Date of decision: 4 June 2026

The Decisions Body decides that:

1. When published on the internet, licence plate of the offending vehicle, street names, and suburb be redacted.

2. The driver of the offending vehicle, ██████, on or around 6:34 pm on 2 May 2026 should receive fines for violating rr 126, 132(2), and 224 of the Road Rules 2014 (NSW).

3. The driver should receive a total fine of $1,408 and receive six demerit points.

File number: DBA26/025

Catchwords: Criminal law—Decision of if person should receive a fine—Road Rules 2014 (NSW)—Following too closely—Overtaking on double continuous dividing lines—Inappropriate use of horn—Penalty of fines—Penalty of demerit points.

Number of paragraphs: 20

Note: This copy of the Decisions Body’s reasons for decision may be subject to review to remedy typographical or grammatical errors.

REASONS FOR DECISION

AIMERSMITH DEL ATH

Background

1 This is not legal advice.

2 On 2 May 2026 at around 6:34 pm, a black 2024 Toyota Prado registered ██████ (Offending Vehicle) was observed to be driving in a matter that was contrary to the law on █████ Road and ██████ Road, █████████. The Offending Vehicle was observed to be tailgating behind the applicant’s car which was following another vehicle ahead which was driving at the posted speed limit of 50 km/h on █████ Road. The driver of the Offending Vehicle used the horn of his or her vehicle, the intention or meaning is unknown. The applicant then pulled over to let the Offending Vehicle driver past. The Offending Vehicle then proceeded to follow too closely to the vehicle in front of the applicant. All three vehicles then turned right at the roundabout. Before double solid lines became broken lines, the Offending Vehicle had overtaken the front vehicle in an aggressive manner.

Road rules

3 The relevant legislation is the Road Rules 2014 (NSW). Within the Road Rules, the following is relevant: r 126 Keeping a safe distance behind vehicles; r 132 Keeping to the left of the centre of a road or the dividing line; r 224 Using horns and similar warning devices.

Following too closely

4 I’ll deal with the offences in the order in which they are listed in the Road Rules.

5 First, I will deal with r 126.

6 Rule 126 states:

A driver must drive a sufficient distance behind a vehicle travelling in front of the driver so the driver can, if necessary, stop safely to avoid a collision with the vehicle.

7 In the evidence provided by the applicant, the Offending Driver had a gap of less than one second behind the applicant, and when the applicant pulled over, it was the same for the vehicle in front. One second is not a safe enough distance in any environment adding to the situation that the sun had already set.

8 In my opinion, the driver has violated r 126.

Overtaking on double continuous dividing lines

9 A driver must stay to the left of the dividing line unless exempted under r 134 or r 139(2) (Road Rules, r 132). Rule 134 sets out when a driver can legally cross over the dividing line. The Offending Vehicle overtook the forward vehicle was a double continuous line. Rule 134 lists many exceptions that allow drivers to cross over the dividing line. The types of dividing lines applicable for overtaking is in subrule 134(2): “… single broken dividing line only, or a broken dividing line to the left of a single continuous dividing line, or 2 parallel broken dividing lines …”. Subrule 134(2) does not list double continuous dividing lines, thus overtaking on double continuous dividing lines is an offence. In driving over the lines, the Offending Vehicle failed to keep left on a multi-lane road and that none of the exemptions in r 130(2) of the Road Rules apply.

10 In my opinion, the driver has violated r 132(2).

Inappropriate use of horn

11 Rule 224 of the Road Rules are as follows:

A driver must not use, or allow to be used, a horn, or similar warning device, fitted to or in the driver’s vehicle unless—

(a) it is necessary to use the horn, or warning device, to warn other road users or animals of the approach or position of the vehicle, or

(b) the horn, or warning device, is being used as part of an anti-theft device, or an alcohol interlock device, fitted to the vehicle.

Maximum penalty—20 penalty units.

12 At several points the Offending Vehicle used their horn behind the applicant. It is unknown whether the vehicle was using the horn against the applicant or the vehicle ahead of the applicant.

13 The use of the horn was indicating the approach of the Offending Vehicle; however, the Offending Vehicle was the one following too closely to the applicant and was impatient despite all other vehicles following the speed limit or being below the speed limit. Rule 224(b) is not relevant. There is no obligation for the front vehicle or the applicant to move out of the Offending Vehicle and the use of the horn to indicate the approach or position of the Offending Vehicle is not necessary. If it was, then every time a car was slowing behind another car, then they would use their horn to indicate their position which will cause announce for anyone living next to a road. The use of the horn multiple times within two minutes of each other on the same stretch of road does not help the case for the Offending Vehicle. Kite AJ found that using a horn for 36 seconds was unlawful though because the case was a civil and not criminal case, no penalty was decided on (Transport Workers’ Union of New South Wales (on behalf of Sidhu Freight Pty Ltd) and Toll Transport Pty Ltd trading as Toll Contract Logistics [2015] NSWIRComm 36 at [45] and [47]). Using the horn for the second time was unnecessary even if it was a blip of the horn for less than have a second.

14 In my opinion, the driver has violated r 224.

Penalties

15 Having formed the opinion that the Offending Vehicle has contravened the Road Rules, now I will go to the question of penalties.

16 For breaching r 126, NSW Jud Com Law Part Code 82709 states that the fine should be $562 and three demerit points.

17 For breaching r 132(2), NSW Jud Com Law Part Code 82823 states that the fine should be $423 and three demerit points.

18 For breaching r 224, NSW Jud Com Law Part Code 82810 states that the fine should be $423.

19 I see no reason to deviate from what is stated by the NSW Judicial Commission Lawcodes and to recommend a higher penalty.

Disposition

20 My decision is that:

(1) When published on the internet, licence plate of the offending vehicle, street names, and suburb be redacted.

(2) The driver of the offending vehicle, ██████, on or around 6:34 pm on 2 May 2026 should receive fines for violating rr 126, 132(2), and 224 of the Road Rules 2014 (NSW).

(3) The driver should receive a total fine of $1,408 and receive six demerit points.

I certify that the preceding twenty (20) numbered paragraphs are a true copy of the reasons for decision of S Aimersmith, Delegate Authorised to Make Decisions.

Signature:

Date: 4 June 2026

References

• Road Rules 2014 (NSW).

• Transport Workers’ Union of New South Wales (on behalf of Sidhu Freight Pty Ltd) and Toll Transport Pty Ltd trading as Toll Contract Logistics [2015] NSWIRComm 36.

Date of decision: 13 May 2026

Date of publication: 1 June 2026

The Decisions Body decides that:

1. ██ ██████ █████ is found in contempt of the Decisions Body and the penalties of being found in contempt apply.

2. The name of the client be redacted on publication of this decision to the internet.

File number: DBA26/024

Catchwords: Contempt of the Decisions Body—Where person impeded work of the Decisions Body—Where person stayed past closing time at decision-maker's work—Decision writing delayed.

Number of paragraphs: 7

Note: This copy of the Decisions Body’s reasons for decision may be subject to review to remedy typographical or grammatical errors.

REASONS FOR DECISION

CRAMSTON DEL ATH

1 Delegates Authorised within the Decisions Body all hold the position part-time or even less so, depending on their personal circumstances. This is not anybody’s full-time job. There is an expectation that decisions are published within a reasonable time frame after an application is received.

2 Last week, I set aside an hour after I finished work to perform tasks relating to the Decisions Body. Unfortunately, a client at work decided to stay 10 minutes after closing time to finish some tasks. Due to the nature of my work, I also needed to stay behind until they finished. My bad luck did not end there, as there were also train delays that further hampered my performance of various tasks for the Decisions Body. This left me with not enough time to work on the tasks needed for the Decisions Body, as I had another commitment after the hour I had scheduled for the Decisions Body.

3 If I was not forced to stay back because of the client, I would have still had enough time to get home and work on the tasks needed for the Decisions Body. The train delays were entirely out of the control of most people, so I find no contempt there. The client had been given warnings that the building would be closing at 5:30 pm; however, they ignored it and asked for extra time, which—due to the nature of my work—I pretty much had to agree to. That will not stop me from holding them in contempt for impeding the work of the Decisions Body.

4 The leading authority on contempt of the Decisions Body is Don v Kate (Contempt) [2026] DecB 5. In that case, Kate was found in contempt for refusing to follow a decision of the Decisions Body: Don v Kate (Contempt) [2026] DecB 5 at [27]. Don v Kate (Contempt) at [18] includes a list of reasons that persons can be found in contempt. At [19], Candlestickmaker Del Ath says that the list is non-exhaustive and that there may be other reasons. Impeding the work of the Decisions Body is not listed there but it is listed in the decisions on the coversheet with the wording “… undermine the performance or dignity of the Decisions Body” (decision 3, Don v Kate (Contempt)).

5 The threshold for holding a person in contempt of the Decisions Body is beyond the balance of probabilities (Don v Kate (Contempt) at [21]–[22]). As there are many other places where that client could have printed, they had a choice and they chose to stay back despite the warning.

6 I therefore hold the client, real name ██ ██████ █████, in contempt of the Decisions Body. The appropriate penalties should apply (Don v Kate (Contempt) at [7]). The name of the client be redacted on publication of this decision to the internet.

I certify that the preceding six (6) numbered paragraphs are a true copy of the reasons for decision of B Cramston, Delegate Authorised to Make Decisions.

Signature:

Date: 13 May 2026

References

• Don v Kate (Contempt) [2026] DecB 5.

Date of decision: 9 April 2026

The Decisions Body decides that:

1. Developers of games must not lock achievements behind pre-orders and donation-gathering websites.

File number: DBA26/018

Catchwords: Video games—achievements—time-locked achievements—paywalled achievements—achievements locked behind pre-order—achievements locked behind crowdfunding—Kickstarter—whether locking achievements behind pre-release funding mechanisms is contra bonos mores—found to be contra bonos mores

Number of paragraphs: 4

Note: This copy of the Decisions Body’s reasons for decision may be subject to review to remedy typographical or grammatical errors.

REASONS FOR DECISION

KALICHAVA DEL ATH

1 InterestingBarnacle3 on Reddit posted to r/Steam bringing attention to the wider community some achievements from the game The Black Watchmen[r1]. The Black Watchmen is a game that was released on 25 June 2025 by Alice & Smith [r2].

2 The screenshot attached to the post is of the achievement list, specifically of the achievements: Futurology, Greenlight Operative, and Shock Trooper. The conditions needed to unlock these achievements are as follows:

(1) Futurology: Back the project on Kickstarter.

(2) Greenlight Operative: Purchase the Steam Funders package on Kickstarter.

(3) Shock Trooper: Pre-order the game.

3 Time-locked achievements in games are not a good thing as it creates the fear of missing out and is a bane on the existence of those who want to get 100% achievements for games they play. The three achievements mentioned above from The Black Watchmen are not only time-locked to before the game even released but also paywalled as all of them required the achiever (or prospective achiever) to fork over a certain amount of currency. There exists the Latin legal term contra bonos mores, which means “against good morals” [r3] or “contrary to morality” (Vella v Commissioner of Police [2019] HCA 38 at [156]). I find that having achievements locked behind pre-ordering and funding the game on a donation to be contra bonos mores.

4 Developers of games must not lock achievements behind pre-orders and donation-gathering websites.

I certify that the preceding ­four (4) numbered paragraphs are a true copy of the reasons for decision of A Kalichava, Delegate Authorised to Make Decisions.

Signature:

Date: 9 April 2026

References

[r1] u/InterestingBarnacle3. (2026-03-04). What is this bullshit 😐[Reddit post]. Reddit. www.reddit.com/r/Steam/s/e3EBiO17rt

[r2] Alice & Smith. (nd). The Black Watchmen [Store page]. Steam. https://store.steampowered.com/app/349220/The_Black_Watchmen/

[r3] Justia. (nd). Contra bonos mores. https://dictionary.justia.com/contra-bonos-mores

Date of decision: 7 April 2026

The Decisions Body decides that:

1. The Honourable Jeremy Rockcliff MP and successive Premiers of Tasmania must not re-name the Department of State Growth to “Building Tasmania”.

