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Chapter 1 - Ministerial discretion – background issues and problems experienced during
the inquiry
1.1
This inquiry into ministerial discretion in migration
matters was established following allegations raised in parliament in May and
June 2003 about the use of the discretionary powers by the then Minister for
Immigration and Multicultural and Indigenous Affairs, the Hon Philip Ruddock, stretching
back to 1998.
1.2
During the course of parliamentary debates surrounding
the allegations the then Shadow Minister for Immigration, Ms Julia Gillard MP,
and Mr Laurie Ferguson MP, raised a number of specific allegations about the possible
misuse by Mr Ruddock of his ministerial discretion powers under the Migration
Act. The accusations related to instances where the minister was alleged to
have granted visas to individuals in exchange for cash donations to the Liberal
Party of up to $100,000 by the individuals concerned or by those acting on
their behalf.[2]
1.3
The allegations were fuelled in part by media
speculation that the immigration minister's strong connection with Australia's
Lebanese community influenced his use of the discretionary powers on more than
one occasion.[3] At the time the allegations
were debated in parliament, they received an air of authenticity in the print
media under two eye-catching headlines which soon became catch-all phrases to
describe an unfolding political controversy for the Howard Government – the 'cash-for-visa'
scandal and 'visagate'.[4]
1.4
This chapter provides a brief overview of allegations
raised in parliament against the former Minister for Immigration, Mr
Ruddock. The Committee believes that
grasping the nature and gravity of the allegations is important because they
gave rise to a range of issues relating to the minister's discretionary powers which,
in turn, guided the Committee's efforts to investigate the allegations.
1.5
The chapter briefly considers the parliamentary debates
on the allegations, in particular the censure motions moved against the
immigration minister and the government. It concludes by examining obstacles to
the conduct of this inquiry created in the first instance by the Department of
Immigration and Multicultural and Indigenous Affairs (DIMIA) and subsequently
by the new minister, Senator Vanstone,
and the wider implications of executive obstruction for parliamentary
accountability.
Allegations of impropriety raised by the Opposition
1.6
Four separate cases involving alleged impropriety by the
former immigration minister, Mr Ruddock,
were raised by the Opposition and debated in the House of Representatives between
29 May and 26 June 2003.[5] The Opposition gradually pieced together
details involving each case over a number of weeks, mainly in response to
answers provided in the House by Mr Ruddock.
The core allegations involved in each of the four cases are summarised below:
-
Mr Bedweny Hbeiche applied for a protection visa
in 1996 when he first arrived in Australia. His application was refused, and
the matter was taken unsuccessfully to the Refugee Review Tribunal (RRT) and
the Federal Court. Following two separate requests for the minister to exercise
his discretion, which he declined, a third request by Bishop Darwish on 27
September 2001 was dealt with by the minister in January 2001. The minister
stated that he dealt with this request because new information was supplied to
him, namely, that Mr Hbeiche has three married sisters who are Australian
citizens, and that it was this information that influenced his decision to
intervene in the case.
The Opposition alleged that Mr
Hbeiche was granted permanent residence as a
result of the minister's intervention after a $3,000 donation was made to the Liberal
Party at a fund-raising dinner by Mr Karim
Kisrwani acting on Mr
Hbeiche's behalf. It was also alleged that Mr
Hbeiche's original application mentioned
that he had three sisters in Australia,
whereas the minister claimed that the brief that came from DIMIA did not
contain this information.
-
Mr Karim Kisrwani is a Parramatta travel agent,
a prominent member of the Lebanese community and long-time acquaintance of Mr
Ruddock. Immigration department statistics show that between 1999-2003 Mr
Kisrwani made 55 requests for the minister to exercise his discretion, of which
36 were finalised and 17 were successful.
The Opposition raised a number of allegations about Mr
Kisrwani, including that he was the central
figure in the 'cash-for-visas' scandal, and that he received money for
migration advice although he was not a registered migration agent.
Specifically, the Opposition alleged that Mr
Kisrwani:
-
made a donation of $3,000 to the minister's
re-election campaign on Mr Hbeiche's behalf to influence the minister's
decision;
-
received $220,000 from Mr Dante Tan to use his
influence with the minister to have his visa restored (see below);
-
received $1,500 from Mr Roumanos Boutros Al
Draibi to represent him in a migration matter; and
-
received $2,000 a month from Mr Jim Foo's failed
Pioneer Spirit Developments in Dubbo for an 'immigration consultancy'.
