LAND COURT OF QUEENSLAND

CITATION: Conway & Ors v Australia Pacific LNG CSG Transmissions

Pty Ltd & Anor [2020] QLC 26

PARTIES: Denis Campbell Conway

(applicant)

Jill Mary Conway

(applicant)

Olivia Jane Martin

(applicant)

v

Australia Pacific LNG CSG Transmissions Pty Ltd

ABN 52 138 156 466

(respondent)

Australia Pacific LNG Pty Ltd

ABN 68 001 646 331

(respondent)

FILE NO: MER708-19

DIVISION: General Division

PROCEEDING: Application to decide a dispute under the Mineral and Energy

Resources (Common Provisions) Act 2014

DELIVERED ON: 17 July 2020

DELIVERED AT: Brisbane

HEARD ON: 15, 16 & 18 June 2020

HEARD AT: Brisbane

MEMBER: PG Stilgoe OAM

ORDERS: 1. The application is dismissed.

2. Any submission as to costs must be filed and served

within 14 days of the publication of these reasons.

CATCHWORDS: ENERGY AND RESOURCES – GAS – OTHER

MATTERS – where the respondent resource authority

holders constructed a gas pipeline on the applicant

landowners’ grazing property – where the applicants

complained to the respondents about the spread of African

2

lovegrass on their property – where the respondents

commissioned a weed survey to be carried out on the

applicants’ property – where the respondents’ environmental

scientists took a sample of a vulnerable ooline tree during that

weed survey and sent it to the Queensland Herbarium for

identification – where a flora survey trigger map was issued

over part of the applicants’ property – whether the

respondents were liable to compensate the applicants for

having caused the trigger map to issue and, if so, what was

the quantum of compensation payable – where the

application was dismissed

Environment Protection and Biodiversity Conservation Act

1999 (Cth)

Mineral and Energy Resources (Common Provisions) Act

2014 s 81

Mineral and Energy Resources (Common Provisions)

Regulation 2016

Nature Conservation Act 1992 s 4, s 5

Nature Conservation (Wildlife Management) Regulation

2006

Petroleum and Gas (Production and Safety) Act 2004

Comcare v Martin (2016) 258 CLR 467, cited

APPEARANCES: P Ambrose QC (instructed by Alroe Somers & O’Sullivan

Solicitors) for the applicants

G Beacham QC, with D Quayle (instructed by Origin

Energy Legal) for the respondents

[1] Resource companies operating in Queensland are often criticised for committing

environmental damage. In this unique case, Australia Pacific LNG CSG

Transmissions Pty Ltd and Australia Pacific LNG Pty Ltd (together APLNG) are

being criticised for taking steps to identify and protect a vulnerable ooline tree present

on Tecoma, a property owned by Denis Conway, Jill Conway and Olivia Martin (née

Conway).

[2] The Conways submit that APLNG’s actions in identifying the ooline give them a right

to compensation of almost $700,000.

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Background

[3] The Conways bought Tecoma in 2012 with the intention of growing leucaena, a

leguminous plant which provides high protein fodder for cattle. The Conways knew

that ooline existed on Tecoma;1 in fact, a large paddock in the south eastern corner of

Tecoma is called “Ooline”. There were already restrictions on the Conways’ ability

to clear vegetation on Tecoma, however, they determined that 10 of Tecoma’s 18

paddocks could be converted to leucaena.

[4] On 6 January 2014, the Conways and APLNG signed an Option for Easement and

Conduct and Compensation Agreement (OECCA) which related to the proposed

construction of part of the Eurombah Pipeline on Tecoma. APLNG exercised the

option and the pipeline was built. It runs from north to south in the western third of

Tecoma.

[5] APLNG also has petroleum leases, an authority to prospect and a petroleum lease

application over the whole of Tecoma. On 5 June 2017, APLNG issued an entry

notice2 pursuant to these Resource Authorities. The notice covered the whole of the

land for the purpose of conducting a site survey “to determine if the site is suitable

for development and to understand any constructability or practical constraints

associated with developing the Land”. One of the activities identified in the entry

notice was to conduct “Investigations and surveys … including, without limitation,

environmental, flora and fauna …”.3 The notice was valid for 12 months.

[6] Claud Zappone and Tim Collins are both environmental scientists. They conducted a

flora survey pursuant to the entry notice on 14 and 15 July 2017. They found what

they thought was an ooline in the south eastern section of Tecoma in the Ooline

paddock. They did not take a sample.