File number: DBA26/017

Catchwords: Names and nomenclature—government departments—Tasmania—Department of State Growth—proposed renaming to “Building Tasmania”—whether proposed name appropriate—application to restrain renaming.

Number of paragraphs: 7

Note: This copy of the Decisions Body’s reasons for decision may be subject to review to remedy typographical or grammatical errors.

REASONS FOR DECISION

GIBSTONE DEL ATH

1 It was announced during the State of the State address in the Parliament of Tasmania by the Honourable Jeremy Rockcliff MP that the Department of State Growth would be abolished and replaced with the entity so-called “Building Tasmania” [r1].

2 The application arises from an applicant wanting to stop the re-naming. The applicant states that they do not necessarily oppose the future prosperity of Tasmania, but they find the name of “Building Tasmania” to be stupid.

3 I agree with the applicant that the name Building Tasmania is stupid. This is the current list of Tasmania government departments [r2]:

• Department of Education, Children and Young People

• Department of Health

• Department of Justice

• Department of Police, Fire and Emergency Management

• Department of Premier and Cabinet

• Department of Natural Resources and Environment

• Department of State Growth

• Department of Treasury and Finance

4 The change will throw off the orderly nature of the names by tossing into this mix “Building Tasmania”. This is a slippery slope that Mr Rockcliff cannot start going down. This phenomenon I will call the “bad name backslide”, akin to democratic backslide. Once the backslide starts, it’s hard to recover from.

5 Making the name Department for Building Tasmania will be better but still has Building Tasmania in it.

6 I therefore decide that Mr Rockcliff and his successors must not re-name the Department of State Growth to “Building Tasmania”.

7 As this decision is unlikely to change the mind of Mr Rockcliff, it is likely a contempt application will be made against Mr Rockcliff by the Prothoclerk.

I certify that the preceding ­seven (7) numbered paragraphs are a true copy of the reasons for decision of M Gibstone, Delegate Authorised to Make Decisions.

Signature:

Date: 7 April 2026

References

[r1] Duggan. (2025-03-03). Tasmanian government announces Department of State Growth to be replaced by Building Tasmania. ABC News. https://www.abc.net.au/news/2026-03-03/tas-department-of-state-growth-transform-into-building-tasmania/106408320

[r2] Wikipedia contributors. (2025-10-25). Tasmanian Government. Wikipedia. Retrieved 2025-03-03, 18:42 from https://en.wikipedia.org/w/index.php?title=Tasmanian_Government&oldid=1318188304

Date of decision: 18 March 2026

The Decisions Body decides that:

1. This first instance case be decided by the Full Body of the Decisions Body, consisting of three decision-makers.

2. The decisions and reasons for decisions made by the Full Body of the Decisions Body (three or more decision-makers) which can over-rule previous cases and but are binding on single decision-makers.

3. The Decisions Body can hold people in contempt of breaching its decisions or actions that interfere with or undermine the performance or dignity of the Decisions Body or those who participate in their proceedings.

The Decisions Body declares that:

A. By failing to take, by 11:59 pm on 21 November 2025 all necessary steps to apologise to the applicant, the respondent breached decision 1 of the Decisions Body’s decisions made in Don v Kate [2025] SpkGenDec 9.

The Decisions Body further decides that:

4. Kate is found in contempt of the Decisions Body and the penalties of being found in contempt apply.

File number: SGDA2025/034

Catchwords: Contempt of the Decisions Body—Where the decision made against respondent—whether the respondents breached the orders—Where the respondent failed to apologise within specified time frame—Respondent found in contempt.

Parties: Don (Applicant); Kate (Respondent)

Number of paragraphs: 27

Note: This copy of the Decisions Body’s reasons for decision may be subject to review to remedy minor typographical or grammatical errors.

REASONS FOR DECISION

THE SPEAKER-GENERL

1 I thank Candlestickmaker Del Ath for doing the research on contempt and the background that that provides, as well as the relevant areas in which the Decisions Body can find people in contempt.

2 Due to the complex nature of this case, being the first time that the Decisions Body will have to find whether or not a person is in contempt of the Decisions Body, I make the decision that this case will be the first case decided by a Full Body of the Decisions Body. That being at least three decision-makers.

3 A Full Body deciding a first instance case is unusual as generally first instance cases are decided by only one decision-maker, which is all cases decided by the Decisions Body up until now.

4 Contempt cases can be decided by either a single decision-maker or by a Full Body.

5 If this case were to be appealed, a decision-maker may decide if there are sufficient merits to grant leave to appeal and if leave is granted, a differently composed Full Body consisting of at least one decision-maker with the title Speaker-General (apart from myself, as it is not proper to sit on an appeal of my own decision and reasons for decision) and at least two other delegates authorised to make decisions.

6 As for penalties for those being found in contempt of the Decisions Body, as Candlestickmaker Del Ath says in his reasons at [21], “penalties … can only be declaratory in form”.

7 Those who have been found in contempt:

(1) Will be entered into the Register of Contempt;

(2) Cannot apply for decisions from the Decisions Body;

(3) Whenever they are mentioned in future reasons for decision, they must be noted to have been found in contempt of the Decisions Body.

I certify that the preceding ­seven (7) numbered paragraphs are a true copy of the reasons for decision of the Honourable the Speaker-General, Head of Decisions.

Signature:

Date: 18 March 2026

BAKER DEL ATH

8 I agree with the decisions made by both the Honourable the Speaker-General and the reasons he has provided. I also have had the advantage of reading in draft the reasons for decision of Candlestickmaker Del Ath and I also agree with the reasons he has provided and the decisions made.

I certify that the preceding ­one (1) numbered paragraph is a true copy of the reasons for decision of J Baker, Delegate Authorised to Make Decisions.

Signature:

Date: 18 March 2026

CANDLESTICKMAKER DEL ATH

9 On 17 November 2025, I made a decision that the respondent in the case, Kate, must apologise to the applicant, Don (Don v Kate [2025] SpkGenDec 9).

10 I will not repeat the background of that case in these reasons.

11 The question arises, however, can the Decisions Body even hold people in contempt for breaching its decisions? For the following reasons, I find that, yes, the Decisions Body can find people in contempt by not following decisions.

12 The Decisions Body cannot hold people in criminal contempt as it is not a superior or inferior court of record. The Decisions Body should still have the ability to declare that a person is in contempt of the Decisions Body in a similar way to when courts declare a person to be in civil contempt.

13 Courts holding people in contempt is an ancient concept, with cases starting from the 14th century (Adams & Baker 2020).

14 Contempt is not only found in the common law but also statute law. The contempt powers of the Federal Court of Australia are found in s 31 of the Federal Court of Australia Act 1976 (Cth). Section 31 states:

31 Contempt of Court

(1) Subject to any other Act, the Court has the same power to punish contempts of its power and authority as is possessed by the High Court in respect of contempts of the High Court.

(2) The jurisdiction of the Court to punish a contempt of the Court committed in the face or hearing of the Court may be exercised by the Court as constituted at the time of the contempt.

15 The High Court of Australia’s contempt provision can be found in the Judiciary Act 1903 (Cth), which states:

24 Contempt

The High Court shall have the same power to punish contempts of its power and authority as is possessed at the commencement of this Act by the Supreme Court of Judicature in England.

16 The Decisions Body should have the power to hold people in contempt.

17 The next thing to decide for what reasons can the Decisions Body hold a person in contempt for. The Judicial Commission of New South Wales’ Local Court Bench Book as at September 2025 at [48-020], provides examples of actions that would be considered contempt in the face of the court, those examples are:

• abusing and swearing at a magistrate/judge: Prothonotary of the Supreme Court of NSW v Hall [2008] NSWSC 994; Prothonotary of the Supreme Court of NSW v Patrick (a pseudonym) [2023] NSWSC 1077

• filming witnesses with a view to intimidation: Prothonotary of the Supreme Court of NSW v Rakete (2011) 202 A Crim R 117

• prevaricating or refusing to answer questions: Keeley v Brooking (1979) 143 CLR 162; Prothonotary of the Supreme Court of NSW v Patrick (a pseudonym) [2023] NSWSC 1077

• refusing to take the oath or give evidence: Smith v R (1991) 25 NSWLR 1

• refusing to leave the court when directed: In the matter of Bauskis [2006] NSWSC 908

• disobeying court orders including subpoena: O’Shane v Channel Seven Sydney Pty Ltd [2005] NSWSC 1358

• destroying evidence upon execution of a search warrant: He v Sun [2021] NSWCA 95

18 Of those examples, the following would be most applicable to the Decisions Body:

(1) abusing and swearing at a magistrate/judge (or in the case of the Decisions Body, the Decision-Maker);

(2) filming witnesses with a view to intimidation;

(3) prevaricating or refusing to answer questions;

(4) refusing to take the oath or give evidence (or in the case of the Decisions Body, giving false evidence or lying);

(5) refusing to leave the court when directed (or in the case of the Decisions Body, refusing to leave the room or building in which the hearing takes place when directed);

(6) disobeying court orders including subpoena (or in the case of the Decisions Body, disobeying decisions of the Decisions Body).

19 Though this is not an exhaustive list as flexibility would be considered most beneficial when deciding future contempt cases.

20 Next is what level of proof is needed to establish contempt of the Decisions Body. The common law of Australia is clear with the case Witham v Holloway (1995) 183 CLR 525; [1995] HCA 3 which held that all contempts should have the criminal burden of proof, which is beyond reasonable doubt. Paragraph [94] of ASIC v Sigalla (No 4) [2011] NSWSC 62 states that “… the rules of evidence applicable to civil proceedings apply, but proof must be established beyond reasonable doubt”. There is also the case Central Coast Animal Care Facility Inc v Wyatt [2023] NSWSC 741 which considered if the Evidence Act 1995 (NSW) displaced Witham v Holloway. Slattery J cited NHB Enterprises Pty Ltd v Corry (No 7) [2021] NSWSC 741 in which Bell P (as the Chief Justice then was) stated the distinction between civil and criminal contempt still existed in common law (NHB Enterprises at [203] to [205]). Slattery J said that—considering the precedent—“[parties have] to prove a charge of civil contempt beyond reasonable doubt”.

21 The simple fact is that the penalty for being found guilty of contempt of court is a fine or gaol time (s 24, Local Court Act 2007 (NSW); s 199, District Court Act 1973 (NSW)). The Decisions Body has no legal power to force someone to pay a fine or to imprison someone. Therefore the penalties for being found in contempt of the Decisions Body can only be declaratory in form.

22 As there are no pains of fines or imprisonment for contempt of the Decisions Body I will depart from the beyond reasonable doubt as exists for contempt of court and say that the level of proof needed for Decisions Body contempt is the balance of probabilities.

23 Now to the case at hand. In Don v Kate [2025] SpkGenDec 9, I decided that:

(1) Kate is to apologise to Don in writing to the nominated e-mail address or telephone number via text message.

(2) The apology is to be submitted to the Decisions Body once made.

(3) Kate has until 11:59 pm on 21 November 2025 to make the apology.

24 Upon publishing the decision and reasons for decision, I send them to Kate via the same e-mail and phone number and a follow up. A week after the deadline, I sent another e-mail and text informing Kate to show cause for apologising to Don or not responding to the decision. No response was received.

25 On 5 December 2025, I received an e-mail from Don saying that he had brought up the decision with Kate in person. Don submits that Kate intentionally ignored the correspondence and did not apologise for lying. As I found in [5] of Don v Kate [2025] SpkGenDec 9, Don is a reliable person and I once again have no reason to doubt his account of events. I tried to contact Kate again to try to get her side of the story, to no avail.

