Hate Crime and Vilification Law: Developments - The University of ...

HATE CRIME AND VILIFICATION LAW: DEVELOPMENTS AND 

DIRECTIONS 

Roundtable on Hate Crime and Vilification Law: Directions and Developments, the Law School, 

University of Sydney, Friday 28 August, 2009. 

PART I: THE NSW CIVIL PROVISIONS 

The law in New South Wales currently prohibits public acts that incite hatred towards, serious 

contempt for, or severe ridicule of, a person or group of persons on the grounds of race, 

homosexuality, HIV/AIDS infection or transgender identity. These prohibitions are contained in 

Section 20C, 49ZT, 49ZXB and 38S (“the NSW civil provisions”) of the Anti Discrimination Act, 

1977 (NSW) (“ADA”). 

Most other States have analogous legislation and in 1995 the Commonwealth enacted Part IIA of 

the Racial Discrimination Act. The latter is also aimed at prohibiting incitement to racial hatred in 

the public domain but its provisions are formulated quite differently from those contained in the 

State Acts. As I am here representing the Anti Discrimination Board of NSW (“ADB”), which 

administers the ADA, my comments will focus on the NSW legislation. 

The acts that are prohibited by the NSW civil provisions are not criminal offences. They are 

analogous to civil wrongs. This means that people who believe that they have been publicly vilified 

on the ground of race, homosexuality, HIV/AIDS infection or transgender identity can seek redress 

under the NSW civil provisions through the ADB against the person or persons who they say 

vilified them. 

The ADB can provide such redress by arranging conciliation through one of its trained officers. If 

conciliation is successful, a range of remedies is available (eg publication of an apology, monetary 

compensation). If conciliation fails, or if the ADB does not believe that conciliation has any 

prospects of resolving the complaint, the matter may be referred to the Administrative Decisions 

Tribunal (“ADT”) for a formal legal hearing, similar to a court case between private parties. 

In practice, conciliation cannot work against a determined offender, that is, someone who sees 

nothing inherently wrong with racism or homophobia or who considers these qualities to be a 

virtue. No purpose can be served by forcing someone with a well-founded complaint into a 

conciliation process that is doomed to failure, and it may simply provide the respondent with an 

opportunity to repeat the vilification with impunity during the conciliation. Almost always, such 

matters will be referred straight to the ADT. Conciliation of a well-founded complaint has better 

prospects if the respondent has no self-perception as a racist or homophobe and would wish not to 

be perceived that way by others. 

Under s.105 of the ADA, the ADT may, on the application of a complainant or respondent at any 

time and pending a final determination of the matter, make an interim order: 

(a) to preserve the status quo between the parties to the complaint, or 

(b) to preserve the rights of the parties to the complaint, or 

(c) to return the parties to the complaint to the circumstances they were in before the contravention 

alleged in the complaint occurred.. 

In a complaint of vilification, the ADT will only find in favour of a complainant if is satisfied, on the 

balance of probabilities, that the person about whom the complaint is made has been the author of: 

(a) a public act

(b) which incites 

(c) hatred towards, serious contempt for, or severe ridicule of a person or group of persons 

2 

(d) on the ground of the race or homosexuality or HIV/AIDS infection or transgender identity of 

the person or group (“the prohibited grounds”). 

It is a complete defence to a complaint made under the civil provisions that the act complained of 

falls within subsection (2) of the relevant section, that is that the act was either a fair report of a 

public act, or a communication in respect of which a defence of absolute privilege would apply in 

defamation proceedings or a public act, done reasonably and in good faith, for academic, artistic, 

scientific or research purposes or for other purposes in the public interest, including discussion or 

debate about and expositions of any act or matter. If the four elements required to establish a 

complaint are proved, the onus shifts to the respondent to establish one or more of the defences. 

This is no simple task, particularly if the respondent must also prove that he or she acted 

“reasonably and in good faith”, as is usually the case. 

I am attaching some statistics produced by the ADB breaking down vilification complaints it 

received in the financial years 2006-2007, 2007-2008, 2008-2009. The statistics are of some, but 

limited, utility. The ADB received more than 1100 complaints under the ADA in each of the last 

three financial years, but only 2% or 3% in each year were complaints of vilification. The relatively 

small number of complaints of vilification might be due to the fact that many, if not most, complaints 

of racial vilification are directed to the Australian Human Rights Commission under the Federal 

legislation, which does not address other forms of vilification. According to information on the 

Commission’s website, “[d]uring 2005-06, the Commission received 259 complaints under the 

Racial Discrimination Act (this includes complaints lodged under the racial hatred provisions). 

