Body Corporate and Community Management Act 1997 (Qld) (Act), sections 227 and 229(3)(a)

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

INTERIM ORDER - whether an interim order is necessary because of the nature or urgency of the circumstances to which the application relates.

ADJUDICATOR POWERS - whether Adjudicator can be satisfied that an application raises a serious legal question and the balance of convenience between the parties justifies injunctive relief.

1. The application for interim orders is dismissed

• [1] Surfers Plaza Resort consists of 146 lots on a building format plan, 144 of which are residential lots, and 2 of which are commercial lots. Lot 1 is a retail shop and lot 2 is designated as a Backpacker Hostel.
• [2] An application, seeking interim and final orders was lodged with this Office on 21 November 2025 by Crestden Pty. Ltd., the owner of Lot 2 (first applicant), and Tequila Sunrise Pods Pty Ltd, the lessee and occupier of Lot 2 (second applicant).
• [3] The applicants seek the following interim orders pursuant to section 279 of the Act:

(a) That pending a further interim order, and until this dispute resolution application is finally determined or discontinued at an earlier time, the Body Corporate for the Surfers Plaza Resort Community Titles Scheme 6388 must not implement, or take any action, pursuant to Motion 5, purportedly passed at the Extraordinary General Meeting of the lot owners in the Scheme held on 7 November, 2025.

(b) Such further or other interim order(s) as may be determined to be just and equitable in the circumstances.

• [4] The applicant also seeks the following interim orders pursuant to section 276 of the Act:

(a) declaration that Motion 5, purportedly passed at an Extraordinary General Meeting of the lot owners in the Surfers Plaza Resort Community Titles Scheme 6388 held on 7 November, 2025 is unreasonable, unlawful, void and of no effect

(b) Such further or other interim order(s) as may be determined to be just and equitable in the circumstances

• [5] The core issue revolves around a large increase in the Body Corporate's 2025 insurance premium and resolutions of the body corporate which seek to allocate a significant portion of the increase, referred to as the "Premium Difference," to the Applicants.
• [6] Previously in 2024, the Body Corporate's annual premium of insurance policy with Strata Community Insurance was $71,708.85 (Previous Premium) which included the following coverage:

(i) Building: $67,946,561.00;

(ii) Public Liability: $30,000,000;

(iii) Office Bearers: $5,000,000;

(iv) Machinery Breakdown: $100,000;

(v) Catastrophe: $21,403,167.

• [7] However on 13 June 2024, Strata Community Insurance, advised that it would not renew the policy due to various factors, including the resignation of their broker, an open claim from 2022, and the advice that a 270-bed backpacker business was operating from Lot 2.
• [8] Another insurance broker engaged by the body corporate, informed them in July 2024 that other local insurers had declined coverage. The applicants state that a number of factors influenced the decision to decline quoting, including:
  • Limited capacity to cover combined Commercial and Residential Strata
  • Limited capacity to write a property of this size
  • Unwillingness to write an uninsured risk
  • The limited time frames to adequately survey and meet any risk recommendation requirements
  • The tenancy of a hostel on floor one
  • Current renovation works in progress

• [9] After local insurers refused coverage, the body corporate was able to obtain coverage via Lloyds of London, albeit at a greatly increased premium of $721,939.42 in total. Of this amount, the premium for property reinstatement insurance was $704,727.89.
• [10] The following year, the body corporate engaged Howden Insurance Brokers (Australia) Pty. Ltd. (a subsidiary of the Howden Broking Group Ltd. UK) which arranged property insurance cover for 2025/2026 at a premium cost of $353,806.07[1] through various insurers.
• [11] The Interest Schedule of Lot Entitlements for the Scheme[2] provide that Lot 2 has 184 lot entitlements[3] out of a total of 10,000 lot entitlements. Therefore, as a starting point it would ordinarily contribute 184/10,000 or 1.84% of the total cost of insurance. However, under section 191(2) of the Accommodation Module a body corporate may adjust the contribution payable by an owner of a lot under section 191(1) in a way that 'fairly reflects':

(c) the proportion of the total risks covered by the policy attributable to activities carried on, or proposed to be carried on, on the owner's lot.