26 This course of action has left me no choice. Kate has on multiple occasions refused to respond to Don or to myself. Most importantly has refused to comply with my decision made in Don v Kate [2025] SpkGenDec 9. With everything stated above, I am satisfied that Kate has met the level of proof needed to be found in contempt and I declare that Kate is in contempt of the Decisions Body.

27 It is so decided that Kate is found in contempt of the Decisions Body. I agree with the decisions of the Honourable the Speaker-General regarding the consequences of being found in contempt.

I certify that the preceding ­nineteen (19) numbered paragraphs are a true copy of the reasons for decision of C Candlestickmaker, Delegate Authorised to Make Decisions.

Signature:

Date: 18 March 2026

References

• Adams and Baker. (2020). Sentencing on contempt of court. National Judicial College of Australia. https://www.njca.com.au/wp-content/uploads/2023/03/Sentencing-for-Contempt-of-Court-Adams-N-and-Baker-B.pdf

• ASIC v Sigalla (No 4) [2011] NSWSC 62.

• Central Coast Animal Care Facility Inc v Wyatt [2023] NSWSC 741.

• District Court Act 1973 (NSW).

• Don v Kate [2025] SpkGenDec 9.

• Federal Court of Australia Act 1976 (Cth).

• He v Sun [2021] NSWCA 95.

• In the matter of Bauskis [2006] NSWSC 908.

• Judicial Commission of New South Wales. (2025). Local Court Bench Book. https://www.judcom.nsw.gov.au/publications/benchbks/local/contempt_in_the_face_of_the_court.html

• Judiciary Act 1903 (Cth).

• Keeley v Brooking (1979) 143 CLR 162

• Local Court Act 2007 (NSW).

• NHB Enterprises Pty Ltd v Corry (No 7) [2021] NSWSC 741.

• O’Shane v Channel Seven Sydney Pty Ltd [2005] NSWSC 1358

• Prothonotary of the Supreme Court of NSW v Hall [2008] NSWSC 994.

• Prothonotary of the Supreme Court of NSW v Patrick (a pseudonym) [2023] NSWSC 1077.

• Prothonotary of the Supreme Court of NSW v Rakete (2011) 202 A Crim R 117.

• Smith v R (1991) 25 NSWLR 1.

• Witham v Holloway (1995) 183 CLR 525; [1995] HCA 3.

Date of decision: 4 March 2026

The Decisions Body decides that:

1. Appeal dismissed.

File number: DBA26/011

Catchwords: Formula 1—Valtteri Bottas—appeal of decision by the Stewards—Five-place grid penalty—Penalty to be served at next race driver participates.

Number of paragraphs: 7

Note: This copy of the Decisions Body’s reasons for decision may be subject to review to remedy typographical or grammatical errors.

REASONS FOR DECISION

BUTCHER DEL ATH

1 The Applicant seeks to appeal the penalty issued to Formula 1 driver Valtteri Bottas for causing a collision.

2 The penalty as issued by the Stewards at the 2024 Abu Dhabi Grand Prix is “[d]rop of 5 grid positions for the next Race in which the driver participates” (Federation Internationale de l’Automobile 2024).

3 Mr Bottas did not race in the 2025 season (Formula 1 2024). Mr Bottas was signed to the Cadillac F1 Team and will drive for them in the 2026 season (Barretto 2025).

4 The Stewards issued the penalty due to Mr Bottas misjudging his braking and colliding with Car 20 driven by Mr Kevin Magnussen (Federation Internationale de l’Automobile 2024). As Mr Bottas retired from the race, a drive-through penalty could not be served and therefore the Stewards issued a five-place penalty for the next race that Mr Bottas participates in.

5 The decision of the Stewards states plainly the “next Race in which the driver participates” (Federation Internationale de l’Automobile 2024). The 2026 Australian Grand Prix is the next race that Mr Bottas will enter—unless prevented by foreseen circumstances—and therefore the penalty will apply.

6 This appeal is also brought to the Decisions Body one year, two months and 24 days after the penalty was issued. While the Decisions Body has not decided on the window in which to accept an appeal application, one year, two months and 24 days is unreasonably long. The appeal should have been brought earlier.

7 Therefore, the appeal is dismissed.

I certify that the preceding ­seven (7) numbered paragraphs are a true copy of the reasons for decision of A-M Butcher, Delegate Authorised to Make Decisions.

Signature:

Date: 4 March 2026

References

• Barretto. (2025-08-26). Perez and Bottas to make F1 returns in 2026 with Cadillac. Formula 1. https://www.formula1.com/en/latest/article/perez-and-bottas-to-make-f1-returns-in-2026-with-cadillac.6sqKNbUEoFjveym9YfGkxQ

• Federation Internationale de l’Automobile. (2024). Doc 50 - Infringement - Car 77 - Causing a collision (2nd). https://www.fia.com/sites/default/files/decision-document/2024%20Abu%20Dhabi%20Grand%20Prix%20-%20Infringement%20-%20Car%2077%20-%20Causing%20a%20collision%20(2nd).pdf

• Formula 1. (2024-11-21). ‘At least I know now’ – Bottas reflects on losing Kick Sauber seat for 2025 after finding himself in ‘unlucky situation’. https://www.formula1.com/en/latest/article/at-least-i-know-now-bottas-reflects-on-losing-kick-sauber-seat-for-2025.717GJ3drHNGhYrfUy5Q0so

Date of decision: 23 February 2026

The Decisions Body decides that:

1. Heather’s parents must push in their chairs when they finish eating at a restaurant or at other venues.

File number: DBA26/009

Catchwords: Etiquette—Social etiquette—Restaurants—Pushing in of chairs—Where applicant alleges respondents do not push in chairs when leaving restaurants.

Number of paragraphs: 7

Note: This copy of the Decisions Body’s reasons for decision may be subject to review to remedy typographical or grammatical errors.

REASONS FOR DECISION

COX DEL ATH

1 Heather (a pseudonym) has applied to the Decisions Body to decide and order (within the maximum extent allowable) that her parents must push in chairs when leaving a table at a restaurant.

2 This application was spurred on by a particular event, that Heather’s Father left a chair out at a restaurant, causing another patron of the restaurant to collide with the chair. The patron did not fall over but a hazard was created by the chair being left out. Heather has submitted that her mother also has left chairs out when leaving restaurants.

3 There are a few reasons as to why everyone should push in chairs when you finish eating.

4 First is that it makes it easier for people to walk around the table, both staff and customers and reduces any trip hazards and second, it shows the customers who use the table practice basic etiquette and know good manners.

5 As this application is of an adversarial nature, an opportunity for Heather’s parents to make submissions to the Decisions Body was given. The parents were given first notice on 13 February 2026 via e-mail and were given until close of business on 20 February 2026 to make submissions via e-mail. Heather also indicated to the Decisions Body that she informed her parents to make a submission. No submissions were received from either parent.

6 I therefore dispose that Heather’s parents must push in their chairs when they finish eating at a restaurant or at other venues.

7 Speaking to Heather, if you catch your parents leaving chairs out at a restaurant again after the publishing of these reasons for decision, you can inform the Decisions Body and contempt proceedings may be initiated.

I certify that the preceding ­seven (7) numbered paragraphs are a true copy of the reasons for decision of C Cox, Delegate Authorised to Make Decisions.

Signature:

Date: 23 February 2026

Date of decision: 26 January 2026

The Decisions Body decides that:

1. The Emperor of Japan dissolves the Japanese House of Representatives.

2. Reports that state the Prime Minister of Japan dissolves the Japanese House of Representatives are wrong.

File number: DBA26/007

Catchwords: Constitutional law—Japan—Article 7—Dissolution of the House of Representatives—Where media outlets have reported that the Prime Minister dissolves the House of Representatives.

Number of paragraphs: 8

Note: This copy of the Decisions Body’s reasons for decision may be subject to review to remedy typographical or grammatical errors.

REASONS FOR DECISION

RATHBONE DEL ATH

1 The Constitution of Japan (Constitution) is the fundamental and supreme law of that nation. It was adopted upon the conclusion of World War II (History.com 2010). The Constitution was promulgated on 3 November 1946 and commenced on 3 May 1947.

2 The Constitution vests legislative powers in the National Diet (Constitution chapter IV). The National Diet is made up of two houses, the House of Councillors and the House of Representatives (Constitution article 42). Of note in these reasons for decision is the House of Representatives.

3 On 23 January 2026, the House of Representatives was dissolved and an election for all 465 members is set for 8 February 2026 (Yamaguchi 2026; NHK World-Japan 2026 7:20).

4 The issue at hand is that much of the world’s media is getting a detail of the dissolution completely incorrect. Many media outlets are claiming that the Prime Minister of Japan, Mrs Sanae Takaichi dissolved the House of Representatives. That detail is most patently incorrect. The correct answer lies in article 7 of the Constitution:

Article 7. The Emperor, with the advice and approval of the Cabinet, shall perform the following acts in matters of state on behalf of the people:

Promulgation of amendments of the constitution, laws, cabinet orders and treaties.

Convocation of the Diet.

Dissolution of the House of Representatives.

…

(Emphasis added)

5 It is His Majesty Emperor Naruhito who dissolves the House of Representatives as well as his heirs and successors according to Japanese law, not the Prime Minister as many outlets have reported.

6 I will take inspiration from Edelman J in [651] of Vanderstock v Victoria [2023] HCA 30; (2023) 279 CLR 333. In that paragraph, Edelman J disagrees with the approach of the majority in Vanderstock v Victoria, being Kiefel CJ, Gageler, and Gleeson JJ with Jagot J agreeing with the orders but with Her Honours separate reasons. Edelman J then lists out all the learned justices whose precedent would be neglected. So, Al Jazeera is wrong (Al Jazeera and News Agencies 2026), the Associated Press is wrong (Yamaguchi 2026), Agence France-Presse is wrong (Agence France-Presse 2026), Bernama is wrong (Bernama 2026), Channel News Asia is wrong (CNA 2026), DW News (2026) is wrong, Nippon TV (2026) is wrong, Reuters (2026) is wrong, The Asahi Shimbun (2026) is wrong, The Japan Times is wrong (Johnson 2026), and all media outlets that licensed articles from the three major news agencies—that being the Associated Press, Agence France-Presse, and Reuters—are by keeping the misleading information in the articles are wrong.

7 Xinhua (2026) is one of the news outlet I have come across that does get it correct as they stated “Japanese Prime Minister Sanae Takaichi announced her decision on Monday to dissolve the 465-seat lower house for a snap election”. China Daily also has it correct. they say that “Japanese Prime Minister Sanae Takaichi’s cabinet on Friday approved a decision to dissolve the 465-seat House of Representatives” (Junjie 2026). Both news outlets are state-owned news organisations in the People’s Republic of China (Molter & DiResta 2020).

8 His Majesty the Emperor dissolves the House of Representations on behalf of the people of Japan on the advice and approval of the Cabinet of Japan (Constitution article 7).

I certify that the preceding ­eight (8) numbered paragraphs are a true copy of the reasons for decision of P Rathbone, Delegate Authorised to Make Decisions.

Signature:

Date: 26 January 2026

References

Al Jazeera & News Agencies. (2026-01-23). Japan PM Takaichi dissolves parliament, paving way for snap election. https://www.aljazeera.com/news/2026/1/23/japan-pm-takaichi-dissolves-parliament-paving-way-for-snap-election

Agence France-Presse. (2026-01-22). Japan PM Takaichi set to dissolve parliament for snap election. France 24. https://www.france24.com/en/live-news/20260122-japan-pm-takaichi-set-to-dissolve-parliament-for-snap-election

Bernama. (2026-01-23). Japan PM Takaichi Dissolves Lower House For Feb 8 Election To Seek Mandate. https://www.bernama.com/en/news.php/?id=2515928

CNA. (2026-01-23). Japan’s PM Takaichi dissolves parliament, snap election set for Feb 8 [Video]. YouTube.