Employment, the provision of services and racial hatred were the main areas of complaint”. (See 

http://www.hreoc.gov.au/about/media/speeches/race/2007/addressing_racism_in_australia.html 

accessed on 17 August 2009). 

The majority of vilification complaints to the ADB over the last three financial years were of racial 

vilification. Homosexual vilification came second. The number of complaints of transgender and 

HIV vilification was very small. Of course not every incident of vilification is the subject of a 

complaint to the ADB or the Commission and the number of complaints is therefore not a reliable 

guide to the incidence of vilification in New South Wales or elsewhere. But one can safely 

conclude that complaints to the ADA, unlike those made to the Commission, are only infrequently 

about vilification. 

Yet complaints of vilification are usually among the most contentious of the complaints received by 

the ADB. In two of the three years under review, none of those complaints was resolved through 

conciliation. In the other year, only 3 out of 27, or 11%, were successfully conciliated. Most 

vilification complaints ended up being declined, withdrawn or abandoned. This might perhaps 

indicate that they lacked merit or, alternatively, that they were well-founded but the complainants 

were unwilling to put themselves through the legal process. The next largest group of 

complainants, on the other hand, were those who fought out their complaints in the ADT. 

Regrettably I was not able to get statistics about the success and failure rates of complaints of 

vilification that are litigated in the ADT; the remedies sought; or the reasons for the failure of 

litigated complaints that are unsuccessful. The high rate of discontinuance of vilification complaints 

and the fact that most complaints of racial vilification in New South Wales appear to be made 

under Federal legislation raise a question about the efficacy of the legislative scheme in New 

South Wales. Is it simply too difficult to pursue even a well-founded complaint of vilification to a 

successful conclusion under the ADA? 

A review of the NSW civil provisions might provide some answers. I will begin by considering each 

element in turn.

(a) Public act 

3 

The expression “public act” is defined in Sections 20B, 38R, 29ZS and 49ZXA of the ADA. The 

expression extends to “any form of communication to the public”, “any conduct...observable by the 

public” and “the distribution or dissemination of any matter to the public with knowledge that the 

matter promotes or expresses hatred towards, serious contempt for, or severe ridicule of, a person 

or group of persons” on one of the prohibited grounds. 

The word “public” is not defined in the legislation. The jurisprudence in this and other areas of the 

law and other jurisdictions suggests that courts are inclined to give a broad interpretation to the 

word “public” and to exclude from its scope only those circumstances that might be characterized 

as purely domestic, for example, a conversation in a private home that cannot be overheard. 

This leads to the fundamental question of whether a public element should be included at all as 

one of the elements of serious vilification. On one view, the harms of vilification are at least as real 

in circumstances where the vilifier and the victim are alone together as they are where the victim is 

not present and the vilification is directed to a large audience. The contrary view is that the 

legislation is directed at addressing a social rather than a personal harm and the social harm 

arises only when the vilification occurs in a public context. 

Another question arises out of the development of communications technology. Section 20B was 

enacted in 1989. The other three sections, all enacted subsequently, essentially replicate section 

20B. In 1989, the internet had not developed into the widely used, publicly accessible medium that 

it has since become. A very large volume of material is now published on the internet and may be 

accessed generally by any member of the public, usually without the necessity for any payment. 

Under Part IIA of the RDA, a vilificatory act is unlawful only if it is done “otherwise than in private”. 

The case law has established that placing material on the internet that is freely available and not 

password protected is an act done “otherwise than in private”: Jones v. Toben [2002] FCA 1150 

(17 September 2002) (para.75) and Toben v. Jones [2003] FCAF 137 (27 June 2003). As was 

determined by the High Court of Australia in Dow Jones v Gutnick (2002) 210 CLR 575; [2002] 

HCA 56, in relation to the net, publication is not a single event located by reference only to the 

publisher's conduct. It occurs each time a reader downloads the material. 

Amending the definitions of “public act” in the ADA so as to incorporate this jurisprudence would 

bring the anti-vilification provisions of the ADA into the internet age and in line with the judicial 

interpretation of the equivalent provisions of Part IIA of the RDA. 

