -
"Dear Mr Slinger RE: REVIEW OF AUDIT REMUNERATION ASSESSMENT AND DEFAULT PENALTY EMPLOYER: SBA FOODS PTY LTD WEN: 6963374 VWA AUDIT REFERENCE: 20 061 I refer to your letters dated 18 December 1998 and 16 February 1999 in which a request was made for a review of the remuneration assessment, and audit default penalty imposed, against the above employer as a result of the audit conducted by Ernst & Young on behalf of the Authority. I understand that the core issues were also discussed at a meeting with the Minister held on 16 June 1999 and attended by you, and other officers of your company, together with officers of the Authority. The Authority has reviewed the assessment of rateable remuneration and the application of Schedule 1, part 6, of the WorkCover Insurance Premiums Order, (Succession), which formed the basis for the adjusted premium notified in the Reconcilation Statement and 1993/94 Confirmed Premium Notice (Audit) issued in December 1998. Additionally the Authority has considered the consequential effect in subsequent premium years. Following the review, the Authority is not satisfied that there are grounds for altering the assessment or the default penalty rate previously imposed. It is the view of the Authority that the operation of SBA Foods Pty Ltd attracts the application of succession according to law. The premium adjustment and audit penalty will therefore stand. Arrangements should now be made to pay any monies that are still outstanding. If you do not agree with the Authority's decision outlined above, you may apply to have the matter determined by a court of competent jurisdiction."
"Judicial review is concerned, not with the decision, but with the decision making process. Unless that restriction on the power of the court is observed, the court will in my view, under the guise of preventing the abuse of power, be itself guilty of usurping power."
"If such an administrative tribunal falls into an error of law which causes it to identify a wrong issue, to ask itself a wrong question, to ignore relevant material, to rely on irrelevant material or, at least in some circumstances, to make an erroneous finding or to reach a mistaken conclusion, and the tribunal's exercise or purported exercise of power is thereby affect, it exceeds its authority or powers. Such an error of law is jurisdictional error which will invalidate any order or decision of the tribunal which reflects it."
"It may have given its decision in bad faith. It may have made a decision which it had no power to make. It may have failed in the course of the enquiry to comply with the requirements of natural justice. It may in perfect good faith have misconstrued the provisions giving it power to act so that it failed to deal with the question remitted to it and decided some question which was not remitted to it. It may have refused to take into account something which was required to be taken into account. Or it may have based its decision on some other matter which, under the provision setting it up, it had no right to take into account. I do not intend this list to be exhaustive. But if it decides the question remitted to it for decision without committing any of these errors it is as much entitled to decide that question wrongly as it is to decide it rightly." (Emphasis added).
"(d) for the purpose of the efficiency or effectiveness of the WorkCover system generally;"
"2.2 In carrying out its obligations, functions and powers under the licence, the insurer must comply with these conditions and with any guidelines directions or advisory notes issued by the Authority from time to time."
"The Governor-in-Council may on the recommendation of the Authority by Order in Council make a premiums order -
(a) specifying the methods to be used in calculating premiums payable by an employer for a WorkCover insurance policy; and
(b) prescribing or specifying any matter or thing required or permitted by this Act to be prescribed or specified by a premiums order."
"5. WorkCover Premium The WorkCover Premium of an employer is the sum of the premium for all periods of coverage of all workplaces of the employer where the premium payable for a period of coverage of a workplace is determined in accordance with the following formula:" (A formula was set out.)
"6. WorkCover Premium Rate (1) The WorkCover Premium Rate for the workplace in respect of the period of coverage is calculated -
(a) if the workplace is a startup workplace, as IR; or
(b) in all other cases,
(i) in accordance with the following formula: (formula set out) or
(ii) as 10% of IR -
whichever is the greater."
(Emphasis added).
"11. Determinations and calculations (1) Unless otherwise expressly stated, any determination or calculation required to be made for the purposes of calculating a premium under this Order is to be made by the authorised insurer. (2) An employer may, in accordance with the policy, apply to the Authority for review of, or the Authority may of its own volition review, a determination or calculation made by an authorised insurer under sub-clause (1) and on review the Authority may make any determination or calculation that the authorised insurer may make."