[7] On 4 August 2017, Mr Conway contacted APLNG complaining about the spread of

African lovegrass, which he thought was due to APLNG’s activities adjacent to the

Eurombah pipeline.

1 T 1-21, lines 30 to 31; T 1-23, lines 3 to 5; T 1-27, lines 45 to 46. 2 “Entry notice for private land”, DCC15 to ex 5. 3 Ibid 3.

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[8] In response, APLNG commissioned a weed survey. Aware that they had not taken a

sample of the ooline in July, Mr Zappone and Mr Collins thought that the weed survey

was an opportunity to rectify that oversight.

[9] Mr Zappone and Mr Collins undertook the weed survey on 12 August 2017. While

they were on Tecoma, they revisited the ooline and took a sample. Mr Zappone sent

that sample to the Queensland Herbarium, which confirmed that it was an ooline.

Some background about the vegetation protection mechanisms in place on Tecoma

[10] There are two regimes that protect vegetation on Tecoma.

[11] Some areas of Tecoma are designated as Category B – remnant vegetation under the

Environment Protection and Biodiversity Conservation Act 1999 (Cth) (EPBC Act).

The ooline is located close to an area which has been designated a Matter of National

Environmental Significance (MNES) since 2001.4 The particular area where the

ooline is located is also an MNES and has been since 2001. The EPBC Act Protected

Matters Search Tool5 indicates the presence of other MNES within a 10 km radius of

the ooline (see Annexure A). Therefore, Tecoma has areas of vegetation that are

nationally protected.

[12] A new, expanded or intensified agricultural development that is likely to have a

significant impact on a nationally protected area requires an approval under the EPBC

Act,6 and a flora survey is normally a prerequisite to obtaining that approval.

[13] The Nature Conservation (Wildlife Management) Regulation 2006 regulates Flora

Survey Trigger Maps for Clearing Protected Plants in Queensland (FSTM). A FSTM

will show where plants that are endangered, vulnerable or near threatened wildlife are

present or are likely to be present (high-risk areas)7 and any buffer zone around a

high-risk area in which clearing is not permitted.8 A FSTM must be reviewed at least

every 12 months.9 The current version of the FSTM must be publicly available.10

4 Ex 11, page 7. 5 Department of Agriculture, Water and the Environment, Protected Matters Search Tool (Web page)

<https://www.environment.gov.au/epbc/protected-matters-search-tool>. 6 Attachment 4 to ex 11. 7 Nature Conservation (Wildlife Management) Regulation 2006 s 248. 8 Ibid s 249. 9 Ibid s 251. 10 Ibid s 252.

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[14] Version 5 of the FSTM, which was the version in place immediately prior to Mr

Zappone’s referral to the Queensland Herbarium, showed no protected plants on

Tecoma (Annexure B).

[15] On 1 June 2018, Version 6 of the FSTM issued (Annexure C). Everything within a 2

km radius of the ooline identified by the Queensland Herbarium is shown as high-

risk vegetation.

[16] On 26 June 2019, Version 7.1 issued (Annexure D). The area of high-risk vegetation

largely mirrors the EPBC Act regulated vegetation management map with the addition

of a small, isolated area to the west of the ooline.

[17] An area of high-risk mapping can be removed only if it is established that no

Endangered, Vulnerable or Near Threatened (EVNT) species11 occur in either the

high-risk area or within a 100 m buffer zone around the high-risk area. Again, that

normally requires a flora survey.

[18] Senior Counsel for APLNG suggested that the Conways wanted to keep the ooline

secret.12 That is a very strong allegation, and there is no evidence to suggest that the

Conways did, in fact, intend to keep the ooline secret. However, the evidence of

Wayne Moffitt, an ecologist engaged by the Conways, is of significant concern (my

emphasis):13

“(xi) This leaves a small group of highly sophisticated (primarily corporate)

entities that may undertake flora surveys outside of the requirements of

protected plants framework to determine obligations under the EPBC Act. If

these entities engaged an environmental consultant to complete a flora

survey, then there is potential for additional EVNT species to be discovered.

However, as part of an EPBC Act-focused investigation, the entity could

carefully brief the consultant to identify and document only those EVNT

species that are also MNES. This would allow the landowner to remain

“unaware” of the occurrence on EVNT species that are not MNES.