(b) Incites 

The word “incite” is not defined in either the civil provisions or the criminal provisions of the ADA. 

Cases that have arisen out of the civil provisions (and analogous provisions in other jurisdictions 

outside NSW) have defined the expression to mean “to urge on, stimulate or prompt to action”. 

This is based on the Macquarie Dictionary definition of the word “incite”. 

The Oxford Dictionary definition includes “stir up, animate”. It therefore seems reasonably clear 

that the concept of incitement involves stimulating others to do something or to feel something. 

This allows for the possibility that incitement may occur when the feelings of others are aroused, 

even if they do not act on those feelings. Both the civil provisions and the criminal provisions of 

the ADA focus on the stirring up of feelings (i.e. “hatred”, “serious contempt”, “severe ridicule”) 

and, in the case of the criminal provisions, on the means used to do so, rather than on any 

consequential action that may be taken or threatened, or the effect on the victims.

4 

The legislation does not make it clear whether proof of incitement requires evidence that others 

have in fact been incited. In certain cases that have come before the Courts, those accused of 

incitement have sought to argue that the concept of incitement encompasses both the act of the 

alleged inciter and the reaction of those who have been incited. They have contended that proof is 

required that other people have actually been incited. 

However, the Courts have not accepted that contention. The case law establishes that 

“incitement” can be proved even in the absence of evidence that other people have in fact been 

roused to hatred (or to acting upon that hatred). Rather, the test is whether a hypothetical 

audience of reasonable people who are neither immune from, nor particularly susceptible to, 

feelings of hatred on one of the prohibited grounds would be incited. 

An alternative approach would be to abandon the terminology of incitement altogether in favour of 

some other test. I discuss this in more detail in the section headed “The Criminal Provisions”. 

(c) Hatred, serious contempt or severe ridicule 

Anti-vilification legislation in other States in Australia has replicated the formulation “hatred 

towards, serious contempt for, or severe ridicule of” that appears in the ADA. Federally, Part IIA of 

the Racial Discrimination Act employs the expression “hatred” only. Examples of both formulations 

can be found in analogous legislative provisions in other countries. Little seems to turn on the 

distinction, even though “serious contempt” and “severe ridicule” are arguably less stringent criteria 

than “hatred”. 

The interpretation of these words does not seem to have presented courts in Australia or overseas 

with undue difficulty. The plain dictionary definition of these words entails something in the nature 

of intense or active dislike. That definition excludes much material that would widely be regarded 

as innocuous. For example, humour based on ethnic or homosexual stereotypes, considered in 

context, can often be accepted as light-hearted and even, in a uniquely Australian way, 

affectionate. It would clearly fall outside the operation of the criminal (and civil) provisions. 

Western Australia’s legislation has expanded the scope of the behaviour that is prohibited to 

include behaviour whose effect is “to threaten [or] seriously and substantially abuse” others on a 

prohibited ground. But these formulations are used in the context of a Criminal Code proscribing 

criminal conduct and do not sit comfortably with legislative provisions which impose civil 

prohibitions. 

(d) The Prohibited Grounds 

Neither the civil provisions nor the criminal provisions of the ADA apply unless there has been a 

public act of incitement to hatred of a person or group on one of four grounds, namely: 

(i) Race 

(ii) Homosexuality 

(iii) HIV/Aids infection; or 

(iv) Transgender identity (ie being a transgender person). 

“Race” is defined in s.4 of the ADA as including “colour, nationality, descent and ethnic, ethnoreligious 

or national origin”. This broad definition is declaratory of the case law on the meaning of 

“race” as it has developed both in Australia and overseas. However, vilification solely on the 

ground of religion would fall outside the prohibitions contained in the ADA. 

The existing prohibited grounds therefore afford protection against vilification only to some groups. 

These groups appear to have been selected on the basis of a well-recorded history of their 

members being victims of hatred. A question arises whether the prohibited grounds should be

5 

enlarged to extend that protection to other groups. The NSW Law Reform Commission’s (LRC) 

Report No. 92 considered whether there should be three further prohibited grounds, namely 

gender, disabilities and religion, but the LRC did not recommend that any of them be included. 

The arguments for and against expanding the prohibited grounds are well summarized in LRC 

Report 92 and need not be repeated here. 

