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AFE v Allianz Insurance Limited [2019] NSWDRS MR 192

NSW DISPUTE RESOLUTION SERVICE (NSWDRS)
Jurisdiction Merit Review Panel
Catchwords Panel Review – PAWE – weekly payments – pre-accident gross weekly earnings – pre-accident net weekly earnings – pre-accident earning capacity – earner – loss of earnings – loss of earning capacity –ATO ruling – post accident earning capacity – statutory interpretation – beneficial legislation
Legislation cited Motor Accident Injuries Act 2017 (NSW) ss 1.3(2), 1.32(a), 1.32(b), 3.6(1), 3.7(1), 3.8(1), 3.8(2), 3.22, 4.5(d), 4.6(2), 7.15(3), 7.15(4), Div 3.3, Schedule 1 Clause 3(1), Schedule 1 Clause 4, Schedule 1 Clause 7(1) & (2), Schedule 1 Clause 8(1)
Motor Accident Injuries Regulation 2017
Motor Accident Guidelines 2017 (as amended on 15 January 2019) cl 4.55, 4.56, 4.59
Cases cited

AQO v Minister for Finance and Services [2016] NSWCA 248
Bull v AG (NSW) [1913] 17 CLR 370
Cullen v Trappell (19800 146 CLR 1
Kajic v Hawker De Havilland Aerospace Pty Ltd [2009] NSW WCCPD 136
Project Blue Sky v Australian Broadcasting Authority (1998) 194 CLR 355
Thiering v Daly [2011] NSWSC 1348

Text cited N/A
Parties AFE – Claimant
Allianz Insurance Limited – Insurer 
Disclaimer This decision has been edited to remove all Unique Personal Identification including the name of the Claimant.
Note: This case is currently the subject of an appeal to the NSW Supreme Court.

Merit Review Panel Certificate

Panel Review of the Single Merit Review Decision

Certificate issued under section 7.15(4) of the Motor Accident Injuries Act 2017 (the Act)

  • The Review Panel confirms the decision of the single merit reviewer dated 26 August 2019.

Background

1.   The single merit review decision determined by Merit Reviewer Leigh Davidson on 26 August 2019 was referred to this Review Panel for determination under section 7.15(3) of the Act.

The Review Panel members confirmed that they had no previous involvement with this matter, or with the above injured person. All Review Panel members also confirmed that there was no conflict or any other reason that they would be unable to approach this review with an open mind.

2.   Review Panel Conference

An initial conference of the Review Panel was held on 13 November 2019 at 2.30pm. Merit Reviewer Terence Stern acted as the Chairperson of the Review Panel.

Merit Review Decision under Panel Review

3.   Merit Reviewer Leigh Davidson had determined the following:

1)   To set aside the decision of ER of the Insurer of 27 May 2019.

2)  To substitute in lieu:-

“The Claimant’s entitlement to weekly payments under section 3.8(2)(a) of the Act is $918.00 ($893.00 indexed) x 0.80 = $734.00.”
3)   That the effective date for the determination to take effect was the 23rd of July 2019.

Disputes identified by the Parties

4.   The Review Panel considered the Application for Review and the submissions made by each party and noted the following aspects of the single merit review decision were in question:

  • Whether the Claimant’s post 78-week entitlements should be calculated on the basis of her pre-accident gross weekly earnings or her pre-accident net weekly earnings.
  • Whether Merit Reviewer Davidson was in error in determining that the Claimant’s pre-accident earning capacity is to be calculated with regard to her gross income when he provided the following reasons:
“In coming to this conclusion, I agree with the Claimant’s submission that had Parliament intended for pre-accident earning capacity to be calculated on a net basis, it would have explicitly said so. In the absence of such direction from parliament, I consider that this determination accurately interprets the provisions of the Act and promotes the objects of the Act contained at section 1.3 of the Act.”
  • Whether Merit Reviewer Davidson was in error in arriving at this conclusion because:
“Most importantly, Schedule 1, Clause 7 of the Act is absent of any reference to net earnings or taxed income from personal exertion that the injured person had the capacity to earn before the accident. As such, I find that the Claimant’s pre-accident earning capacity is to be calculated with regard to the Claimant’s gross income.”

