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Doolan v Queensland Building and Construction Commission[2017] QCAT 58

Doolan v Queensland Building and Construction Commission[2017] QCAT 58

CITATION:

Doolan v Queensland Building and Construction Commission [2017] QCAT 58

PARTIES:

Sharon Maree Doolan

(Applicant)

v

Queensland Building and Construction Commission

(Respondent)

APPLICATION NUMBER:

GAR023-16

MATTER TYPE:

General administrative review matters

HEARING DATE:

6 February 2017

HEARD AT:

Brisbane

DECISION OF:

Member Hughes

DELIVERED ON:

28 February 2017

DELIVERED AT:

Brisbane

ORDERS MADE:

  1. The Decision of the Queensland Building and Construction Commission dated 16 December 2015 not to issue a Direction To Rectify is confirmed; and
  1. The Decision of the Queensland Building and Construction Commission dated 15 July 2016 to decline the claim under the statutory insurance scheme is confirmed.

CATCHWORDS:

PROFESSIONS AND TRADES – BUILDERS – STATUTORY POWER TO REQUIRE RECTIFICATION OF DEFECTIVE OR INCOMPLETE BUILDING WORK – HOME WARRANTY INSURANCE

STATUTORY TIME LIMIT - where statutory time limit expired – whether Tribunal can extend time – where provision has mandatory precondition to exercise of discretion – where precondition not satisfied – where Tribunal cannot extend time and application must therefore be dismissed

FAIRNESS – whether fair to give ‘Direction To Rectify’ - where cause of defect and blameworthiness of homeowner relevant

CAUSE OF DEFECT - where homeowner did not provide independent expert evidence to support claims – where one Commission expert did not attend for cross-examination – where relying upon evidence of what a party claims an expert said would be contrary to procedural fairness – where weight of evidence did not suggest that builder caused problems

BLAMEWORTHINESS – where Commission cannot give ‘Direction To Rectify’ where homeowner has not obtained relevant permission to enable compliance - where not fair to give ‘Direction To Rectify’ where homeowner did not mitigate loss - where evidence suggested homeowner at least contributed to drainage issue by not obtaining neighbour’s permission and not maintaining rubble pit to prevent it being clogged – where homeowner had duty to mitigate loss to ensure ‘Direction To Rectify’ is given in timely manner so builder can comply in timely manner – where negotiating with builder or lack of awareness of rights did not justify delay in complaint – where evidence suggested homeowner was aware or should reasonably have been aware of Commission’s existence and that it could take action – where homeowner had opportunity to obtain legal advice - where giving ‘Direction To Rectify’ after delay by homeowner who does not mitigate their loss is contrary to interests of building industry and consumers as a whole – where not fair to give ‘Direction To Rectify’ after delay – where builder cannot connect stormwater drainage without connection point – where ‘Direction To Rectify’ has no utility - where builder offered to connect stormwater drainage “free of charge” if connection point provided – where not fair to give ‘Direction To Rectify’ when no utility

HOME WARRANTY INSURANCE – where claim outside time limit – whether Tribunal should extend time – where no reasonable explanation for delay

Queensland Building and Construction Commission Act 1991 (Qld), s 3, s 72, s 72A

Queensland Civil and Administrative Tribunal Act 2009 (Qld), s 20, s 28, s 61

Brisbane South Regional Health Authority v. Taylor (1996) 186 CLR 541

Campaigntrack Victoria Pty Ltd v. The Chief Executive, Department of Justice and Attorney-General & Ors [2016] QCA 37

Dixon Projects Pty Ltd v. Queensland Building Services Authority [2009] QCCTB 2

Ireland v. Queensland Building Services Authority [1999] QBT 180

Mansoor & Rezaee v. Queensland Building Services Authority [2011] QCAT 53

O'Brien v. Gladstone Regional Council [2015] QCATA 82

Olindaridge Pty Ltd & Anor v. Tracey & Anor [2014] QCATA 207

Taouk v. Queensland Building Services Authority [2013] QCAT 508

APPEARANCES:

APPLICANT:

Ms Sharon Doolan represented herself

RESPONDENT:

Ms Jodie Stroud, Solicitor appeared for the Queensland Building and Construction Commission

REASONS FOR DECISION

What is this application about?