-
The Opposition questioned the minister on a
number of occasions about a donation of $100,000 that was made by the Maha
Buddhist Monastery to the NSW Liberal Party and the number of visas for
religious workers received by the monastery. The minister responded that he
only became aware of the donation when it was reported in the media in February
2002, and that 23 nominations and 10 visas for religious workers were awarded
to the monastery in the three years from 2000-01.
-
Mr Dante Tan, a business migrant from the
Philippines who was granted a visa on 11 September 1998, had his visa cancelled
on 5 September 2001, when he could not be contacted following expiration of the
three-year period that applies to all business migrants. In November of that
year, one of Mr Tan's business associates, Mr Kisrwani, contacted the minister's
office to inquire about the status of Mr Tan's visa. After Mr Tan lodged an
appeal to the Administrative Appeals Tribunal (AAT), the immigration department
withdrew from the case after consulting with the minister on the question of
costs.[6] More importantly, the
department vacated the decision to cancel Mr Tan's visa after he convinced the
department (and the Australian Securities and Investment Commission) that he
was engaged in business activities in Australia. Mr Tan subsequently became an
Australian citizen in May 2002.
The
Opposition alleged that Mr Tan's
visa was reinstated after he made a $10,000 donation to the minister's
re-election campaign at a fund-raising dinner organised by Mr
Kisrwani, probably on 14 October 2001. Of added interest to this case
is that the Philippine authorities laid charges of fraud against Mr
Tan in 2000. When Mr
Tan was informed that the Philippine
authorities were seeking his extradition, he left Australia
in 2003.
1.7
The Committee points out that unlike the cases involving
Mr Hbeiche
and Mr Kisrwani,
those involving the Maha Buddhist Monastery and Mr
Dante Tan did
not involve Mr
Ruddock exercising his ministerial
discretion. It became clear during parliamentary debate that ministerial
intervention had not been exercised in the granting of visas to the monastery,
and that ministerial intervention could not have been considered for Mr
Tan under the Migration Act because there
had not been a review tribunal decision in that case.
1.8
While the Maha Buddhist Monastery and Tan cases do not fall
directly within this inquiry's terms of reference, the Committee notes that they
nevertheless raise serious allegations of impropriety by Mr
Ruddock similar to the allegations
surrounding cases involving Mr Hbeiche
and Mr Kisrwani.
Outcome of parliamentary debate
1.9
The parliamentary debate that followed airing of the 'cash-for-visa'
allegations resulted in two censure motions being moved by the Shadow Minister
for Immigration, Ms Julia
Gillard, against Mr
Ruddock on 5 June and 26 June, respectively.
Not surprisingly, both motions were defeated on party lines. A third attempt by
the Opposition to move a censure motion against Mr
Ruddock on 18 June was prevented when the
Deputy Speaker ruled the motion out of order (the motion was not consistent
with a special ruling on government business that had been made for that sitting
day).[7]
1.10
On both occasions the minister rejected the allegations
made against him, and brushed aside the censure motions as nothing more than
planned and premeditated political stunts. He claimed that the motive behind
the first censure motion was 'quite malevolent', and that it was 'a deliberate
attempt to diminish me'.[8] On other
occasions, the minister stated categorically that: 'I have never exercised my
personal discretion in return for a donation'.[9]
1.11
The parliamentary debate surrounding the allegations reiterated
long-standing criticisms of the discretionary powers. These included that the
powers are open to real or perceived distortion, political influence and
corruption at the highest levels of public office because they are too broad in
scope and far removed from the established avenues of accountability that apply
across all levels of executive decision-making.[10]
1.12
In short, because the minister's discretionary powers
are non-compellable, non-reviewable and non-delegable – an issue examined in
detail in this report – they are effectively beyond the reach of parliamentary
scrutiny and leave a significant accountability 'black hole' in the
administration of immigration policy.