5.   The Review Panel considered the reply to the Application for Review and noted that:

  • The respondent opposed the application

Summary of documents considered

6.      The Review Panel members confirmed that they had received and considered the following documentation:

  • The single merit review decision issued by Merit Reviewer Leigh Davidson on 26 August 2019.
  • Application for review and attached documents
  • Reply and attached documents
  • The Statement of Reasons issued by the Proper Officer referring this matter to a Review Panel
  • All the documents which were provided to Merit Reviewer Leigh Davidson prior to the assessment under review.

Legislation and Guidelines

7.  In making our decision the Panel has considered the following legislation and guidelines:

  • Motor Accident Injuries Act 2017 (the Act)
  • Motor Accident Injuries Regulation 2017
  • The Motor Accident Guidelines 2017 (the Guidelines)
  • Caselaw as noted below.

Reasons

Matters Considered and Decided by the Review Panel

8.   The Review Panel considered afresh all aspects of the decision under review.

A.   Evidence Considered

9.   The Review Panel considered all the documentary material and did not require any additional information and evidence.

B.  Panel Deliberations

The Legislation

10.The Motor Accidents Injuries Act 2017 (“the Act”) relevantly provides (section 1.3(2)):-

“…

(a)            to encourage early and appropriate treatment and care to achieve optimum recovery of persons from injuries sustained in motor accidents and to maximise their return to work or other activities,

(b)          To provide early and ongoing financial support for persons injured in motor accidents.

(c)           To keep premiums for third-party policies affordable by ensuring that profits achieved by Insurers do not exceed the amount that is sufficient to underwrite the relevant risk and by limiting benefits payable for minor injuries.

(e) To promote competition and innovation in the  setting of premiums for third-party policies and to provide the Authority with a role to ensure the sustainability and affordability of the compulsory third-party insurance scheme and fair market practices.

(g)    to encourage the early resolution of motor accident claims and the quick, cost effective and just resolution of disputes,

… (4) In the interpretation of the provision of this Act… a construction that would promote the objects of this Act or the provision is to be preferred to a construction that would not promote those objects.”

11.   Division 3.3 of the Act provides for weekly payments of statutory benefits during 3 entitlement periods.

12.   Section 3.6(1) provides:

An earner who is injured as a result of a motor accident and suffers a total or partial loss of earnings as a result of the injury is entitled to weekly payments of statutory benefits under this section during the first entitlement period.

13.  Section 3.7(1) provides:

“An earner who is injured as a result of a motor accident and suffers a total or partial loss of earnings as a result of the injury is entitled to weekly payments of statutory benefits under this section during the second entitlement period.”

14.  Section 3.8(1) provides:

“A person who is injured as a result of a motor accident and suffers a total or partial loss of earning capacity as a result of the injury is entitled to weekly payments of statutory benefits under this section after the end of the second entitlement period, but only if the person:

(a)                is at least 18 years of age (whether or not the person is an earner), or

(b)                 is under 18 years of age and is an earner. Note : The person's age after the second entitlement period is relevant to determining entitlement to statutory benefits after the second entitlement period. A person's age at the date of the motor accident is not relevant. Schedule 1 defines when a person is an earner.

15.  Schedule 1 sets out a number of definitions relating to earnings for the purposes of weekly payments of statutory benefits under Division 3.3.

16.  In clause 3(1), “loss of earnings” is defined as:

“… a loss incurred or likely to be incurred in a person's income from personal exertion.”

17.  In clause 4, pre-accident weekly earnings are defined as:

“…the weekly average of the gross earnings received by the earner as an earner during the 12 months immediately before the day on which the motor accident occurred, unless subclause (2) applies.”

18.  In clause 7(1), pre-accident earning capacity is defined as:

“… the weekly amount a person had the capacity to earn before the motor accident concerned in employment reasonably available to the person in view of the person's training, skills and experience.”

19.  Clause 7(2) provides:

“If the amount of an injured person's pre- accident earning capacity cannot be determined, the amount is deemed to be the amount that is equal to 80% of the average weekly total earnings of adults in full-time employment in New South Wales last published by the Australian Statistician.”

20.  In clause 8(1), the meaning of “post-accident earning capacity” is defined as:

“…

(a)  for the first and second entitlement periods-- the weekly amount that the person has the capacity to earn in the employment in which the person was engaged immediately before the motor accident, determined on the basis of the person's fitness for work in that employment, or

(b)  for any period after the second entitlement period--the weekly amount the person has the capacity to earn in any employment reasonably available to the person, determined on the basis of the person's fitness for work in any such employment.”

