Honorary Justices Regulations 2024

Honorary justice is the umbrella term covering both justices of the peace (JPs) and bail justices under the Honorary Justices Act 2014. The Regulations prescribe different training and oath requirements for each. A JP’s core function is to witness documents, administer oaths, and certify copies; a bail justice has additional powers concerning bail applications, arrest warrants, and emergency orders under various Acts. The Regulations do not define these functions further but refer to them as a criterion for the Secretary when approving training courses (regulations 6(1), 8(1), 9(1), 12(1), 13(1) and (3)). The concept of “prescribed training” is central: the Regulations do not specify the curriculum, duration, or assessment method for any course. Instead they leave it to the Secretary to approve a course (or multiple courses) from time to time. That means the substantive requirements to become or remain a JP or bail justice can change administratively without amending the Regulations. The training is a condition for appointment under sections 7(2)(d)(i) (JP) and 14(2)(e)(i) (bail justice) and for re-appointment under section 15(2)(d)(i) (bail justice), so the Secretary effectively controls who can become an honorary justice. This creates a gatekeeping power with no statutory criteria beyond “having regard to the duties and functions”.

Oath or affirmation of office is a formal declaration required before appointment. Schedule 1 provides two alternatives: a religious oath (with reference to Almighty God or a named god) and a secular affirmation. The wording differs slightly between JP and bail justice; the bail justice version includes the phrase “do equal justice to all persons”. The oath must be administered by a magistrate, who must then send a certificate to the Secretary (regulations 7(2) and 10(2)). This requirement is a one-time event, but it is a prerequisite to appointment or, in the case of ex-officio bail justices, to the exercise of powers (see section 18(2)(b) of the Act). The concept of “prescribed office” (regulation 11) is another key concept: certain public servants automatically become bail justices without the normal appointment process. They are not volunteers; their bail justice status is an incident of their employment grade and duties. However, they must still complete the prescribed training and take the oath or affirmation to be able to exercise bail justice powers. That means a person who holds a prescribed office does not automatically have the powers; they must satisfy those conditions first.

Code of conduct is set out in Schedule 2 and is binding on all honorary justices (regulation 14). It covers conduct (must discharge duties courteously and lawfully, must not bring office into disrepute, must not provide legal advice, must not administer oaths if doubts about competency), conflicts of interest (must disclose and refrain), competency and knowledge (must maintain knowledge of applicable laws), privacy (must not use or disclose information obtained in the course of functions except as authorised), reasonably active and reasonably available (must not unreasonably refuse to perform duties), provision of information for the JP directory (JPs must provide name, suburb, hours, and a contact number unless exceptional circumstances), and use of titles (must not use “JP” or “BJ” to advance business or personal interests). The code creates binding obligations and breaches may be grounds for removal. It also incorporates by reference the Act and regulations.

Professional development is a continuing obligation. Regulation 13 allows the Secretary to approve courses of training or professional development for both JPs and bail justices. This is distinct from initial appointment training. Section 23(1)(a) of the Act requires honorary justices to undertake such training or development as prescribed. The Regulations thus give the Secretary ongoing control over the knowledge refresh requirements. Failure to complete approved professional development could lead to removal under the Act (contravention of a condition of appointment), though the Regulations do not spell that out directly. The concept of “reasonably active and reasonably available” in the code (paragraphs 12 and 13) reinforces that honorary justices are expected to perform their functions when capable. For JPs, this includes a positive duty to provide directory information unless exceptional circumstances justify withholding it. That is a privacy intrusion for volunteers, and “exceptional circumstances” is not defined.

The Regulations directly affect three groups: persons who hold or seek to hold the office of justice of the peace, persons who hold or seek to hold the office of bail justice, and holders of prescribed offices (certain public servants in the Victorian public service at Grade 3-6 levels performing specified duties). Persons seeking appointment as a JP must complete an approved training course (regulation 6), take the oath or affirmation before a magistrate (regulation 7), and thereafter comply with the code of conduct and any professional development requirements (regulation 13). Existing JPs are affected by the continuing professional development requirements and the binding code, which may oblige them to change their practices (e.g., they must not administer an oath if they doubt the person’s competency, and they must not unreasonably refuse duties). They also must provide directory information unless exceptional circumstances apply. This affects a JP’s privacy: their name, suburb, hours, and phone number will be published on the Department’s public internet and telephone directory. For a person who wishes to keep their JP role separate from their private life or who is concerned about safety, the “exceptional circumstances” carve-out is vague and may be strictly interpreted by the Secretary.