  1. [1]
    Sharon Doolan did not complain to the Queensland Building and Construction Commission about her drainage problem, for more than seven years after Hallmark Homes Pty Ltd completed work on her home, for more than six years after she became aware of the defect and for more than 12 months after she became aware of its recurrence.
  2. [2]
    Unfortunately for Ms Doolan, her complaint was outside the prescribed time limit to give Hallmark a ‘Direction To Rectify’[1] and outside the prescribed time limit to claim on her Home Warranty Insurance Policy.[2] The Commission decided not to give Hallmark a ‘Direction To Rectify[3] and declined Ms Doolan’s claim for insurance.[4]
  3. [3]
    Ms Doolan has applied to the Tribunal to review these decisions.[5]

Should Hallmark be given a ‘Direction To Rectify’?

Has the statutory time limit to give a ‘Direction To Rectify’ expired?

  1. [4]
    A ‘Direction To Rectify’ cannot be given more than six years and three months after building work was completed or left in an incomplete state.[6]
  2. [5]
    Because Hallmark completed the building work in or around June 2008 and Ms Doolan did not complain to the Commission until 10 December 2015,[7] a ‘Direction To Rectify’ cannot be given as it would be outside the prescribed time limit of six years and three months.  
  3. [6]
    The statutory time limit to give a ‘Direction To Rectify’ has expired.

Can the Tribunal extend the statutory time limit?

  1. [7]
    Section 72A(4) of the Queensland Building and Construction Commission Act 1991 (Qld) provides (my underlining):

72A Powers and limitations of directions to rectify or remedy

(4) A direction to rectify or remedy cannot be given more than 6 years and 3 months after the building work to which the direction relates was completed or left in an incomplete state unless the tribunal is satisfied, on application by the commission, that there is in the circumstances of a particular case sufficient reason for extending the time for giving the direction and extends the time accordingly.              

  1. [8]
    For the Tribunal to extend time to issue a ‘Direction To Rectify’, section 72A(4) requires an application by the Commission for the Tribunal to extend the time. The Commission has not so applied.
  2. [9]
    Although the Tribunal has a general discretion to extend a time limit fixed by an enabling Act,[8] the language used in section 72A(4) is mandatory: a Direction cannot be given after 6 years and 3 months unless the Commission has applied to extend time.[9] By providing a precondition to the Tribunal’s jurisdiction to extend time, the provision is substantive. As this precondition to the exercise of the Tribunal’s discretion to extend time has not been satisfied, the Tribunal has no jurisdiction to extend time.
  3. [10]
    This means that because it is more than 6 years and 3 months after the work was completed and the Tribunal cannot extend the time to give a ‘Direction To Rectify’ without application by the Commission, a ‘Direction To Rectify’ cannot be given.
  4. [11]
    Ms Doolan’s application for review the Commission’s decision not to give a ‘Direction To Rectify’ must therefore be dismissed.
  5. [12]
    However, even if Ms Doolan’s application was within time, the Tribunal does not consider it would be fair to issue a ‘Direction To Rectify’.

Is it fair to give a ‘Direction To Rectify’?

What does the Tribunal consider?

  1. [13]
    A ‘Direction To Rectify’ may not be given if, in the circumstances, it would be unfair.[10] The Commission – and the Tribunal[11] - may consider all circumstances that are reasonably relevant to decide whether to give a Direction, and is not limited to the terms of the contract.[12]
  2. [14]
    The discretion to issue a Direction is seamless and involves weighing up factors, both for and against, its exercise.[13]  The Tribunal must consider the competing interests of the parties: the cause of the defective building work and blameworthiness of the homeowner is relevant.[14]

What caused the defect?