Some protection is already provided in the existing legislation to religious minorities by the 

inclusion of “ethno-religious origin” as a prohibited ground. However, the way the case law has 

developed, there is no prohibition in New South Wales against criticizing the beliefs or practices of 

a particular religion on exclusively philosophical or theological grounds. The only restriction is that 

if the adherents of that religion are also an ethno-religious group, the manner of such criticism 

must not collectively vilify the group. 

The question of which categories of groups should be protected is not the only issue that arises. 

Section 88 of the ADA precludes a vilification complaint from being made by anyone who does not 

have, or reasonably claim to have, the characteristic that was the ground of the alleged vilification. 

This means that the protection afforded by the criminal (and civil) provisions extends only to 

persons who are actually members of the groups referred to in those provisions but not to persons 

who are vilified because they are presumed to be members. 

Clearly, a person may be publicly vilified, say, as a homosexual even though that person is not a 

homosexual. The question therefore arises whether the legislation should be amended so that the 

protection afforded by the criminal provisions extends to any person or group of people because of 

their actual or presumed race, homosexuality, HIV/AIDS infection or transgender identity. 

In Western Australia, again in the context of proving criminal offences, there is no requirement that 

victims be actual members of the relevant protected group. A conviction may be secured even if 

that is not the case, and the alleged offender merely believed it to be so, correctly or incorrectly. I 

can see no reason in logic or principle why the protection afforded by both the civil and criminal 

provisions in NSW should not extend to any person or group of people because of their presumed 

(even if not actual) characteristics under one of the prohibited grounds. 

PART II: THE NSW CRIMINAL PROVISIONS 

Even though this paper principally addresses the NSW civil provisions, I would like to make some 

brief observations also about the corresponding criminal provisions contained in Sections 20D, 

49ZTA, 49ZXC or 38T of the ADA (“the criminal provisions”). A prosecution under any of the 

criminal provisions cannot succeed unless each of the four elements specified in the civil 

provisions are proved. And they must be proved to the criminal standard, that is, beyond 

reasonable doubt. A fifth element must also proved. The incitement must occur: 

“by means which include either: 

(i) threatening physical harm towards, or towards any property of, the person or group 

of persons, or 

(ii) inciting others to threaten physical harm towards, or towards any property of, the 

person or group of persons.” 

Under the ADA a person cannot be prosecuted under the criminal provisions unless the Attorney 

General of NSW has consented to the prosecution. In point of fact, not a single person in New 

South Wales has ever been prosecuted for, let alone convicted of, a criminal offence under any of 

the criminal provisions. Altogether, there were 16 occasions between 1993 and 2008 when the 

Attorney General referred to the Director of Public Prosecutions (DPP) complaints received by the 

President of the ADB to consider whether an offence of serious vilification might have occurred.

6 

The fact that there have been no prosecutions raises the question of whether there is a gap 

between the way legislators and the public have expected the criminal provisions to operate and 

the way they in fact operate – an “expectation gap”. If there is such a gap, the main reason 

according to the advice received from the DPP is the need to prove two of the elements of the 

offence that are particularly difficult to prove – the “incitement” element and the “means” element. 

(a) The ‘incitement’ element 

I have already mentioned the difficulties involved in proving ‘incitement’, even in the civil context 

and to the civil standard. Are there alternatives, particularly in the context of the NSW criminal 

provisions? 

Article 4 of the International Convention on the Elimination of All Forms of Racial Discrimination, to 

which Australia is a party, requires States to “declare as an offence punishable by law all 

dissemination of ideas based on racial superiority or hatred” (see para. (a)). 

The Convention thus seems to require that the mere expression and advocacy of racial hatred to 

others ought to be made a punishable offence. Implicit in this requirement is the proposition that 

the mere dissemination of ideas of racial hatred necessarily involves a sufficiently serious breach 

of the peace to justify the imposition of criminal sanctions. As noted earlier, there may well be 

sound sociological and historical reasons for accepting that proposition, although it remains 

controversial and would almost certainly be challenged by some on civil liberties grounds. 

Moreover, removing the terminology of incitement from the ADA and replacing it with new 

terminology, such as “the dissemination of hatred” on any of the prohibited grounds, would involve 

jettisoning the body of jurisprudence that has developed in Australia in particular around the 

concept of incitement. Whatever benefit may be obtained from removing the difficulties inherent in 

the concept of incitement from the criminal provisions may well be outweighed by introducing 

entirely new concepts whose interpretation by the Courts could not be predicted. 