Bail justice applicants face similar requirements: prescribed training (regulation 8), oath or affirmation (regulation 10), and ongoing professional development (regulation 13(3) and (4)). For those who are already bail justices by virtue of holding a prescribed office under section 18(1) of the Act, the Regulations impose training and oath conditions (regulations 10 and 12). These ex-officio bail justices are not volunteers; they are public servants whose job already includes duties such as registrar of the Magistrates’ Court or associate to a judge. The Regulations require them to complete a training course approved by the Secretary and to take the oath or affirmation before a magistrate, otherwise they cannot exercise the powers of a bail justice. That could be a significant compliance burden for a person whose day-to-day work already involves court functions. They may need to attend a separate training programme and find time to appear before a magistrate, both of which consume time and public resources.

The Secretary of the Department of Justice and Community Safety is the key administrator: approves training courses, receives certificates of oath administration, and receives directory information. Magistrates are also affected because they are required to administer the oath or affirmation and forward a certificate. This is an additional administrative task for magistrates, who are already under workload pressure. The Regulations do not provide a fee for this service; it is presumably done in the course of magisterial duties. Members of the public who use JP services are indirectly affected because the code of conduct (paragraph 13) aims to make JPs more locatable through the public directory. However, the directory only includes JPs who have provided information; the code does not require bail justices to be listed, only JPs. The public also gains or loses depending on the quality of training and the ethical standards enforced through the code.

The broader public interest is affected by the risk that the Secretary’s training approval discretion may be exercised inconsistently, making it harder for some volunteers to qualify while others find it easy. There is no cost-recovery mechanism in the Regulations, but training courses may be provided by the Department or external providers. If the Department chooses to charge fees for training, that could deter some potential applicants. The Regulations do not address that. Overall, the Regulations increase the administrative apparatus around honorary justices without any obvious reduction in the compliance burden on volunteers. The effect on private enterprise is negligible, but the restriction on using the JP or BJ title to advance commercial or personal interests (code paragraph 14) directly limits how honorary justices can use their official status. That is appropriate to prevent fraud or misleading conduct, but it also prevents a business from advertising that a JP works on the premises as a point of differentiation, which could be a small restriction on commercial speech.

The Regulations impose several duties on honorary justices and applicants, and grant certain rights, though the rights are largely procedural. The key duties are as follows.

Duty to complete prescribed training. An applicant for appointment as a JP or bail justice must complete a course approved by the Secretary (regulations 6 and 8). A bail justice seeking re-appointment must complete a further prescribed training course (regulation 9). An ex-officio bail justice (prescribed office holder) must complete a prescribed training course before exercising powers (regulation 12). All honorary justices must also undertake prescribed training or professional development (regulation 13) as a condition of continuing in office under section 23(1)(a) of the Act.

Duty to take oath or affirmation. Each honorary justice must take an oath or affirmation in the form set out in Schedule 1, administered by a magistrate (regulations 7 and 10). The magistrate must then forward a certificate to the Secretary. This is a one-time duty but must occur before appointment or, for ex-officio bail justices, before exercising powers.

Duty to comply with the code of conduct. The code in Schedule 2 is binding (regulation 14). It requires honorary justices to act courteously, lawfully, impartially, with integrity, and without discrimination. They must not provide legal advice in their capacity as an honorary justice, must not improperly influence anyone, must not administer an oath if they doubt the person’s legal or mental competence, must disclose conflicts of interest and refrain from acting where a conflict exists, must maintain knowledge of applicable laws, must not misuse information obtained in the course of duties, must not unreasonably refuse to perform duties, and must not use the title to advance business or commercial interests. For JPs only, there is a duty to provide name, suburb, hours, and contact telephone number for the public directory unless exceptional circumstances exist (code paragraph 13). The code does not specify what constitutes exceptional circumstances, nor who decides. It also does not provide a mechanism for requesting an exemption.

Duty to be reasonably active and available. Code paragraph 12 prohibits an honorary justice from unreasonably refusing to perform duties if they are capable. This goes beyond the Act’s general availability and activity requirements in section 24. The word “unreasonably” imports an objective standard, which may be tested in a removal proceeding.