Constitution of Japan.

DW News. (2026-01-23). Japan’s PM Takaichi dissolves parliament and calls snap elections [Video]. YouTube.

History.com (2010-02-09). New Japanese constitution goes into effect. https://www.history.com/this-day-in-history/May-3/new-japanese-constitution-goes-into-effect

Molter & DiResta. (2020). Pandemics & propaganda: How Chinese state media creates and propagates CCP coronavirus narratives. Harvard Kennedy School (HKS) Misinformation Review. https://doi.org/10.37016/mr-2020-025

Murakami. (2026-01-23). Japan’s Takaichi Dissolves Parliament for Shortest Campaign. Bloomberg. https://www.bloomberg.com/news/articles/2026-01-23/japan-s-takaichi-to-dissolve-parliament-for-shortest-campaign

NHK World-Japan. (2026-01-23). Japan’s Lower House dissolved [Video]. YouTube.

Qatar News Agency. (2026-01-23). Japan PM Dissolves Lower House for Feb. 8 Election. https://qna.org.qa/en/news/news-details?id=japan-pm-dissolves-lower-house-for-feb-8-election&date=23/01/2026

Johnson. (2026-01-23). Takaichi dissolves Lower House for Feb. 8 snap election. The Japan Times. https://www.japantimes.co.jp/news/2026/01/23/japan/politics/diet-dissolves/

Junjie. (2026-01-23). Japan’s cabinet approves decision to dissolve lower house. China Daily. https://www.chinadaily.com.cn/a/202601/23/WS6972dc54a310d6866eb35599.html

Nippon TV. (2026-01-23). PM Takaichi dissolves lower house for ultra-short midwinter election. https://www.ntv.co.jp/englishnews/articles/2021622gqh5704xxw5a3.html

Reuters. (2026-01-23). Japan’s lower house of parliament dissolves ahead of snap election on February 8. https://www.reutersconnect.com/item/japans-lower-house-of-parliament-dissolves-ahead-of-snap-election-on-february-8/dGFnOnJldXRlcnMuY29tLDIwMjY6bmV3c21sX1JDMlQ2SkFUTDUxVQ

The Asahi Shimbun. (2026-01-23). Prime minister dissolves Lower House, setting up Feb. 8 snap poll. https://www.asahi.com/ajw/articles/16304825

Vanderstock v Victoria [2023] HCA 30; (2023) 279 CLR 333.

Xinhua. (2026-01-23). Japan’s lower house formally dissolved for Feb. 8 election. https://english.news.cn/20260123/cf48b5fc638649c8b8b0fd6904102da1/c.html

Yamaguchi. (2026-01-23). Japan’s Takaichi dissolves parliament after only 3 months in office, setting up snap election. Associated Press. https://apnews.com/article/japan-politics-takaichi-parliament-dissolution-election-74e9b32eb12a6f9823242255b92150b2

Date of decision: 23 December 2025

The Decisions Body decides that:

1. Federal Circuit and Family Court of Australia (Division 1) should have a shortened form in writing of “Division 1 Court”.

2. Federal Circuit and Family Court of Australia (Division 2) should have a shortened form in writing of “Division 2 Court”.

File number: SGDA2025/036

Catchwords: Writing—Abbreviations—Shortened forms of names—Federal Circuit and Family Court of Australia (Division 1)—Federal Circuit and Family Court of Australia (Division 2).

Number of paragraphs: 15

Note: This copy of the Decisions Body’s reasons for decision may be subject to review to remedy minor typographical or grammatical errors.

REASONS FOR DECISION

THE SPEAKER-GENERAL

Federal Circuit and Family Court of Australia

1 The Federal Circuit and Family Court of Australia consists of two courts.

2 The Federal Circuit and Family Court of Australia (Division 1) is the continuation of the Family Court of Australia (s 8(1), Federal Circuit and Family Court of Australia Act 2021 (Cth)) which was first established by s 21 of the Family Law Act 1975 (Cth) as a superior court of record (s 21(1) Family Law Act 1975 (Cth)).

3 The Federal Circuit and Family Court of Australia (Division 2) is the continuation of the Federal Circuit Court of Australia (s 8(2), FCFCA Act) which was established as the Federal Magistrates Court (s 8(1), Federal Magistrates Act 1999 (Cth)) as an inferior court of record (s 8(3), Federal Magistrates Act 1999 (Cth)). The Federal Magistrates Court was renamed by the Federal Circuit Court of Australia Legislation Amendment Act 2012 (Cth) to the Federal Circuit Court of Australia.

4 The previous two paragraphs may have been a bit clunky but was needed to get the point across that two courts with different names were combined but also not really combined and had their names changed to two very similar names. I will not delve into the reasons for this change as it is not in the application. As the names are unwieldy, they will need to be abbreviated lest judgments, journal articles, and other media are filled mentions of “Federal Circuit and Family Court of Australia”.

5 I will reject the abbreviations used in the medium neutral citations for the judgments of the court, being: FedCFamC1A (Division 1 appellate jurisdiction), FedCFamC1F (Division 1 first instance), FedCFamC2F (Division 2 family law), and FedCFamC2G (Division 2 general federal law). It will be confusing when used as an abbreviation next to in-text citations.

Examples in the Common Law

6 I will now look into which shortened forms courts have used.

New South Wales Supreme Court

7 Various judges in the New South Wales Supreme Court use Division 1 Court and Division 2 Court.

8 Judges that have used Division 1 Court are: Robb J in O’Donnell v O’Donnell (No 2) [2023] NSWSC 1196 at [107], Ferrer Lawyers Pty Ltd trading as Ferrer Lawyers ACN 641 830 873 v Khanchedar [2023] NSWSC 1085 at [4]; Meek J in Hadid v Sabouh [2023] NSWSC 483 at [1], Aviani v Loh (No 2) [2022] NSWSC 1148 at [12]; Chen J in Comino v Kremetis & Anor [2023] NSWSC 32 at [17]; Henry J in Re Neil (No 5) [2022] NSWSC 1704 at [10], Wurz bht NSW Trustee & Guardian v Elawaad (No 2) [2022] NSWSC 1486 at [4]; Hallen J in Bolinger v Bell (No 2) [2022] NSWSC 1495 at [211]; and Beech-Jones CJ at CL in Yu v Wang [2021] NSWSC 1280 at [18].

Federal Court of Australia

9 Judges of the Federal Court of Australia appear to use the old names of the courts. The examples I have found are: O’Bryan J in AJM18 v Federal Circuit and Family Court of Australia [2023] FCA 1625 at [1], Markovic J in Nguyen v Federal Circuit and Family Court of Australia [2024] FCA 471 at [1], and most recently Thawley J (Cheong v Federal Circuit and Family Court of Australia (Division 2) [2025] FCA 1505 at [1]). All three honourable and learned justices used the old name from before the court amalgamation. It just so happens that all three cases involve Federal Circuit and Family Court of Australia (Division 2), as such all three justices abbreviated the Division 2 as the Federal Circuit Court.

High Court of Australia

10 Just as I was getting ready to publish these reasons for decision, the High Court of Australia published its reasons for judgment in Genesalio v Justice Johns and other Judges of the Federal Circuit and Family Court of Australia (Division 1) [2025] HCA 45. In Genesalio, Gageler CJ, Steward, and Jagot JJ abbreviated the Federal Circuit and Family Court of Australia (Division 1) as “Division 1 Court” (Genesalio at [3], [6], [11], [14], [16], [17], [18], [20], and [23]).

11 In R Lawyers v Mr Daily [2025] HCA 41, Gageler CJ, Jagot, and Beech-Jones JJ uses Division 1 Court in [2]–[3], [18]–[27], [29]–[31], [33]–[35], [37]–[38], [43]–[46], [48], [50], and [53]. Gordan and Edelman JJ uses “Full Court” as the shortened form to refer to the Federal Circuit and Family Court of Australia (Division 1) in its appellate jurisdiction (R Lawyers v Mr Daily [2025] HCA 41 at [75]).

12 Another example is from Rapallino v The Federal Circuit and Family Court of Australia Division 1 [2025] HCASJ 49, where Jagot J used Division 1 Court.

13 There would appear to be a constant as to when the High Court uses Division 1 Court… being that Jagot J. While it is not possible to know if Jagot J was the sole author of the reasons in Genesalio and R Lawyers v Mr Daily, Her Honour was the sole author in Rapallino so I think it can be reasonably inferred that Her Honour uses Division 1 Court and where applicable, Division 2 Court. Although there does not appear to be any uses of Division 2 Court yet in High Court jurisprudence.

14 As the common law of Australia progress as and we as a society move further away from the commencement of the FCFCA Act, much to the chagrin of myself and potentially others, the original names of Federal Circuit Court/Federal Magistrates Court and Family Court will fade into further and further into obscurity. The term “magistrate” will also disappear soon from New South Wales with the passage and Royal assent of the Local Court and Bail Legislation Amendment Act 2025 (NSW) which renames magistrates to local court judges, something that I disagree with but I will not go further in these reasons for decision.

Conclusion

15 I make the following decisions:

(1) Federal Circuit and Family Court of Australia (Division 1) should have a shortened form in writing of “Division 1 Court”.

(2) Federal Circuit and Family Court of Australia (Division 2) should have a shortened form in writing of “Division 2 Court”.

I certify that the preceding ­fifteen (15) numbered paragraphs are a true copy of the reasons for decision of the Honourable the Speaker-General.

Signature:

Date: 23 December 2025

References

• AJM18 v Federal Circuit and Family Court of Australia [2023] FCA 1625.

• Aviani v Loh (No 2) [2022] NSWSC 1148.

• Bolinger v Bell (No 2) [2022] NSWSC 1495.

• Cheong v Federal Circuit and Family Court of Australia (Division 2) [2025] FCA 1505.

• Comino v Kremetis & Anor [2023] NSWSC 32.

• Family Law Act 1975 (Cth).

• Federal Circuit and Family Court of Australia Act 2021 (Cth).

• Federal Circuit Court of Australia Legislation Amendment Act 2012 (Cth).

• Federal Magistrates Act 1999 (Cth).

• Ferrer Lawyers Pty Ltd trading as Ferrer Lawyers ACN 641 830 873 v Khanchedar [2023] NSWSC 1085.

• Genesalio v Justice Johns and other Judges of the Federal Circuit and Family Court of Australia (Division 1) [2025] HCA 45.

• Hadid v Sabouh [2023] NSWSC 483.

• Local Court and Bail Legislation Amendment Act 2025 (NSW).

• Nguyen v Federal Circuit and Family Court of Australia [2024] FCA 471.

• O’Donnell v O’Donnell (No 2) [2023] NSWSC 1196.

• R Lawyers v Mr Daily [2025] HCA 41.

• Re Neil (No 5) [2022] NSWSC 1704.

• Rapallino v The Federal Circuit and Family Court of Australia Division 1 [2025] HCASJ 49.

• Wurz bht NSW Trustee & Guardian v Elawaad (No 2) [2022] NSWSC 1486.

• Yu v Wang [2021] NSWSC 1280.

Date of decision: 17 November 2025

The Decisions Body notes that:

A. The applicant has been given the pseudonym of Don.

B. The respondent has been given the pseudonym of Kate.

The Decisions Body decides that:

1. Kate is to apologise to Don in writing to the nominated e-mail address or telephone number via text message.

2. The apology is to be submitted to the Decisions Body once made.

3. Kate has until 11:59 pm on 21 November 2025 to make the apology.

File number: SGDA2025/034

Catchwords: Reconciliation — Where the applicant has alleged that the respondent lied — Where the respondent is said to have lied so as to not walk with respondent.