"1. Where the authorised insurer or the Authority becomes aware of any new information affecting the calculation of the premium after the premium payable is calculated, the authorised insurer or the Authority may recalculate the premium in accordance with this order and the difference must be met by a further payment by the employer or by a refund to the employer, as the case requires."
"(1) The premium payable by an employer for a WorkCover insurance policy must be calculated in accordance with the method specified in the relevant premiums order."
"26. Payment of premiums (1) ... (2) ... (3) ... (4) The Authority or the authorised insurer may by notice in writing to the employer at any time after the commencement of a policy period adjust the amount of premium in accordance with the premiums order and the adjusted amount is the premium for the purposes of this Act."
"... as I see it, that scheme was in substance a scheme of private insurance. It is true that the scheme was overlaid with and subject to, a number of statutory requirements, but in essence, it was designed to bring the employer and an insurance company into direct contractual relations over the liability of the employer in respect of work-related injury or death." (Emphasis added).
* The employer had paid annual premiums from 1985 on the same classification;
* The employer had received visits from officers of the Authority and there was no suggestion that the classification was wrong;
* The employer had not been deceptive or misleading in registering its classification;
* The employer was initially informed that the adjustment was for the year 1 July 1995 to 30 June 1996.
(i) Did the insurer have the power under the various Acts, including the Premiums Order and policies, to adjust the amount payable for premium for the three policy periods from 1993 to 1996?
(ii) If the insurer had the power to adjust, was it exhausted when notice was given that the re-classification was "effective from the 1995-6 financial year only"?
* That under the legislative scheme established by the 1993 Act, the scheme was, in substance, one of private insurance, i.e. a contractual relationship between the employer and the insurer.
* That the form of the policy supported this conclusion.
* That the policy was expressly subject to the A.C. Act, the 1993 Act, and the regulations and orders made under the Acts.
* That clause 10 of the Premiums Order and condition 10 of the policy emphasised the nature of the scheme as private insurance, and the authorised insurer was bound to determine the rate of the premium.
* That s.17 of the 1993 Act did not permit the insurer to adjust the premiums retrospectively, and to give this construction would lead to an absurdity because the insurer could review the classification at any time and an employer would never know its obligations. The section did not provide for an adjustment.
* The right to adjust premiums depended upon the terms of the relevant policy when read and understood in the context of the legislative scheme.
* The contract of insurance is a contract and cannot be re-made without agreement by all parties. His Honour did observe that his finding was subject always to statute. Once the premium is struck and paid it cannot be altered.
* Unless there was some provision justifying it for the past, there was no basis for adjusting the premium.
* Neither Schedule 7 of the Premiums Order nor s.26(4) justified the power to revisit past years.
* Section 26(4) gave a power to adjust in accordance with the Premiums Order - one had to go to the Premiums Order.
* Schedule 7, which is headed "Revised Premium", did not authorise the insurer, well after the expiry of a policy period, to revisit the situation and adjust the premium.
* The words in Schedule 7 did not require it, and nothing in principle justified it.
"3. If a premium has been discounted in accordance with item 2, for the purposes of calculating - (a) ... (b) any adjusted premium payable after the policy period has expired where the policy period expires at 4.00 p.m. on 30 June 1997 - the amount of premium so calculated is to be reduced by the
amount by which the premium was reduced as a result of the discount." (Emphasis added).
"Premium for Policy. The premium for this policy or any renewal thereof is the amount fixed by the Insurance Premiums Order in force under the WorkCover Insurance Act in respect to the relevant policy period."
"6. Predecessor A workplace is the predecessor of another workplace if the predominant activity that was being carried on in the former is being carried on, in substance, in the latter and in succession to the former, notwithstanding that, when carried on in the former, it may have been carried on by a different employer or at a different physical location or both."
