BUDAVARI, Ms Rosemary Margaret, Co-Director, Criminal Law and Human Rights, Law Council of Australia

Committee met at 16 : 12

CHAIR ( Mr Melham ): I declare open this hearing of the Parliamentary Joint Committee on Australia's Immigration Detention Network. I welcome our first witness today, Ms Rosemary Budavari, representing the Law Council of Australia. The committee has received your submission. I now invite you to make an opening statement, after which committee members will ask questions.

Ms Budavari : Thank you, Chair. The Law Council is the peak body for over 56,000 Australian lawyers, and has a longstanding interest in Australia's migration laws. It has opposed mandatory immigration detention since it was introduced. The Law Council's written submission makes a number of recommendations relating to the repeal of provisions concerning mandatory detention, and the enactment of provisions for detention only as a last resort for the purposes of health, identity and security checks. Our submission also recommends the enactment of provisions imposing time limits on detention and the enactment of provisions providing for judicial oversight. The Law Council's written submission also relates to the repeal of provisions that prevent offshore entry persons making applications for protection visas without the exercise of ministerial discretion and to the discontinuing of the separate process now known as the protection obligations determination process. The Law Council's written submission recommends the enactment of provisions to ensure that no children are held in immigration detention facilities, the enactment of provisions providing clear standards for the operation of immigration detention facilities and the treatment of detainees, and the implementation of new directions in detention policy. The Law Council's submission also recommends that this committee consider the community assessment and placement model, developed by the International Detention Coalition, and the use of bridging visas as an alternative to mandatory immigration detention. The submission also addresses limiting the exercise of ministerial discretion in relation to character grounds for refusing or cancelling visas.

Similar recommendations have been made by others in written submissions, and the Law Council is aware that this committee has already heard evidence from a number of witnesses in relation to these issues. Therefore, the Law Council wishes to focus today on another major issue raised in its written submission and on which the committee has heard evidence in Darwin and Sydney. That issue is access to legal assistance for detainees. As outlined in the Law Council's submission, migration law is highly complex and inherently difficult for people, particularly vulnerable people, to understand without professional legal and migration advice. The Law Council has strong concerns that many detainees are unable to obtain timely assistance in order to fully understand their legal rights and the process to which they will be subject. This lack of assistance is not only having an impact on their rights but also exacerbating delays in visa processing, increasing pressure on the courts and increasing costs to the community. The Law Council has advocated over many years for the provision of legal assistance at all stages of the resolution of people's immigration status and particularly in relation to judicial review.

Most recently, following the November 2010 High Court decision in the M61 case, which found that offshore entry detainees had the right to seek judicial review, the Law Council raised the issue of legal assistance, for such persons in particular, with a number of people. It was raised, firstly, with Professor John McMillan, who was appointed by the government on 7 January 2011 to report on options for enhancing the efficiency and minimising the duration of judicial review proceedings for offshore entry persons. The Law Council met with Professor McMillan and asked him to consider the need for increased resources for legal aid commissions and community legal centres to provide assistance to these applicants and to provide community legal education sessions and materials to them. The Law Council asked Professor McMillan to consider how detainees would access relevant court forms and how they would access the internet, email, printers and faxes to file and serve court documents, and to examine the access by detainees to videoconferencing facilities. The Law Council also asked him to consider having an immigration application advice and assistance scheme, or IAAAS, agent at the initial screening interviews with detainees and the same agent attending interviews with the detainee for the protection obligations evaluation, previously known as refugee status assessment, and the independent protection assessment, previously known as independent merits review. The Law Council also raised concerns about that agent and I observe that many of these agents are lawyers having sufficient time to obtain instructions from the detainee and having access to sufficient material before their interview with the detainee. The Law Council also wrote to the minister for immigration on 4 February 2011 and raised concerns about legal assistance for offshore entry persons seeking judicial review and the likely increase in the demand for such assistance following the High Court case. We specifically asked for additional funding for legal aid commissions in that letter and copied the letter to the Attorney-General.

Further, we wrote to the minister for immigration and the Attorney again on 8 April and confirmed that we were receiving reports of increasing demand for legal assistance for these applicants and increasing applications in the Federal Magistrates Court. Some community organisations and pro bono lawyers reported to us that they were overwhelmed with the demand. The Law Council on this occasion asked about the availability of the McMillan report, which the department of immigration had committed to releasing publicly. We also asked about the appointment of two additional federal magistrates to assist with the increased demand for judicial review, which was announced by the government on 7 January 2011.

