The Committee took a submission from CANCOM on the Administrative Adjudication of Road Offences (AARTO) Amendment Bill. CANCOM acts on behalf of large companies with fleets, or rental companies, and thus has continuous and first-hand experience of the processes under the AARTO Act. At the outset it stressed that it fully supports the principles behind the Act, and the legislation, but has been continuously seeking better administration of the processes to achieve the aims of addressing the behaviour of the drivers who have actually breached the Act. It made the point that because over the last twelve months no fines have in fact been issued by registered mail, and because traffic departments have not been redirecting infringement notices, there has not been any change in behaviour. There is still not provision in the Act for infringements incurred by foreigners and CANCOM therefore feels it has no option other than to call for cancellation of the fines. Where infringements have not been administered properly, attempts at enforcement fail because they are deemed illegal. Medical emergency companies infringements are not being administered, which causes medical response vehicles to be unable to renew their vehicle licences. It cited various instances where constitutional rights have been infringed.
Ms Olinsky then went on to discuss some of the proposed changes. CANCOM felt that the proposal to insist upon certified copies rather than ordinary photocopies would lead to huge administrative difficulties, particularly since Commissioners of Oaths may not charge, and this would affect car rental business. More clarity was requested on date of service. Although electronic service was defined and therefore accepted there was no clarity on the exact form that it could take. There was a question over how the habitual offender provisions would operate, and CANCOM expressed concern that labelling a proxy as a habitual offender, and indeed holding a proxy liable at all, was not only ludicrous but an infringement of the proxy's constitutional rights under sections 34 and 35 of the Constitution. It was opposed to “any other“state institution being permitted to be involved as issuing authority, partially due to the lack of training but also the potential for corruption. CANCOM stressed that the Bill should be amending the Act to provide for the specific position of fleet companies; this was something CANCOM had requested numerous times from RTIA but it had never been granted the opportunity to meet with RTIA to discuss.
Members commented that many of the submissions now made by CANCOM repeated what it had said in relation to earlier versions of the Bill, and asked for comment whether it did not feel that the changes made addressed the problems. They asked CANCOM to clarify its fears that the Tribunal could be both player and referee, why exactly it was seeking a special dispensation for drivers of hired cars, why the certified copies would be a problem and why it was concerned that more drivers would elect to go to court. They asked how much of the fines levied had been paid or challenged. Members asked CANCOM to come up with specific proposals. The Chairperson suggested that the Committee needed to interact with the rental companies directly.
The Road Traffic Infringement Agency (RTIA) then responded to comments made in earlier submissions, by Business Unity SA (BUSA) Driving.co.za, OUTA and individuals, as well as the comment by CANCOM. Many of the submissions had dealt with similar issues. BUSA was also concerned about the administrative issues. Several submissions had deal with the removal of the references to sheriffs and the RTIA explained that this was because mention of sheriffs meant a court process and that the broader options now proposed meant that service by sheriffs would not always be necessary. RTIA was satisfied that no loopholes were being created. The sheriffs were appointed in terms of Sheriffs Act 90 of 1989. Several submissions had been made that assumed that rehabilitation programmes would be applied only to habitual offenders, but RTIA clarified that they were voluntary and open to all. The time limits were also questioned and explained. Further clarity was given on what “infringements” meant and how the Criminal Procedure Act and AARTO were linked. Driving.co.za feared that the Tribunal will not have sufficient capacity to deal with potentially millions of referrals each year, but RTIA noted that its capacity would be reviewed and it might be quasi-permanent. It would be a central location and its functions were clarified. RTIA conceded that there might be a perception that if it was funded by revenue from RTIA it might be seen as not independent, and said it would look into other funding options. OUTA submissions about penalties being imposed without hearings was explained in the context of section 17 of the Act. RTIA noted that other submissions suggested that the public needed to be better informed on how the current system worked, and it would consider either holding workshops or better communication and explanations on its website. Comments by Neil Louwrens suggesting new wording for “sent and/or received” in relation to service, and mechanisms to obtain electronic address information, were appreciated and would be considered. RTIA noted that some submissions from CANCOM did not actually address the Bill. Some matters were covered already. It was stressed that the election to apply to the Appeals Tribunal was an additional process that would hopefully avoid premature lodgment of expensive review applications in court. The right of access to court review is not taken away.