  1. [15]
    Ms Doolan’s complaint was that her stormwater drainage does not work, leading to flooding and overflowing.[15] She claimed that Hallmark caused this because it did not construct the dwelling to local council building standards[16] and poorly constructed the stormwater drainage.[17]
  2. [16]
    To support her claims, Ms Doolan stated that - in September 2015 - she had approached “a very well respected and reputable plumbing and drainage company” to inspect the drainage,[18] and “was informed that the initial works were deficient and the quality of the work was below quality.”[19]
  3. [17]
    However, Ms Doolan did not provide or make available for cross-examination any independent expert evidence from this (unnamed) company, or any other expert to support her claims.
  4. [18]
    Similarly, the Commission procured a report from Mr Ben Theslow, licensed plumber of BT Plumbing Service following an inspection on 15 August 2016,[20] but did not make him available for cross-examination.
  5. [19]
    The Tribunal must observe procedural fairness.[21] If either party is relying upon what an expert told them, they are obliged to make that expert available for cross-examination by the other party. An expert’s assessment and methodology cannot be tested by cross-examining the party relying upon that expert: cross-examining the party could only test that person’s recollection of what the expert told the person.[22]
  6. [20]
    Relying only upon evidence of what a party claims an expert said would be contrary to procedural fairness, as it denies the other party the opportunity to cross-examine the expert who is the best and direct source of that evidence.[23]
  7. [21]
    I therefore do not admit into evidence Ms Doolan’s hearsay evidence of her plumber’s conclusions, nor do I admit into evidence Mr Theslow’s report. 
  8. [22]
    However, Mr Chris Coombes, a Technical Claims Officer who has also been a Building Inspector with the Commission, inspected the property on 11 August 2016. Although Mr Coombes considered Mr Theslow’s report in arriving at his conclusions, I am not satisfied that it tainted his evidence to the extent that it is inadmissible.
  9. [23]
    This is because Mr Coombes was able to apply his own expertise as a licensed builder by conducting his own inspection and considering the subdivision Assessment Report,[24] a letter from a nearby resident permitting access,[25] the surveyor’s drawing of the proposed subdivision prepared for the developer,[26] a letter from the certifier,[27] relevant extract from Council’s Subdivision and Development Guidelines,[28] Brisbane City Council fact sheets on connecting stormwater pipes[29] and a Google Maps search of Ms Doolan’s property.
  10. [24]
    Mr Coombes concluded:
  • The developer did not provide a stormwater connection point to Ms Doolan’s property;
  • The Builder could have only connected a stormwater drain with permission from Mrs Doolan’s neighbour;
  • Mrs Doolan did not obtain permission from the correct neighbour. Although Mrs Doolan obtained permission from a nearby resident, this related to a property two blocks uphill, unsuitable for connection; 
  • Because no stormwater connection point to the property was available, the builder constructed a rubble pit to discharge stormwater;
  • The rubble pit was an acceptable point of discharge according to council requirements when the house was built and should have worked effectively before becoming clogged with silt and roots;
  • Although the rubble pit does not comply with current council requirements because it is too close to the boundary and house, the downward slope of the block and lack of suitable connection points meant no other suitable location was available; and
  • A solution for Mrs Doolan to rectify her stormwater issue would be to obtain approval from the relevant neighbours to connect to the main.[30] 
  1. [25]
    Ms Doolan claimed that an undated Site Plan showed a connection point.[31] However, the drawer of the plan did not give evidence. Mr Coombes viewed the plan and said it did not change his opinion of no connection point. He said that when he inspected the property, he could find no evidence of any legal point of discharge.
  2. [26]
    The Tribunal is not satisfied that a stormwater connection point existed for Hallmark to access. It would not have been in Hallmark’s commercial interests to build the rubble pit if a connection point existed. Because building a rubble pit requires excavation and associated work, it would have been less cost-effective for Hallmark than simply connecting the stormwater drain to the main. The most logical explanation to build a rubble pit is no connection point.
  3. [27]
    The weight of evidence does not suggest that the builder caused the problems with stormwater drainage. Rather, without an accessible stormwater connection point or Mrs Doolan obtaining permission from the relevant neighbour, Hallmark provided an acceptable alternative solution of a rubble pit. That rubble pit provides adequate drainage if not clogged.
  4. [28]
    The Tribunal is not satisfied that Hallmark caused the drainage issue.

What is the ‘blameworthiness’ of the home owner?