(xii) If I was advising the Applicant in regard to the need for a

Controlled Action Referral for the proposed development, then I would

suggest that a referral could be avoided by:

Protecting and buffering all areas of Brigalow TEC and SEVT TEC (as was

intended). Given the low intensity nature of the proposed development, I

consider a 20m buffer sufficient;

11 See Nature Conservation Act 1992 ss 78A, 78B and 79, and schedule dictionary (definition of

“wildlife”). 12 T 1-16, lines 7 to 9. 13 Ex 11, pages 9-10. Footnotes omitted.

6

Identifying and buffering all specimens of Ooline (as was intended by the

proposed development). I consider a 20m buffer from individual specimens

to be sufficient.

(xiii) In this sense, there is some limited opportunity for flora surveys to

identify EVNT species. However, the survey data would only be used to plan

the set out of the proposed development at fine detail. The data would

remain as confidential correspondence between the consultant and the

Applicant. It would only be revealed to a third-party if the DAWE was

undertaking a compliance investigation in regard to the proposed

development, or it was willingly provided by the Applicant to a prospective

purchaser to inform their due diligence investigations.

(xiv) Discovery of additional Ooline (beyond that shown on the FSTM) does

raise an issue of the Applicant being (or becoming) aware11 of an EVNT

species beyond the FSTM trigger area. However, if each specimen is

buffered by 100m, then there is no requirement to obtain a protected plants

permit. While this creates a constraint for the proposed development around

the EVNT specimens, it does not prohibit continued grazing. Most

importantly though, the EVNT specimens remains known to only the

landowner, and do not become a “beacon” on common environmental

constraint mapping such as the FSTM and the VMSM. I understand

that such beacons would affect the value of the Site. This is an issue to

be considered further by the valuers in this matter.”

[19] In his evidence before the Court, Mr Moffitt said that, under Version 5, there was a

low likelihood of finding an ooline because one would not be looking for it.14

[20] The first object of the EPBC Act is to provide for the protection of the environment,

especially those aspects of the environment that are matters of national environmental

significance.15 Another object of the EPBC Act is to promote the conservation of

biodiversity.16

[21] The object of the Nature Conservations Act 1992 is, not surprisingly, to conserve

nature17 by, among other things:18

“(a) Gathering of information and community education etc.

• gathering, researching, analysing, monitoring and disseminating

information [my emphasis] on nature;

• identifying critical habitats and areas of major interest;

• encouraging the conservation of nature by the education and

cooperative involvement of the community, particularly

landholders;

(b) Dedication and declaration of protected areas […]

(c) Management of protected areas […].”

14 T 2-25, lines 21 to 23. 15 EPBC Act s 3(1)(a). 16 Ibid s 3(1)(c). 17 Nature Conservation Act 1992 s 4. 18 Ibid s 5.

7

[22] I fail to see how Mr Moffitt’s suggested course of action meets any of these criteria.

It is of great concern that an ecologist considers it legitimate to structure the EPBC

Act process to allow a landowner to be “unaware” of EVNT species on the land, to

keep EVNT data confidential, not to reveal it to a third party, and to avoid an

environmental “beacon” affecting land value. Horatio Nelson and his telescope would

feel right at home in Mr Moffatt’s company. His approach to vegetation protection is

to be discouraged.

The causes of action

[23] Initially, the Conways claimed damages on a number of bases: breach of the OECCA,

going beyond the scope of the Entry Notice, breach of the Land Access Code,

negligence, breaches of the Mineral and Energy Resources (Common Provisions) Act

2014, breach of the Mineral and Energy Resources (Common Provisions) Regulation

2016, breach of the Petroleum and Gas (Production and Safety) Act 2004 (P&G Act),

and an action for trespass.

[24] By the close of the hearing, the Conways’ claim was restricted to a breach of the

OECCA, compensation under s 81 of the Common Provisions Act either because of

the alleged breach of the OECCA or under the terms of s 81 itself or, in the alternative,

an action in trespass.

[25] At the hearing, the parties could not tell me the basis of the Land Court’s jurisdiction

to decide a claim in trespass. After the hearing, counsel for APLNG provided written

submissions (with which senior counsel for the Conways agreed) that s 363 of the

Mineral Resources Act 1989 gives the Land Court jurisdiction for a claim in

trespass.19 I do not need to decide this question given my findings in these reasons,

but I do not disagree with that submission.