In April, the minister for immigration replied advising that Professor McMillan would be considering the provision of guidance to appellants and that that might include legal representation or other legal services. The minister advised that legal aid funding was a matter for attorneys-general but he referred to an increase of $154 million over four years, which had been made available to that sector in 2010. However, I observe that the Law Council has raised the inadequacy of this increase for general legal aid provision on numerous occasions.

In June, the minister for immigration also advised that he had only recently received the McMillan report and would respond publicly when the government had had the opportunity to consider its recommendations in full. The Law Council is not aware of the report having been released and suggests that this is a matter the committee could take up with the department of immigration, which had committed to publicly release it.

In June 2011, the Attorney also advised that the appointment of the two additional federal magistrates was a 2011-12 budget measure and the appointments would be made early in this financial year. The Law Council is not aware of these appointments having been made and suggests that this is also a matter the committee may wish to take up with the Attorney-General's Department. The Attorney, in that correspondence, confirmed there was no provision for additional funding for legal assistance in immigration matters in the 2011-12 budget.

The Law Council observes that the following submissions have raised the issue of legal assistance for detainees and the difficulties of access to legal assistance in immigration detention facilities: the Australian Human Rights Commission; Balmain for Refugees; the Commonwealth Ombudsman; National Legal Aid; Northern Territory Legal Aid; the Public Interest Law Clearing House, New South Wales and Victoria; Refugee Advice and Casework Service, Refugee and Immigration Legal Service and the Refugee Council of Australia.

The following types of references are made in these submissions: we are struggling to provide the required assistance; there is no active assistance by DIAC to refer asylum seekers for advice on judicial review; the ongoing movement of people throughout the immigration detention network poses challenges to the provision of legal assistance and to the conduct of legal proceedings; access to clients for legal purposes is poor and worsening; interpreters are not readily available; access to legal aid, even for meritorious cases, is patchy; it is significantly harder for detainees in remote centres to access legal representation; the locations and sizes of detention centres have resulted in disproportionate applications for legal aid assistance across states; due to lack of resources, some state legal aid offices are no longer taking applications for judicial review from irregular maritime arrivals; communication between migration agents and clients is inhibited by a lack of infrastructure; and it is expensive, time-consuming and difficult to travel to most of the immigration detention centres, which means that lawyers find it difficult to have any face-to-face contact with clients. Compounding this lack of direct access is the absence of consistent protocols between centres for contacting people by phone. Only one immigration detention centre has a videoconference link facility.

There is a significant need to provide information sessions and take instructions from people who hold the right to judicial review. DIAC materials and fact sheets should be distributed in relevant languages and DIAC letters should be sent in relevant languages, not just English. DIAC case managers should be educated about judicial review. Claimants report that insufficient time was given to them to discuss their claim. They report a lack of continuity in lawyers or agents assisting them. It is observed that it is not the role of IAAAS providers to refer an individual to another legal provider if judicial review is an option. Given that there are strict limits for applications—namely, 35 days—it is not known how many people miss out simply because no agency has a formal responsibility to refer them on. The Law Council submits that this committee should make recommendations in relation to these types of matters and particularly recommend that the government increase resources for legal assistance to detainees.

That concludes the opening statement. I am happy to take questions.

Senator HANSON-YOUNG: Thank you very much for your submission. I just want to pick up on a number of issues you raised in the conclusion, which I guess I read as relating directly to recommendations. Firstly, I want to ask about point (d), 'repealing provisions relating to offshore entry persons being unable to make applications for protection visas without the Minister exercising a discretion allowing them to do so and discontinuing the separate POD process'. What is the effect of these provisions at the moment, given the decision by the High Court last year?

Ms Budavari : The provisions that relate to the initial part of the POD process are still in operation. They are not affected by that decision. The decision affects the rights of people once that process has concluded and they have been found not to be owed protection by Australia.

Senator HANSON-YOUNG: But couldn't you argue that effectively there is not a material difference in the end result?

Ms Budavari : There are a number of material differences. One is that if people are going through the onshore process then they have the right to go to the Refugee Review Tribunal rather than an independent assessor who is contracted to the department to provide that service.

Senator HANSON-YOUNG: So it is still very much a two-class system.