  • Did the homeowner obtain neighbour permission to connect to the main and maintain the rubble pit?
  1. [29]
    The Commission cannot lawfully give a ‘Direction To Rectify’ where a homeowner has not obtained relevant permission to enable its compliance. Without Ms Doolan obtaining permission for access from the correct neighbour, complying with a ‘Direction To Rectify’ would amount to trespass.
  2. [30]
    It would also not be fair to give Hallmark a ‘Direction To Rectify’ in circumstances where Ms Doolan has not mitigated her loss. 
  3. [31]
    Unfortunately for Ms Doolan, the above evidence also suggests that she at least contributed to the drainage issue by not obtaining the relevant neighbour’s permission to access a connection point to the main and by not maintaining the rubble pit to prevent it from being clogged by roots and silt.
  • Does the homeowner’s delay make it unfair to give a ‘Direction To Rectify’?
  1. [32]
    Because the drainage issue is a ‘Category 1’ item, it may also be unfair or unreasonable to give a ‘Direction To Rectify’ if the homeowner delayed in complaining to the Commission more than three months after the defect became apparent.[32]
  2. [33]
    Hallmark completed the work in or around June 2008. Ms Doolan first notified Hallmark about her concerns by telephone on 18 November 2008 and in writing by letter dated 11 February 2009. Hallmark undertook some repairs by 6 June 2012,[33] but on September 2015 Ms Doolan notified Hallmark that the defect had recurred since November 2014.[34]
  3. [34]
    However, Ms Doolan did not complain to the Commission until 7 December 2015, more than six years after she became aware of the defect in 2008 and more than 12 months after she became aware of the defect in November 2014. Ms Doolan explained that this was because she had been negotiating a solution with Hallmark and was not aware of the Commission’s existence until September 2015.[35]
  4. [35]
    However, this contradicts Ms Doolan’s letter to Hallmark dated 17 April 2012, when she specifically foreshadowed seeking action via “BSA” (the Commission’s former title):

I would appreciate a response by your office within 14 day (sic). Then I will be seek (sic) action via BSA whom I have already contacted. They too have advised me to formally write to you.[36]

  1. [36]
    When questioned about this during the hearing, Ms Doolan said that the letter was not correct and that in fact, she had not contacted the “BSA”. Ms Doolan said that because her sister-in-law had some knowledge about these matters, she helped Ms Doolan write the letter and Ms Doolan thought “BSA” meant something else. Ms Doolan said she could not remember exactly when she first became aware of the Commission’s existence, but when pressed said it would have been in 2013 or 2014 after looking on the Internet.
  2. [37]
    The Tribunal finds that a reasonable person in Ms Doolan’s position would have known or made enquiries about the “BSA” – either via her sister-in-law or the Internet – at the time of writing the letter foreshadowing BSA action on 17 April 2012. Based on the letter and help from her sister-in-law and her access to the Internet, the Tribunal finds that Ms Doolan was aware or should reasonably have been aware of the Commission’s existence at least since April 2012.
  3. [38]
    An important premise of regulatory time limits is that people should be entitled to move on with their lives without an ongoing and indefinite threat of complaints or legal action.[37] Ms Doolan has a duty to mitigate her loss to ensure any ‘Direction To Rectify’ is given in a timely manner, so the Builder can comply in a timely manner.
  4. [39]
    Ms Doolan said the delay was because Hallmark had temporarily fixed the issue and she was still in telephone contact with Hallmark.[38] She claimed that Hallmark “dragged out the period to address the poor workmanship” to exhaust her rights to raise the matter with the Commission.[39]
  5. [40]
    However, none of this prevented Ms Doolan from complaining to the Commission. Negotiating directly with the builder or a lack of awareness of her rights did not justify Ms Doolan’s delay in making her complaint to the Commission.
  6. [41]
    If Ms Doolan felt that Hallmark was not properly addressing her concerns, she could have complained to the Commission or obtained legal advice. Ms Doolan did not do either for more than seven years after the defect first became evident and more than 12 months after its recurrence.
  7. [42]
    Ms Doolan was or should reasonably have been aware of the Commission’s existence (at least under its former name) and that it could take action since writing her letter in April 2012,[40] or even on her own evidence, since 2013 or 2014 after looking on the Internet. Ms Doolan also had an opportunity to obtain legal advice.
  8. [43]
    A ‘Direction To Rectify’ is not given solely to benefit the individual home owner, but to discharge the Commission’s statutory responsibilities to ensure proper industry standards[41] and achieve a reasonable balance between the interests of builders and consumers.[42]
  9. [44]
    Giving a ‘Direction To Rectify’ after a delay by a homeowner who does not mitigate their loss is contrary to the interests of the industry and consumers as a whole. This is because it means the burden of insuring against and responding to ongoing and indefinite complaints is inevitably passed on to other builders and home owners through higher insurance premiums and increased building costs.[43]
  10. [45]
    It would not be fair to give Hallmark a ‘Direction To Rectify’ after the delay in Ms Doolan’s complaint to the Commission.

What other circumstances are relevant?