[26] APLNG has, properly, conceded that to establish a right to compensation under s 81

of the Common Provisions Act the Conways do not have to prove that there has been

a breach by APLNG or that APLNG lacked authority to enter Tecoma, take the ooline

sample or send it to the Queensland Herbarium. The question of APLNG’s authority

19 “Submissions of the Respondents on the question of whether the Land Court has jurisdiction to

adjudicate the claim in trespass”, filed by the respondents on 8 July 2020.

8

is relevant only to whether there was a breach of the OECCA or whether APLNG

trespassed on Tecoma.

[27] Regardless of the cause of action, the parties agree that the question of

causation/remoteness is the same. The Conways also submit that the measure of

damages is the same, regardless of the cause of action.

Causation/remoteness

[28] Given that causation/remoteness is central to resolving this dispute, I should consider

the issue first. If the Conways don’t establish causation under s 81 of the Common

Provisions Act, where they do not have to prove fault or breach, it follows that they

will not be able to satisfy me in an action for trespass.

[29] Section 81(1) makes APLNG liable to compensate the Conways for any

compensatable effect they suffer caused by any authorised activities carried out by

APLNG or a person authorised by it. “Compensatable effect” is defined20 to include

diminution of the land’s value,21 diminution of the use made or that may be made of

the land or any improvement on it,22 and any cost, damage or loss arising from the

carrying out of activities under the resource authority on the land.23

[30] The Conways submit that the event which caused them loss is the taking of the ooline

sample and sending it to the Queensland Herbarium. They submit that it is not two

separate acts. They submit that sending the sample to the Queensland Herbarium

resulted in Version 6 which caused a diminution in the value of Tecoma.

[31] APLNG agrees that, if I apply the “but for” test to determine causation, the provision

of the ooline sample to the Queensland Herbarium was connected with the imposition

of Version 6. It submits, though, that s 81 should not be construed by applying the

closest equivalent at common law. It referred me to the High Court’s comments in

Comcare v Martin:24

“Causation in a legal context is always purposive. The application of a causal

term in a statutory provision is always to be determined by reference to the

statutory text construed and applied in its statutory context in a manner which

best effects its statutory purpose. It has been said more than once in this Court

20 Common Provisions Act s 81(4). 21 Ibid s 81(4)(ii). 22 Ibid s 81(4)(iii). 23 Ibid s 81(4)(v). 24 (2016) 258 CLR 467, 479 [42]. Citations omitted.

9

that it is doubtful whether there is any “common sense” approach to

causation which can provide a useful, still less universal, legal norm.”

[32] APLNG submits that in applying Comcare v Martin I must look at the Common

Provisions Act as a whole to determine the meaning of “caused by”.

[33] The main purposes of the Common Provisions Act are, relevantly, to consolidate

particular provisions common to each of the Resource Acts25 and to assist in

achieving the purposes of each of the Resource Acts.26 “Resource Act” includes the

P&G Act.27 The Common Provisions Act is to be read and construed with, and as if it

formed part of, the P&G Act.28

[34] The main purpose of the P&G Act is to facilitate and regulate the carrying out of

responsible petroleum activities and the development of a safe, efficient and viable

petroleum and fuel gas industry in a way that, relevantly, manages the state’s

petroleum resources in a way that has regard to the need for ecologically sustainable

development.29

[35] As can be seen from my discussion of the vegetation protection regime over Tecoma,

the Conways’ agricultural activities and APLNG’s resource authority activities exist

within a network of legislation aimed at protecting the environment. APLNG submits

that the interpretation of “caused by” should be informed by that framework, and it

would not be likely that the purpose of the access regime would be served by

construing s 81 of the Common Provisions Act in a way that discourages preservation

of the environment.

[36] An ecological survey is a preliminary activity and, therefore, an authorised activity

under s 81. It is obvious that an ecological survey might reveal some pre-existing

ecological condition that has adverse impacts for the landowner. A soil sample might

show contamination of which a landowner was unaware. A water sample may reveal

unacceptably high levels of a particular contaminant. A fauna survey might reveal the

presence of an animal previously thought to be extinct. And a flora survey might

reveal, as it did here, a vulnerable species.