21.  Section 4.5(d) of the Act provides:

4.5   Limits on economic loss

(1)  The only damages that may be awarded for economic loss are (subject to this Division):

(d) damages by way of re-imbursement for income tax paid or payable on statutory benefits or workers compensation benefits arising from the injury that are required to be repaid on an award of damages to which this Part applies.

22.  Section 4.6(2) of the Act provides:

4.6   Maximum for loss of earnings etc

(2)  In the case of such an award, the amount (if any) by which the injured or deceased person's net weekly earnings would (but for the injury or death) have exceeded the maximum weekly statutory benefits amount under Division 3.3 is to be disregarded (even though that maximum weekly statutory benefits amount is a maximum gross earnings amount).

The Submissions

23.  The Review Panel briefly summarises the submissions of the Review Applicant and of the Review Respondent.

Review Applicant

24.  The Review Panel briefly sets out the Insurer’s submissions at A1:

i.   The decision under review was materially incorrect/errors of law, including in the interpretation of the Act and in failing to have regard to the objective to the true objectives of the Act.

ii.   The decision was contrary to the long-standing common law principles.

iii.   Merit Reviewer Davidson was in error in setting out his reasons for his conclusions at A4. Such reasons which are set out under the heading ‘Error of Law’ are submitted to be an entirely incorrect application of the law and an implausible approach to statutory interpretation. The Insurer submits that to decide that something bears its meaning because there is nothing indicating that it means contrary, is submitted to be absurd.

iv.   The Merit Reviewer was in error in basing her presumption that “earning capacity” and “weekly earning amount” in Schedule 1 Clause 7(1) of the Act equates to “gross earning capacity” and “gross weekly amounts” because neither is explicitly referred to as to be “net of tax” was in error. There was no basis for such a presumption in the Act, nor anything in the Explanatory Note or Second Reading Speech which would justify such a conclusion.

v.   The Insurer submits that the relevant wording in sections 3.6 and 3.7 is “loss of earnings” compared to the third entitlement period where section 3.8 refers to “loss of earning capacity”. The Insurer submits that the deliberate use of the words “loss of earning capacity” were introduced by parliament to instruct that payments in the third entitlement period be made on a net basis as opposed to “earnings”.

vi.   The Insurer refers to the ATO Ruling of 30 November 2017 that payments in respect of “loss of earning capacity” have the character of capital as opposed to income, and are therefore not taxable, while payments in respect of loss of earnings have the character of income.

vii.   The Insurer submits that, if no tax is payable on weekly payments made after week 78 and Merit Review Davidson’s decision was to stand, then in the third entitlement period payments would be made based on gross pre-accident earnings, an amount which no longer would be payable as in the previous two entitlement periods, and the amount paid directly to the Claimant would actually increase.

viii.   The Insurer submits that this would be “nonsensical” because:

a.   Merit Reviewer Davidson’s interpretation of gross earning capacity is incompatible with the common law approach to assessing future incapacity. Although the common law is not determinative in respect of legislative intent, it is said to be reasonable to infer that the common law approach would be one consideration which the legislature took into account in using the language that it did.

b.   The courts in Australia have adopted the use of net after tax earnings as the most common basis for assessing future loss of earning capacity. The Insurer refers to decisions which reflect the common law intent that the purpose of compensation is to put the person in the same position as the person would have been in had the injury not happened.

c.   The Insurer refers to the decision of the High Court of Australia in Cullen v Trappell (1980) 146 CLR 1.

d.   If payments were made based on gross weekly earnings, this would create an inconsistency between section 3.6, 3.7 and 3.8 of the Act.

e.   If weekly payments in the third entitlement period are not susceptible to tax, either to the ATO or in the hands of the Claimant, continuing to make payments on a gross payment would see statutory benefits increase following the commencement of the third period creating an inconsistency between section 3.6, 3.7 and 3.8 in so far as, in the first two periods, the Claimant would receive a net amount, whereas in the third entitlement period, a gross amount.

ix.   The Insurer submits that it could not have been the intent of parliament for there to be such an inconsistency.

x.   The Insurer refers to an example of practical inconsistency if Merit Reviewer Davidson’s determination were to hold [at the bottom of page 5].

xi.   The Insurer relies on Thiering v Daly [2011] NSWSC 1348 per Garling J at [50 (g) and (f)].

xii.   The Insurer emphasises the importance of the Objects of the Act at subss 1.3(2)(a) and (g) and criticises the determination as having had only limited regard to section 33 of the Interpretation Act 1987:

“33 Regard to be had to purposes or objects of Acts and statutory rules

In the interpretation of a provision of an Act or statutory rule, a construction that would promote the purpose or object underlying the Act or statutory rule (whether or not that purpose or object is expressly stated in the Act or statutory rule or, in the case of a statutory rule, in the Act under which the rule was made) shall be preferred to a construction that would not promote that purpose or object.”

