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Understanding Administrative Powers and Abuse

Nov 5, 2024

Administrative Law Lecture Notes

Section 7.3: Powers of the Administrator

7.3.1: Powers Prescribed by Law

  • Administrators can only take actions authorized by law.
  • Their powers are defined in the empowering statute (e.g., the Refugees Act).
  • Common law rules assist in interpreting statutes when administrative powers are ambiguous.
  • Courts have developed rules for statutory authority based on administrative law principles.

Scope and Content of Administrative Authority

  1. Statute and Constitution: The statute defines power, and the Constitution provides the framework for exercising powers through constitutional legality.
  2. Statutory Interpretation: Important rules help determine the scope of power, but these are not expanded upon here.
  3. General Principles of Administrative Law: Developed and applied by courts.

Empowering Legislation Delimits Powers

  • Geographical area: Where the power must be exercised.
  • Time: When the power must be exercised.
  • Object: The subject matter of the action.

Exercise of Power

  • Administrators must adhere to geographical boundaries and time limits prescribed.
  • Powers must be exercised prospectively, not retrospectively, unless statute permits.

Prohibition on Abuse of Power

  • Various forms of abuse: misuse of discretion, unauthorized or ulterior purposes, and more.
  • Administrators should not exercise power for purposes not set in the empowering act.

Unauthorized or Ulterior Purpose

  • Meaning: Administrators must use power for the authorized purpose only.
  • Objective Test: Evaluates if the authorized purpose has been achieved regardless of the administrator's intentions.
  • Case Law Examples:
    • University of Cape Town vs. Minister of Education: Invalid conditions set by the minister for withholding subsidies.
    • Rick Hoto vs. East Rand Administration Board: Misuse of section 10(1)(b) to exclude an applicant.

Unauthorized Procedure and Ulterior Motives

  • Administrators sometimes use shortcuts to avoid cumbersome processes, undermining the law.
  • Examples of Abuse:
    • Van Coller vs. Administrator Transvaal: Unlawful transfer of an educator instead of disciplinary action.
    • Pretoria City Council vs. Mere Last Investments: Incorrect use of private law for expropriation.

Exercise of Power in Bad Faith (Mala Fide)

  • Using ulterior motives to defeat the purpose of the law, known as Fraudem Legis.

Conclusion

  • Administrators must exercise their powers within the legal framework provided by statutes and the Constitution.
  • Abuse of power, whether through unauthorized purpose, procedure, or ulterior motives, is unlawful and invalid.