  1. [46]
    The evidence is that without a connection point, the builder is unable to connect the stormwater drainage. This means that giving a ‘Direction To Rectify’ has no utility, as Ms Doolan has not provided a connection point.
  2. [47]
    Hallmark offered to connect Ms Doolan’s stormwater drainage “free of charge” if a connection point is provided.[44] 
  3. [48]
    The evidence suggests that a connection point can be provided with permission from the correct neighbour. This would provide an expedient and commercially viable solution at no cost to Ms Doolan or the Commission. Ms Doolan offered no evidence of attempts to obtain that permission.
  4. [49]
    It would not be fair to give Hallmark a ‘Direction To Rectify’ when it has no utility.

Should Ms Doolan’s insurance claim be approved?

Did Ms Doolan claim within time?

  1. [50]
    To claim on her Home Warranty Insurance Policy, Ms Doolan had three months from when the defect became evident.[45]
  2. [51]
    Ms Doolan first became aware of the defect in November 2008 and its recurrence in November 2014. However, she did not complain to the Commission until 10 December 2015.
  3. [52]
    This means that Ms Doolan claimed outside the time limit.

Should the Tribunal extend time?

  1. [53]
    As noted above, Ms Doolan’s explanation for the delay was that she had been negotiating a solution with Hallmark and was not aware of the Commission’s existence until September 2015.
  2. [54]
    However, the Tribunal does not consider this reasonable. For reasons previously cited,[46] the Tribunal finds that a reasonable person in Ms Doolan’s position would have known or made enquiries about the Commission at the time of writing the letter foreshadowing “BSA” action on 17 April 2012.  As the Tribunal has already noted, even on Ms Doolan’s own evidence, she was aware of the Commission’s existence since 2013 or 2014.[47]
  3. [55]
    The Tribunal therefore finds no reasonable explanation for not making the complaint until December 2015. Extending time without good reason would mean the burden of insuring against and responding to ongoing and indefinite complaints is inevitably passed on to other builders and home owners through higher insurance premiums and increased building costs.[48]
  4. [56]
    Because the Tribunal finds no reasonable explanation for the delay, it is not appropriate to extend time:

Three months, in the mind of the Tribunal, is a relatively short period for a significant defect to be notified given that failure to do so may result in the Policy expiring and the insured being denied the right to claim… the Policy states in very definite terms that the insured is not entitled to payment for loss under any section of this policy where a claim is not made within the time limits specified… any “further time” to be allowed should be of limited duration and should be allowed only for good reason.[49]

What are the ‘correct and preferable’ decisions?

  1. [57]
    The statutory time limit to give a ‘Direction To Rectify’ has expired. The Tribunal cannot extend the statutory time limit. Even if the Tribunal could extend the statutory time limit, it is not ‘fair’ to give Hallmark a ‘Direction To Rectify’.
  2. [58]
    Ms Doolan’s insurance claim is outside the time limit and because the Tribunal finds no reasonable explanation for the delay, it is not appropriate to extend time.
  3. [59]
    The ‘correct and preferable’ decisions are that:
    1. The Decision of the Queensland Building and Construction Commission dated 16 December 2015 not to issue a ‘Direction To Rectify’ is confirmed; and
    2. The Decision of the Queensland Building and Construction Commission dated 15 July 2016 to decline the claim under the statutory insurance scheme is confirmed.

Footnotes

[1]Queensland Building and Construction Commission Act 1991 (Qld), s 72A(4).

[2]Insurance Policy Conditions, Edition 7, effective 29 September 2006, Parts 2.4, 2.5.

[3]Letter QBCC to Sharon Maree Doolan dated 16 December 2015.

[4]Letter QBCC to S M Doolan dated 15 July 2016.

[5]Application to review a decision dated 13 January 2016; Tribunal Directions dated 29 November 2016, Direction 1.

[6]Queensland Building and Construction Commission Act 1991 (Qld), s 72A(4).

[7]Complaint dated 7 December 2015.

[8]Queensland Civil and Administrative Tribunal Act 2009 (Qld), s 61(1)(b).

[9]Unlike the provisions considered by the Court of Appeal in Campaigntrack Victoria Pty Ltd v. The Chief Executive, Department of Justice and Attorney-General & Ors [2016] QCA 37.

[10]Queensland Building and Construction Commission Act 1991 (Qld), s 72(5).

[11]The Tribunal’s role is to produce the correct and preferable decision by way of a fresh hearing on the merits: Queensland Civil and Administrative Tribunal Act, s 20.