Neither the civil nor the criminal provisions of the ADA expressly require that the incitement be 

intentional. When anti-vilification laws were first introduced in New South Wales in 1989, the then 

Attorney-General said in his Second Reading Speech that intention to incite would need to be 

proved in order to establish a breach of the criminal provisions, but not of the civil provisions. 

The argument that proof of intention to incite ought to be a requirement for securing a conviction 

under the criminal provisions derives from the common law concept that the element of mens rea 

(literally “guilty mind”) must be present to justify the imposition of criminal sanctions. Satisfying 

this requirement in any criminal prosecution usually entails proof of criminal intent or at least 

reckless indifference by the accused to the consequences of the proscribed behaviour. 

The counter-argument is that public acts of vilification on any of the prohibited grounds ought to be 

criminalised whether or not there is intent or recklessness, because of the destructive message 

that would be conveyed to society if those acts went unpunished. 

One possible way of dealing with the mens rea element would be to introduce two types of offence 

to proscribe vilificatory behaviour. The first offence would require proof of an intention to incite 

hatred and would carry the heavier penalty. The second offence would be in the nature of a strict 

liability offence and would require proof only of the likelihood (or reasonable likelihood) of a 

proscribed outcome. A person charged with the first offence could, if intention is not proved, be 

liable nevertheless to be convicted of the second offence, if the evidence is sufficient to prove the 

elements of the second offence.

7 

In essence, this is the regime that was introduced in The Criminal Code of Western Australia in 

2004. The “strict liability offences” in that Code are framed in identical terms to the criminal 

offences but without the element of intent. If the proscribed conduct is merely “likely” to incite 

racial animosity or racist harassment or to result in racist harassment, the offence in each case will 

be proved. The word “likely” is usually associated with the civil standard of proof, and its 

appearance in a criminal statute might be considered anomalous. 

Further, there are defences that are available to a person accused of committing any of the strict 

liability offences, which are not available to persons accused of the intentional offences. These 

defences are set out in Section 80G. In essence, these defences excuse conduct that is done 

“reasonably and in good faith” if the conduct was either a fair report of a public act, or a 

communication in respect of which a defence of absolute privilege would apply in defamation 

proceedings or a public act, done reasonably and in good faith, for academic, artistic, scientific or 

research purposes or for other purposes in the public interest, including discussion or debate about 

and expositions of any act or matter. The availability of these defences can provide an accused 

person with the opportunity of using the proceedings to grand-stand and repeat the vilificatory 

conduct in the court-room with impunity. 

(b) The ‘means’ element 

Even the most egregious examples of public acts of incitement to hatred on one of the prohibited 

grounds will not attract criminal sanctions unless it can be proved, beyond reasonable doubt, that 

the means of incitement were those stipulated in the criminal provisions. This element, the 

“means” element, presents perhaps an even more significant evidentiary hurdle than the need to 

prove incitement and, perhaps more than any other factor, accounts for the fact that there have 

been no prosecutions for serious vilification in New South Wales to date. 

The policy underpinning the inclusion of this element in the criminal provisions is that public 

incitement to hatred on a prohibited ground is said not to be sufficiently serious to warrant the 

imposition of criminal sanctions, even if the incitement is proved beyond reasonable doubt to have 

been intentional. Only a contemporaneous threat of harm to a person or property is said to justify 

criminalising vilificatory behaviour. 

And yet it seems clear that a vilificatory act need not be accompanied by, or itself constitute, a 

threat, or incitement to others to threaten, physical harm to person or property, and the act may 

nonetheless be perceived by the target person or group (and by others) – and reasonably 

perceived – as extremely threatening. The threat may be unmistakable to a reasonable observer 

even if it is merely implicit and not provable beyond reasonable doubt. 

There is a strong argument to be made that public incitement of hatred on any of the prohibited 

grounds, of itself, entails a breach of the peace, and that criminal sanctions are therefore 

appropriate where the incitement is intentional. Even if the incitement is not immediately 

accompanied by a threat of physical harm, or by an incitement of others to threaten physical harm, 

the incitement of the public to hatred on one of the prohibited grounds contributes to the creation of 

a social climate that is more conducive to the occurrence of acts or threats of physical harm to the 

groups that are targeted, and more conducive to social violence in general. 