25 Common Provisions Act s 3(a). 26 Ibid s 3(d). 27 Ibid s 9. 28 Ibid s 6(1). 29 P&G Act s 3(1)(a)(i).

10

[37] It cannot be the case that a resource authority holder can be responsible for loss

occasioned by the revelation of an ecological condition that existed on the land

regardless of the resource company’s activities.

[38] If, by taking a flora sample, Messrs Zappone and Collins caused the destruction of

grazing habitat through erosion or the introduction of a weed, then the Conways

would be entitled to compensation.

[39] However, the Conways’ “loss” through Version 6 was not triggered by the referral to

the Queensland Herbarium, or even the report confirming that the tree was, in fact,

an ooline. A team from the Department of Environment and Science (DES)

considered a range of sources and within a rigorous framework when conducting a

review of Version 5.30 The ooline was one of 3,287 new plants identified.31 The

review of Version 5 was conducted across the state, not just on Tecoma. The

comprehensive change to the mapping in Version 6 was approved by the Director of

Conservation and Biodiversity Policy at DES.32 The presence of the ooline would

have been revealed if the Conways had undertaken a flora survey before clearing, as

contemplated by both the EPBC Act and the FSTM. To suggest that APLNG’s action

in taking one sample on Tecoma produced the change in Version 6 is, frankly, absurd

given the numerous people and steps involved in creating that document.

[40] The connection between the taking of the sample and the alleged loss is too remote

to satisfy the test of causation.

What is the quantum of the loss?

[41] If I am wrong about the question of causation, I should decide the measure of the

Conways’ loss.

[42] The valuers agree that the value of the 2 ha directly affected by the “discovery” of the

ooline is $6,600/ha. They also agree that the value of this area is diminished by 50%.

30 “Metadata: Nature Conservation Act Protected Plants EVNT Flora Species Records Spatial Layer

Ver 6”, subpoenaed document 67 from the Department of Environment and Science, hearing bundle

page 3013. 31 “Briefing Note – Director: Review and Update of Protected Plants Flora Survey Trigger Map”,

subpoenaed document 31 from the Department of Environment and Science, hearing bundle page

3008, page 1. 32 Ibid 3009.

11

[43] They do not agree that about any other loss. Shaun Salter, a valuer engaged by the

Conways, says that there is an additional diminution in the value of Tecoma which

he assesses at $400,000 plus GST. Tito Lando, a valuer engaged by APLNG, says

there is no additional diminution in the value of Tecoma, but that the Conways will

incur additional expense in experts’ fees giving a total loss of approximately $20,000

plus GST.

[44] The valuers agree that, if a purchaser applied a price discount of 5% or more because

of a FSTM, it would probably show up in the comparable sales.33 They agree that the

comparable sales show that a FSTM has no effect on the price a purchaser would pay

for land so affected.34 They also agree that an analysis of the comparable sales, by

inquiring of the purchasers, reveals that the FSTMs had no impact on the prices.35

[45] Despite these agreements, Mr Salter thought that a discount of 2.5% to the balance of

Tecoma was an appropriate discount for the presence of Version 7.1. He justified this

discount in several ways. Firstly, he said that the selling agents he had spoken to

would “assume” that there would be market resistance to a property with a FSTM.

Secondly, he pointed to media coverage36 critical of the FSTM system. Thirdly, he

relied on his own experience as a rural landowner and producer. Finally, he said that

the discount accounted for the risk that the FSTM on Tecoma would revert from

Version 7.1 to the much more restrictive Version 6.

[46] While it is true that this Court is not bound by the rules of evidence,37 and while it is

true that this Court often allows valuers to act on hearsay evidence when analysing

comparable sales, it is quite another thing to ask the Court to accept vague hearsay

evidence from real estate agents as the basis for justifying a discount to the value of

the subject land.

[47] The information that I have about the agents’ perceptions is not compelling. Two

agents have never knowingly sold land subject to a FSTM but “assume” there would

be market resistance. One agent said that he saw no evidence of resistance in one of

the comparable sales and did not expect any in the current market. One agent believed

33 Ex 13, page 28; T 2-70, line 41; T 2-72, lines 1 to 11; T 2-78, line 40 to T 2-79, line 5. 34 Ex 11, page 32. 35 Ex 13, pages 10-22; T 2-68; T 2-69, lines 1 to 5. 36 See annexure 6 to ex 13. 37 Land Court Act 2000 s 7(a).