Members asked if there were draft regulations on the rehabilitation programmes, the reasons why notices were not received on time, why proxies were being charged, whether those unable to pay fines would be referred to the Tribunal and to give a summary of the common concerns and feeling around the Bill. These questions would be responded to at a later meeting.
Administrative Adjudication of Road Traffic Offences (AARTO) Amendment Bill: CANCOM submission
Ms Lauren Olinsky, Managing Director, CANCOM, expressed thanks for the opportunity to present comment on the Bill.
She then outlined the problems that CANCOM foresaw. The first had to do with service. At present, no AARTO fines had been issued via registered mail for approximately the last 12 months. The Johannesburg and Tshwane Metropolitan Police had not redirected any Infringements at all. There was still nothing providing for the collection and administration around infringements incurred by foreigners. It had been found that enforcement orders were issued on Infringements that should have been administered, thus deeming the enforcement orders “illegal”. The infringements of medical emergency companies were not being administered, thus causing medical response vehicles to be off the road due to being unable to renew their vehicle licenses. Other infringements of the constitutional rights of individuals were occurring in relation to ,section 32 “Access to Information”; section 33 “Just Administrative Action”; section 34 “Access to Courts” and section 35 “Right to a Fair Trial”.
She made the point that if, as stated, the purpose of AARTO was to improve road safety and reduce bad road behaviour resulting in accidents and death, then why did the custodians of AARTO not want to implement achievable administrative processes to ensure that this happened? Driver behaviour will only change if the correct offender is being held liable and this is currently not happening.
Ms Olinsky said that, on average, CANCOM received a fine receipt per month of 50 000 infringements and notices at a monthly average amount of R 18.75 million. (This is a somewhat reduced amount being presented at R 375.00 per infringement).
The impact of not redirecting infringements to the correct offenders resulted in the following:
- actual habitual offenders were never held liable
- there was increased lawlessness
- there were ongoing accidents and road deaths caused by speeding and lawlessness
- National road safety figures were negatively increasing
- lawlessness was also seen in the low or non-collection of infringement money
- the fact that the wrong individuals were being held liable resulted in flooding of the courts (and this would extend to the proposed Tribunal) with unnecessary cases
She went on to deal with the court case of Fines 4 U. Although CANCOM had had many dealings with the custodians of AARTO, both good and bad, as well as having launched a few court cases, these cases had never been discussed in the media, and CANCOM had never felt the need to bring any of these matters to the media’s attention. The judgment in the Fines 4 U case, however, was highly published in the media. She expected that the public would use this judgment in their favour, and so would other companies with immoral motives.
She stressed that CANCOM has always supported the roll-out of AARTO, although it had made the point that it needs to be administratively correct.
Ms Olinsky then went on to discuss some of the proposed changes. On page 1, there was a change of wording in relation to “acceptable identification” - from a photocopy to a clear certified copy of the applicable certificate of document referred to in paragraphs (a) to (e). CANCOM believed that this was neither practical or feasible. It is already difficult to present a copy of an ID of a driver renting a vehicle due to the sheer volumes involved. It is not feasible to obtain a certified copy from a rental client on every occasion. Commissioners of Oaths cannot be employed for such purpose by the car rental companies, and she stressed that a Commissioner of Oaths is not permitted to charge a fee for this service. Clients - including foreign clients who hire vehicles - will not be in a position to obtain certified copies. This requirement will negatively impact on the business of car rental companies.
In relation to the definition of “date of service”, this definition had changed from the date on which the infringer signed, to the date of receipt. She asked how the date on which an infringement notice was received, particularly important given the strict time lines implemented by the AARTO Act.
“Electronic service “ was defined as service by means of an electronic communication, as defined in the Electronic Communications Act of 2005. Despite the intimation that electronic service was allowed, there was not a clear provision for this. She enquired whether this would, for example, include SMS Delivery, E-mail Delivery, e-Postal Delivery. If so, to whom will the notifications for businesses be sent. She further enquired if this would allow any person or company to enter into a electronic interface with the current eNatis System that is currently running successfully between ABSA and eNaTIS?
She asked if the electronic service will allow for nominations and representations to be submitted electronically?
Ms Olinsky then noted that the intention was seemingly to be able to label a proxy as a “habitual offender” meaning that the proxy will ultimately have demerit points against him/her at all times and will be “disqualified” as a legal driver. This provision is grossly unfair and an infringement of the constitutional rights of the proxy, including those under section 34 and 35 of the Constitution. Furthermore, the proxy of a company is seemingly being held responsible for all offences allegedly incurred by any vehicle that is registered in the name of the company. This is ludicrous, as it logistically impossible that a proxy can drive multiple vehicles at the same time.
