FAMILY FIRST NEW ZEALAND V ATTORNEY-GENERAL [2020] NZCA 366

Court of Appeal of New Zealand, Clifford, Gilbert and Stevens JJ, 27 August 2020 Appeal seeking registration of a charity with a purpose of promoting traditional family values

Key words: Charity, New Zealand, Charitable Purposes, Advocacy, Family, Ancillary Purposes, Education, Fourth Head, Human Rights

1. Family First New Zealand (Family First) was first deregistered by the New Zealand Charities Registration Board (the Board) in 2013, and over the next seven years, there were five decisions about their charitable status (Family First New Zealand v Charities Registration Board [2018] NZHC 2273; Family First New Zealand [2015] NZHC 1493).

2. In a split decision Clifford and Stevens JJ, Gilbert J dissenting, the Court of Appeal set aside the Board’s decision and declared that Family First qualified for registration under the Charities Act 2005 (NZ).

3. Family First takes a relatively traditional approach to the importance of families and marriage. Since its establishment in 2006 it has engaged in community discussions on divorce, prostitution, pornography, broadcasting standards and censorship, availability of alcohol and tobacco, gambling, abortion, euthanasia, embryonic cell research and the “anti-smacking” legislation. It has done this in many ways including published opinions, polemics and dissemination of various forms of research.

First deregistration decision1

4. Family First was registered by the Board in 2007, but was deregistered in 2017. The Board summarised their reasons as follows (at [18]):

First, the Trust’s main purpose is to promote points of view about family life, the promotion of which is a political purpose because the points of view do not have a public benefit that is self-evident as a matter of law. The Board’s view on the Trust’s main purpose is to promote the view that the “natural family” (defined by the union of a man and a woman through marriage) is the fundamental social unit, and should be supported as such to the exclusion of other family forms (described by the Trust as “incomplete or fabrications of the state”). Secondly, the Board considers that the Trust’s purpose to promote points of view about family life is not a charitable purpose to advance religion or education, nor a purpose beneficial to the public within the

1 Family First New Zealand (CC42358) Charities Board Decision 2013-1, 15 April 2013

fourth category of charity at general law. Thirdly, the Board considers that the Trust has an independent purpose to procure governmental actions (including legislation, policies and governmental decisions) consonant with the Trust’s point of view. This purpose to procure governmental actions is a political purpose that is not charitable, and is not ancillary to any valid charitable purpose of the Trust.

The appeal against first deregistration decision

5. The appeal to the High Court was delayed until the decision in Re Greenpeace of New Zealand Inc [2014] NZSC 105 was handed down in the Supreme Court of New Zealand. That Court held by a majority, contrary to earlier authority, that the Charities Act (2005) (the Act) does not create a general exclusion of advocacy from charitable purposes, even where it is more than an ancillary purpose, and there is no standalone doctrine of exclusion of political purposes.

6. In Family First new Zealand [2015] NZHC 1493, the High Court held that the Board’s fundamental proposition, that Family First’s political objectives could never be charitable, could not be reconciled with the approach taken by the majority of the Supreme Court in Greenpeace and thus was incorrect. Further, it prompted the Board to consider whether Family First had a charitable education activity for the public benefit. The Board was directed to reconsider the question of Family First’s registration.

Second deregistration decision2

7. Family First made further submissions to the Board on the basis that (relying on the fourth head) its purposes were either analogous to purposes the courts have previously accepted as being charitable — the promotion of moral and mental improvement — or, relying on the second head, involved the advancement of education.

8. The Board again refused registration on the basis that Family First’s advocacy could not be regarded as for the benefit of the public and although one piece of their research might be of educational value, Family First did not present the results objectively, but merely to persuade the reader to a particular point of view consistent with their own.

High Court Judgement in 2018

9. The High Court disallowed the appeal in Family First New Zealand [2018] NZHC 2273. If Family First’s purposes were solely to promote the role of the Family, it would have a strong claim to charitable status, but the Court found other non-charitable purposes, such as to promote life by reducing access to abortion, and opposing legislation enabling assisted death disqualified it from charitable status. Further, even if there were an educative aspect to Family First’s activities, this was not its only purpose. Its other purposes and activities could not be regarded as ancillary to any educative purpose. Family First appealed to the Court of Appeal.