Rights. The main right conferred by the Regulations is the right to make a secular affirmation instead of a religious oath. Schedule 1 provides alternative forms, giving effect to the statutory recognition of secular belief. The Regulations also give applicants and holders a right to have the Secretary approve a training course “having regard to the duties and functions” - but this is a weak right because the Secretary retains discretion and there is no right to a particular course. There is a right to a certificate from the magistrate that the oath was administered, since the Regulations require the magistrate to forward it, but the Regulations do not give the honorary justice a private right to demand that certificate. In practice, the certificate may be needed to prove eligibility. The directory listing for JPs is both a duty to provide information and a right to be listed (the code does not say the Secretary can refuse to list a JP who provides the information). However, the Secretary controls the directory and could potentially omit entries without recourse.

The duties under the Regulations are enforceable only through the Act’s removal process or, for the code, through the Secretary’s decision to initiate removal proceedings. There is no civil penalty or criminal offence created by the Regulations themselves; the parent Act provides for removal on grounds including breach of a condition of appointment or misconduct. The Regulations thus create the conditions under which appointment can be terminated, but the actual enforcement mechanism is elsewhere.

The Regulations themselves do not create any direct penalties, fines, or criminal offences. Instead, enforcement operates through the Honorary Justices Act 2014. Regulation 14 incorporates the code of conduct by reference, and the code’s introduction (paragraph 2) states that a contravention may constitute grounds for removal from office. Section 25 of the Act requires the Governor in Council to make a code of conduct and provides that contravention may be a ground for removal under section 31 (removal by the Governor in Council on the recommendation of the Minister). The Regulations do not specify any other enforcement mechanism, such as reprimand, suspension, or monetary penalty. The only stated consequence is removal from office.

Because the Regulations make the code binding, a failure to comply with any provision of Schedule 2 could potentially lead to removal. That includes relatively subjective obligations, such as “act, and be seen to act, with due care, diligence, honesty, integrity, respect, independence, impartiality and without prejudice or discrimination” (code paragraph 5). The phrase “be seen to act” introduces a perception test that may be difficult for an honorary justice to challenge. Similarly, failing to maintain “a competent knowledge of all laws applicable” (paragraph 10) is an ongoing duty that could be enforced through a review of competence by the Secretary. If an honorary justice is found to lack competence, that could be a ground for removal. The code does not contain any procedural safeguards, such as a warning or opportunity to remedy before removal proceedings commence. The Act may provide due process protections, but the Regulations do not.

The Secretary’s role in approving training courses also creates an indirect enforcement lever. If the Secretary decides that a particular training course is not completed or that a professional development requirement has not been met, that could lead to the honorary justice not being reappointed or being considered in breach of a condition of appointment. There is no merits review or appeal mechanism in the Regulations; the only avenue would be judicial review under the Victorian Civil and Administrative Tribunal Act 1998 or common law for jurisdictional error. The Regulations also do not prescribe any record-keeping obligations for the Secretary, so an honorary justice may have difficulty proving compliance if the Secretary fails to maintain records.

Enforcement of the directory provision (code paragraph 13) is uncertain. If a JP does not provide the required information, that is a breach of the code, but is it a “contravention” that can lead to removal? The code says “must provide”, but there is no time limit or process for requesting compliance. The “exceptional circumstances” exception may be interpreted broadly or narrowly, and the Regulations give no guidance. Similarly, refusing to perform duties (code paragraph 12) is a breach, but what constitutes an unreasonable refusal is not defined. The high degree of subjectivity in many code obligations means that removal decisions could be arbitrary or inconsistent. That creates legal risk for honorary justices who may be removed for conduct that would not have been considered misconduct under a clearer standard. Given that honorary justices receive no remuneration, the deterrent effect of removal is primarily loss of status and any associated privileges (such as identity verification benefits). The actual enforcement risk is low for most compliance matters, but the ambiguity itself imposes a psychological burden.

The Regulations are subordinate legislation made under section 49 of the Honorary Justices Act 2014. That parent Act provides the framework for appointment, removal, powers, and obligations. The Regulations fill in details that the Act leaves to prescription: training courses, oath forms, offices that confer bail justice status, and the code of conduct. Section 25 of the Act requires the Governor in Council to prescribe a code of conduct, and regulation 14 together with Schedule 2 satisfies that requirement. Section 7(2)(d)(i) requires an applicant for JP appointment to have completed prescribed training; regulation 6 provides that. Similarly, sections 14(2)(e)(i) and 15(2)(d)(i) require prescribed training for appointment and reappointment of bail justices; regulations 8 and 9 provide for that. Sections 16 and 18(2)(b) require the prescribed oath or affirmation for bail justices; regulation 10 and Part 2 of Schedule 1 provide that.