She then commented on the altered definition that “issuing authority” means (d) any other state institution declared by the Minister by regulation to be an issuing authority.
CANCOM is in agreement that the Demerit Point System should include drivers with learners licenses, but made the point that any issuing authority would need intense training, guidance and management, and CANCOM does not believe that “any other” state institution should simply be given the “rights” of an Issuing Authority. She backed this up by saying that there is major corruption in numerous state licensing departments, and that a large number of individuals have recently been arrested for false transactions. These same individuals have removed “enforcement orders” and “blocks” against various entities during their corrupt dealings. As recently as last week she had received an e-mail stating that she could get all my AARTO Fines discounted by 70%. She was very concerned that this type of corruption will flow over into the demerit point system.
Ms Olinsky summarised the problems that CANCOM had identified with the Bill. She concluded that there is a need for provisions in the Act and Regulations to accommodate fleet companies. The current AARTO Act and some of the proposals could work for the individual, but these proposals that she had outlined were making it impossible for the fleet owners to comply. She suggested the need for a sufficient and cost effective electronic system that fleet companies can use to obtain their liability, to make representations and payments (as is currently working with ABSA). She proposed that companies or entities such as CANCOM should be given the opportunity to discuss concerns and issues (as they experienced these on the ground on a daily basis) and afford such companies the time to “fix” problems. She stressed that CANCOM had requested - no less than 15 times - a meeting with the RTIA to discuss these issues. She was adamant that the proxy cannot be held liable for all infringements and this was a matter that needed urgently to be addressed.
Ms T Xego (ANC) said that many of the submissions on the Bill had been made on previous versions of the Bill and that she thought that many of the concerns had in fact already been catered for, by the proposed amendments in this version.
She commented on the particular concern about the Tribunal being seen as both player and referee. The Bill stated there that the tribunal is independent of the process. She pointed out that the amendments were essentially to cut out the loopholes that were found with the Act.
Mr L Ramatlakane (ANC) also commented on the characterisation of the tribunal as a referee and a player. He could not understand why there was opposition to the concept of the Tribunal, and how those making submissions objecting to it saw the Tribunal; was it the question of how it was staffed, so that there was an impression that representations would be made to one person.
Mr Ramatlakane asked why drivers of hired vehicles that are represented by CANCOM as a middleman should be treated differently from ordinary drivers, and why should there be a special legislation for those drivers who had committed the same offences as other drivers. He asked for specific suggestions as to how the legislation should cater for this situation. In particular, he asked why CANCOM thought that there was a problem with producing copies of the ID documents.
Mr Ramatlakane also asked what the problem was if a driver elected to go to court. He pointed out that there must be an agreed administrative process to follow, as set down by law.
Mr G Radebe (ANC) said that most of the issues raised by CANCOM had been addressed by RTIA and he asked CANCOM to check the latest reports. .He asked for clarity on slide , where CANCOM mentioned about 50 000 infringements and notices, and asked how much of that amount had been paid to RTIA, and how much had been challenged as a result of allegedly incorrect processes.
Mr M Sibande (ANC) commented that this platform was for people to give proposals, not only to criticise. He asked who CANCOM is representing, and whether they were legal or illegal foreigners and individuals. The aim of the Bill was to encourage legitimate and better behaviour. He asked for clarity on the suggestions around representation at the Tribunal. He asked what CANCOM would suggest to counter the fear of the courts being flooded with cases, and again asked that CANCOM produce concrete proposals.
Ms Olinsky said that since she had last presented to this Committee there had in fact been no improvement in terms of the administration of matters under the AARTO Act. CANCOM had not come to the Committee to criticise and had not in any way suggested that it would like to see the AARTO Act scrapped. CANCOM was trying to make suggestions that would actually make the Act effective because if the country was serious about changing road behaviour, it would have to correct the inadequacies that were not making that happen under the current Act.