Ms Budavari : Yes.

Senator HANSON-YOUNG: If that provision was repealed, and people still arrived at Christmas Island as the closest point, how long would you foresee them having to be there before they were transferred to the mainland to enable all the other processes to start? Could it be done there?

Ms Budavari : The time period is something that the department would be able to give you a better idea of. We are also arguing for a time limit on detention. A number of submitters have said 30 days; some people say 60 days. All we are saying is that there needs to be a time limit, because at the moment it is arguably indefinite, and that is a breach of Australia's obligations.

Senator HANSON-YOUNG: Is that regardless of whether that is on Christmas Island as an offshore entry point or on the mainland?

Ms Budavari : Yes.

Senator HANSON-YOUNG: I guess the 30-day time limit relates directly to point (b) of your conclusion. It is arguing that detention is only used for health, security and identity checks. Is that correct?

Ms Budavari : Yes.

Senator HANSON-YOUNG: So it is not for the processing of people's applications?

Ms Budavari : No.

Senator HANSON-YOUNG: Should that length of time be open to judicial review or some type of review mechanism?

Ms Budavari : The Law Council has always argued that detention should be subject to judicial oversight. Many years ago it was, but that was many years ago.

Senator HANSON-YOUNG: Your submission states:

(c) enact provisions to ensure that other non-citizens, who present unacceptable risks to the community and who have repeatedly refused to comply with visa conditions are only detained as a last resort ...

Who do you foresee being in that 'other' category?

Ms Budavari : There are people who come to Australia on visas and overstay visas and people who come on a visa and then undertake an activity that they are not entitled to in relation to that type of visa.

Senator HANSON-YOUNG: So you are not talking about crew who come on the boats, for example, who obviously do not have visas either?

Ms Budavari : The crew would be charged with criminal offences in most instances, unless they are juveniles, so there is a whole separate process that deals with those people.

Senator HANSON-YOUNG: In terms of the concerns you raised about access to facilities, being able to give appropriate legal advice and assistance to help people, I would argue that, if there were time limits on detention and the detention was not being used for the application process for a protection visa, those issues would be overcome. How do your members and the different firms associated with you deal with issues such as how far away places are, how remote the locations are and having access to interpreters? Are these things built into the fee that is paid by the Commonwealth? At what point are individuals, firms or associations paying these things themselves?

Ms Budavari : I probably cannot answer that question categorically, but I can make a few observations. One is that a large amount of this work is being done pro bono, including by some of Australia's leading law firms, and people are obviously giving of their own time, their skills and in some instances paying their own way to and from Christmas Island or to and from remote locations in Australia to interview these people. As far as I know, those additional expenses are not factored into the IAAAS service.

The initial observation you made about if people are only held in immigration detention centres for a short period of time for these purposes might obviate that problem about lawyers not having appropriate access to people and not being in a position to advise them properly may be true to a certain extent but for a long period of time the Law Council has also argued that lawyers should be able to be present at the initial screening interview with asylum seekers. That has not been acceded to and it is still a live concern. So even if people are just in immigration detention for a short period our argument would be that they actually need legal advice completely upfront because that legal advice may well determine what types of matters they disclose to the departmental officer who interviews them in the first instance. That may very well affect the complete outcome of their claim.

Senator HANSON-YOUNG: Just so we are all very clear and for the purposes of the report, at what point is a lawyer engaged officially?

Ms Budavari : My understanding is that the lawyer is engaged after that initial screening interview and when the detainee requests some assistance under the IAAAS.

Senator HANSON-YOUNG: Can the Law Council be confident that everybody who needs legal assistance has access to legal assistance?

Ms Budavari : No, we are not confident of that and that is why we have raised these concerns with the committee and with the government on several occasions.

Senator HANSON-YOUNG: What about the impact on unaccompanied minors? This is a question that I keep struggling to grapple with. Because there is no trigger for a legal representative to be at those initial entry interviews, you have a situation where an unaccompanied minor has no-one present who is able to advocate for them legally. That, of course, is in conflict with the person who is interviewing them being an employee of their legal guardian, the minister.

Ms Budavari : Yes. For a long period of time, the Law Council has argued that there is a conflict of interest for the minister in being both the guardian of unaccompanied minors and the decision maker. We have called for change in that regard.