The Regulations also interact with the Subordinate Legislation Act 1994, which governs the making and sunsetting of statutory rules. The endnote states that the Regulations will sunset ten years after the date of making (2 July 2034). That means they have a fixed lifespan unless remade. The current Regulations replace the 2014 regulations, which sunset in 2024 (having been made on 22 July 2014). The new Regulations were made on 2 July 2024 and came into operation on 25 August 2024, ensuring continuity.

The Interpretation of Legislation Act 1984 applies to the interpretation of the Regulations. The endnotes include a note about style changes, headings, examples, and punctuation provisions of that Act. These are standard interpretive provisions and do not change substantive obligations.

The Regulations also interact with the Public Administration Act 2004 and the Victorian Public Service Enterprise Agreement because ex-officio bail justices are public servants whose salary and grade are defined by regulation 11. The Regulations require them to undertake training and oath-taking without any provision for paid time to do so. That could create tension with employment conditions if the training is not considered part of their official duties. Additionally, the code of conduct’s prohibition on using the title to advance business or commercial interests (paragraph 14) interacts with the Australian Consumer Law (as applied in Victoria) by restricting representations that could lead to misleading or deceptive conduct. A JP who advertises their services in a business context could face enforcement under both the code (leading to removal) and the Australian Consumer Law (leading to penalties). The Regulations do not provide any conflict of law mechanism, but the code would likely be read consistently with the broader law. The binding nature of the code may also interact with the Equal Opportunity Act 2010 (Vic) because the code requires impartiality and non-discrimination, which aligns with that Act’s requirements. There is no interaction with federal law except possibly through the Oaths and Affirmations Act 2018 (Cth) for federal oaths; but the Regulations are confined to state honorary justices. Overall, the Regulations are a narrow piece of delegated legislation that operate within the parent Act and standard Victorian public law.

The Honorary Justices Regulations 2024 (S.R. No. 66/2024) are a new instrument that replaces the Honorary Justices Regulations 2014 (S.R. No. 110/2014). According to endnote 2, there are no amendments made to the 2024 Regulations by statutory rules, subordinate instruments, or Acts as at the version date of 25 August 2024. The Regulations themselves have not been amended since they came into operation. The 2014 regulations were revoked by regulation 4 of the 2024 Regulations. The key change from the 2014 to 2024 version is that the training provisions now refer to the Secretary’s approval of courses rather than specifying particular courses. The 2014 regulations had a similar structure but with slightly different wording for some provisions (e.g., regulation 6 of the 2014 regulations also allowed the Secretary to approve a course of training for JPs). The 2024 regulations update the forms of oath to include the optional naming of a god or personal belief, reflecting changes in the Oaths and Affirmations Act 2018 possibly. The code of conduct appears largely the same; the 2024 version includes the directory information requirement for JPs, which may have been present in the 2014 code as well (source does not provide the old code, but the current code is identical in structure). The sunset date is ten years from the date of making, so they will expire on 2 July 2034 unless remade. There is no amendment history because the Regulations are only three months old as at the version date. Practitioners should monitor the Victorian Government Gazette and the legislation website for any amendments.

There is no litigation history directly concerning the Honorary Justices Regulations 2024. The Regulations came into force only on 25 August 2024, and as of the version date there have been no court or tribunal cases reported involving their interpretation or application. The earlier 2014 regulations may have been the subject of administrative decisions regarding training or removal, but no such cases are referenced in the source. Because the Regulations delegate significant discretion to the Secretary (especially in approving training courses and enforcing the code), it is possible that future litigation could arise on administrative law grounds. For example, a person refused approval of a training course (or denied recognition of a completed course) could seek judicial review for failure to consider relevant considerations or for unreasonableness. Similarly, an honorary justice facing removal based on a breach of the code could challenge the decision in the Supreme Court or the Victorian Civil and Administrative Tribunal if the Act provides for review (the Act may not; the Regulations do not mention any appeal right). The code’s provisions on conflicts of interest and “reasonably active” are open to different interpretations, which could lead to disputes. However, as at the version date, no such litigation has occurred. The Regulations themselves do not create a private cause of action, so any litigation would be under general administrative or public law principles.