She cited an example – if infringements were not received, by registered mail, for over 12 months, this meant that the infringements would not be received on time, and that CANCOM was therefore unable to direct them to the correct offender. There mere fact that there was still such a high death toll over December and January meant that the system had not targeted and corrected the behaviour of the real offenders. Car rental companies were trying to administer in excess of 150 000 infringements a month, which meant that they were simply not reaching the correct offenders. The proxies should not be held liable for fines, because the proxies had not incurred them and this too would not change the behaviour of the drivers. This was a point brought up in the previous presentations, but the same problems were still seen.
The point that she had made about the copies of the ID and drivers licence was that whereas previously, copies only were adequate, the Bill was now proposing that certified copies were needed. Who would the commissioners of oaths be to certify 200 car infringements every month. That was simply an impossible administrative task. If nominations were done by the eNatis electronic link, the only information that was needed is the South African ID number and the driver licence number. She could see no reason to demand any more than this in a manual process.
Ms Olinsky then addressed the questions around the independence of the Tribunal process. CANCOM believed that if the infringement was brought within the 33 days after issuance, to the correct driver, then there would not in fact be a need for a Tribunal, because there would not be a need to challenge it. However, under the current system, the infringements have been dealt with properly. The proxies were being held liable because of that administrative failure. The proxies now had no option other than to take the matter to court. As mentioned already, the proxies are not liable for infringements and it would be physically impossible for the proxies were to drive all the cars at the same time. It was therefore clearly incorrect to try to hold them liable and that was the reason for the challenge.
Ms Olinsky then amplified the problems with the Tribunal process. CANCOM found it confusing why the Tribunal had been set up. One must pay for cases to be heard there, and this escalated the financial problems. Currently any summons under the Criminal Procedure Act would be taken to the Public Prosecutor. There was a problem with traffic fines being redirected.
She stressed that the AARTO Act does not address infringements incurred by international drivers, commonly known as foreigners. Approximately 40% of cars rented in South Africa are rented by foreigners, so it made no sense not to provide for them. CANCOM cannot nominate an infringement notice to a foreigner, as they refuse to accept it. It would normally therefore ask that the fine must be cancelled. The proxy cannot be held liable for the infringement – again, because the proxy was not driving the vehicle. The option that a proxy would take would be to elect to be tried in court to verify the name of the person actually liable. The point is that these issues really needed to be dealt with before they reached that stage.
Ms Olinsky agreed with Mr Ramatlakane that drivers must have drivers licences and should understand the law.
Ms Olinsky then dealt with the comment about CANCOM as the middle-man. CANCOM represented the proxies of the companies that are clients of CANCOM. Its main aim is to ensure that whenever a traffic fine has been imposed, the fine will be sent or nominated to the driver who actually committed the offence. She was not suggesting that the law should be any different for rental companies. However, she was suggesting that there should be a simpler process for companies that, because of the nature of their business, do incur large numbers of traffic fines. It is an unfortunate situation for a car rental business that its rental clients will incur large amounts of traffic fines, but at the moment the Act is not assisting the rental companies to comply properly with the Act, because of the way it is worded.
The Chairperson said she is concerned that they are dealing with the proxy, which is the middle man of car rental companies. She asked at what stage the Committee could interact with the rental companies themselves and hear their side of the story.
Ms Olinsky said there was a representative from one of the car rental companies present. Her point was that the Tribunal would be flooded with cases unless the RTIA was able to find a way to administer the . infringements properly. Car rental companies will not pay, but will challenge, infringements that are not in their own name. Those infringements should be redirected to the drivers who actually committed the offence.
Administrative Adjudication of Road Traffic Offences (AARTO) Amendment Bill: Road Traffic Infringement Agency (RTIA) responses
Response to Business Unity SA submission
Mr Thabo Tsholetsane, Chief Operations Officer, RTIA, thanked the Committee for the opportunity to respond to comments made by Business Unity South Africa (BUSA) on the AARTO Bill. Some of the comments from BUSA talked about operational issues but one critical one related to the AARTO Amendment Bill itself.
BUSA firstly commented on the issue of date of service and date of electronic service, which is covered in terms of clause 1 of the AARTO Act. RTIA pointed out that the electronic service will be offered as another method of service. The efficiencies of electronic service have already been tested under Electronic Communications Act, 2005.
BUSA then commented on the nature of the infringements. RTIA clarified that AARTO is an administrative statute that covered both the Criminal Procedure Act (CPA) and National Road Traffic Act (NRTA) matters, where the high impact offences were handled under the CPA, and the lower impact offences under the AARTO. The AARTO was introduced in the first instance to alleviate the burden on courts and it aims to change the driver behaviour, rather than focusing on collection of money for its own sake.