Also, threats of physical harm towards a person or property, even in the absence of incitement to 

hatred, may well fall within the reach of the general provisions of the criminal law. For example, a 

person who “counsels or procures another” to commit a serious indictable offence can be 

prosecuted as an accessory before the fact under section 346 of the Crimes Act (NSW) 1900. To 

“counsel” others would include urging or inciting them. Apprehended violence orders are available 

under Part 15A of the Crimes Act and a common assault, if sufficiently serious, can be prosecuted 

as an indictable offence under Section 61 of that Act. The common law concept of assault

8 

encompasses acts that intentionally or recklessly put a victim in fear of physical or other unlawful 

danger. 

It follows that if there were to be a threat of physical harm towards a person or property, it would 

make sense to deal with it, where applicable, under the general criminal law so that there would be 

no need to prove the occurrence of (i) a public act (ii) that has incited hatred (iii) on one of the 

prohibited grounds. It would make no sense at all to prosecute the matter under the criminal 

provisions of the ADA, which impose penalties that are no higher than under other available 

provisions of the criminal law, but carry a far heavier evidentiary burden. 

In fact, conduct proscribed by s.20D of the ADA might be more heavily punished if prosecuted 

under other available provisions of the criminal law. A conviction under the Crimes Act 1900 

(NSW) for example can result in the imposition of enhanced penalties under Section 21 A(h) of the 

Crimes (Sentencing Procedure) Act, 1999 (NSW), which provides that one factor that can be taken 

into account in sentencing is whether: “the offence was motivated by hatred for or prejudice against 

a group of people to which the offender believed the victim belonged (such as people of a 

particular religion, racial or ethnic origin, language, sexual orientation or age, or having a particular 

disability”. 

However, the extent of the “enhancement” of the penalty is left entirely to the discretion of the 

sentencing judge. In most States of the USA, in contrast, the extent of penalty enhancement is 

prescribed by statute. Some 43 States (out of 50) and the District of Columbia have enacted such 

laws. An increase of 1/3 rd in the maximum term of imprisonment that would otherwise be 

applicable is typical of the way penalty enhancement provisions currently work in the US. In 

Wisconsin v Mitchell 508 U.S. 476 (1993), the US Supreme Court upheld the constitutionality of a 

penalty enhancement Statute directed against crimes motivated by hate based on the victim’s 

race, religion, national origin, sexual origin or gender. 

(c) Conclusions concerning the criminal provisions 

The treatment of serious vilification as a criminal offence varies widely between Australia and other 

common law jurisdictions such as the UK, Canada and the US. Even among the States of 

Australia, and the ACT, there are significant differences despite the many commonalities. In my 

view, short of a wholesale re-writing of the criminal provisions, reformers of anti-vilification law in 

New South Wales should focus primarily either on replacing the means element with something 

that will not operate in practice to emasculate the criminal provisions, as is presently the case, or 

better still, on simply eliminating the means element altogether. 

Peter Wertheim AM 

Statutory Board Member 

NSW Anti-Discrimination Board 

28 August 2009

9 

Breakdown Of Vilification Complaints Received In Financial Years 2006- 

2007, 2007-2008, 2008-2009 

Results for Financial Year 2006-2007 

2006-2007 Received 

Outcome Number % Conciliated 

Total Vilification Rec’d 35 0% 

HIV/Aids Vil. 0 0% 

Homosexual Vil. 11 0% 

Race Vil. 24 0% 

Transgender Vil. 0 0% 

Total complaints in Fin Year 2006-2007 = 1101 

% Of Vilification Complaints = 3% 

Results For Financial Year 2007-2008 








Total Complaints in Fin Year 2007-2008 = 1143 


Type of Vilification and Outcomes 

Outcomes From Complaints Received in 

2006-2007 

Outcome Number 

Declined 12 

Withdrawn 6 

Referred To ADT 11 

Declined, Referred to ADT 2 

Conciliated 0 

Settled, no conference 0 

Abandoned 3 

Referred to AG, Serious Vil. 1 

Outcomes From Complaints Received in 

2007-2008 


Declined 9 

Withdrawn 4 



Conciliated 3 



Referred to AG, Serious Vil. 1

Results For Financial Year 2008-2009 








Total Complaints in Fin Year 2008-2009 = 1188 


10 

Outcomes From Complaints Received 

in 2008-2009 


Declined 4 

Withdrawn 0 



Conciliated 0 



Referred to AG, Serious Vil. 0 

Open 7

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