Senator HANSON-YOUNG: If it is good enough for unaccompanied minors to have legal representatives at the initial entry interview, it should be good enough for all, but even that change, I think, would go some way to dealing with concerns that young people who have no-one advocating for them are at least able to access the legal assistance that they need. I think it is astonishing. We have been to several detention centres over the last couple of months and I have met with a number of unaccompanied minors who have never spoken to a lawyer and do not know what their rights are. From a legal perspective that just flies in the face of natural justice that we have here in this country, surely.

Ms Budavari : Yes, and also a number of international conventions.

Mr MORRISON: I want to pick up something you said earlier about the number of requests you receive, particularly for pro bono support. Could you give me an idea of the volume of those requests and how you have seen that change.

Ms Budavari : Unfortunately, I cannot give you an accurate figure on the volume of the requests. I am not sure if the committee is going to take evidence from the public interest law clearing houses, but they have been performing a coordination role in relation to the pro bono services.

Mr MORRISON: Can you give me an idea of the level? Are we talking hundreds? Are we talking thousands?

Ms Budavari : I think we would be talking hundreds if not thousands.

Mr MORRISON: That is each year?

Ms Budavari : That is since the High Court decision.

Mr MORRISON: And prior to that?

Ms Budavari : Prior to that, again, what we hear is that there are many, many requests for pro bono assistance in this particular area because legal aid in this area has been quite restricted for quite some time.

Mr MORRISON: Are the requests also coming from crew who are facing criminal charges?

Ms Budavari : My understanding is that crew would generally be eligible for legal aid under legal aid criminal law guidelines.

Mr MORRISON: With this increase in the number of requests for pro bono assistance, what is the impact on the more regular caseload that pro bono lawyers would be undertaking? What are they having to say no to to say yes to this?

Ms Budavari : Again, I probably cannot give you a complete answer to that, but pro bono work occurs in all sorts of areas—civil law, criminal law, family law. Generally most firms have a limited budget; a certain percentage of their overall turnover is devoted to pro bono.

Mr MORRISON: What sorts of cases would lawyers doing these cases normally do? They would not be involved in commercial law disputes, I assume. I do not know if there would be too many requests on that front.

Ms Budavari : Or too many that would be granted.

Mr MORRISON: I am just trying to get an idea of what work those who would be doing pro bono work in this area would otherwise be doing.

Ms Budavari : There are a number of different schemes that provide assistance, for example, in victims' compensation matters, where Legal Aid commissions generally would not provide assistance. Generally, Legal Aid commissions in civil law areas are quite restricted in the assistance they provide: debt matters, minor criminal matters which might have a significant impact on someone's life—for example, if someone is at risk of homelessness as the result of a criminal conviction.

Mr MORRISON: Debt was the other one. It might be families who literally do not have the money for a lawyer to support them deal with a bank or a credit card company or a utility company.

Ms Budavari : Yes.

Mr MORRISON: Are they missing out?

Ms Budavari : Perhaps they are. You would have to ask the pro bono providers but, as I said, they generally have a limited budget and if this sort of work is eating up a proportion of that budget then what they can do in a particular year in those other areas is obviously going to be restricted.

Mr MORRISON: I appreciate that you have suggested we probably need to speak to someone else to get specifics, but when you say 'a proportion', what proportion do you think we are talking about of the budget being eaten up?

Ms Budavari : I could not answer that, I'm sorry.

Mr MORRISON: What was the level of request four years ago for pro bono work in this area?

Ms Budavari : Again, I probably can't give you an accurate answer on that. There is a national Pro Bono Resource Centre, which I don't think has made a submission to this committee, but it collects statistics on pro bono work.

Mr MORRISON: Do you expect there would have been many, given that there were only four people who arrived by boat in detention four years ago?

Ms Budavari : Perhaps not in relation to detention matters.

Senator BERNARDI: You made a mention that there was only one centre with video conferencing, which centre is that?

Ms Budavari : I think it is Christmas Island. I think they video conference to Christmas Island.

Senator BERNARDI: You know there is only one centre or is that what you have been told?

Ms Budavari : I was reading from remarks that had been made in those submissions.

Senator BERNARDI: In your submission and introductory statements there is a quote: 'there is little justification for a differential treatment of onshore asylum seekers and offshore entry persons.' There is a significant difference, though, in respect of the identification of those who have come here by plane with visas or with incorrect visas, as you said in your opening statement. Do you recognise that that is a significant difference?