The Court of Appeal decision

Family First’s submissions to the Court of Appeal

2 Family First New Zealand (CC10094) Charities Board Decision 2017-1, 21 August 2017 [Second deregistration decision].

10. Family First submitted that:

- It was sufficient for Family First to show it had a purpose of advancing education or a purpose within the fourth head of charity which is also for the public benefit, provided that any other purposes are ancillary to these charitable purposes. The need to demonstrate public benefit is only required under the fourth head of charity, where the purpose is analogous to existing cases.

- That one should merely examine the Family First trust deed objects, and that an entity’s activities will only be relevant where its constituent documents do not disclose its purpose or where there is evidence of activities that displace or belie its stated charitable purpose.

- Family First’s promotion of the traditional family unit was not discriminatory and contrary to human rights law, but a reasonable view protected by the New Zealand Bill of Rights Act 1990 (NZBORA).

- Family First’s trust deed objects included an educational purpose and public benefit could therefore be presumed.

The Attorney-General’s submissions to the Court of Appeal

11. The Attorney-General submitted that:

- Family First’s contention that its activities benefited all forms of families could not be sustained on the evidence.

- Family First did not establish that its principal purpose, advocacy on behalf of the traditional Family, was of public benefit or was sufficiently analogous to any purpose previously accepted as charitable.

Charity Law Association of Australia and New Zealand (CLAANZ) as Intervenor

12. CLAANZ’s submissions were:

- where an organisation’s purpose does not entail a service provision, the public benefit test will depend on the existence of wider benefits to the community.

- that the possibility of incidental wider benefits arising from the fact of political advocacy itself should be considered, irrespective of the end advocated (Aid/Watch Inc v Commissioner of Taxation [2010] HCA 42).

- that removal of a subsidy to a previously registered charitable entity could result in an unreasonable limitation on that party’s right to freedom of expression.

Clifford and Stevens JJ

13. The majority dealt with the case by posing three broad questions (at [59]):

(a) Was the High Court wrong to conclude that Family First is not a trust for, presumptively charitable, educational purposes?

(b) Was the High Court wrong to conclude that Family First was not a trust for a fourth head charitable purpose, namely that of promoting families and marriage as of benefit and good to society?

(b) If the answer to either of those questions is yes, does Family First have non-charitable purposes of more than an ancillary nature which, notwithstanding, disqualify it from registration as a charity?

Approach to establishing the Purpose of Family First

14. The majority declared that the purposes of an entity may be expressed in its statement of objects or may be inferred from the activities it undertakes, as per s 18(3) of the Charities Act, affirming the view as expressed in Re Greenpeace of New Zealand Inc [2014] NZSC 105. The majority found that Family First’s objects in its trust deed, on their face, promote the advancement of education and were for a public good. After examining a cross-section of publications by Family First, the majority found its activities were broadly consistent with its objects expressed in its trust deed (at [113]).

Whether charitable under the fourth head and of public benefit

15. Family First asserted that it was a trust established to promote and support (that is, to advocate for) self-evident public goods, the institutions of the family and marriage. Consequently, this is a fourth head charitable trust established for matters which are beneficial to the community in the relevant sense.

16. The majority saw its task as the “assessment of whether there is public benefit in a charitable sense therefore requires consideration of the end promoted and the means and manner of that promotion” (at [136]). The majority agreed with the High Court that an overall objective of supporting, in a selfless way, the role and importance of families and marriage would not be self-evidently beneficial, in an analogously charitable sense, as a public good (at [138]).

17. They pointed to international conventions and treaties dealing with families in society as well as social research on disadvantage. The majority stated that it “would be curious if promotion of what the Board called the “traditional family” would cease to be of public benefit because there is a growing acceptance of other forms of stable family life, including within whānau and hapū relationships” (at [147]).

18. The majority also agreed with the issue raised by CLAANZ, of the public benefit associated with free speech and associated political discourse in a rule of law, liberal and democratic society such as New Zealand.

Non-charitable and non-ancillary advocacy for specific political/legislative responses?

19. The majority resolved this issue by posing the question “to the extent that Family First has advocated for positions on specific issues where views differ, Family First has a non-charitable purpose that is more than ancillary” (at [159])? They considered that Family First’s engagement in the deliberations of the community on issues such as abortion, assisted death, anti-smacking laws, prostitution reform and censorship was properly characterised as part of its broader purpose of supporting marriage and family as being foundational to a strong and enduring society.