"10. Determinations and Calculations (1) Unless otherwise expressly stated, any determination or calculation required to be made for the purposes of calculating a premium under this Order is to be made by the authorised insurer."
"(2) An employer may, in accordance with the policy, apply to the Authority for review of, or the Authority may of its own volition review, a determination or calculation made by an authorised insurer under sub-clause (1) and on the review the Authority may make any determination or calculation that the authorised insurer may make." (Emphasis added).
"(1) Where the authorised insurer or the Authority becomes aware of any new information affecting the calculation of a premium after the premium payable is calculated, the authorised insurer or the Authority may re-calculate the premium in accordance with this order and the difference must be met by a further payment by the employer or by a refund to the employer, as the case requires." (Emphases added).
"It can now be taken as settled that, when a statute confers power upon a public official to destroy, defeat or prejudice a person's rights interests or legitimate expectations, the rules of natural justice regulate the exercise of that power unless they are excluded by plain words of necessary intendment."
"It is a fundamental rule of the common law doctrine of natural justice expressed in traditional terms that, generally speaking, when an order is to be made which will deprive a person of some right or interest or legitimate expectation of a benefit, he is entitled to know the case sought to be made against him and to be given an opportunity of replying to it." (Emphasis added).
"As discussed with Marcelle, when succession is applied, consideration is given to the following type of issues. Did SBA Foods Pty Ltd take over R.J. Gilbertson's Pty Ltd employees plant and equipment and maintain the same physical location? In essence for succession to be applied the predominant activity must be maintained from the predecessor to the successor workplaces."
"If you have any queries do not hesitate to contact Marcelle on 9288 8204."
"Where the decision in question is one for which provision is made by statute, the application and content of the doctrine of natural justice or the duty to act fairly depends to a large extent on the construction of the statute ... What is appropriate in terms of natural justice depends on the circumstances of the case and they will include, inter alia, the nature of the enquiry, the subject matter and the rules under which the decision maker is acting ... In this respect the expression 'procedural fairness' more aptly conveys the notion of a flexible obligation to adopt fair procedures which are appropriate and adapted to the circumstances of the particular case. The statutory power must be exercised fairly, i.e., in accordance with procedures that are fair to the individual considered in the light of the statutory requirements, the interests of the individual and the interests and purposes, whether public or private, which the statute seeks to advance or protect or permits to be taken into account as legitimate considerations." (Emphases added).
"These considerations lead me to the conclusion that the party to a dispute who has lost the opportunity to have his case heard through the default of his own advisers to whom he has entrusted the conduct of the dispute on his behalf cannot complain that he has been the victim of a procedural impropriety or that natural justice has been denied him, at all events when the subject matter of the dispute raises issues of private law between citizens. Is there any principle which can be invoked to lead to a different conclusion where the issue is one of public law where the decision taken is of an administrative character rather than the resolution of a lis inter partes? I cannot discover any such principle and none has been suggested in the course of argument."
"I refer to your letter dated 5 October 1998 regarding the audit conducted on the above named employer. I have spoken to Steve Kolotylo concerning the succession issue. He is of the opinion that succession should apply, however he would like your letter to advise that: 1. Gilbertsons effectively became an agency providing staff to SBA. 2. SBA Foods maintained the predominant activity, previously undertaken by Gilbertsons, at each workplace. If you agree with this could you please re-write your letter." (Emphasis added).
"On 18 November 1996 R.J. Gilbertson Pty Ltd effectively became an agency providing staff to SBA Foods Pty Ltd. On 18 November 1996 SBA Foods Pty Ltd maintained the predominant activity, previously undertaken by R.J. Gilbertson Pty Ltd, at each workplace."
2. That the plaintiff pay the costs of each defendant, including reserved costs.
SBA Foods Pty Ltd
Victorian WorkCover Authority [2001] VSC 276
(1994) 184 CLR 163
(1966) 116 CLR 644
(1990) 170 CLR 596
(1985) 159 CLR 550
(1979) 1 NSWLR 1
(2000) 100 FCR 519
(2000) 100 FCR 495