Ms Budavari : Yes, I do recognise that that is a difference, but not a difference that cannot be overcome through the regular statutory process.

Senator BERNARDI: But the regular process is to identify people. People have been vetted for a visa initially when they come here. They have appropriate travel documents that we believe are legitimate versus someone who just turns up without any appropriate travel documents. There is a requirement to identify them where they pose a security risk, etcetera.

Ms Budavari : But in both instances there is a requirement for an assessment of their entitlement to protection, regardless of whether someone has got papers or not got papers.

Senator BERNARDI: But you know who someone is. That is the big difference.

Ms Budavari : Yes, you do.

Senator BERNARDI: You know who this person is. They have been approved for a visa to come into the country in the first instance versus someone you have no idea about.

Ms Budavari : But there are means of finding that out.

Senator BERNARDI: Indeed, and part of those means is an initial interview. That takes me to something else you said. You said the outcome may be different—and I don't want to put words in your mouth—if a lawyer was present at the initial interview. My initial reaction to that, and it was a bit of a bristling, was the suggestion that a legal advisor would say, 'Don't be forthcoming with the information that has been asked' or 'Don't tell the full truth' or to hide something from the inquiry. You aren't suggesting that, are you?

Ms Budavari : Senator, you would be aware that there are ethical obligations on lawyers which would prevent any of that sort of behaviour.

Senator BERNARDI: How then would you anticipate having a lawyer at the first interview would possibly change the outcome?

Ms Budavari : The lawyer could certainly advise the client about the criteria under the refugee convention and under the other conventions under which complementary protection obligations could arise in Australia towards that person. Sometimes people do not understand the types of matters that they need to bring forward to establish a well-founded fear of persecution on the grounds of religion, race, political opinion. Sometimes people do not understand the types of matters that they need to bring forward to establish a well-founded fear of persecution on the grounds of religion, race or political opinion.

Senator BERNARDI: But common sense would say that if someone has enough resources and the wherewithal to travel through a number of countries, get on a boat from Indonesia and come out here and claim asylum, and they are doing it under the guise that they are fleeing persecution or whatever their claims may be, they would be a full and complete advocate, don't you think, for the pain and trauma and potential danger that they have fled?

Ms Budavari : It is not really a matter of what I think. The reports we hear from lawyers who are out there in the field interviewing these people is that many of these people are frightened, they are vulnerable, they have been victims of torture and trauma in their own countries and they may not be in a position at the time of that initial interview to address all of the criteria under all of the conventions under which Australia may owe them protection obligations, and that they need advice at that point and sufficient time for someone to give them that advice. For example, we provide complementary protection in relation to cases of women being subject to female genital mutilation. That is an incredibly sensitive matter that a woman without advice may not disclose at that initial interview.

Senator BERNARDI: Indeed, that is a cultural issue. Senator Cash is well equipped to discuss these sorts of things and she has given a number of speeches, but that is a cultural issue. It is reprehensible. I think it is a disgraceful thing.

Senator HANSON-YOUNG: Would you give people protection?

Senator BERNARDI: It has been happening, and it has happened. If they are fleeing to avoid it, that is one case. In relation to the point I am making, it sounds like it is witness coaching almost. You are advocating that the lawyers should be coaching the detainees.

CHAIR: I do not think she said that, Senator.

Senator BERNARDI: That is what it sounds like, though.

Ms Budavari : Let me make it clear, I am not advocating that, and there are ethical obligations on lawyers which would prevent that type of behaviour. Lawyers would be subject to discipline if they engaged in that type of behaviour.

Senator BERNARDI: There is a reference that alternative places of detention may still breach Australia's international human rights obligations, depending on the facility and children's ability to access services and to play. Can you give me an example of which is the alternative places of detention or community detention arrangements you believe are in violation of human rights obligations?

Ms Budavari : Those matters are addressed probably most comprehensively by the Australian Human Rights Commission in their submission, so I would have to refer you to that. One of those places of detention that has been brought to our attention has been Construction Camp on Christmas Island. Another place is the Melbourne Immigration Transit Accommodation Centre.

Senator BERNARDI: Can you tell me what specifically about those two detention centres are the failings or breaches you are concerned about?

Ms Budavari : In relation to the Melbourne Immigration Transit Accommodation Centre, there have been questions raised by our members about the access to education provided for young people at that centre and the quality of that education.