Number of paragraphs: 11

Note: This copy of the Decisions Body’s reasons for decision may be subject to review to remedy minor typographical or grammatical errors.

REASONS FOR DECISION

CANDLESTICKMAKER DEL ATH

1 The applicant, who I will name Don, has filed for a decision to compel the respondent, who I will name Kate, to apologise for lying.

2 In the application, Don states that after finishing work for the day. He caught up with Kate just a dozen metres from their workplace. Don states he greeted Kate and another colleague as they had only seen each other once before that day. Don waited for Kate and the other colleague while the other colleague was tying their shoe laces.

3 Kate said “[w]e are waiting for someone”. Don said “[o]kay, I’ll see you next week”. Don then makes his way to the next traffic light. Due to the cycle of the traffic light, Don crosses perpendicular to the intended direction of travel. While waiting for the traffic light to change once again, he just do happens to look over to the where Don first cross the road. There he saw Kate and the colleague conversing with each other and no-one else.

4 Don alleges that the earlier statement of Kate of waiting for someone was a lie so that she would not have to walk with him.

5 Along with the application, Don provided six character references from two direct supervisors, another colleague, a friend, a business partner, and the local bishop. All character references signed and authenticated. All were in favour of the applicant as a person who is hard working and always wanting to help where possible.

6 Kate was contacted by the Decisions Body and informed that an application was to be made against her. An e-mail, text message were sent on 27 October 2025. A follow up was a week later on 3 November 2025.

7 There was no response. There was also no bounce-back e-mail so the e-mail account is still active.

8 I have no reason to doubt the details provided by Don.

9 The lack of response from Kate leaves me with no other option than to make a default decision in favour of Don.

10 I make the following decisions:

(1) Kate is to apologise to Don in writing to the nominated e-mail address or telephone number via text message.

(2) The apology is to be submitted to the Decisions Body once made.

(3) Kate has until 11:59 pm on 21 November 2025 to make the apology.

11 A copy of the decisions and reasons for decision have been sent to Kate.

I certify that the preceding ­eleven (11) numbered paragraphs are a true copy of the reasons for decision of C Candlestickmaker, Delegate Authorised to Make Decisions.

Signature:

Date: 17 November 2025

Date of decision: 21 October 2025

The Decisions Body declares that:

1. Cait Kelly is in breach of The Guardian’s style guide with the article “Centrelink illegally cancelled Daniel’s jobseeker payment. He fought back against the system – and won” written by Cait Kelly published on 18 October 2025 (the Article).

The Decisions Body decides that:

2. The following proper nouns must be capitalised:

(a) Administrative Review Tribunal;

(b) Commonwealth Ombudsman.

3. The Article must be corrected in accordance with these reasons for decision.

4. Affected parties are to give effect to these reasons for decision within 14 days of publication.

5. Writers and editors for The Guardian must be familiar with the general rules of capitalisation as well as what The Guardian has already set out in their style guide.

File number: SGDA2025/030

Catchwords: English—Style guides—Capitalisation—Where a journalist has improperly used capitalisation or lack of capitalisation—Where misuse is against the style guide used by journalist’s organisation.

Number of paragraphs: 15

Note: This copy of the Decisions Body’s reasons for decision may be subject to review to remedy minor typographical or grammatical errors.

REASONS FOR DECISION

CRAMSTON DEL ATH

History and style guide

1 The Guardian is a British newspaper that also publishes on the internet (The Guardian, nd). It was founded by John Edward Taylor in 1821 (GNM Archive 2017).

2 Like many newspapers and media organisations, The Guardian has a style guide (The Guardian nd a). The layout of the style guide is based on letters in which each convention falls. In particular for this decision is an entry the letter C, as that is the page in which capitalisation falls under.

3 The Guardian (2021) states this when capitalising names of government departments, government agencies and related bodies:

government departments in English-speaking countries

Initial capitals when full name is used, eg Home Office, Foreign Office, Ministry of Justice (UK), Department of Defense, Department of Homeland Security (US), Department of Immigration and Border Protection (Australia), Fisheries and Oceans Canada, Department of Communications, Energy and Natural Resources (Irish Republic), Ministry of Railways (India) …

…

government agencies, public bodies, quangos initial caps, eg Crown Prosecution Service, Equality and Human Rights Commission, Heritage Lottery Fund, Parole Board, Revenue and Customs.

4 I bring this up as it has come to the attention of the Decisions Body that a writer for The Guardian may have violated what I have quoted above.

The allegations

5 The Applicant has filed with the Decisions Body to decide and make a declaration on whether the following article violates The Guardian’s style guide and if the article should be corrected.

6 The allegation is that Cait Kelly is in violation of The Guardian’s style guide (the Style Guide) with the article “Centrelink illegally cancelled Daniel’s jobseeker payment. He fought back against the system – and won” written by Cait Kelly published on 18 October 2025 (the Article).

7 The Applicant has enclosed a copy of the article printed from a web browser. I have looked at it and compared it with the current version on the internet. There are no differences.

8 Kelly (2025) has in the subhead of the Article:

Exclusive: After taking his case to the administrative review tribunal, Daniel’s complaint then went to the commonwealth ombudsman, which is now investigating Centrelink

9 This subhead contains the errors that are are alleged in the application. Administrative Review Tribunal also has incorrect capitalisation three further times in the Article. The first two times that the Commonwealth Ombudsman is mentioned, it has incorrect capitalisation. The second instance of Ombudsman, does have the correct capitalisation. Credit where credit is due, this is not enough for any credit. This draws me to the Latin maxim res ipsa loquitur, which means “the thing speaks for itself” (Schulz 2000 citing Butterworths Australian Legal Dictionary (1997), p 1015).

10 There may be cases before the Decisions Body where decisions are made on the basis of res ipsa loquitur. This will be the first case in which it is applied directly..

Government entities

11The Style Guide says that “government departments in English-speaking countries … government agencies, public bodies, quangos” must have capitalised initial letters (The Guardian 2021). I will now go into the establishment of the Administrative Review Tribunal and the Commonwealth Ombudsman.

Administrative Review Tribunal

12 The Administrative Review Tribunal was established in 2024 by s 8 of the Administrative Review Tribunal Act 2024 (Cth). The Administrative Review Tribunal Act is administered by the Attorney-General’s Department (Administrative Arrangements Order — 13 May 2025).

Commonwealth Ombudsman

13 The Commonwealth Ombudsman is established by s 4(1)(a) of the Ombudsman Act 1976 (Cth). The Ombudsman Act is also administered by the Attorney-General’s Department (Administrative Arrangements Order — 13 May 2025).

Conclusion on government entities

14 As the Administrative Review Tribunal and the Commonwealth Ombudsman are administered by the Attorney-General’s Department of the Australian Government, both are government agencies or public bodies and therefore, it should be capitalised according to the Style Guide.

Disposition

15 Journalists of all people should have a good grasp of the English language to convey the news to their audience. Of course, they should also have a good grasp of their organisation’s style guide. This correction is easy to make. I will make the following declaration (numbered (1)) and decisions (numbered (2)–(5)):

(1) Cait Kelly is in breach of The Guardian’s style guide with the Article.

(2) The following proper nouns must be capitalised:

(a) Administrative Review Tribunal;

(b) Commonwealth Ombudsman.

(3) The Article must be corrected in accordance with these reasons for decision.

(4) Affected parties are to give effect to these reasons for decision within 14 days of publication.

(5) Writers and editors for The Guardian must be familiar with the general rules of capitalisation as well as what The Guardian has already set out in their style guide.

I certify that the preceding ­fifteen (15) numbered paragraphs are a true copy of the reasons for decision of B Cramston, Delegate Authorised to Make Decisions.

Signature:

Date: 21 October 2025

References

• Administrative Arrangements Order — 13 May 2025

• Administrative Review Tribunal Act 2024 (Cth).

• GNM Archive. (2017-12-12). History of the Guardian. The Guardian. https://www.theguardian.com/gnm-archive/2002/jun/06/1

• The Guardian. (2021-04-30). Guardian style guide: C. Retrieved on 2025-10-20 from https://www.theguardian.com/guardian-style-guide-c

• The Guardian. (nd). [Homepage]. Retrieved on 2025-10-20 from https://www.theguardian.com/

• The Guardian. (nd a). The Guardian style guide. Retrieved on 2025-10-20 from https://www.theguardian.com/info/series/the-guardian-style-guide

• Kelly, C. (2025-10-18). Centrelink illegally cancelled Daniel’s jobseeker payment. He fought back against the system – and won. The Guardian. https://www.theguardian.com/australia-news/2025/oct/18/centrelink-illegally-cancelled-jobseeker-payment-tribunal-case

• Ombudsman Act 1976 (Cth).

• Schulz, L. (2000). Res Ipsa Loquitur in Australia — the maxim remains. 26(2) Monash University Law Review 379. https://www.austlii.edu.au/au/journals/MonashULawRw/2000/16.pdf

Date of decision: 29 August 2025

The Decisions Body decides that:

1. The name of the organisation is to be redacted in this decision and reasons for decisions.

2. █████ must have a full time staff member at each location in which █████ operates.

3. Decision 2 also applies to the location in which the Head of IT is based.

File number: SGDA2025/025

Catchwords: Corporations — Management—Staffing — Information Technology — Lack of available IT staff to handle requests

Number of paragraphs: 9

Note: This copy of the Decisions Body’s reasons for decision is subject to review to remedy minor typographical or grammatical errors.

REASONS FOR DECISION

POTTER DEL ATH

1 It has been submitted to the Decisions Body an application seeking for █████ (the Company) to have a full-time IT staff member at each location. The name of the Company has been redacted for reasons of anonymity.

2 The Applicant submits that at two of the locations where the Company operates, there is no constant presence of IT staff. At one of the locations, there is a part-time IT staff member and the IT manager.

3 The Applicant submits that there has been constant issues particularly with the printer that requires the attention of the IT department.

4 The Applicant also submits that due to a recent change to IT policy, only IT staff can reset customers’ passwords and not the reception staff. The Applicant states that they never had the power to reset the customers’ passwords.

5 The scope of the application only extends to the staffing and not the IT policy on password changes.

6 The Applicant also stated that many other IT issues that could have been resolved a lot quicker if there was an IT staff member on site. For anonymity reasons, I will not state them here but I agree with all issues that the Applicant has submitted.

7 The IT manager is based at one of the locations. I understand that due to their position, they cannot constantly be responding to queries that a subordinate can handle.

8 It is also completely impractical for there to be an IT staff member in the home of every employee works.

9 I therefore decide that:

(1) The name of the organisation is to be redacted in this decision and reasons for decisions.

(2) █████ must have a full time staff member at each location in which █████ operates.

(3) Decision 2 also applies to the location in which the Head of IT is based.

(4) Decision 2 does not apply to locations in which employees of █████ are working from home.

I certify that preceding nine (9) numbered paragraphs are true copy of the reasons for decision of M Potter, Delegate Authorised to Make Decisions.

Date:

Signature:

Date of decision: 22 July 2025

Decision(s): THE DECISIONS BODY DECIDES THAT:

1. The New South Wales Government should use “NSW” as the shortened form of “New South Wales” and not the letter “N”.

File number: SGDA2025/013

Catchwords: Names—Abbreviations—Abbreviations of names—Abbreviations of government entity names—Where New South Wales abbreviated to “NSW” that was further abbreviated to “N”—Whether New South Wales should be abbreviated to “NSW” or “N”.

Number of paragraphs: 23

Note: This copy of the Decision Body’s reasons for decision may be subject to review to remedy minor typographical or grammatical errors.

REASONS FOR DECISION

KALICHAVA DEL ATH

Background

New South Wales Government

1 Before the Decisions Body is an application for a decision regarding how the New South Wales Government (the Government) shortens “New South Wales” for its agencies.