The Claimant’s Submissions

25.  I briefly summarise the Claimant’s submissions adopting the same numbers:

[5]   ATO ruling that payments for loss of earning capacity pursuant to section 3.8 are payments of a capital nature.

[6]   Questions of taxation does not arise.

[8]-[9]   Section 3.7 and 3.8 of the Act both refer to the weekly amount a person had or has the capacity to earn before and after the accident without reference to any distinction between gross or net payments.

[11]-[12]   The Insurer submits that payments are not for loss of earnings but for loss of capacity. In those circumstances, tax does not arise and the Claimant should be paid 80% of her pre-accident earning capacity which was $918.00 per week.

[13]   The Act is beneficial legislation and should be construed beneficially. If Parliament had intended payments to be subject to tax, it would have said so. There is nothing in the section, Schedule 1 or in the Explanatory Note, nor in the Second Reading Speeches, which indicates that there was an intention that tax be deducted.

[14]   The Claimant is entitled to $734.40 per week, being 80% of $918.00 and if there is any ambiguity in beneficial legislation, it should be construed beneficially – Bull v AG (NSW) [1913] 17 CLR 370.

[16]   The Bull v AG interpretation was applied in Kajic v Hawker De Havilland Aerospace Pty Ltd [2009] NSW WCCPD 136. Judge Keating said at [66]:

“In beneficial legislation where any ambiguity exists, that is to be construed beneficially. The true significance of the provision should not be strained or exceeded, but it should be construed so as to give the fullest relief which the fair reading of its language will allow.”

26.   The Merit Reviewers decision is consistent with fundamental principles of statutory interpretation discussed above. Particularly, the principles referred to below.

Statutory Interpretation

27.  McColl JA said in AQO v Minister for Finance and Services [2016] NSWCA 248 [73] that:

“The task of statutory interpretation is concerned with giving a statutory provision the meaning that the legislature is taken to have intended it to have. The exercise must begin with a consideration of the text.”

28.   McColl JA then referred to the majority in Project Blue Sky v Australian Broadcasting Authority (1998) 194 CLR 355:

“[69] The primary object of statutory construction is to construe the relevant provision so that it is consistent with the language and purpose of all the provisions of the statute. The meaning of the provision must be determined by reference to the language of the instrument viewed as a whole … [referring to Dixon CJ in the Commissioner for Railways (NSW) v Agalianos] the context, the general purpose and the policy of the provision and its consistency and fairness are surer guides to its meaning than the logic with which it is constructed. Thus the process of construction must always begin by examining the context… [70] A legislative instrument must be construed on a prima facie basis that its provisions are intended to give effect to harmonious goals. When a conflict appears to arise from the language of particular provisions, the conflict must be alleviated so far as possible by adjusting the meaning of the competing provisions to achieve that result which will best give effect to the purpose and language of those provisions while maintaining the unity of all the statutory provisions. Reconciling conflicting provisions will often require the court to determine which is the leading provision.”

29.McColl JA continued [74] that the Court was required to undertake the exercise of statutory construction with a view to promoting the purpose or object underlying the Act.

30.McColl JA continued [77]:

“The function of a definition is not to enact substantive law but to provide aid in construing the statute. Statutory definitions should be construed according to their natural and ordinary meaning without reading in limitations and qualifications unless clearly required by the terms of the definition or its context, for example, if it is necessary to give effect to the evident purpose of the Act. It is also necessary to address the language used, bearing in mind the functions which the defined terms serve in its operative provisions.”

31. At [78]:

“… Once it is clear that the definition applies, the only course is to read the words of the definition into the substantive enactment and then construe the substantive enactment, whether in its extended or confined sense, in context, and bearing in mind the purpose and the mischief that it was designed to overcome.”