[12]Queensland Building and Construction Commission Act 1991 (Qld), s 72(3).

[13]Ireland v. Queensland Building Services Authority [1999] QBT 180 at [29].

[14]Dixon Projects Pty Ltd v. Queensland Building Services Authority [2009] QCCTB 2.

[15]Complaint dated 7 December 2015.

[16]Letter Sharon Doolan to Lenette Evans dated 11 February 2009.

[17]Letter Sharon Doolan to Hallmark Homes dated 17 April 2012.

[18]Letter Sharon Doolan to Hallmark Homes dated 15 September 2015.

[19]Letter Sharon Doolan filed with the Tribunal dated 12 January 2016.

[20]Report of BT Plumbing Service dated 11 August 2016.

[21]Queensland Civil and Administrative Tribunal Act 2009 (Qld), 28(3)(a).

[22]O'Brien v. Gladstone Regional Council [2015] QCATA 82 at [13].

[23]Olindaridge Pty Ltd & Anor v. Tracey & Anor [2014] QCATA 207 at [40] to [43].

[24]Assessment Report for Reconfiguring A Lot for 1 into 2 Lot Subdivision prepared by DTS Group, Licensed Land & Engineering Surveyors, Development & Subdivisional Consultants and Town Planners dated March 2004.

[25]Letter Tony & Mary Chalmers to Brisbane City Council dated 25 February 2004.

[26]Drawing No. A3 3053 of DTS Group dated 18 March 2004.

[27]Letter Suncoast Building Approvals to Community Legal Centre dated 9 September 2016.

[28]Brisbane City Council Subdivision and Development Guidelines, Chapter 6.0 dated November 2000.

[29]Connecting your stormwater pipe to Council’s Stormwater System – Information For Neighbours; Connecting your stormwater pipe to Council’s Stormwater System – Information For Developers.

[30]Statement of Christopher Coombes sworn 3 November 2016, paragraphs 7 to 12.

[31]Hydraulic Services Stormwater Services Site Plan, undated.

[32]QBCC Rectification Of Building Work Policy.

[33]Letter Hallmark Homes to S M Doolan dated 6 June 2012.

[34]Letter Sharon Doolan to Hallmark Homes dated 15 September 2015.

[35]Letter Sharon Doolan to QBCC dated 24 June 2016.

[36]Letter Sharon Doolan to Hallmark Homes dated 17 April 2012.

[37]Review of the Limitation Of Actions Act 1974 (Qld), Report No. 53, Queensland Law Reform Commission September 1998, p 6.

[38]Letter Sharon Doolan to QBCC dated 24 June 2016.

[39]Letter Sharon Doolan filed with the Tribunal dated 12 January 2016.

[40]Letter Sharon Doolan to Hallmark Homes dated 17 April 2012.

[41]Taouk v. Queensland Building Services Authority [2013] QCAT 508 at [39].

[42]Queensland Building and Construction Commission Act 1991 (Qld), s 3(a)(ii).

[43]Review of the Limitation Of Actions Act 1974 (Qld), Report No. 53, Queensland Law Reform Commission September 1998, p 8, citing Brisbane South Regional Health Authority v. Taylor (1996) 186 CLR 541 per McHugh J at 553.

[44]Letter Hallmark Homes to Sharon Doolan dated 17 November 2015.

[45]Insurance Policy Conditions, Edition 7, effective 29 September 2006, Parts 2.4, .5.

[46]See paragraphs [33] to [42] under the heading “Does the homeowner’s delay make it unfair to give a ‘Direction To Rectify’?”.

[47]Paragraph [42].

[48]Review of the Limitation Of Actions Act 1974 (Qld), Report No. 53, Queensland Law Reform Commission September 1998, p 8, citing Brisbane South Regional Health Authority v. Taylor (1996) 186 CLR 541 per McHugh J at 553.

[49]Mansoor & Rezaee v. Queensland Building Services Authority [2011] QCAT 53 at [46] to [47].

Close

Editorial Notes

  • Published Case Name:

    Sharon Maree Doolan v Queensland Building and Construction Commission

  • Shortened Case Name:

    Doolan v Queensland Building and Construction Commission

  • MNC:

    [2017] QCAT 58

  • Court:

    QCAT

  • Judge(s):

    Member Hughes

  • Date:

    28 Feb 2017

Appeal Status

Please note, appeal data is presently unavailable for this judgment. This judgment may have been the subject of an appeal.

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