2 The Government consists of the Executive Council (Constitution Act 1902 (NSW) s 35B) and Ministers of State (Ministers) appointed by the Governor of New South Wales (the Governor) (Constitution Act 1902 (NSW), s 35E).

3 The Government can employ people to form the public service (Government Sector Employment Act 2013 (NSW), s 21(1)) and “to enable Ministers to exercise their functions; to enable statutory bodies or statutory officers to exercise their functions; for any other purpose” (Government Sector Employment Act 2013 (NSW), s 21(2)(a)–(c)).

4 The Governor can use administrative arrangement orders to assign agencies to particular Ministers (Constitution Act 1902 (NSW), s 50B).

5 The agencies will need names of course in order to function. For the sake of brevity and because it was not in the original application, I will not go into how agencies get their names.

Abbreviations

6 Abbreviations have a long history, being used since Ancient Roman times (Partington, 1838). I will not go into much detail as the issue is not with the concept of abbreviations.

7 For the purposes of these reasons, abbreviation includes “shortening”, “contraction”, “initialism”, “acronym”, and “crasis”. Each does mean something distinct but I will use “abbreviation” and its variants in these reasons.

Current usages

8 Currently the Government uses both versions of abbreviation.

“NSW”

9 By far the most common abbreviated form of New South Wales is “NSW”. This is because of the Government’s tendency to have government agency names in the form of “[noun] NSW”. Here are some examples of the “[noun] NSW” name which will not include any “of NSW” names (Department of Customer Service, n.d.): Women NSW, Water NSW, Homes NSW (listed as a division and not an agency), Create NSW, Destination NSW, Liquor & Gaming NSW, Service NSW, Building Commission NSW, Revenue NSW, Training Services NSW, Careers NSW, Justice Health NSW, Fire and Rescue NSW, Cemeteries & Crematoria NSW, and Property and Development NSW.

10 The courts and tribunals of New South Wales use the abbreviation “NSW” in their medium neutral citations (New South Wales Case Law, n.d.).

11 There are also agencies that have “NSW” at the beginning of the name (Department of Customer Service, n.d.): NSW Electoral Commission, NSW Police Force, NSW Crime Commission, NSW Trustee and Guardian, NSW Small Business Commission, NSW Resources.

Building Commission NSW or NSW Building Commission

12 A note about Building Commission NSW. ABC News published an article detailing an alleged example of inaction on the part of Building Commission NSW. One of the factors of the inaction relates to the name of the Building Commission (Greenbank, 2025):

The regulator also took more than 16 months to deliver authorisation badges to staff who were legally required to identify themselves on worksites, which some feared might undermine investigations.

The delay stemmed from a long-running branding dispute over whether the new agency should be called the NSW Building Commission or Building Commission NSW.

13 You read that right, there was a dispute over the name that led to a delay in badges that in turn potentially impeded investigations. As I mentioned in [9], the name at the time of writing of these reasons is Building Commission NSW.

“N”

14 There are two prominent entities that I will write about here that go a step further and abbreviate the abbreviation, that is the NSW Education Standards Authority and the NSW Independent Casino Commission. Both entities use the following abbreviations: “NESA” (NSW Education Standards Authority, n.d.) and “NICC” (NSW Independent Casino Commission, 2024, p viii). The abbreviations of both initialisms abbreviate the already abbreviated form of New South Wales down to just the letter “N”.

Why “N” should not be used

15 The decision that I am making is that:

(1) The New South Wales Government should use “NSW” as the shortened form of “New South Wales” and not the letter “N”.

16 I have come to that decision because it will cause confusion as “N” in abbreviations can mean a wide variety of words.

17 The main confusion would be if “N” in an abbreviation means “New South Wales” or “National”. There are various countries that start with the letter “N” like Namibia, Nauru, Nepal, the Netherlands, New Zealand (this decision should be used as precedent if any New Zealand organisations use “N” instead of NZ in their abbreviations), Nicaragua, Niger, Nigeria, North Korea, North Macedonia, and Norway.

18 Confusion will be more apparent domestically as there are Australian Commonwealth agencies that use “N” as a shortening of the word “National”. Of which here are some examples: National Anti-Corruption Commission (NACC), National Capital Authority (NCA), National Disability Insurance Agency (NDIA), National Emergency Management Agency (NEMA), National Health and Medical Research Council (NHMRC), National Indigenous Australians Agency (NIAA), and the National Archives of Australia (NAA).

19 The word “National” being very generic is also used by agencies from other countries, such as the United States of America… there are too many to list here (USA.gov, n.d.). As well as the United Kingdom (Gov.UK, n.d.).

20 To avoid confusion, both the NSW Education Standards Authority and NSW Independent Casino Commission should use the abbreviation of NSWESA and NSWICC respectively. Both are not too long to write, albeit are now initialisms and not acronyms but if you force it to be acronyms it would be “en-swé-sa” and “en-sw-ik”.

21 There is also precedent for NSW being part of an abbreviation at the beginning of the abbreviation, the New South Wales Institute of Sport uses NSWIS as their abbreviation. It was established by the Government in 1995 with the Institute of Sport Act 1995 (NSW), that commenced on 1 December 1995 with the Institute of Sport Act 1995—Proclamation (Government Gazette of New South Wales, 1995, No 156, Page 8118).

22 There certainly will be certain costs associated with changing the abbreviations of the NSW Education Standards Authority and NSW Independent Casino Commission but analysing that is beyond the scope of this application for this decision, so it does not arise.

Disposition

23 Accordingly, the Government should use “NSW” as the shortened form of “New South Wales” and not the letter “N”.

I certify that the preceding twenty-three (23) numbered paragraphs are a true copy of the reasons for decision of A Kalichava, Delegate Authorised to Make Decisions.

Signature:

Date: 22 July 2025

References

• Constitution Act 1902 (NSW)

• Department of Customer Service. (n.d.). Departments and agencies. New South Wales Government. Retrieved 20 July 2025 from https://www.nsw.gov.au/departments-and-agencies

• Gov.UK. (n.d.). Departments, agencies and public bodies. HM Government. Retrieved 20 July 2025 from https://www.gov.uk/government/organisations

• Government Gazette of New South Wales. 1995. No 156. Page 8118. Institute of Sport Act 1995—Proclamation.

• Government Sector Employment Act 2013 (NSW)

• Greenbank, A. (2025, July 9). Building Commission NSW fails to seek fines for developers that lag on defect orders. ABC News. https://www.abc.net.au/news/2025-07-10/building-commission-nsw-fines-developers-delaying-defect-orders/105509562

• New South Wales Case Law. (n.d.). About. New South Wales Government. Retrieved 20 July 2025 from https://www.caselaw.nsw.gov.au/about

• NSW Education Standards Authority. (n.d.). About NESA. New South Wales Government. https://www.nsw.gov.au/education-and-training/nesa/about

• NSW Independent Casino Commission. (2024). 2024 Inquiry into The Star Pty Ltd (Volume 1). https://www.nicc.nsw.gov.au/sites/default/files/2024-08/2024%20Inquiry%20into%20The%20Star%20Pty%20Ltd%20-%20Volume%201.pdf

• Partington, C. F. (1838). Abbreviations. In The British cyclopaedia of the arts, sciences, history, geography, literature, natural history, and biography (Vol. 3). Wm. S. Orr and Company.

• USA.gov. (n.d.). A-Z index of U.S. government departments and agencies. United States Government. Retrieved 20 July 2025 from https://www.usa.gov/agency-index/n#N

Decision of: THE ASSISTANT SPEAKER-GENERAL

File number: SGDA2025/020

Date of decision: 15 June 2025

Date of publication: 16 June 2025

Catchwords: Journalism—Errors—Obvious errors—Where author of article used incorrect title—Where the Prime Minister of Canada was referred to as “Canadian President”.

Number of paragraphs: 7

DECISION

DECISION MADE BY: THE ASSISTANT SPEAKER-GENERAL

DATE OF DECISION: 15 JUNE 2025

THE DECISIONS BODY DECIDES THAT:

1. The Head of Government of Canada is titles the Prime Minister.

2. The Telegraph must correct the article in question (https://www.telegraph.co.uk/politics/2025/06/14/canada-is-sovereign-says-starmer-in-rebuke-to-trump/) by replacing “Canadian president” with “Canadian prime minister”.

3. The correction must be made by 11:59 pm AEST on 20 June 2025.

4. In the event that the correction be made, decision 2 will be considered followed and decision 3 will cease to have effect without needing a separate decision or reasons for decision.

REASONS FOR DECISION

THE ASSISTANT SPEAKER-GENERAL

1 On 14 June 2025, Ben Riley-Smith published an article for The Telegraph titled “Canada is sovereign, says Starmer in rebuke to Trump”. This article goes on about the British First Lord of the Treasury and Prime Minister the Right Honourable Sir Keir Starmer MP’s visit to the G7, a meeting with the Right Honourable Mark PC OC MP, and a statement about Canadian sovereignty.

2 I am not here to making decisions on geopolitics. I will leave that for others to do. What I am making a decision about here is a very obvious error that a “political editor” for a major British newspaper should not be making.

3 The following is a paragraph from the said article (Riley-Smith, 2025):

Sir Keir’s decision to meet Mark Carney, the new Canadian president, for talks in Ottawa before the summit is a clear show of support.

4 To anyone even remotely aware of how the Canadian system of government works, the error is obvious.

5 Canada follows the Westminster system of government (Constitution Act 1867 (Imp) (30 & 31 Vict c 3)). In following that system the head of the government has the title of Prime Minister as mentioned a few times in the Act 30 & 31 Vict c 3 and in the Letters Patent Constituting the Office of Governor General and Commander-in-Chief of Canada (The Canada Gazette, vol LXXXI, No 12) as the name of the position that counter-signed the proclamation containing a copy of the Letters Patent.

6 The website of the Prime Minister of Canada (pm.gc.ca) also makes it very clear what the title is.

7 For the reasons above, I make the following decisions:

(1) The Head of Government of Canada is titled the Prime Minister.

(2) The Telegraph must correct the article in question (https://www.telegraph.co.uk/politics/2025/06/14/canada-is-sovereign-says-starmer-in-rebuke-to-trump/) by replacing “Canadian president” with “Canadian prime minister”.

(3) The correction must be made by 11:59 pm AEST on 20 June 2025.

(4) In the event that the correction be made, decision 2 will be considered followed and decision 3 will cease to have effect without needing a seperate decision or reasons for decision.

I certify that the preceding seven (7) numbered paragraphs are a true copy of the reasons for decision of the Assistant Speaker-General.

Date: 15 June 2025

Signature:

References

• Canada. The Canada Gazette. Volume LXXXI. No 12. 1 October 1947.

• Constitution Act 1867 (Imp) (30 & 31 Vict c 3)

• Riley-Smith, B. (2025, June 14). Canada is sovereign, says Starmer in rebuke to Trump. The Telegraph. Retrieved 15 June 2025 from https://www.telegraph.co.uk/politics/2025/06/14/canada-is-sovereign-says-starmer-in-rebuke-to-trump/

Decision of: AIMERSMITH DEL ATH

File number: SGDA2025/019

Date of decision: 28 May 2025

Catchwords: Video games—Purchasing video games—Purchasing a video game when the buyer has hesitation—Hesitation due to perceived quality of video game—Video game sequel perceived to be of inferior quality compared to original—Where the video game has discount applied—Discount of 67%—Dying Light series—Dying Light 2.

Number of paragraphs: 8

DECISION

DECISION MADE BY: AIMERSMITH DEL ATH

DATE OF DECISION: 28 May 2025

THE DECISION BODY DECIDES THAT:

1. Dying Light 2 is best purchased when there is a discount applied.

2. The Anonymous Friend Group should purchase Dying Light 2.

REASONS FOR DECISION

AIMERSMITH DEL ATH

1 Dying Light 2: Stay Human was released on 4 February 2022. It was developed by Techland SA and was released to initially mixed to good reviews (Stuart, 2022; The_King_of_Okay, 2022). The game is “an action role-playing survival horror video game featuring a zombie apocalyptic-themed open world” (Wikipedia contributors, 2025).