12

there was some resistance, although he was the agent for a comparable sale in which

there was no evidence of a discount or buyer resistance. The last agent said that he’d

had three discussions with lawyers recently about this topic (the context of which was

not disclosed) and he thought that, perhaps, there would be some resistance. That

agent marketed one of the comparable sales in which the purchaser did not apply a

discount because of the FSTM.

[48] The comparable sales evidence contradicts the agents’ belief. I prefer the evidence of

the comparable sales.

[49] Similarly, the media “noise”38 is contradicted by the comparable sales. Looking at the

media reports, I see that the criticisms are directed to Version 7, which designated

areas such as the Gabba Stadium as high-risk areas but had no appreciable effect on

Tecoma. Version 7.1 removed those anomalies. A briefing note to the Director-

General of the Department of Environment and Science notes that Version 7.1

“refines mapped areas to include only semi-natural/natural areas that contain remnant

vegetation, high value regrowth, offsets and wetland areas”.39

[50] When Mr Salter gives evidence as a landowner and producer, he steps outside his area

of expertise and becomes simply a lay witness giving his opinion. Again, the

comparable sales do not support his view.

[51] If there were any further need to dismiss Mr Salter’s evidence, it is to be found in his

own calculations. He calculated the discount that would have applied if Version 6

were still in place at $720,000.40 Mr Lando agreed a discount would apply.41 Mr

Salter’s calculation for the discount for the risk that there might be a reversion from

Version 7.1 to Version 6 was $400,000, over 55% of the discount Mr Salter actually

applied if Version 6 was in place.42

[52] There is no evidence of any risk of reversion. As I have noted, the FSTM regime is

regularly reviewed and any number of factors may result in a change. To ascribe the

risk of change to one thing – the presence of Version 6 at some time in the past – is

unsustainable.

38 T 2-58, line 42 to T 2-59, line 4; T 2-59, lines 14 to 27. 39 Ex 24, page 1. 40 Ex 13, page 25. 41 T 2-60, lines 19 to 46. 42 Ex 13, page 28; T 2-71, lines 11 to 39.

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[53] If there was a loss due to the activities of APLNG, and I find there was not, the

quantum of that loss is limited to $20,000.

Conclusion

[54] Senior counsel for the Conways directed me to Mr Conway’s “heartfelt” evidence:43

“‘It distresses me and my family that such ill-considered decisions are made

in the absence of reliable scientific data and without any appreciation for the

inconvenience, cost and heartache it causes for us as landowners.’”

[55] I have no doubt that the Conways are distressed by these events. Landowners expect

to have total control over the way they manage their land. Unfortunately, the P&G

Act and the Common Provisions Act give resource authority holders rights that

override the interests of landowners. There is a balance between the operations of the

resource authority holders and the operations of landowners which is difficult to get

right.

[56] The Conways’ distress was compounded by the information APLNG provided during

the course of this dispute. They think that APLNG should have provided information

sooner. They think that APLNG was less than frank in its initial communications

about the entry to land. They think that evidence of Messrs Zappone and Collins was

contradictory and self-serving.

[57] I don’t necessarily agree that APLNG should have disclosed the fine detail of its entry

onto Tecoma but I can see how its ex post facto justification did not instil confidence.

Could the APLNG paperwork have been better? Yes. Could they have trained their

environmental scientists better? Yes. Could APLNG have communicated better with

Mr Conway? Probably yes. Would any of that have made a difference to this case?

Probably not. The only thing that could have changed this case is if Mr Conway had

been able to persuade Messrs Zappone and Collins not to engage with the Queensland

Herbarium and make the location of the ooline public. As I have already commented,

I do not consider such an action to be within the ambit of a competent and

conscientious environmental scientist.

43 “Closing Submissions on behalf of the Applicants”, filed by the applicants on 17 June 2020 [12].

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[58] The Common Provisions Act does not permit this Court to compensate parties for hurt

feelings, disappointment, or anger at an environmental protection regime. The

Conways’ application must fail.

Orders

1. The application is dismissed.

2. Any submission as to costs must be filed and served within 14 days of the

publication of these reasons.

PG STILGOE OAM

MEMBER OF THE LAND COURT

15

Annexure A

16

Annexure B

17

Annexure C

18

Annexure D