BUSA then commented on the clause around warrants. This was linked to the repeal of section 21 of the Act, which dealt with issuing of warrants. He explained that the appointment of sheriffs and issuing of warrants fell outside of the administrative scope and related to court processes as regulated by the rules of the courts. The sheriffs were appointed in terms of Sheriffs Act 90 of 1989.
BUSA also commented on the administration of prescribed rehabilitation programmes for habitual offenders. RTIA clarified that rehabilitation is not necessarily geared at habitual infringers only but such programmes could be offered to every infringer (who wants to accelerate the redemption of their points) on a voluntary basis. The infringer will fund 90% of the cost of the programme. These rehabilitation programmes will be accredited by the relevant Sector Education and Training body.
BUSA commented on the new clause dealing with the effect of representation, and whether this would succeed if the prescribed procedures had not been followed. RTIA response is that the issue of reserving is also based on the 180 day rule allowed by Promotion of Administrative Justice Act (PAJA) but that the AARTO 1 will not be subject to the re-issuance.
BUSA then commented on then amendment of section 25 of the principal Act. RTIA replied that the amendment does not change in relation to the redemption cycle. The amendment is being introduced to distinguish different classes of infringers.
In conclusion Mr Tsoletshane summarised that the offences under NRTA were formally brought into AARTO through the gazetting processes of Schedule 3 of the AARTO Act.
Response to Driving.co.za submission
Mr Tsholetsane moved on to the comments made by Driving.co.za. The first comment related to the amendment of section 30 of the principal Act and introduction of the new clause. Again, Mr Tsholetsane commented that the electronic service now provided was an alternative service option to an infringer who is able to transact through this method of service, by providing the email address or other electronic form of service. This would be covered in Regulation 32A. He reiterated that South African Post Office (SAPO) (SAPO) provides this service, as set out in point 12.4.1 of the document.
The submission then dealt with the definition of the word “infringements”. The RTIA responded that the infringement is based on the classifications under Schedule 3 of the Act. The offences are still excluded under the Amendment Bill and will still be dealt with under CPA.
Another comment was on section 12 which dealt with the removal of the word “sheriffs”. The removal of sheriff is linked to Section 21, dealing with Warrants. Under the AARTO the linking of these had effectively linked the AARTO Act to the court system. The removal of any mention of sheriffs from the Act, by the amendment Bill, will not compromise the issue of service as the Act has sufficient mechanisms to achieve that through other multiple methods now canvassed through the new section 30.
Driving.co.za dealt with the new Chapter IV A , relating to the Appeals Tribunal. There was a fear that the Tribunal will not have sufficient capacity to deal with potentially millions of referrals each year. However, RTIA said that the capacity of the Tribunal will be reviewed from time to time and it will have to adhere to the same timeline of the 21 day adjudication period. The creation of the Tribunal will be to some degree flexible; it may be a quasi-permanent structure as the situation demands (for instance, where large populations of infringers opt to use it as an option in order to test the appellate mechanism under the amended Act).
The point was then made that the structure of the Tribunal will have to adhere to the Constitutional precept that the accused has to be afforded an opportunity of facing his/ her accuser in court (or the Tribunal). RTIA clarified that the Tribunal is not conceptually designed to be physically located in the various provinces, as are the courts, but will instead be located at a central point, where it will attend to all referrals from the adjudication processes. It is also important to note that the Tribunal will function as a kind of administrative “High Court” – with an absolute referral function.
Finally, Driving.co.za said that the unintended consequences of the Tribunal being funded by the revenues from RTIA will result in the public perceiving the Tribunal to be swayed in favour of the revenue to be collected from every fine, because of its dependence on such finds for its own sustainability. RTIA responded that the funding model of the Tribunal will need to be adequately addressed if that perception of bias was indeed a genuine fear. There was room to discuss whether, for instance, RTIA might advance its surplus to the National Revenue Fund, which would then effect an independent advance to the Tribunal, rather than a direct funding.
Response to Organisation Undoing Tax Abuse (OUTA) submission
Mr Tsholetsane said that OUTA had proposed a broadening of the definition of the word “infringements” to include contravention of any road traffic legislation, not limited to the National Road Traffic Act and National Land Transport Act. It also raised concerns that the corresponding penalties are imposed without hearing or trial. RTIA responded that there was a misunderstanding by OUTA and that audi alteram partem principles were catered for, as there were elective options under Section 17 of the AARTO Act.