1.13
In the light of the unsatisfactory responses to the allegations
by Mr Ruddock,
the Opposition parties decided that the allegations and the government's
response were serious enough for the issue of the minister's discretionary
powers to be brought before a parliamentary committee of inquiry.[11]
1.14
The Select Committee on Ministerial Discretion in
Migration Matters was subsequently appointed by the Senate on 19 June 2003. Although the
allegations raised in parliament in 2003 provided a focus for the inquiry, the
Committee was empowered under its terms of reference to examine broader issues,
such as the appropriateness of the ministerial discretion powers under sections
351 and 417 of the Migration Act within the current migration system. The
Committee was also empowered to consider the operation of the discretionary
powers by immigration ministers, including the criteria that applied (and
should apply) to the exercise of the powers.
1.15
The Committee decided during the inquiry process that
it would seek access to case files, information and documents held by the immigration
department and documents kept by departmental liaison officers in the
immigration minister's Parliament House office. The Committee formed the view
that having access to the case files and documents was necessary to enable it
to properly examine allegations involving Mr Ruddock's
use of the discretionary powers, and to address in full the inquiry's terms of
reference.
1.16
The following section describes how during the course
of its inquiry the Committee met a number of obstacles that prevented the
inquiry moving forward. Specifically, in a period of nearly five months, from
mid-September 2003 to March 2004, the Committee was impeded on a number of
occasions in its efforts to gain access to certain documents it considered
important to its inquiry.
Obstacles to the conduct of the inquiry
1.17
The Committee's efforts to test the allegations outlined
above were hampered by the lack of cooperation received from both DIMIA and Senator
Vanstone, as the new immigration minister. The
Committee made numerous requests for information that might shed light on
specific cases where allegations had been aired in parliament and the media. At
various stages of the inquiry, Committee members requested, inter alia: case files and details of
cases where Mr Karim Kisrwani had made representations on behalf of an
applicant; details of cases where Mr Ruddock used the intervention powers in a
case initially assessed by DIMIA officers as falling outside the ministerial
guidelines; cases decided by Mr Ruddock during his last week in office; case
files where the 'top ten' sponsors had made representations; and the case
history of certain individuals who had received ministerial intervention and
who became the subject of media interest, including Mr Bedweny Hbeiche. The
Committee was also interested in how Senator Vanstone
used the power after she became minister, and sought information about the
well-publicised case of Mr Ibrahim
Sammaki.
1.18
The Committee also requested the notebooks kept by a departmental
liaison officer (DLO) serving in Mr Ruddock's
office during the period in question. The departmental liaison officer told the
Committee that he kept notebooks to keep track of the content and any outcome
of phone calls,[12] some of which could
be relevant to ministerial intervention cases of interest to the Committee.[13]
1.19
All of the Committee's requests for detailed case file
information were met with resistance, initially from DIMIA and ultimately from Senator
Vanstone. Their responses to these requests
are summarised below:
-
At a public hearing on 23 September 2003, the
Committee asked DIMIA to provide case files where Mr Kisrwani and Ms Marion Le
had made representations. On 31 October 2003, DIMIA wrote to the Committee
advising that the request raised significant workload implications for the
department, in that it would take an estimated 120 person days to prepare the
files for the Committee's perusal. The letter also indicated that the
department had broader concerns about the provision of files, as the files 'relate
to individuals who are not themselves the subject of the inquiry' and the
persons concerned were assured that their personal details would not be
disclosed by the department except for certain purposes.
-
In correspondence dated 29 October 2003, the
Committee asked DIMIA to provide information about 17 cases in respect of which
Mr Kisrwani had made representations. DIMIA evidently commenced work on
compiling this information, as at a public hearing on 17 November 2003 Ms Philippa
Godwin, a deputy secretary in DIMIA, informed the Committee that the department
was on the point of providing it.[14] On
18 November Ms Godwin again stated that she had reviewed a significant portion
of the work, and that answers should be provided by the next week.[15] These answers never eventuated, due to
events outlined below.
-
At the public hearing on 18 November 2003, the
issue of DIMIA providing information about individual cases was discussed at
some length.[16] DIMIA witnesses
indicated that the Committee's requests for information involved some 250
individual cases, and that to provide the information requested by the
Committee would require around 250 person days. In light of the workload and
timing considerations, the Committee agreed to prioritise its information requests,
and suggested holding a private meeting with DIMIA officials to work though
some of those issues.
-
On 27 November 2003, the Committee Chair and
Deputy Chair met with DIMIA officials to discuss the provision of case file
related information. At that meeting, the Committee endeavoured to reduce the
workload implications for the department by scaling back the information
requests.
