Week 6: Jurisdictional Error of Law
Narrow Ultra Vires Recap
- Key Points of Narrow Ultra Vires:
- If legislation does not authorize a decision, the decision is invalid.
- Failure to follow required procedures invalidates the decision.
- Only authorized personnel or their delegates can make decisions.
Jurisdictional Error of Law
- Definition: A broader concept than narrow ultra vires, overlapping but extending further.
- Importance: Requires understanding beyond just narrow ultra vires.
Scenario Explanation
- Example: Parent (legislature) gives older child decision-making power under two conditions:
- Younger child must request to watch TV (application).
- Request must be after midday (jurisdictional fact).
- If conditions are unmet, older child has no jurisdiction to decide.
Types of Jurisdictional Error
- **Lack of Authorization: ** Decision not authorized by the enactment.
- Unauthorized Decision Maker: The decision maker lacks authority.
- Procedural Noncompliance: Required procedures were not followed.
- Absence of Jurisdictional Fact: Non-procedural condition needed is missing.
Legal Case Example
- Case: Hussein and the Minister for Immigration
- Defined jurisdictional error as an error in statutory decision-making, where statutory conditions or preconditions are not fulfilled.
Real-World Implications
- 2001 Tampa Incident: Government's attempt to legislate migration law review out of court's jurisdiction.
- High Court Decision: In Plaintiff S-157, the High Court ruled that jurisdictional errors of law are unchallengeable by privative clauses, upholding the constitutional right to review.
Summary
- **Narrow Ultra Vires Grounds: **
- No legislative authorization.
- Unauthorized decision maker.
- Failure to follow procedures.
- **Jurisdictional Errors Include Above and: **
4. Absence of necessary jurisdictional facts.
- Significance: Jurisdictional errors of law protect against administrative tyranny.
Looking Forward
- Next week: Broad Ultra Vires and further grounds for review.
- Importance of administrative law as a protection mechanism.
Enjoy your weekend and see you next week!