Senator BERNARDI: They do not go out? The children do not get access to external education?

Ms Budavari : Our understanding is that the younger children do and that there are issues with the older minors being able to access year 11 and year 12, for example.

Senator BERNARDI: I am interested in this because a claim was made recently at a hearing in Adelaide that I understand—once again, I will stand corrected by the Hansard record—was in relation to senior school students, so for post-primary education—

Senator HANSON-YOUNG: Over 13.

Senator BERNARDI: Over 13? Is that about right? Whatever; they were in the senior schooling. The claim was that they did not have access to education facilities either. The department were less than forthcoming in responding to that inquiry. That is a concern in Melbourne. Is it a concern in the construction camp that you mentioned, in Christmas Island?

Ms Budavari : I think the concern about the construction camp at Christmas Island relates more to the actual physical infrastructure there and the lack of—again I would have to refer you to the Human Rights Commission report; I am really just trying to recall the details from the report.

Senator BERNARDI: What would you suggest we do with those asylum seekers who fail security checks?

Ms Budavari : This is a vexed issue that a number of other submitters have addressed. We have not particularly addressed this issue but—

Senator BERNARDI: But you are against mandatory detention.

Ms Budavari : Yes.

Senator BERNARDI: There are a number of people who are in detention not because they are not asylum seekers but because they have failed the security test.

Ms Budavari : Yes, or they have been found to be refugees but they have failed the security test.

Senator BERNARDI: Yes, and in some instances they are not able to be sent home to their mother country.

Ms Budavari : Yes.

Senator BERNARDI: What would you do with them?

Ms Budavari : There are a number of options that are on the table. One is that the committee could look at removing the current restriction for people to apply for merits review of their security assessment in the Administrative Appeals Tribunal. That restriction does not apply to Australian citizens but it does apply to noncitizens. One recommendation which has been made both by the Human Rights Commission and the Inspector-General of Intelligence and Security is that that restriction be removed, so that people can actually test the merits of that decision. Another possibility that we have looked at recently is that ASIO could be asked to review its assessments periodically. At the moment, our understanding is that, once you have an adverse ASIO assessment, you have that virtually for life. There may be information that can come to light later in the process which would justify a review of that assessment.

Senator BERNARDI: But through whatever reviews you have you would not say these people should be detained in a detention centre? Is that your position?

Ms Budavari : There are models overseas where even people in that situation can be released into the community on certain conditions.

Senator BERNARDI: Is that what the Law Society is advocating, because you are against mandatory detention? You would have everyone in the community and, even if they had failed a security assessment process, you would continue to have them in the community pending whatever appeals process there may be, for an indeterminate period?

Ms Budavari : We have not addressed that specific question.

Senator BERNARDI: No, but it is an attitudinal issue of the Law Society, I guess. I am just trying to establish whether you think there is any justification for locking people up who come here to seek asylum.

Ms Budavari : There obviously is always justification for detaining certain people who may be a national security risk, but in every circumstance like that the Law Council has always argued that the reaction needs to be proportionate to the particular threat that that person poses. So that question needs to be examined in each individual case and there needs to be provision for review of that if different circumstances come to light, or different information comes to light. At the moment, there is no opportunity for review of that assessment.

CHAIR: Would it be fair to summarise part of your submission in relation to the provision of legal assistance along the following lines: if people were legally assisted early on in the process, those lawyers following their professional obligations would be putting the case to the authorities in a professional way and there would be confidence that the case was properly presented and could be properly considered by the authorities?

Ms Budavari : Yes, and we would say that early legal advice would actually lead to cases being better presented and to better decision making in the first instance.

CHAIR: That is not unique to migration cases.

Ms Budavari : No.

CHAIR: Indeed, you represent the Law Council here this evening. I recall a saying that, 'He who represents himself has a fool for a client.' The reason I quote that is that that principle also applies to people appearing in courts of law—that they have better prospects if their case is professionally presented by a professional lawyer. What you are saying is that that principle should apply so that the cases of those who are unworthy will not succeed anyway. Someone representing themselves in such a system might not be doing themselves justice. Is that a fair summary?

Ms Budavari : Yes.

CHAIR: Thanks for your attendance. If there are any additional submissions that you want to make to the committee, please feel free to do so.

Ms Budavari : Thanks very much, senators.