-
In correspondence dated 12 December 2003, DIMIA
indicated that, despite refinement of the information requested, there remained
some 130 cases about which further information was requested, which would still
require a substantial amount of work. DIMIA also noted that the nature of the
information requested raised privacy concerns, and could 'have implications
going well beyond this inquiry'. DIMIA advised that: 'We have therefore
consulted with the Minister's office. In view of the considerable workload
implications and unprecedented nature of the request, the Minister, Senator
Vanstone has not authorised the Department to provide such a broad ranging and
significant amount of personal material'. This letter did not mention the 17
Kisrwani cases on which, as outlined above, most of the work had already been
done.
-
On 14 January 2004 DIMIA notified the Committee
that it had received advice from its Special Counsel (Australian Government
Solicitor) that in order to provide detailed information on Mr Hbeiche and Mr
Sammaki as requested by the Committee, it would need to seek their permission. This
letter stated that DIMIA was in the process of contacting those two individuals
and it would forward the information once permission was received. On 10 March 2004 DIMIA advised that it had written to
Mr Hbeiche and Mr Sammaki on 16 January but had not received a response from
either.
-
The Committee's request to view the notebooks
kept by DLOs serving in the minister's office was referred to the minister, and
was eventually refused by Senator Vanstone in a letter dated 23 January 2004. Senator
Vanstone's letter expressed concern at the 'broad' and 'unprecedented' nature
of the request. Her stated grounds for withholding the notebooks were, broadly
speaking: the notebooks contain records of phone calls from a range of people
on topics across the whole portfolio, only some of which related to ministerial
intervention; without contextual information, the notebooks could give
misleading impressions to the Committee; it would be inappropriate to pass to
the Committee information related to people whose affairs are outside the scope
of the inquiry, and; even in matters that may touch on ministerial
intervention, normal privacy principles would require the approval of specific
individuals before passing on information about them.
-
On 11 February 2004, the Committee Chair wrote
directly to Senator Vanstone, noting the Committee's power, delegated by the
Senate, to order the production of any documents it deems relevant to its
inquiry, and pointing out that the Senate and its committees are not bound by
privacy legislation or privacy principles. This letter requested that Senator
Vanstone meet the Committee's outstanding information requests by
19 March 2004.
-
On 2 March 2004 Senator Vanstone replied to the
Committee Chair refusing to provide the information requested. Her letter
stated that: '...I am not intent on refusing to provide the Committee with
information, but I do not believe that it is appropriate to provide it in the
way that it has been sought'. Notwithstanding the Chair's explanation of the
Senate's powers to require the production of documents and to request any
information it considers relevant to its inquiries, Senator Vanstone reiterated
her concern about the Committee seeking 'a broad ranging and significant amount
of personal information in relation to individuals who are not themselves the subject
of [this] inquiry'.
1.20
Without access to case files, documents and other
contextual information on specific cases where Mr
Ruddock used the intervention powers, the
Committee has been unable to resolve the suspicion and doubt that has arisen
following the airing of allegations last year. This has led to a situation where the Committee has been unable to fully
address one of the inquiry's key terms of reference on the operation of the
discretionary powers by ministers and the criteria that applied when ministers
exercised their discretion (term of reference (c)). The Committee can only conclude
that the present minister's unwillingness to provide the detailed information
necessary to conduct a full and thorough investigation of relevant cases
suggests a reluctance to expose the decision making process to close scrutiny.
1.21
Through the course of this inquiry, the Committee has discovered
investigations by the Australian Federal Police and Australian Electoral
Commission into matters which may be relevant to the subject of the inquiry. However,
operational constraints have prevented the Committee from obtaining further
details about the nature of those investigations and what, if any, relevant
information is held by those organisations. The Committee accepts the reasons
given by the AFP and AEC for not disclosing information pertinent to current investigations.
The Committee has not been advised of the results of these investigations and
is therefore unable to determine whether they would have had any bearing on the
findings of this inquiry.
1.22
The Committee was unsuccessful in efforts to obtain
direct comment from Senator Vanstone
on her views on the ministerial discretion powers. On 27 October 2003, the Chair wrote to Senator
Vanstone inviting her to express her views
on the use and operation of the ministerial discretion powers for the record. Senator
Vanstone did not respond until shortly before this report was due to be
printed, when she said a response was 'overlooked' last year and expressed the
view that 'it was not appropriate' for her to comment on the issues before this
inquiry.