Another comment related to section 2 (h) of the principal Act and the introduction of the new clause. OUTA expressed concerns about the conceptual basis of the rehabilitation programmes and how they will be implemented. RTIA wanted to suggest that OUTA should be engaged in a bigger workshop on rehabilitation programmes, so that they would have a better understanding. Another option could be that RTIA should post its various concept documents on its website, so that the public could have a better understanding of the work that it was doing. OUTA made the mistake of isolating the application of rehabilitation programmes to habitual infringers, whereas as explained this was not the case.
OUTA also commented on Chapter IV A – Appeals Tribunal. It supported the setting up of Appeals Tribunal, but was concerned about the manner in which the initial representations are conducted. It said that if they are conducted slavishly by the Representation Officers, the Tribunal will be inundated with Appeals because of the misapplication of the Representation Officers clauses. It was further concerned that the penalties may be implemented before the matters are heard by the Appeals Tribunal.
RTIA said that this comment showed that OUTA was not aware of how the system operated in practice. The Bill sets out how the system runs as and when an infringer exercises an elective option, save for instances where they elect to pay, either in full or payment in instalments.
Response to Neil Louwrens submission Mr Tsholetsane said Mr Neil He had also commented on the definition of “date of service” and was concerned that the change to “received” would bring about unintended complexities, and that “sent and/or posted” would be more in line with ECTA. Alternatively, he suggested that all vehicle owners (natural and juristic) should be compelled to supply eNaTIS with the email address and a cell phone number, so that RTIA can effectively be able to prove receipt of the infringement documents.
These comments from Mr Louwrens were quite sound and rational. However, RTIA wanted to stress that Regulation 32A would have the effect of providing reliable address information. The choice of providing electronic address information is a voluntary election of the vehicle owner. The owner may choose any other address of service that s/he may deem convenient for their use.
Response to CANCOM submission
Mr. Tsholetsane said that some of the comments by CANCOM did not actually relate to matters contained in the Amendment Bill. RTIA is of the view that the proxies do have a duty to nominate the driver. In the event that they cannot, they then will run the risk of having the points’ demerits being levied against them. It has also been proven that the current NCR system is able to accommodate any overseas ID numbers for the purpose of nominations.
The comment in terms of section 2 (h) of the principal Act is mistakenly linked to a person being labeled “habitual infringers” and then being compelled to attend rehabilitation programmes. This is not correct. The attendance of rehabilitation programmes will happen on a voluntary basis.
He commented, in relation to the election process under section 17 of the principal Act, that the section 17 choice to be tried in court is not being outlawed under the Bill or the Act, but in the first instance the process is being replaced with an election to apply to the Appeals Tribunal. It is hoped that this additional process will avoid premature lodgment of expensive review applications in court.
In terms of Chapter IV A, he explained that the reasoning behind this was that there would be improvements of administrative adjudication processes. The right of access to court review is thus not taken away. The comment is quite sound and rational when considering the plight of the unemployed infringer, who wants to access the services of the Tribunal.
Mr. Tsholetsane said the comment on section 17 of the principal Act is unrelated to the Amendment Bill. The NCR has fields that accommodate the nomination of foreign drivers.
Mr M De Freitas (DA) asked whether there are any draft regulations on the rehabilitation programmes.
He also asked why notices are not received on time, and asked for an indication of how the RTIA will deal with concerns of limited time.
Mr Sibande asked for clarity in terms what RTIA meant when it said “point taken” on page 5 of the document.
Mr Sibande also asked for clarity on operator infringements and how RTIA would charge the owner instead of the driver.
Mr Sibande asked Mr Tsholetsane to explain how many proposals or submissions were submitted, how many of them agreed on proposals, and how many were positive and how many are negative.
Mr Ramatlakane asked how the RTI dealt with foreign drivers. He also asked that if the Committee were to decide, following the submission of the Justice Project to replace “adjudication” with “finalisation” would this be likely to raise any problems.
Ms Xego asked if a person unable to pay a fine would be referred to the tribunal.
The Chairperson said that responses to the questions from Members would be dealt with on the following day. Other issues would also be discussed in the next meeting. Mr Stanley had a constitutional issue with the Bill and the submission on that would be heard next week. Further submissions would be made on the following day.
The meeting adjourned.
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