2 On 26 May 2025, the online game distribution platform Steam started a sale called “Zombies vs Vampires Fest” (Valve Corporation, 2025b). The sale—as indicated by the name—is themed around zombies and vampires. As Dying Light 2 is a zombie game, a 67% discount was applied.

3 The normal retail price of the “Digital Extras Edition” of Dying Light 2 is $104.99 AUD and with the discount applied, the price is $34.64 (Valve Corporation, n.d.). This is the cheapest this bundle has been (SteamDB, 2025b) and the base game was a little cheaper (SteamDB, 2025a) but does not come with the extras from the Digital Extras Edition.

4 Amongst an anonymous group of friends (Anonymous Friend Group), there has been some hesitation about getting the game due to the comments made by various reviews. As the game has been so heavily discounted, it is now the best time to get the game, if one may be on the fence of purchasing or not.

5 Dying Light 2 does indeed feature co-op of up to four players (Williams et al., 2022).

6 If the individuals of the Anonymous Friend Group are not happy with the purchase, Dying Light 2 can be refunded in accordance to Steam’s refund policy (Valve Corporation, 2025a).

7 The Decisions Body as well as myself do not have any affiliation with Valve Corporation or Techland. This decision is a result of an application from a person who wishes to remain anonymous where there were questions as to whether or not to buy Dying Light 2.

8 Accordingly, the decision is that:

(1) Dying Light 2 is best purchased when there is a discount applied.

(2) The Anonymous Friend Group should purchase Dying Light 2.

I certify that that preceding eight (8) are a true copy of the reasons for decision of S Aimersmith, Delegate Authorised to Make Decisions.

Signature:

Date: 28 May 2025

References

• SteamDB. (2025a). Dying Light 2: Reloaded Edition Price history. SteamDB. https://steamdb.info/app/534380/

• SteamDB. (2025b). Dying Light 2: Stay Human Digital Extras Edition price history. SteamDB. https://steamdb.info/sub/1150220/

• Stuart, K. (2022, February 3). Dying Light 2: Stay Human review – as dead inside as the zombie hordes. The Guardian. https://www.theguardian.com/games/2022/feb/02/dying-light-2-stay-human-review-as-dead-inside-as-the-zombie-hordes

• The_King_of_Okay. (2022, February 3). Dying Light 2—Review Thread [Online post]. Reddit. https://www.reddit.com/r/Games/comments/siqug2/dying_light_2_review_thread/

• Valve Corporation. (n.d.). Dying Light 2 Stay Human: Reloaded Edition. Retrieved May 28, 2025, from https://store.steampowered.com/app/534380/Dying_Light_2_Stay_Human_Reloaded_Edition/

• Valve Corporation. (2025a, April 24). Steam Refunds. https://store.steampowered.com/steam_refunds/

• Valve Corporation. (2025b, May 27). Steam’s Zombies vs Vampires Fest is on now! Steam. https://store.steampowered.com/news/app/593110/view/500574015912411744

• Wikipedia contributors. (2025). Dying Light 2. In Wikipedia, The Free Encyclopedia. https://en.wikipedia.org/w/index.php?title=Dying_Light_2&oldid=1292463077

• Williams, C., Orr, J., & Pun, A. (2022, February 10). How to Play Co-Op—Dying Light 2 Guide. https://www.ign.com/wikis/dying-light-2/How_to_Play_Co-Op

Decision of: COX DEL ATH

File number: SGDA2025/012

Date of decision: 15 April 2025

Catchwords: Advertising—Advertising for films—Social media platforms—Horror movies—Where some advertisements for horror films use jump scares.

Number of paragraphs: 10

DECISION

DECISION MADE BY: COX DEL ATH

DATE OF DECISION: 15 APRIL 2025

THE DECISIONS BODY DECIDES THAT:

1. Jump scares should be discouraged from being used in advertisements for any instance of media.

REASONS FOR DECISION

COX DEL ATH

1 I have been tasked with deciding whether horror movie advertisements containing sudden jump scares ought to be discouraged, particularly in formats where users do not expressly seek out horror content—namely, on social media platforms such as YouTube and on broadcast television.

2 A jump scare is “something, such as a scene in a film, that shocks and frightens you so that you suddenly move or jump” (Cambridge University Press, n.d.). When used within films, jump scares can be very effective at frighting people. However, when deployed in advertisements, particularly where viewers have no warning or interest in horror, it is jarring, invasive and in most cases, it is unwanted.

3 In the context of online social media platforms and television, users are often watching shows that do not form part of the horror genre, these can include cooking videos, children’s programming, or educational material. Injecting horror ads with jump scares into such videos is not a matter of creative expression—it is a form of interruption that disregards audience context.

4 I believe that such advertisements are not intriguing—I find them irritating. Rather than building suspense or curiosity, they might prompt viewers to block the ad, avoid the film, or develop a negative impression of the franchise being promoted.

5 Unlike traditional marketing that seeks to entice and interest potential viewers, jump scare advertisements gamble on a one-second burst of fear. Depending on what is featured in the jump scare, whether it be a zombie nun or a possessed animation bear. This does not promote the movie’s plot, style, or uniqueness, instead, it leans on cheap shock.

6 If horror film advertisements want invoke fear in the view it can be done through other techniques such as an uneasy or unfamiliar atmosphere, lack of sound, and psychological tension. Consider scenes where there is no immediate threat, but a pervasive sense that something is wrong. Take for example an empty hallway lit too brightly, or a family eating dinner as if everything is normal but if you look closely to the background, eyes are peering through a window. These moments create dread not through audio or visual stimuli, but through the anticipation of danger.

7 It is not unreasonable to expect platforms and advertisers to exercise discretion or to abide by this decision. I humbly request that production companies at least consider my reasons

8 Targeting systems already exist for advertisements. There are algorithms that serve you advertisements based on the viewing, search history, and various other factors (Pepper, 2024). Either use more data to serve more relevant advertisements, though I understand why some people may not be in favour of major technology companies have more of people’s data or not serve film advertisements at all. There should be a solution in between those scenarios. Finding that middle ground, however, is out of the scope of the application submitted to the Decisions Body and the reasons for my decision.

9 Though for the most part I have only mentioned horror films, this must apply to any horror-related media, including but not limited to video games, television shows, and books (although I cannot remember a time that a book was advertised on television with a jump scare).

10 With consideration to my reasons, I decide that jump scares should be discouraged from being used in advertisements for any instance of media.

I certify that that preceding ten (10) numbered paragraphs are a true copy of the reasons for decision of C Cox, Delegate Authorised to Made Decisions.

Signature:

Date: 15 April 2025

References

• Cambridge University Press. (n.d.). Jump scare. In Cambridge English Dictionary. Retrieved 10 April 2025, from https://dictionary.cambridge.org/dictionary/english/jump-scare

• Pepper, F. (2024, April 25). How social media is showing us what we like, rather than letting us find out for ourselves. ABC News. https://www.abc.net.au/news/2024-04-25/how-social-media-algorithms-are-flattening-culture/103735868

Decision of: THE SPEAKER-GENERAL

File number: SGDA2025/016

Date of decision: 10 April 2025

Catchwords: Speaker-General’s Decisions Body—Appointments—Delegates Authorised.

Number of paragraphs: 3

DECISION

DECISION MADE BY: THE SPEAKER-GENERAL

DATE OF DECISION: 10 APRIL 2025

THE DECISIONS BODY DECIDES THAT:

1. The following persons have been appointed as Delegates Authorised to Make Decisions for as much time the Speaker-General sees fit:

   1. B Cramston

   2. C Cox

   3. S Aimersmith

   4. M Gibstone

   5. P Rathbone

   6. M Granville

   7. M Potter

   8. D Softower

   9. L L’Estrange

   10. A Butcher

   11. J Baker

   12. C Candlestickmaker

   13. K Bear

REASONS FOR DECISION

THE SPEAKER-GENERAL

1 I am pleased to appoint the following persons as Delegates Authorised to Make Decisions to the Speaker-General’s Decisions Body:

• B Cramston

• C Cox

• S Aimersmith

• M Gibstone

• P Rathbone

• M Granville

• M Potter

• D Softower

• L L’Estrange

• A Butcher

• J Baker

• C Candlestickmaker

• K Bear

2 The appointments will take effect from the date of publication of this decision.

3 Any similarity of the names of persons appointed to any real life person is entirely coincidental.

I certify that that preceding three (3) numbered paragraphs are a true copy of the reasons for decision of the Honourable the Speaker-General.

Signature:

Date: 10 April 2025

Decision of: THE ASSOCIATE SPEAKER-GENERAL

File number: SGDA2025/007

Date of decision: 12 February 2025

Catchwords: Entertainment—Films—Artificial intelligence—Where a film was made using artificial intelligence—Where the trailer for the film was released

Number of paragraphs: 5

DECISION

DECISION MADE BY: THE ASSOCIATE SPEAKER-GENERAL

DATE OF DECISION: 12 FEBRUARY 2025

THE DECISIONS BODY DECIDES THAT:

1. TCLtv+ must stop with the production and release of the work Next Stop Paris.

2. Decision 1 on is backdated to 13 April 2024.

REASONS FOR DECISION

THE ASSOCIATE SPEAKER-GENERAL

1 On or around 12 April 2024, TCLtv+ uploaded to their YouTube channel a trailer to an alleged production called Next Stop Paris (TCLtvplus, 2024). The description states that “Next Stop Paris marks the first AI production from TCLtv+, and a first step into original content production” and that “[t]he special is animated by a global team including artists from the US, Canada, UK, and Poland” (TCLtvplus, 2024).

2 It has been 10 months since the publication of the trailer and in those 10 months, there appears to have been no other mention of Next Stop Paris from TCLtv+.

3 There is general backlash for using artificial intelligence (AI) in creative endeavours due to AI taking work away from artists and using artworks as AI training material where permission may not have been sought (Di Placido, 2024, Shaffi, 2023). In an apparent and brazen attempt at controlling the amount of backlash against Next Stop Paris, TCLtv+ has disabled the comments under the trailer. People will find other platforms for expressing their discontent at the use of AI to make this production.

4 TCLtv+ should stop production of Next Stop Paris and work with real actors and actresses to make a real film rather than what ever appears in the trailer.

5 I will backdate the stop decision to the day after the trailer released, being 13 April 2024.

I certify that that preceding five (5) numbered paragraphs are a true copy of the reasons for decision of the Associate Speaker-General.

Signature:

Date: 12 February 2025

References

Di Placido, D. (2024, May 30). AI is generating online backlash and mockery. Forbes. https://www.forbes.com/sites/danidiplacido/2024/03/28/how-the-generative-ai-backlash-took-over-the-internet/

Shaffi, S. (2023, January 23). ‘It’s the opposite of art’: why illustrators are furious about AI. The Guardian. https://www.theguardian.com/artanddesign/2023/jan/23/its-the-opposite-of-art-why-illustrators-are-furious-about-ai

TCLtvplus. (2024, April 12). Next Stop Paris | Trailer | TCLtv+ [Video]. YouTube. https://www.youtube.com/watch?v=KhQnnISdDIU

Decision of: SNARSKI DEL ATH

File number: SGDA2024/010

Date of decision: 27 December 2024

Catchwords: Non-judicial review—Appeal from New South Wales Civil and Administrative Tribunal—Procedural fairness—Whether the Tribunal ought to recuse itself on the ground of apprehended bias—whether information sought in the applicant’s request is held by the respondent.