1.23
Despite these constraints, this inquiry has put on the
public record a substantial volume of information about an area of public
administration not generally known for its transparency and accountability. The
information provided by DIMIA, while limited in its usefulness for examining
specific uses of the intervention powers subject to the allegations outlined
above, has partially enabled the Committee to address its terms of reference in
a general way.
1.24
The Committee's examination of the evidence available
to it from the department and non-government witnesses suggests that a
systematic investigation of the operation of the ministerial discretion powers
under the Migration Act is indeed warranted. The Migration Act 1958 vests the minister for immigration with an
extraordinarily free discretion to intervene on behalf of unsuccessful visa
applicants where the minister considers it 'in the public interest' to do so.
However, the minister's exercise of this discretion is subject to no external
review. The only accountability mechanism is the requirement to table
statements in parliament every six months. Under the Howard Government, the
statements have outlined in the broadest terms cases where the minister has
intervened.
1.25
A key area of concern for the Committee through the
course of this inquiry has been to assess whether the systems currently in
place are adequate to ensure that the operation of this unusual power is
transparent and open to scrutiny. One area of interest is the department's
processes for supporting the operation of the ministerial intervention powers.
The Committee noted with some concern that DIMIA officials did not view the
department's role as including any 'decision making', despite clear evidence
that ministerial intervention requests are vetted by departmental officials in
the first instance to determine whether the minister would be briefed in any
detail on that case. Furthermore, the Committee has found that departmental
processes surrounding the ministerial intervention powers do not involve
generating adequate records or statistical data to enable effective external
scrutiny of the way the powers are operating. The Committee has also heard of
aspects of the administration of the powers that appear to create hardship for
individual visa applicants.
1.26
The Committee has heard significant concerns from
non-government stakeholders that a lack of authoritative, publicly available
information on the operation of the powers leads to a perception in the
community that it is not 'what you know but who you know' that will determine
whether a ministerial intervention request is successful. Through this inquiry,
the Committee has sought to ascertain whether this perception is justified, by
looking at the available information on the role of representatives, be they
lawyers, community leaders or parliamentarians, in accessing the minister to
support cases seeking ministerial intervention. The lack of conclusive evidence
in this area has led the Committee to the view that the current structure of
the system invites the perception of corruption, and opens the way for
unscrupulous behaviour at all levels.
1.27
The most concerning aspect of the inquiry has been the
lack of information the Committee has been able to access about the decision
making process once a case reaches the minister's office. The Committee's
difficulty obtaining evidence to investigate serious allegations relating to
the use of these powers highlights how easy it would be for a minister to use
them for party political ends. The intention of parliament when these powers
were inserted in the Act was that
parliament would be able to scrutinise a minister's use of the powers. If,
however, as has been seen through this inquiry, a parliamentary committee
charged with investigating the use of these powers can be frustrated by a lack
of cooperation by the government, the ability of parliament to scrutinise the
operation of the powers is impaired.
Powers of Senate committees: ministers, officials and departments
1.28
Parliamentary accountability is the cornerstone of
modern democracy. The Committee notes the assessment made in the report of the 'children
overboard' inquiry that, within the context of the public service:
...there is a continuum of accountability relationships, both
vertical and horizontal, between the public service, the government, the
parliament and Australia's
citizens. Nevertheless, there are some fundamental tenets and practices of
accountability that are well established in public administration, even though
these received notions of accountability are increasingly being stretched.[17]
1.29
Against this background, the Committee would like to
stress that the difficulty it has had in gaining access to material central to
its inquiry and in obtaining full and accurate information in a timely way, is
an issue of overriding importance. As discussed in the previous section, the
Committee was unable to obtain access to all the documents relevant to its
inquiry for reasons provided by the department that the Committee does not
accept. Much like the experience of the 'children overboard' inquiry, the Committee
is of the view that actions taken by Senator Vanstone
and her department during this inquiry do not promote transparency, accountability
and good governance.[18]
1.30
The Committee is left in no doubt that it was obstructed
in carrying out the full task requested of it by the Senate, as provided in the
inquiry's terms of reference. The obstacles to the conduct of this inquiry created
by Senator Vanstone and her
department raise a number of broader issues relating to parliamentary
accountability, the powers of Senate committees and the ability of Senate
committees to fulfil their reporting obligations to parliament.