The Regulations contain several traps for the unwary, particularly for volunteers who may not read the fine print or who rely on advice from colleagues. The first major gotcha is the discretionary power of the Secretary to approve training courses. The Regulations do not require the Secretary to publish a list of approved courses, provide reasons for refusing approval, or establish any review mechanism. An applicant who completes a course that the Secretary later decides does not satisfy the “having regard to the duties and functions” criterion could be disqualified from appointment or reappointment, with no avenue for internal review. The Regulations also do not specify a time limit for the Secretary to make a decision, so an applicant could be left in limbo.

The second gotcha is the breadth of the code of conduct. Paragraph 5 requires an honorary justice to “act, and be seen to act, with due care, diligence, honesty, integrity, respect, independence, impartiality and without prejudice or discrimination”. The phrase “be seen to act” introduces an objective appearance test that goes beyond actual conduct. If a JP attends a political rally in their personal capacity, for example, a third party might perceive a lack of impartiality. The code does not carve out personal conduct when not performing official functions, although paragraph 6 prohibits behaviour that brings the office into disrepute. That could extend to off-duty conduct on social media. An honorary justice could be removed for something they did in private life if the Secretary or the Minister considers it brings the office into disrepute. The terms “impartiality” and “without prejudice” are also undefined.

The third gotcha is the duty to provide directory information (code paragraph 13). This applies only to JPs, not to bail justices. The duty is mandatory unless “exceptional circumstances” exist. The Regulations do not define exceptional circumstances, nor do they say who decides whether the circumstances are exceptional. A JP who refuses to provide a home phone number or address (the regulation only asks for town/suburb, hours, and a telephone number, but that still discloses location and contact) risks being in breach of the code. If the Secretary takes a narrow view, almost no circumstances qualify. The directory is public on the internet, so a JP concerned about stalking or harassment may have no recourse other than not applying for appointment in the first place. The provision also creates a privacy risk without any clear benefit to the public: the hours and contact number may become obsolete quickly, but there is no obligation to update them (although failure to maintain accuracy could be a breach of the diligence requirement).

The fourth gotcha is the requirement that the oath or affirmation be administered by a magistrate. If no magistrate is available in a remote area or if a magistrate refuses to administer the oath for any reason (no statutory duty exists), the applicant cannot proceed. The Regulations do not provide an alternative, such as a commissioner for declarations or a retired magistrate. Similarly, the magistrate must forward a certificate to the Secretary. If the magistrate loses the certificate or delays, the applicant may not receive confirmation. The applicant has no right to demand a certificate; the duty is on the magistrate to forward it. The Regulations do not specify what happens if the certificate is lost; presumably the appointment cannot be finalised.

The fifth gotcha is the conflict of interest provision (code paragraph 9). An honorary justice must disclose an actual or potential conflict and must not exercise powers where there is such a conflict. This is framed absolutely: “must not exercise the powers of an honorary justice where there is such a conflict of interest.” There is no de minimis exception. A JP who is asked to witness a document for a family member or a client of their business is prohibited from doing so, even if the conflict is trivial and could be managed by disclosure. The absolute bar may be overly restrictive and difficult to comply with in small communities where the JP knows everyone. The code does not provide a mechanism for managing conflicts, such as with a waiver or independent oversight.

The sixth gotcha is the prohibition on providing legal advice in the capacity as an honorary justice (code paragraph 7(b)). This is straightforward, but the line between legal information and legal advice is often blurry. An honorary justice who explains the effect of an affidavit may be accused of giving legal advice. The code does not include a safe harbour for providing neutral information about court procedures or common document requirements. Similarly, the prohibition on “improperly influence[ing] or attempt[ing] to influence a person” (paragraph 7(c)) is vague; “improperly” is not defined.

The seventh gotcha is the professional development requirement (regulation 13). The Secretary may approve a course of training or professional development. The Regulations do not specify how often the professional development must be undertaken, what happens if it is not completed, or whether there is a grace period. An honorary justice who fails to complete the required professional development could be considered in breach of a condition of appointment under section 23 of the Act, potentially leading to removal. Without a clear schedule, an unwary honorary justice may let the requirement lapse and only discover the problem when seeking reappointment or when a complaint is made.