32. At [79]:

“It is impermissibly circular to construe the words of the definition by reference to the term ‘defined’”.

33.   The Explanatory Memorandum states that:

“The Division provides for the variation of the rate of weekly payments during 3 entitlement periods … Weekly payments after week 78 are not available to persons until they reach the age of 18 years unless they were employed or receiving workers compensation or payments under the proposed Act in respect of loss of earnings before the motor accident.”

Consideration

34.   The Merit Review Panel firstly notes that the change in wording from “loss of earnings” in the first and second entitlement periods to “loss of earning capacity” in the third entitlement period should not be taken to have been a vagary of drafting but to be deliberate.

35.   It is reasonable to conclude that the parliamentary draftsmen must have considered the distinction and have intended to change the meaning of the different provisions.

36.   The issue is – what is the meaning of the changed words? This approach is consistent with the fundamental principle of statutory interpretation that legislative provisions are to be interpreted according to their natural and ordinary meaning [AQO v Minister for Finance and Services [2016] NSWCA 248 77].

37.   Section 3.8 provides that after the second entitlement period, weekly payments of statutory benefits are to be at the rate of 80% of the difference between the person’s pre-accident earning capacity and the person’s post-accident earning capacity (if any) after the second entitlement period.

38.   Pre and post-accident earning capacity are defined in Schedule 1. In the first two entitlement periods, an injured person is entitled to weekly benefits based on a proportion of the difference between the person’s pre-accident weekly earnings (as defined) and the person’s post-accident earning capacity. For this first 78 weeks, post- accident earning capacity is only measured by reference to the employment in which the injured person was engaged immediately before the accident (clause 8(1)(a) of Schedule 1).

39.   After 78 weeks, benefits are determined based on a proportion of the mathematical difference between the person’s pre-accident earning capacity and the post-accident earning capacity. During this entitlement period, the assessment of the injured person’s post-accident earning capacity is based on the weekly amount the person has the capacity to earn in any employment reasonably available determined on the basis of the persons fitness for work in such employment. The persons fitness for employment is determined by the method set out in clause 8(2).

40.   The assessment of the person’s pre-accident working capacity is set out in Schedule 1 clause 7 and means the weekly amount the person had the capacity to earn before the accident in employment reasonably available to the person in view of the person’s training, skills and experience.

41.   If the amount of an injured person’s pre-accident earning capacity cannot be determined, the amount is deemed to be the amount that is equal to 80% of the average weekly total earnings of adults in full-time employment in NSW, last published by the Australian Statistician.

42.   Statutory benefits after 78 weeks are intended to take into account the possibility of an increase in pre-injury earnings, taking into account changes in circumstances over the longer term.

43.   Clause 7(2) is significant in assisting the Merit Review Panel to arrive at a proper interpretation of whether the weekly statutory benefits are intended to reflect the gross or net amount.

44.   Average weekly total earnings of adults in full-time employment in NSW as last published by the Australian Statistician are expressed by the Australian Statistician as “ordinary time earnings” (“OTE”). Average weekly total earnings are calculated by the Australian Statistician as follows:

Average weekly total earnings (includes overtime) = Total taxable gross weekly earnings/ Total employees

[Australian Bureau of Statistics, ‘6302.0 – Average Weekly Earnings, Australia, May 2014: Average Weekly Earnings and Wage Price Index – What do they measure?’]

45.   Accordingly, if pre-accident earnings cannot be determined, section 3.8 requires a calculation of 80% of gross average weekly total earnings of adults in full-time employment in NSW.

46.   The Merit Review Panel considers this showed a clear intention of Parliament that the pre-accident earning capacity is to be calculated on the basis of the injured person’s pre- accident gross weekly earnings.

47.   The Merit Review Panel refers to section 3.22 – Indexation of Weekly Statutory Benefits. In subsection (2):

“NSWAWE means the amounts estimated by the Australian Statistician of the average weekly total earnings of adults in full-time employment in NSW.”

48.   The Merit Review Panel notes that the Act continues to use the said calculation with respect to determining an injured person’s future ongoing benefits in the third entitlement period and in particular in the application of indexation.

49.   Section 3.8 provides that weekly payments should be at the rate of 80% of the difference between the person's pre-accident earning capacity and the person's post-accident earning capacity (if any) after the second entitlement period.