• [12] By motion 5, the body corporate sought to reallocate the contribution of lot 2 toward the reinstatement insurance premium of $364,806.07 to "fairly reflect the proportion of the total risks attributable to activities carried out on the owner's lot", pursuant to section 191(2)(c) of the Body Corporate and Community Management (Accommodation Module) Regulation 2020. It was proposed that Lot 2 would be liable for 55% of the 2025-2026 reinstatement insurance premium.
• [13] The applicants argue that the resolution on Motion 5, passed at an Extraordinary General Meeting, on 21 August 2025, was unreasonable, void, and of no effect because it unfairly reallocated most of a substantial increase in the body corporate insurance premium primarily to Lot 2, from which a 270-bed backpacker hostel is operated.

• [14] At the last Annual General Meeting on 21 August 2025, the following motions were purportedly carried:

9. Fair Apportionment of Insurance 2024 - 2025 Premium (ordinary resolution)

THAT pursuant to section 191(2)(c) of the Body Corporate and Community Management (Accommodation Module) Regulation 2020 the contribution of the respective lot owners to the total insurance premium for the reinstatement insurance policy for the 2024 to 2025 period with Co-insurance - Lloyds of London Policy No. WHHCTS6388 of $704,727.89 be adjusted so that it fairly reflects the proportion of the total risks covered by the policy attributable to activities carried on, on the owner's lot as follows:

AND contribution notices for the reinstatement insurance policy be issued to the respective owners for the total amounts as follows:

$246,654.76, in proportion to their respective contribution entitlements for Lots 3 - 146

AND THAT the amount of the contribution will be payable by two equal instalments with the due date for each instalment as follows:

Amount - 50% of total amount owing in accordance with the above, and in line with the respective contribution entitlements.

Amount - 50% of total amount owing in accordance with the above, and in line with the respective contribution entitlements.

10. Fair Apportionment of Insurance 2024 - 2025 Premium (ordinary resolution)

THAT pursuant to section 191(2)(c) of the Body Corporate and Community Management (Accommodation Module) Regulation 2020 the contribution of the respective lot owners to the total insurance premium for the reinstatement insurance policy for the 2024 to 2025 period with Co-insurance - Lloyds of London Policy No. WHHCTS6388 of $388,045.73 be adjusted so that it fairly reflects the proportion of the total risks covered by the policy attributable to activities carried on, on the owner's lot as follows:

AND contribution notices for the reinstatement insurance policy be issued to the

$177,724.94 in proportion to their respective contribution entitlements for Lots 1 and 3 - 146

AND THAT the amount of the contribution will be payable by two equal instalments with the due date for each instalment as follows:

Amount - 50% of total amount owing in accordance with the above, and in line with the respective contribution entitlements.

Amount - 50% of total amount owing in accordance with the above, and in line with the respective contribution entitlements.

• [15] However, on 10 October, 2025, the Body Corporate gave notice to the lot owners in the Scheme of an Extraordinary General Meeting (EGM) to consider:

(a) a motion to rescind Motion 10 (Rescission Motion); and

(b) passing the following motion (Motion 5) to replace Motion 10:

5. FAIR APPORTIONMENT OF INSURANCE 2025-2026 PREMIUM

RESOLVED THAT subject to the passing of the previous motion rescinding motion 10 of the 2025 AGM, pursuant to section 191 (2)(c) of the Body Corporate and Community Management (Accommodation Module) Regulation 2020 ("Accommodation Module"), the contribution of the respective lot owners to the total insurance premium for the reinstatement insurance policy for the 2025 to 2026 period with Howden Insurance Brokers of $364,806.07 (inc GST) be adjusted so that it fairly reflects the proportion of the total risks covered by the policy attributable to activities carried on, on the Owner's Lot as follows:

1. Lot 1 - Pilates Studio 2%
2. Lot 2 - Hostel 55.23%

3. Lots 3 -146 Residential (in accord with the interested entitlement of each Lot) 42.77%

• [16] The explanatory notes accompanying the motion state that following the last AGM, the committee sought and obtained advice from Howden, their insurance broker, as to how the insurers calculated the premium taking into account the uses of the lots in the building. The insurer advised that it determined that the use of lot 1 for the purposes of a Pilates Studio accounted for 2% of the total risk covered by the Policy. The committee proposes that the contribution that lot 2 pays to the insurance premium be adjusted so that it pays 2% of the total insurance premium, as this fairly reflects the proportion of the total risks covered by the policy attributable to activities carried on in lot 1. The insurer advised that it determined that the use of lot 2 for the purposes of a hostel accounted for 55.23% of the total risk covered by the Policy.
• [17] The committee proposed that motion 10 be rescinded and that motion 5 be adopted instead so that the contribution of lot 2 to the reinstatement insurance premium is 55.23% of the reinstatement insurance premium, as this fairly reflects the proportion of the total risks covered by the policy attributable to activities carried on in lot 2.
• [18] As stated above, the core issue in this dispute stems from the Body Corporate's resolution to impose most of the insurance premium increase onto the applicants' hostel lot via Motion 5**,** claiming the high cost reflects the risk posed by their hostel business.
• [19] Motion 5 adjusts the 2025-2026 insurance contribution to allocate 55.23% of the total risk covered by the policy (amounting to $201,489.80), to Lot 2 (the Hostel). The Applicants are now seeking interim and final orders declaring Motion 5 "unreasonable, unlawful, void and of no effect". The Body Corporate refused the Applicants' request for an undertaking not to act on Motion 5 pending a final decision.
• [20] The applicants argue the insurance cost increase was multifactorial**,** resulting from the Body Corporate allowing the scheme to become uninsured and requiring "last resort" coverage. The application seeks a final declaration that Motion 5 is unlawful, unreasonable, and void**,** and requests urgent interim orders to stop the Body Corporate from proceeding with the collection of the levies. The applicants claim the Body Corporate's reallocation relies only on statements by the broker rather than quantifiable evidence from the actual insurer. Granting the interim orders, they contend, carries a lower risk of injustice than forcing the applicants to pay sums that would be financially ruinous**.**

The applicants' grounds for seeking to Invalidate Motion 5

• [21] Firstly, the applicants argue that for a fair apportionment to occur, there must be quantifiable evidence from the actual insurer that the activities in Lot 2 led to a quantifiable increase in the premium. They say the Body Corporate failed to produce such evidence, rendering the percentage reallocation arbitrary.
• [22] Secondly, the applicants argue that the power to adjust contributions (Section 191) applies only to "reinstatement insurance".[4] They believe the body corporate is seeking to reallocate the entirety of the policy premiums, which included coverage for industrial special risks, public liability, and management liability.
• [23] Thirdly, the Applicants argue that the motion fails to account for numerous other factors resulting in the premium increase and unfairly attributes the entire Premium Difference to the operation of the hostel. The Applicants argue that the premium increase was multifactorial, stemming from various issues.
• [24] Finally, the applicants argue that lot owners were not provided with sufficient information (i.e., material from the insurer) to allow them to make an informed, evidence-based decision that the proposed reallocation was "fair".
• [25] Further, they argued that if the interim order was granted, the only prejudice suffered by the Body Corporate is a delay in recovering the cost, which has already been funded through a premium funding facility, minimizing prejudice to the Body Corporate while protecting the Applicants from "practical destruction".

Investigations Pursuant to section 271 of the Act

• [26] Pursuant to my investigative powers under section 271 of the Act, I invited submissions from the body corporate regarding the interim outcome sought. I also had regard to submissions submitted by lot owners and material submitted by the body corporate pursuant to application 920-2025.
• [27] The applicants seek an interim order that the body corporate not implement, or take any action, pursuant to Motion 5, purportedly passed at the Extraordinary General Meeting of the lot owners in the Scheme held on 7 November, 2025.
• [28] The body corporate says the scheme needs to recoup the massive unbudgeted expenditure and faces the imminent risk of becoming uninsured due to lack of available funds. The applicants failed to disclose the Body Corporate's existing dire financial stress and minimal cash reserves. This would have been clear if I had been provided with the balance sheet of the body corporate, and been informed that there was a very real risk that the body corporate would not have sufficient funds to pay the insurance premium for the current insurance year.
• [29] One lot owner says that the reference to previous insurance costs e.g. from 2023 does not reflect the fact that a 270 bed backpacker hostel started operating in December 2024. As a result of the backpacker hostel commencing operations, the insurance costs were reassessed by 2 different Insurance Providers, and after undertaking a total risk assessment of residential and business aspects, they allocated the premiums accordingly and are reflected in motion 5.
• [30] They believe this was a fair allocation of costs by the Insurers. They say it is unreasonable to require owners of private residential units to cover costs relating to the applicants' business operations from which they obtain no benefit.
• [31] Two lot owners made submissions stating that they seek a fair and evidence-based assessment of the contribution and risk profile associated with Lot 2, which operates a 270-bed backpacker hostel. They point out that there is a huge inconsistency between the lot's 184 contribution entitlements and the actual intensity of use.
• [32] One lot owner notes that Lot 2 holds 184 contribution entitlements out of the total out of a total of 10,000 lot entitlements. A typical residential lot holding 66 entitlements would house up to 4 people (but often just two people). On a proportional basis, a 184-entitlement lot would reasonably align with approximately 11-12 occupants. However lot 2 operates at least 24 times this intensity. The 270-bed hostel dramatically increases foot traffic, use of common facilities, security incidents, waste, plumbing demand, and insurer-identified risk.
• [33] They say that insurers attributed a significant proportion of total scheme risk to Lot 2. The disparity between 184 entitlements and a 270-bed operation supports a risk-based reallocation under section 191(2)(c). Entitlements do not capture extraordinarily high-intensity commercial use. Residential owners should not subsidise risk created by a disproportionate commercial operation. This disparity is relevant to determining fair contribution levels and supports aligning insurance cost apportionment with actual operational risk.
• [34] They say Lot 2's hostel operations were responsible for:

• persistent insurer concerns regarding occupancy volume and fire risk.

• [35] The only issue to decide at this time is whether an interim order is warranted. However, to determine that question, it is necessary to consider the substantive issue in dispute.
• [36] Section 276(1) of the Act provides that:

An adjudicator may make an order that is just and equitable in the circumstances (including a declaratory order) to resolve a dispute, in the context of a community titles scheme, about-

(a) a claimed or anticipated contravention of the Act or the community management statement; or

(b) the exercise of rights or powers, or the performance of duties, under the Act or the community management statement; or

(c) a claimed or anticipated contractual matter about-

(i) the engagement of a person as a body corporate manager or service contractor for a community titles scheme; or

(ii) the authorisation of a person as a letting agent for a community titles scheme.

• [37] An order may require a person to act, or prohibit a person from acting, in a way stated in the order (section 276(2)). An adjudicator's order may contain ancillary and consequential provisions the adjudicator considers necessary or appropriate (section 284(1)).
• [38] Further, section 279 provides that:

(1) The adjudicator may make an interim order if satisfied, on reasonable grounds, that an interim order is necessary because of the nature or urgency of the circumstances to which the application relates.

Examples

1. The adjudicator may stop the body corporate from carrying out work on common property until a dispute about the irregularity of proceedings has been investigated and resolved.

2. The adjudicator may stop a general meeting deciding or acting on a particular issue until it has been investigated and resolved.

(2) An interim order

(a) has effect for a period (not longer than 1 year) stated in the order; and

(b) may be extended, varied, renewed or cancelled by the adjudicator until a final order is made; (c) may be cancelled by a later order made by the adjudicator; and

(d) if it does not lapse or is not cancelled earlier, lapses when

(i) the application is withdrawn; or

(ii) the commissioner gives the person who made the application a written notice under section 241 rejecting the application; or

(iii) a final order is made by an adjudicator to whom the application is referred. ...

• [39] As outlined above, the applicant is seeking both interim and final orders. The only issue at this time is whether an interim order is warranted. Any order granted must be just and equitable.[5] An interim order will not be granted unless it is necessary due to the nature or urgency of the circumstances.[6] The examples in the Act indicate the usual circumstances where an interim order might be made are in the nature of injunctive relief. An applicant must establish that the circumstances warrant an interim order. An interim order will not be made if the only urgency is a desire to expedite the dispute.
• [40] In order to make an interim order an adjudicator must be satisfied an applicant has established that it has a prima facie case[7] and the balance of convenience between the parties justifies injunctive relief.[8] That is, an adjudicator must balance the inconvenience of granting relief now if final orders are ultimately refused, against the inconvenience of refusing relief now if final orders are ultimately granted. Of particular relevance is evidence an interim order is necessary to prevent serious or irreparable harm.
• [41] The case of SDW2 Pty. Ltd. V JLF Corporation Pty Ltd [2017] QSC 1 provides some guidance as to when it would be appropriate to make an interlocutory injunction at paragraph [21]:

The legal principles governing the disposition of an application for interlocutory injunction were discussed by me in Stacks Managed Investments Ltd v Tolteca Pty Ltd [2015] QSC 234 at 3 to 5 and again in Tribal Health Pty Ltd v Flush Fitness Pty Ltd [2016] QSC 103. In the latter case I summarised relevant principle in these terms (at [23]):

(a) The law in Australia has long regarded it to be necessary to make two main inquiries: (i) whether the applicant has shown that it has a prima facie case; and (ii) whether the applicant has shown that the balance of convenience favours the granting of the relief claimed.