20. The approach as regards fourth head charities is one of recognising goals and objectives of general public benefit. Having done so, the Court will not seek to reach a concluded view on self-evident public benefit on specific issues where views may differ. Nor will advocacy in support of one or other of the competing viewpoints necessarily disqualify an organisation from charitable status. The majority compared this to the advancement of religion. Belief in religion is seen as a good thing, so the courts do not distinguish between particular religions, or consider advocacy of specific beliefs and practices which one group believes in, but not another, as a bar to charitable status.

Human rights law considerations

21. The majority held that, whether or not the law changes advocated by Family First are in tension with human rights law, its purpose in advancing them cannot be considered to be illegal in the relevant sense. This was not an obstacle to charitable status.

CLAANZ’s submission on tax subsidy

22. The majority did not deal with the CLAANZ suggestion that removal of a tax subsidy to a previously registered charitable entity could be an unreasonable limitation on its right to freedom of expression, particularly if this meant it could not continue to engage in its political purposes.

Gilbert J (dissenting)

23. The dissenting judgement concurred with the High Court in Family First’s appeal from the second deregistration decision, in that it was considered that Family First’s objects did not fit comfortably with the advancement of education. Further, the majority’s analysis appeared to conflate the two limbs of the public benefit test. The purpose must be such as to confer a benefit on the public or a section of the public (the benefit component), and the class of persons eligible to benefit must constitute the public or a sufficient section of the public (the public component). The focus on “family” as a “self-evident public good” is misplaced and does not satisfy the benefit component. Finally, Family First’s advocacy on social issues cannot be categorised as merely ancillary to some other charitable object. Rather, the evidence demonstrates that this forms an important part of its core purpose.

New Zealand – Sue Barker Sue Barker is director of CharitiesLaw Ltd, a boutique law firm based in Wellington, New Zealand, specialising in charities law and public tax law. Sue Barker is currently on sabbatical as the 2019 New Zealand Law Foundation International Research Fellow, undertaking research into the topic “What does a world-leading framework of charities law look like?” with a report due in 2021. Sue is also a director of the Charity Law Association of Australia and New Zealand (“CLAANZ”), the intervener in the case. However, all views expressed are those of the writer and not necessarily those of CLAANZ. The writer would respectfully suggest that a conclusion, as to whether New Zealand is in convergence or divergence with the rest of the common law world on the topic of advocacy by charities, would be premature: the Supreme Court decision in Re Greenpeace of New Zealand Inc [2015] 1 NZLR 169 (SC) (Greenpeace SC) is open to more than one interpretation, and the position remains unsettled even following the Court of Appeal decision in Family First New Zealand v Attorney-General [2020] NZCA 366 (“Family First CA”).

The position should have been considered settled after the decision of the High Court in Re The Foundation for Anti- Aging Research and The Foundation for Reversal of Solid State Hypothermia (2016) 23 PRNZ 726 (“Foundation for Anti- Aging Research”), where Ellis J set out the orthodox position, as discussed in ACPNS Legal Case Note Series: 2020-109 at page 8. However, it appears that the agency responsible for administering New Zealand charities’ legislation (currently, the Department of Internal Affairs – Charities Services Ngā Ratonga Kaupapa Atawhai (“Charities Services”) and the Charities Registration Board Te Rātā Atawhai (“the Board”)) put forward arguments based on an entirely different paradigm in the very next case to be argued under the Charities Act 2005, resulting in the decision of Simon France J in Re Family First New Zealand [2018] NZHC 2273 (“Family First HC 2”).

Engagement in the democratic process

The difficulties of Family First New Zealand (“Family First”) appear to have crystallised when it made submissions in 2012 opposing the Marriage (Definition of Marriage) Amendment Bill (“the Gay Marriage Bill”). The Gay Marriage Bill passed its final stage in Parliament in March 2013, and a few weeks’ later, the Charities Registration Board issued a decision that Family First should be deregistered. In upholding Family First’s appeal of the decision, Collins J noted in Re Family First New Zealand [2015] NZHC 1493 (“Family First HC 1”) at [84] that the approach taken by the Board could not be reconciled with the approach subsequently taken by the majority in Greenpeace SC, and referred the matter back to the Board for reconsideration in light of the Supreme Court decision.

However, some 2 years later, in 2017, the Board surprisingly made the same decision.