Compliance with the Honorary Justices Regulations 2024 requires attention to initial appointment and ongoing obligations.

For initial appointment as a JP or bail justice. First, identify a training course approved by the Secretary under regulation 6 (JP) or regulation 8 (bail justice). The Department of Justice and Community Safety should publish information on approved courses; check the Department’s website or contact the Secretary’s office. Do not assume that any generic court training or online course counts; it must be specifically approved. Complete the course satisfactorily and obtain evidence of completion (certificate or transcript). Second, arrange to take the oath or affirmation before a magistrate. Contact the local Magistrates’ Court or a magistrate directly. The magistrate must administer the oath in the form set out in Schedule 1. The JP’s oath (Part 1) refers to discharging duties according to law without fear, favour, or affection; the bail justice’s oath (Part 2) adds doing equal justice to all persons. The magistrate will then forward a certificate to the Secretary. The applicant should also request a copy of the certificate for their own records, even though the Regulations do not require the magistrate to give one to the applicant. Third, ensure that all documentation (training certificate, certificate of oath administration) reaches the Secretary so that the appointment can be processed under the Act. Keep copies.

For re-appointment of a bail justice. Complete a prescribed training course for re-appointment approved under regulation 9. The Act (section 15) sets out conditions for reappointment, and the Regulations supply the training requirement. The same process as above applies.

For ex-officio bail justices (prescribed office holders). If you hold a Grade 3 to Grade 6 public service position performing duties as prothonotary, registrar, principal registrar, or associate to a judge, you are a bail justice by virtue of office under section 18(1) of the Act, but you cannot exercise the powers until you complete the prescribed training under regulation 12 and take the oath or affirmation under regulation 10 (which refers to sections 16 and 18(2)(b) of the Act). Identify the approved training course (likely similar to that for appointed bail justices) and complete it. Then arrange for a magistrate to administer the oath or affirmation in the form set out in Part 2 of Schedule 1. The magistrate forwards a certificate to the Secretary. Keep records.

Ongoing compliance for all honorary justices. Maintain a competent knowledge of applicable laws (code paragraph 10). Undertake any prescribed professional development under regulation 13. The Secretary may approve courses from time to time; check for notices. If no courses are approved, there is no obligation, but the obligation arises once courses are approved. Comply with the code of conduct at all times. Particularly:

• Act courteously, timely, lawfully, and to the best of your ability (paragraph 4).
• Act with integrity, impartiality, and without discrimination (paragraph 5). Avoid any behaviour that could bring the office into disrepute (paragraph 6). Be cautious about personal conduct that could be linked to your honorary justice role.
• Do not purport to hold powers beyond those conferred, do not provide legal advice in your honorary capacity, and do not improperly influence anyone (paragraph 7).
• Before administering an oath or witnessing a document, confirm that the person is legally and mentally competent; if you have reasonable doubt, refuse (paragraph 8).
• Disclose any actual or potential conflict of interest and do not exercise powers if a conflict exists (paragraph 9). Err on the side of recusal.
• Protect information obtained in the course of duties; do not use it for any other purpose unless authorised by law (paragraph 11).
• Do not unreasonably refuse to perform duties if you are capable (paragraph 12). If you cannot perform a particular duty, document the reason to show it was reasonable.
• For JPs: provide your name, town/suburb, hours of availability, and a contact telephone number to the Secretary for publication on the public JP directory. If you believe exceptional circumstances justify withholding this information, seek legal advice and document the reasons. There is no prescribed form; comply in writing.
• Do not use the title “JP” or “BJ” to advertise or advance business or commercial interests (paragraph 14). Remove any use of the title from business cards, websites, or advertisements that could be seen as advancing a commercial interest.

Record-keeping. Keep copies of training certificates, professional development completions, any conflict disclosures, and correspondence with the Secretary. There is no statutory limitation period, but given the sunset in 2034, retain records until after any potential removal proceeding or until you cease to hold office. Note that the code requires maintaining competent knowledge, which may involve self-directed study; keep a log.

If a dispute arises. The Regulations do not provide an internal review process. If the Secretary rejects a training course or initiates removal proceedings, seek legal advice promptly. Judicial review may be available in the Supreme Court. The Victorian Civil and Administrative Tribunal may have jurisdiction under the Act; check. Do not simply ignore a notice from the Secretary.