(b) The significance of the requirement that a prima facie case be shown is elaborated upon in Australian Broadcasting Corporation v O'Neill (2006) 227 CLR 572 and Live Earth Resource Management Pty Ltd v Live Earth LLC [2007] FCA 1034 at [11] to [13].

(c) The considerations brought to bear on the balance of convenience requirement were the subject of discussion in Australian Broadcasting Corporation v O'Neill and Bowen Central Coal Pty Ltd v Aquila Coal Pty Ltd [2011] QCA 334, the latter case clarifying that the adequacy of an award of damages and the question of the sufficiency of the usual undertaking were to be considered as part of the totality of the balance of convenience question.

(d) The progression of the two main inquiries is not a mechanical exercise. Whether the relief sought is prohibitory or mandatory, the Court should take whichever course appears to carry the lower risk of injustice if it should turn out to have been "wrong" in the sense of granting an injunction to a party who fails to establish his right at an ultimate trial, or in failing to grant an injunction to a party who succeeds at trial. In making that decision, the Court should weigh in the balance all relevant factors, including matters pertaining to the strength of the case to be tried and the balance of convenience.

(a) there are urgent circumstances;

(b) there is a prima facie case of sufficient merit to justify relief; and

(c) the balance of convenience between the parties justifies the order.

Extent to which Motion 5 concerns Reinstatement Insurance

• [43] As stated, the central controversy involves a large increase in the scheme's property reinstatement insurance premium. Whereas the 2024 premium was $71,708, the premium for 2024/2025 was $704,727 (out of a total insurance premium of $721,939.42).
• [44] The body corporate subsequently engaged Howden Insurance Brokers (Australia) Pty. Ltd. (a subsidiary of the Howden Broking Group Ltd. (UK) which has arranged property insurance cover for 2025/2026 at a premium cost of $353,806.07[9] through various insurers.
• [45] The applicants argue that although the reallocation power under section 191 applies only to "reinstatement insurance", motion 5 seeks to reallocate premiums for insurance policies to which the reallocation right in section 191 does not apply.[10] However from the information at hand at this point in time, I am unable to agree.
• [46] Subsections 191(1) and (2) of the Accommodation Module provide as follows:

(1) The owner of each lot that is included in the community titles scheme and is covered by reinstatement insurance required to be taken out by the body corporate is liable to pay a contribution levied by the body corporate that is a proportionate amount of the premium for reinstatement insurance that reflects -

(a) for a lot created under a building or volumetric format plan of subdivision - the interest schedule lot entitlement of the lot; and

(b) for a lot created under a standard format plan of subdivision - the cost of reinstating the buildings on the lot.

(2) The body corporate may adjust the contribution payable by an owner of a lot under subsection (1) in a way that fairly reflects -

(a) the extent to which the premium relates to fixtures and fittings that -

(i) form part of the lot; and (ii) are of a higher standard than the fixtures and fittings of lots included in the scheme generally; or

(b) the extent to which the premium relates to improvements made to the common property that benefit the lot; or

(c) the proportion of the total risks covered by the policy attributable to activities carried on, or proposed to be carried on, on the owner's lot.

• [47] Motion 5, specifically states that it concerns the contribution of the respective lot owners[11] to the insurance premium of $364,806.07 for the 2025/2026 building reinstatement insurance policy arranged by Howden Insurance Brokers.
• [48] The motion clearly states that the premium of $364,806.07 is for the 2025/2026 building reinstatement insurance .
• [49] It is clear from the Howden proposal that an additional premium of $23,241.66[12] is payable for the following coverage:

• [50] The applicants also argue that there is no evidence from which it can be determined that the Applicants (or either of them) are responsible for the lions share of the Premium increase. However I find it difficult to agree with this argument.
• [51] The body corporate says it received detailed advice from their insurance broker about the apportionment of the premium based on the use of lot 2. Their broker has advised that in apportioning risk, it was determined that the use of lot 2 for the purposes of a hostel accounted for 55.23% of the total risk covered by the Policy. The committee has therefore proposed that the contribution that lot 2 pays to the insurance premium be adjusted so that it pays 55.23% of the total insurance premium, as this fairly reflects the proportion of the total risks covered by the policy attributable to activities carried on in lot 2.
• [52] While not finally deciding the point at this point in time, I do not believe the Broker's advice should be dismissed out of hand as argued by the applicants, particularly where it is a large broker that is qualified to undertake risk assessment and risk profiling.
• [53] As a matter of common sense one would deduce that the addition of the 270-bed hostel in a building containing 144 residential lots would increase foot traffic, use of common facilities, use of utility services and various insurer-identified risks. The disparity between 184 entitlements and a new 270-bed operation supports a risk-based reallocation under section 191(2)(c). This disparity is relevant to determining fair contribution levels and supports aligning insurance cost apportionment with actual operational risk accompanying high-intensity commercial use.
• [54] The body corporate has previously pointed out that if this motion were to be invalidated, the proportion of the total insurance premium of $364,806.07 payable by Lot 1 will be .54% of the total premium or $1,969.95 and the proportion of the insurance premium payable by Lot 2 will be 1.84% of the total premium or $6,712.43 instead of the figure proposed above. The owners of lots 3 - 146 will pay 97.62% of the total premium or $356,123.68 as opposed to the lower figure proposed above.
• [55] A further concern to me is the failure to disclose the financial effect the requested interim order would have on the Body Corporate. It is evident from correspondence between the parties that if the interim order is made, there is a real risk that the body corporate would be in the position that it would not have sufficient funds to pay the insurance premium. In these circumstances its insurance would be cancelled with a very real risk that if the building went "off risk" again that it would be uninsurable.

• [56] The applicants argue that if the motion is not invalidated, the First Applicant will, under Clauses 4(e)(i) and 4(g)(i) of the Lease Agreement be entitled to require the Second Applicant to pay the Premium Difference. The Director of the Second Applicant gives evidence that being required to pay the Premium Difference would be financially ruinous to the Business if indeed even possible at all.
• [57] However the Accommodation Module provides that the Body Corporate can only recover unpaid contributions from the owner (i.e. the First Applicant, Crestden Pty Ltd).
• [58] Further, at this point in time I am not convinced that all costs of the lot owner are recoverable from the lessor under the lease agreement. Much depends on the terms of the lease agreement.

• [59] Clause 4 of the Lease Agreement reads as follows**:**

1. The Tenant is not liable to pay the Landlords Outgoings for the Lot but the Tenant is liable to pay the Tenants expenses identifiable as incurred with respect of the tenants use of the Land

• [60] I would think that the liability of the tenant for the lot owners increased levy contributions would depend on whether they can be characterised as "Tenants expenses identifiable as incurred with respect of the tenants use of the Land".
• [61] I note that paragraph 4 (g), referred to by the applicants, refers to "Further new or novel taxes" which are "payable to an assessing authority".
• [62] In short, at this point in time I am not satisfied that the second Applicant can be required to meet the increased contribution levies charged to the owner of lot 2.

• [63] For the above reasons, I am of the view that:

(a) The applicants have not established that there are urgent circumstances.

(b) The applicants have not established that there is a prima facie case of sufficient merit to justify relief; and

(c) In any event the balance of convenience between the parties does not justify making the requested interim orders.

• [64] The application for interim orders is therefore dismissed.
• [65] The application for final orders remains outstanding. This application will now be administered in accordance with the Act and the normal processes of this office. Submissions will be sought from the Respondent and affected parties before final orders are made.

[1] See Howden Insurance renewal proposal at pp370-394 of attachments to application.

[2] Schedule A to the Community Management Statement

[3] Both Interest Schedule and Contribution Schedule

[4] Section 191 of the Accommodation Module

[7] Also described as a serious question to be tried.

[8] SDW2 Pty Ltd v JLF Corporation Pty Ltd [2017] QSC 001

Australian Broadcasting Corporation v Lenah Game Meats [2001] HCA 63

[9] See Howden Insurance renewal proposal at pp370-394 of attachments to application.

[10] For example public liability, and management liability.