This decision, that Family First should be deregistered on the basis of its advocacy for the “traditional family”, appears to have caused such consternation across the Tasman in Australia that the May 2018 Report of the Expert Panel on the Religious Freedom Review recommended section 11 of the Australian Charities Act 2013 (Cth) be amended “to clarify that advocacy of a “traditional” view of marriage would not, of itself, amount to a “disqualifying purpose” (recommendation 4). The Report noted (at 1.200) that charities advocating for a “traditional” view of marriage would not be at risk of losing their charitable status under Australian law, and the Panel was “reluctant to draw too many inferences from overseas experiences which turned on different legislation and specific facts in those cases”. However, the Panel saw a benefit to “assist certainty” to put the issue raised by the legalisation of same-sex marriage in Australia “beyond doubt”.

Despite submissions that such an amendment was not required and would set an unfortunate precedent that could itself have unintended consequences, the Australian Government accepted the recommendation, and included a proposed amendment to section 11 of the Charities Act 2013 in 2 exposure drafts of a bill released in 2019 (see item 4 of the exposure draft Human Rights Legislation Amendment (Freedom of Religion) Bill). Passing of the bill into law appears to have been affected by a number of matters, not least an intervening global pandemic. To the extent that it might be appropriate to make a Trans-Tasman observation, one might be forgiven for wondering whether such an amendment would still be considered necessary following the decision of the Court of Appeal in Family First CA. Of course, the decision of the Court of Appeal is split 2:1 and, at the time of writing, it is not known whether the Attorney-General will appeal. Hence, the position in New Zealand arguably remains unsettled.

The Latimer paradigm

Fundamentally, the difficulty in New Zealand appears to arise from what might be described as a “clash of paradigms”. The orthodox paradigm, as described in cases such as Latimer v Commissioner of Inland Revenue [2002] 3 NZLR 195 (CA) (Latimer CA)) and Foundation for Anti-Aging Research, would support a disciplined approach that encompasses key elements such as the following:

(i) An entity’s purposes are to be ascertained primarily from a construction of its constituting documents, the decision-maker’s role in this regard being one of “interpretation, not creation”.3

(ii) There is a 2-step approach to ascertaining whether a purpose is charitable: first, does the purpose operate for the public benefit; second, if so, is the purpose charitable, in the sense of falling within the spirit and intendment of the preamble to the Statute of Charitable Uses 1601 (43 Eliz c4).4 The Supreme Court in Greenpeace SC did not dispense with this 2-step test and, despite at times using a short-hand expression that might appear to conflate the two limbs of the test,5 in fact was at pains to emphasise that both limbs of this test must be satisfied.6

(iii) Deriving from an equitable jurisdiction, the law of charities does not easily give rise to “bright lines” or hard and fast rules. Ascertaining whether a purpose operates for the public benefit is a question of fact that must be determined on the evidence before the decision-maker. Wider public benefits, and also any detriments, can and should be taken into account. Importantly, prior to the Charities Act 2005, charities were able to access a full de novo oral hearing of evidence before a trier of fact,7 allowing first instance decisions to be made on the basis of a robust evidential platform.

(iv) There is a distinction between purposes and activities: it is purposes that must be charitable, not activities. The key question with respect to activities is whether they are carried out in furtherance of the charity’s stated charitable purposes.

Applying this “Latimer paradigm”, the purpose of the Crown Forestry Rental Trust to assist Māori to bring claims before the Waitangi Tribunal regarding licensed land, was found to be charitable, despite the acknowledged private benefits to individual claimants. Importantly, the purpose was also found not to be “political”,8 despite the fact that the Treaty Settlement process was highly controversial at the time, and always, without exception, results in an Act of Parliament to settle the wrongs.

Even under the Latimer paradigm, the decision of the New Zealand Court of Appeal in Molloy v Commissioner of Inland Revenue [1981] 1 NZLR 688 (CA) (“Molloy”) seems correct in its factual context, as subsequently noted by the Supreme

3 See Inglis v Dunedin Diocesan Trust [2011] NZAR 1 (HC) at [29]-[33], Public Trust v Cancer Society of New Zealand Incorporated [2020] NZHC 615 (23 March 2020) at [11] and Family First CA at [86]-[89]. 4 See Latimer CA at [32]. 5See Greenpeace SC at [3], [18], [73], [103], [114]. 6 See Greenpeace SC at [27], [29], [30], [32] and [113]. 7 See Foundation for Anti-Aging Research v Charities Registration Board, [2015] NZCA 449 at [44]. 8 See Latimer CA at [40]. Court.9 The topic of abortion was extremely divisive in New Zealand society at the relevant time.10 The writer recalls news media reports of doctors’ houses being burned. It seems understandable in all the circumstances that the Court might have considered such an issue not appropriately justiciable. However, far from indicating a “strict political purpose exclusion”, the writer would argue the decision in Molloy simply manifests a fundamental Latimer paradigm principle: that the question of whether a purpose is “political” is simply one facet of the public benefit test, as is the issue of controversy, as has subsequently been acknowledged by the Supreme Court.11

