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Australia (Federal) · Administrative Law

Commencing judicial review of a Commonwealth administrative decision

Judicial review examines the legality of a decision, not its merits. Grounds include jurisdictional error, denial of procedural fairness, improper purpose, unreasonableness, and failure to consider a mandatory consideration. The remedy is a writ returning the matter for reconsideration.

In short

This is an 8-step workflow for commencing judicial review of a Commonwealth administrative decision under the ADJR Act 1977 (Cth), s 39B of the Judiciary Act 1903 (Cth), or s 75(v) of the Constitution.

Time: 60-200 hours from intake to final hearing.
Audience: Litigation lawyers acting for individuals or corporations challenging Commonwealth decisions — migration, social security, tax, environment, freedom of information.
Run this workflow with Quillio — free trial
Prerequisites

Before you start

  • Decision under review identified
  • Statement of reasons (s 13 ADJR) or s 28 AAT Act
  • Client standing (person aggrieved)
  • Within time or strong case for extension
8 steps

The workflow

1

Identify the statutory pathway

Identify whether the decision is reviewable under the ADJR Act, s 39B Judiciary Act, s 75(v) Constitution, or a specific privative clause (e.g. Migration Act Part 8). Pathway affects grounds and remedies.

Tools: Quillio
ADJR Act 1977 (Cth); Judiciary Act 1903 (Cth) s 39B
2

Calendar the time limit

ADJR is 28 days from receipt of reasons or decision; s 39B is no fixed limit but delay affects discretion. Migration decisions have specific statutory limits.

ADJR Act 1977 (Cth) s 11
3

Obtain the statement of reasons

Request a s 13 ADJR statement if not provided. Statement must contain findings on material questions, reference to evidence, and reasons. Defects can ground an error.

ADJR Act 1977 (Cth) s 13
4

Identify reviewable grounds

Map the decision against the s 5 ADJR grounds — breach of natural justice, procedural unfairness, relevant/irrelevant considerations, improper purpose, no evidence, unreasonableness.

Tools: Quillio
ADJR Act 1977 (Cth) s 5
5

Draft the originating application

Draft the Originating Application for Review with grounds particularised. Attach the decision and statement of reasons. Plead specific, not generic, errors.

Tools: Quillio
Federal Court Rules 2011 (Cth) r 31.11
6

File and serve

File in the Federal Court (most ADJR) or FCFCOA (migration). Serve the decision-maker and the Attorney-General where constitutional writs are sought.

Tools: Federal Court portal
Federal Court Rules 2011 (Cth)
7

Manage discovery and evidence

Judicial review is usually determined on the decision-maker's record. Limited additional evidence may be admitted to establish jurisdictional facts or denial of natural justice.

8

Run the hearing and pursue remedy

Hearing is usually on written submissions and short oral argument. Remedies include certiorari (quash), mandamus (compel), prohibition, and declaratory relief.

Judiciary Act 1903 (Cth) s 39B
Outcome

What you will have at the end

Either the decision quashed and remitted for fresh consideration, a declaration of invalidity, or a careful refinement of the record for appeal.

Common issues

  • Pleading merits complaints dressed as legal errors
  • Missing the 28-day ADJR window without grounds for extension
  • Over-broad grounds that dilute the strongest arguments
  • Failing to serve the Attorney-General on constitutional writs
  • Bringing ADJR where a privative clause forecloses review
Use with Quillio

Run this workflow on a real matter

Quillio maps administrative decisions to s 5 ADJR grounds and drafts originating applications with jurisdictional error argued with precision. See /practice-areas/litigation-lawyers.

This workflow is a general guide. State administrative decisions are reviewed under state legislation — NSW JR Act 1999 has distinct provisions.

Try this workflow with Quillio.

Quillio can run this workflow on a real matter, with citations to current AU authority on every step. The free trial requires no credit card.

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