Number of paragraphs: 12

DECISION

SGDA2024/010

DECISION MADE BY: SNARSKI DEL ATH

DATE OF DECISION: 27 DECEMBER 2024

THE DECISIONS BODY DECIDES THAT:

1. Appeal dismissed.

2. Senior Member Michelle Riordan gets full commendation for including excerpts of the hearing transcripts in her reasons for decision.

3. Mr Akhil Sethi gets a modicum of appreciation.

REASONS FOR DECISION

SNARSKI DEL ATH

Introduction

1 I have granted an application for non-judicial review that the Decisions Body has received. The application is in regards to an appeal from the New South Wales Civil and Administrative Tribunal (the Tribunal) in the case of Sethi v Secretary, Department of Communities & Justice [2024] NSWCATAD 35 (Sethi No 1).

2 The application appeals the orders made by NCAT. Those being:

(1) The applicant’s request that I disqualify myself from conducting these proceedings on the ground of apprehended bias is refused.

(2) The decision under review is affirmed.

3 The application also sees to answer another question, that being: “Should Mr Akhil Sethi be commended for bringing to the people of NSW an entertaining and fun decision?”

4 I will not consider the appeal for orders 1 and 2 as the decision was appealed to the Appeal Panel of the Tribunal.

Original Tribunal Decision

5 Sethi No 1 was decided by was decided by Senior Member Michelle Riordan on 14 February 2024. Mr Sethi made an application to the Executive Director and Principal Registrar of the Supreme Court of New South Wales seeing access to information under the Government Information (Public Access) Act 2009 (NSW) (the GIPA request). The GIPA request can see found in [1] of Sethi No 1.

6 I will not go much further to describe the background of the case as Member Riordan describes it very well (Sethi No 1, [1]–[17]).

Appeal

7 The reason I will not consider the appeal of orders 1 and 2 of Sethi No 1 is that it was appealed to the Appeals Panel of the Tribunal in Sethi v Secretary, Department of Communities and Justice [2024] NSWCATAP 142 which was decided by Deputy President M Harrowell.

8 Deputy President Harrowell ordered that:

(1) Pursuant to s 50(2) of the Civil and Administrative Tribunal Act 2013, the Appeal Panel dispenses with a hearing of the application to dismiss the appeal.

(2) The appeal is dismissed and the hearing on 9 August 2024 is vacated

9 I agree with the reasons that Deputy President Harrowell and the orders that the Appeal Panel of the Tribunal makes.

Commendation for an Entertaining and Fun Decision

10 The final question that was in the application is this:

Should Mr Akhil Sethi be commended for bringing to the people of NSW an entertaining and fun decision?

11 Mr Sethi was the person who initiated the GIPA request to the Department of Communities and Justice (DCJ). Mr Sethi was the person to initiate action in the Tribunal. Mr Sethi was the person to appeal. However Mr Sethi cannot take full commendation for the decision. It was Senior Member Michelle Riordan who made the orders and wrote the reasons for decision with extracts of the hearing ([22]–[25], [27], [66]–[67] of Sethi No 1).

12 As the transcripts of Tribunal hearing are hidden behind a palaver of a process that involves requesting an audio recording of the hearing from the Tribunal by filling a form, sending it in person or by post, and getting a private transcription company to transcribe the hearing (New South Wales Civil and Administrative Tribunal, 2024). Considering that, Senior Member Michelle Riordan should get full commendation and Mr Sethi should not get commendation for his behaviour in the Tribunal hearing but gets some appreciation for going through with the effort of paying $30 for a GIPA request and appealing to the Tribunal after feeling that DCJ wronged him when handling the GIPA request.

I certify that the preceding twelve (12) numbered paragraphs are a true copy of the reasons for decision of E Snarski, Delegate Authorised to Make Decisions.

Signature:

Date: 27 December 2024

References

• Ebner v Official Trustee in Bankruptcy (2000) 205 CLR 337; [2000] HCA 63

• Gaudie v Local Court of New South Wales & Anor [2013] NSWSC 1425.

• Government Information (Public Access) Act 2009 (NSW).

• New South Wales Civil and Administrative Tribunal. (2024, August 26). Sound recording and transcripts. https://ncat.nsw.gov.au/how-ncat-works/after-the-hearing/sound-recording-and-transcripts.html

• Sethi v Secretary, Department of Communities & Justice [2024] NSWCATAD 35.

• Sethi v Secretary, Department of Communities and Justice [2024] NSWCATAP 142

Decision of: THE DEPUTY SPEAKER-GENERAL

Date of decision: 9 December 2024

Catchwords: Video games—Simulators—Flight Simulators—Microsoft Flight Simulator 2024—Career Mode—Where simulation rate can be sped up—Where a forum user raised issue on forums—Where changeable simulation rate raised as bug.

Number of paragraphs: 18

DECISION

SGDA2024/020

DECISION MADE BY: THE DEPUTY SPEAKER-GENERAL

DATE OF DECISION: 9 DECEMBER 2024

THE DECISIONS BODY DECIDES THAT:

1. Asobo should not disable the changing of sim rate in the Career Mode of Microsoft Flight Simulator 2024.

2. If Asobo disables the changing of sim rate in the Career Mode of Microsoft Flight Simulator 2024 in a future update, it should be reversed.

REASONS FOR DECISION

THE DEPUTY SPEAKER-GENERAL

1 Microsoft Flight Simulator 2024 (MSFS2024) was developed by Asobo Studio was released on 20 November 2024 to negative reception (Livingston, 2024). One of the new features of MSFS2024 is Career Mode that allows players to earn certifications, manage companies, and do missions (Baqery, 2024).

2 A feature of MSFS2024 is to change the simulation rate (sim rate). The sim rate can be sped up or slowed down. This feature is useful as flights can often be long and speeding up time can be useful.

3 A user on the Microsoft Flight Simulator Forums (FS Forums) by the name of Shack371 posted in the Bug Reporting Hub wanting sim rate adjustment to be disabled (Shack371, 2024).

4 Shack371’s as well as others’ reasons for wanting to sim rate to be disabled are as follows: (1) it is disappointing; (2) the ability to skip sections exists; (3) it is cheating the system.

5 I will rebut each point.

6 First point, it is disappointing. Your personal opinion should not dictate the enjoyment of others.

7 Second point. Sure, the ability to skip sections of a mission exists, such as skipping to taxiing, take-off, descent, and parking. The pay-outs of missions when the main flying part is skipped is minuscule when compared to not skipping. For example, if a job that pays out 3,500 credits, skipping the main flying would result in a pay-out of around 300–500 credits. Not skipping or speeding up the simulation rate would have the full pay-out of 3,500 credits.

8 Not everyone will have the time to fly an entire mission. Some missions in MSFS2024 are 30 minutes, however some may last three or four hours. People with—you know—responsibilities like a job or a family to take care of will not have the time to fly four-hour missions. The longer the mission, the more it pays out so people with lives will have more of a grind to earn credits to advance their virtual pilot career as certifications like instrument flight rules, turboprop planes, jet planes will require certifications that costs credits. When players have enough money to start their own company, they will have to buy planes that costs hundreds of thousands of credits. Being able to speed up missions will help people with lives to advance quicker through the career and therefore have better enjoyment out of the game and feel that they have gotten a better value for money from paying the AU$110 price tag.

9 Third point. I would not consider changing the sim rate to be cheating the system as it is a feature that is available for players to use. By default the controls for changing the simulation rate are not bound to any keys but they can be bound to keys and activated during Career Mode. Changing the sim rate also existed in the Missions Mode of Microsoft Flight Simulator X so it is not a new concept.

10 Other users in the replies to Shack371 on the FS Forum post have also commented in support with their own reasons and justifications. I shall deal with them.

11 AngusDLX2 in a reply Shack371 to compares changing the sim rate to “going into Euro Truck Simulator and changing the maximum speed of a truck from 80 km/h to 600 km/h just to deliver a cargo faster.” This is a bad analogy. Firstly, by default, trucks in Euro Truck Simulator 2 are limited to 90 km/h not 80 km/h (through some countries have a maximum posted speed limit of 80 km/h). Secondly, it is not possible to change the speed of trucks to 600 km/h. Mods do exist that have more powerful engines but faster you drive, the more uncontrollable the truck is so you are going to crash and the trip will end up being slower due to crashing everywhere. Euro Truck Simulator 2 is a brilliant example of developers giving players choice by allowing players to make the game easier with simplified controls, being able to turn off fatigue and traffic fines, the softness of suspension, how easy the truck and trailer can tip over, amongst other options.

12 Shack371 responds to AngusDLX2 expressing their previously state point about skipping sessions and adding an additional reason why sim rate adjustment should be disabled being that it is unfair. Unfair to who though? I get the fairness argument if Career Mode is a multiplayer mode where players’ companies are versing each other for market share. The Career Mode is a single player mode. Players in single player modes should be able to play how they want and developers should be accommodating of this like SCS Software have done with Euro Truck Simulator 2 as I mentioned in the previous paragraph. A point that is seconded by LanglestOne. I agree with B101UKNo1 who states that skipping section removes gameplay as even when the sim rate is sped up, players will still have to pay some attention as it will be quicker for the plane to crash or if some other event happens.

13 GaugeForever makes the brilliant point of why some players, want other to play a game or use a simulator like how they want. Instead of players having the freedom of play style without an over-intrusive player dictating that something should be played a certain way.

14 FierceXerxes brings up the point that Euro Truck Simulator 2 is scaled down. Time and scale is not one-to-one in Euro Truck Simulator 2 so trips across Europe do not take days. Also Euro Truck Simulator 2 has the ability to save mid drive, a feature that MSFS2024 currently lacks.

15 DirtMerchant132 reinforces the point from [13] saying:

[A]bsolutely indefensible take - your time may not be worth much, but many of us feel that ours is. single player game, stay in your lane. not to mention this argument is so far down the list of needed fixes it doesn’t bear discussion.

16 Sim rate adjustment should not be disabled. The opinions of a select few hardcore sweaty flight simulator players should no impact the enjoyment of the hundreds of thousands of players to play MSFS2024 for fun. If players want to play by following all procedures to the letter, they should. If players want to play by speeding things up, they should. To each their own.

17 To note, at the writing of these reasons, the forum post Shack371 made in the matter of disabling sim rate adjustment sits at 15 votes (Shack371, 2024). A post about not disabling the adjustment of sim rate in career mode sits at 226 votes (E1ephant42, 2024). This is a clear indication of community consensus.

18 For these reasons, Asobo should not restrict the changing of sim rate in the Career Mode of MSFS2024. If they do, I decide that Asobo should reverse their decision to disable the changing of sim rate.

I certify that the preceding eighteen (18) numbered paragraphs are a true copy of the reasons for decision of the Deputy Speaker-General.

Signature:

Date: 9 December 2024

References

• Baqery, M. (2024, December 1). MSFS 2024: Complete Career Mode Guide (Missions, Companies, Specializations). Game Rant. https://gamerant.com/msfs-microsoft-flight-simulator-2024-career-mode-specialization-guide/

• E1ephant42. (2024, December 4). Please Do Not Disable Simrate In Career Mode [Online forum post]. Microsoft Flight Simulator Forums. https://forums.flightsimulator.com/t/please-do-not-disable-simrate-in-career-mode/680465

• Livingston, C. (2024, December 6). Microsoft Flight Simulator 2024 dev apologizes for “what can only be described as an awful launch experience.” PCGamer. https://www.pcgamer.com/games/sim/microsoft-flight-simulator-2024-dev-apologizes-for-what-can-only-be-described-as-an-awful-launch-experience/

• Shack371. (2024, November 24). Simrate Adjustment must be disabled in Career mode! [Online forum post]. Microsoft Flight Simulator Forums. https://forums.flightsimulator.com/t/simrate-adjustment-must-be-disabled-in-career-mode/672454