The alternative paradigm

By contrast, the alternative paradigm, espoused by Charities Services, the Charities Registration Board and now, it seems, the Attorney-General, would take a fundamentally different approach:

(i) An entity’s purposes are “inferred from activities”, seemingly without reference to an entity’s constituting document. How this approach sits with the duty of governors of charitable entities to comply with the terms of their constituting document is not explained.

(ii) The 2-steps of the test for whether a purpose is charitable are conflated, if the test is mentioned at all.

(iii) Evidential discipline in determining whether any purpose operates for the benefit of the public is replaced with a subjective “free-range” assessment of whether the decision-maker can perceive public benefit in all of the entity’s activities (the inadvertent removal by the Charities Act 2005 of charities’ access to a trier of fact may be a contributing factor in this regard).

(iv) Purposes and activities are conflated and treated more or less interchangeably.

With respect, decisions decided under the alternative paradigm, such as Family First HC 2 and the minority decision in Family First CA, are based on an interpretation of the Supreme Court decision that cannot be said to be settled. These decisions do not analyse, or even make any reference to, the Court of Appeal decision in Latimer CA, despite the Supreme Court’s approval of the decision. Other controversial decisions, such as Canterbury Development Corporation & Ors v Charities Commission [2010] 2 NZLR 707 (HC), Re Draco Foundation (NZ) Charitable Trust (2011) 25 NZTC 20- 032 (HC), and Re Queenstown Lakes Community Housing Trust [2011] 3 NLZR 502 (HC), similarly make no reference to the Court of Appeal decision in Latimer CA, and in the writer’s view cannot be sustained in light of their inconsistency with that higher authority.

Discussion

The majority of the Court of Appeal applies an orthodox Latimer paradigm approach to find Family First entitled to registration, on the basis that its purposes are exclusively charitable, and all its activities are undertaken in furtherance of those charitable purposes. While there may be some complexity involved in the majority’s analysis of the 4th head and the ancillary purposes doctrine, no doubt caused by an attempt to reconcile the fundamentally irreconcilable

9 Greenpeace SC at 73. 10 Re Greenpeace New Zealand Incorporated, [2011] 2 NZLR 815 (HC) at [45]. 11See Greenpeace SC at [72]-[74], [75] and [99]. alternative paradigm with the Court of Appeal decision in Latimer CA, in principle, the decision of the majority must be correct: as noted at [114], the function of the Court is not to take sides, but to sieve out debates which are for improper purposes, and then leave the public debate to lie where it falls, in the public arena. To deregister charities simply because there is not universal acceptance of their advocacy is fundamentally to undermine freedom of expression, and New Zealand’s system of participatory democracy. It is also fundamentally inconsistent with New Zealand’s international treaty obligations. Under the alternative approach, slavery would never have been abolished and women in New Zealand would never have got the vote.

We must have tolerance for views we disagree with. As Rowan Atkinson pointed out in submissions to the English Parliament in 2012 seeking reform to section 5 of the Public Order Act (UK),12 underlying prejudices, injustices or resentments are best addressed by the issues being aired, argued and dealt with: “As with childhood diseases, you can better resist those germs to which you have been exposed”. As former US President Barack Obama has noted:13 “Laudable efforts to restrict speech can become a tool to silence critics or oppress minorities. The strongest weapon against hateful speech is not repression, it is more speech”.

In other words, I may not agree with what you say, but I will defend to the death your right to say it. It is hoped that the upcoming appeal to the Court of Appeal by Better Public Media Trust, against the decision of the Board declining its application for charitable registration, will shed further light on the status of the Latimer paradigm in New Zealand law, and how the Supreme Court decision in Greenpeace SC should be correctly interpreted.

Australia - Matthew Harding is a Professor of Law at the Melbourne Law School. Murray Baird is a Senior Fellow at the Melbourne Law School.