50.   It is agreed the claimant has a total loss of earning capacity.

51.   The Review Panel considers the above interpretation of section 3.8 is consistent with sections 4.5 and 4.6(2) which deal with “damages” for economic loss, as distinct from statutory benefits. The wording of these provisions in relation to damages suggests it is intended by the Act that statutory benefits under Division 3.3 are payable on a gross earnings basis, regardless of whether they are payable under section 3.6, 3.7 or 3.8 and that an assessment based on net earnings is only relevant to an assessment of damages.

52.   The Review Panel considers that the ATO determination is problematic.

53.   The ATO has crossed over into a situation where a person is compensated by way of damages for loss of earning capacity. Conventionally, and at common law, a person does not pay tax on such damages and this has been the case for decades (refer to Cullen v Trappell [op cit].

54.   Statutory benefits are not by way of compensation for loss of earning capacity. That is a matter to be determined later if the Claimant has an action for damages at common law.

55.   Cullen v Trappell is distinguishable on the facts, as it deals with assessing damages for future economic loss in circumstances where the recipient of the damages will not be reassessed thereafter. On the other hand, an injured person being paid statutory benefits under section 3.8 remains subject to the requirements of the Act and Guidelines in relation to ongoing fitness for work (see for example Guidelines 4.55, 4.56 and 4.59). Unlike damages or compensation for loss of earning capacity, the insurer is entitled to vary, suspend or cancel payments under section 3.8 to accommodate a change in circumstances during the period in which payments are being made. The ability for payments to be varied by direct reference to a change to the claimant’s fitness for work or available employment, for example, suggests payments under section 3.8 are not capital in nature. This also gives effect to the objects of the Act, in a particular to maximise a return to work.

56.   Loss of earning capacity is only a pre-condition to the entitlement to continuation of statutory benefits after 78 weeks. Prior to the period of 78 weeks, it was sufficient that a person had in fact lost earnings which may be the result of a temporary situation but not permanent.

57.   Loss of earning capacity requires something in the order of permanence and, if that is the case, then it triggers an entitlement to a continuation of statutory benefits.

58.   The intention of section 3.8 with respect to continuation of statutory benefits after 78 weeks is to replace, substitute or supplement weekly earnings for a prescribed period which are income in nature, rather than to compensate for the loss of the injured persons ability to earn income which are generally capital in nature.

59.   Because such statutory benefits are income in nature, the Claimant will be liable for the payment of taxation to the extent that there is a tax liability.

60.   If payments in the third entitlement period were calculated on the basis of net earnings, the Claimant would be financially worse off in the third entitlement period than she was in the first and second entitlement periods. This would be inconsistent with the intention of section 3.8 which is either to maintain or increase weekly payments.

61.   The Merit Review Panel expects that those receiving payments in the third entitlement period will probably have more significant injuries and potentially be less likely to return to their pre-accident injury earnings. Providing a lesser income in the third entitlement period is arguably inconsistent with the objectives of the Act and, in particular, 1.32(a) and (b), in that payments made at 80% of the net are not likely to provide adequate financial support for people more seriously injured and less likely to get back to the work force at pre-injury hours.

62.   Section 3.8 is only inconsistent with section 3.6 and 3.7 if you accept the ATO determination. If payments made under section 3.8 are subject to income tax, the Claimant will be in the same position as she was in the first or second entitlement periods. There is no inconsistency.

63.   The Merit Review Panel considers that the Insurer is interpreting the legislation in the light of the ATO ruling, which is not law. It may or may not be incorrect, though the Merit Review Panel tends to the view that it is probably incorrect as it is getting itself mixed up with an entitlement to damages for loss of earning capacity.

64.   If the statutory benefits in the third entitlement period are taxable, then most of the Insurer’s arguments fall away.

Panel Decision

65.   In conclusion, the Merit Review Panel considers that the Merit Reviewer’s determination that the Claimant’s entitlement to weekly payments under section 3.8(2) amounts to $734.40 is correct.

Review Panel Certification

This certificate has been viewed by Merit Reviewer Terence Stern, Merit Reviewer Jeanette Woollacottt and Merit Reviewer Katherine Ruschen who have confirmed that they are in agreement.

Terence Stern

Katherine Ruschen

Jeanette Woollacottt

Merit Reviewer

Merit Reviewer

Merit Reviewer

Dispute Resolution Service

Dispute Resolution Service

Dispute Resolution Service