1.31
While the Committee does not wish to dwell on the
complex issue of accountability in modern governance arrangements, it believes
it is necessary to summarise at the outset four established tenets of parliamentary
accountability that underpin the operation of Senate committees:
-
Senate committees empowered by the Senate have a
clear authority to require the attendance of witnesses, the answering of
questions, and the production of any document relevant to their inquiries;
-
The power to call for persons and documents is a
necessary adjunct of the Senate's authority to conduct inquiries. The undoubted
source of this authority is section 49 of the Constitution.[19] There are no known limitations in law
to this power. The power is delegated to the Senate's committees in the
operating rules of the Senate known as Standing
Orders and other Orders of the Senate;
-
While a minister may offer reasons for the
non-attendance of persons at a public hearing or the non-production of documents
– for example, commercial-in-confidence, public interest, or privacy – it is
the committee in the first instance, and ultimately the Senate, that determines
whether or not to accept the reasons; and
-
The Senate and its committees are not bound by
privacy legislation or privacy principles, but may choose to respect them in
practice.[20]
1.32
The Committee notes that other Senate committees have
had similar experiences of ministers, departments and agencies failing to
provide documents, and invariably it has been commercial-in-confidence, public
interest and, in the case of this inquiry, privacy issues that were provided by
the minister as reasons for not complying with committee requests. It is no
wonder that the consideration of accountability, especially the accountability
of the executive as a whole, featured prominently in their published reports.[21]
1.33
The Committee takes the issue of executive obstruction
of a Senate committee inquiry very seriously. In this context, the Committee's
dealings with the immigration minister, Senator Vanstone,
reinforce the main findings of the first interim report of the Senate Finance
and Public Administration Reference Committee's inquiry into the government's
information technology outsourcing initiative. That report highlighted:
-
the apparent disregard or ignorance in the
Australian Public Service about parliamentary accountability;
-
the lack of timeliness and quality of answers in
response to the Committee's request; and
-
the continuing need to facilitate an improved
awareness of the powers of Senate committees and the framework of
accountability in which ministers are accountable to the parliament for the
policies and actions of their departments and ultimately, through parliament,
to the public.[22]
1.34
The Committee is aware that executive departments have
been advised on numerous occasions by the Auditor-General, the Administrative
Review Council and by Senate committees about the rules of parliamentary
accountability and the powers of Senate committees to call for persons, papers
and documents.[23] It is for this reason
that the Committee regrets having to repeat the fundamental principles of
parliamentary accountability and to remind the immigration minister and her
department that they are bound by these clear accountability requirements.
1.35
The minister's disregard for the Committee's power to
obtain the departmental case files and ministerial notebooks necessary to fully
explore the minister's discretionary powers is a dominant theme that runs
through this inquiry. As previously noted, the Committee acknowledges that
internal departmental procedures may have been a legitimate factor behind some
of the delays experienced by DIMIA in providing the Committee with information.
The Committee nevertheless finds that the history of executive obstruction of
Senate committees has been magnified during the course of this inquiry, given Minister
Vanstone's unacceptable responses to the
Committee's repeated requests for information.
1.36
In the light of this obstruction, the Committee decided
that the best course of action was to report its findings and recommendations
to the Senate and place on the public record information about the operation of
the minister's discretionary power that is otherwise not available. The
Committee formed the view that further requests to the minister for case files
and documents would most likely be refused, which would needlessly prolong the
inquiry process. However, the evidence before the Committee was sufficient to
enable it to formulate conclusions on the exercise and administration of the
discretionary power. The Committee's conclusions are reflected in the
recommendations to this report.
1.37
The Committee decided not to attempt to exercise its
power to call for persons, documents and witnesses. It concluded that this
course of action would have led to considerable and unacceptable delays in
bringing the inquiry to a satisfactory conclusion and would probably have embroiled
the Committee, and ultimately the Senate, in a protracted dispute with the government.
In reaching this decision, the Committee was mindful of the view of the
majority report of the 'children overboard' inquiry that a stand-off between a Senate
committee and the executive over the powers of Senate committees could be
challenged in the courts at considerable cost to taxpayers, causing further
delays until the issue was settled.[24]
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