Matthew is President and Murray is Secretary of the Charity Law Association of Australia and New Zealand. CLAANZ was given leave of the Court to intervene in the case to address two issues of principle: the benefits flowing from political advocacy and the right to freedom of expression. Jennifer Batrouney QC of the Victorian Bar and Kate Davenport QC of the New Zealand Bar appeared for CLAANZ instructed by Sue Barker Charities Law of Wellington. All views expressed are those of the writers and not necessarily those of CLAANZ.

While the implications of this decision will be felt mostly in New Zealand, it is interesting to reflect on how the reasoning of the majority stands in relation to cognate Australian jurisprudence. This is found largely in the judgment of the majority of the High Court of Australia in Aid/Watch v Federal Commissioner of Taxation [2010] HCA 42.

In parts of the majority’s judgment in Family First, the reasoning seems to align with that of the majority in Aid/Watch. For example, around [92] the majority seem to bring advancement of education and advocating for a point of view of public interest into close alignment, at least where that point of view relates to a recognised charitable purpose. This is arguably more accommodating of advocacy in support of recognised charitable purposes than Keifel J was Aid/Watch, and comes closer to the majority’s view that the generation by lawful means of public debate is of public benefit, at least where this relates to extant charitable purposes. See also Family First at [109], where the majority recognises the

12 Which allowed the Police to “arrest anyone for saying anything that might be construed by anyone else as insulting”. 13 In a speech to the United Nations in 2012. connection between advancement of education and stimulating ‘public discourse on important social issues relevant to families’.

Moreover, [153] seems to recognise the public benefits associated with political expression in a liberal democracy, an argument urged by the Charity Law Association of Australia and New Zealand as intervener in the appeal. At [170]-[174] an analogy was drawn between purposes of religious evangelism and purposes of political advocacy, suggesting that in both cases public benefit might be present even if decision-makers remain agnostic as to the ends sought to be achieved (in the one case conversion to one or another faith; in the other case acceptance of some point of view on a contested question in political debate). All of this is redolent of the majority in Aid/Watch in the following passage (at [45]):

…it is the operation of … constitutional processes which contributes to the public welfare. A court administering a charitable trust for that purpose is not called upon to adjudicate the merits of any particular course of legislative or executive action or inaction which is the subject of advocacy or disputation within those processes.

On the other hand, aspects of the majority reasoning in Family First seem to confirm that New Zealand law is heading down a path quite different from that signposted in Aid/Watch. Nowhere is this clearer than in the part of the majority judgment ([138]ff) in which there is discussion of the public benefit associated with the ‘ends’ that Family First sought to advocate for. It seems difficult to accept the distinction drawn here between ‘self-evidently beneficial’ objectives and other objectives when it comes to questions over which there is deep and abiding disagreement in the community.

Equally, the majority’s resort ([151]ff) to ‘moral improvement’ cases seems strained and the reasoning here is, with respect, weak. Australian jurisprudence, under Aid/Watch and now s 12 of the Charities Act 2013, does not demand that such value judgments be made about individual political ends to which charity advocacy is directed. This may be viewed as a strength of the current Australian approach as it insulates decision-makers from political controversy in much the same way as the old rule from Bowman v Secular Society [1917] AC 406 managed to do.

Family First raises numerous further legal questions of interest in Australia as well as New Zealand. Perhaps the most fundamental is whether any of the recent antipodean cases purporting to change the law relating to political purposes has, in fact, effected any legal change at all. On one reading, Aid/Watch, Family First and, for that matter, Greenpeace may all be understood as cases in which charitable purposes were pursued by ancillary political means, a state of affairs that should be viewed with equanimity even under the Bowman rule.

This case may be viewed at http://www.austlii.edu.au/nz/cases/NZCA/2020/366.html

Read more notable cases in The Australian Nonprofit Sector Legal and Accounting Almanac series.

Author: McGregor-Lowndes, Myles & Hannah, Frances M.

Email: [email protected]

Date of creation: September 2020

Number of case: 2020-115

Disclaimer: The material included in this document is produced by QUT’s Australian Centre for Philanthropy and Nonprofit Studies (ACPNS) with contribution from some authors outside QUT. It is designed and intended to provide general information in summary form for general informational purposes only. The material may not apply to all jurisdictions. The contents do not constitute legal advice, are not intended to be a substitute for legal advice and should not be relied upon as such. You should seek legal advice or other professional advice in relation to any particular matters you or your organisation may have.

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