| 38. | Procedure to be followed by disciplinary bodies |
[section 95(1)(zG) read with section 38(1) and 39(1)]
| 38.1 | Disciplinary proceedings |
In rules 38 to 45—
| 38.1.1 | "alternative dispute resolution" or "ADR" means a procedure involving a meeting between a complainant who has lodged a complaint against a legal practitioner, and the respondent, in the presence of and under the guidance and supervision of a legal practitioner trained in ADR procedures, with the objective of arriving at a speedy resolution of complaints which are the subject of an ADR procedure." |
| 38.1.2 | "the executive officer" means the executive officer of the Council appointed in terms of section 19(1) of the Act; |
| 38.1.3 | "the legal officer" means a person, by whatever title he or she may be designated, who is an employee of the Council and who is appointed or charged by the Council to perform the disciplinary functions referred to in these rules; |
| 38.1.4 | "the respondent" means a legal practitioner or candidate legal practitioner or juristic entity referred to in section 37(1) of the Act whose conduct is the subject of any proceedings (of whatever nature, including a complaint or a decision whether or not to refer such conduct to investigation) under these rules; |
| 38.1.5 | "costs", where an investigating committee or a disciplinary committee or an appeal tribunal orders a respondent to pay the costs of the investigation or of the disciplinary or appeal hearing, means the actual costs incurred by the Council in conducting the disciplinary proceedings, including without limitation: |
| 38.1.5.1 | the cost of procuring the attendance of witnesses; |
| 38.1.5.2 | the professional fees of accountants or auditors in public practice, or other experts, in relation to evidence of an accounting nature; |
| 38.1.5.3 | the professional fees of legal practitioners engaged by the Council to act as pro forma complainant, or in any other capacity, to assist the investigating committee or the disciplinary committee or the appeal tribunal in the disciplinary process, assessed on the scale as between attorney and client by an independent assessment committee, consisting of legal practitioners, appointed by the Council. |
| 38.2 | The Council shall have disciplinary jurisdiction over all respondents no matter where the conduct which is, or allegedly is, misconduct is perpetrated. On the understanding that the Council is empowered by section 38(1) of the Act to enquire into and deal with any complaint of misconduct, and on the further understanding that this rule is not intended to be a complete list of acts or omissions which may constitute misconduct on the part of a legal practitioner, any legal practitioner shall be guilty of misconduct if he or she— |
| 38.2.1 | contravenes or fails to comply with any rule or any provision of a code of conduct applicable to him or her; or |
| 38.2.2 | fails after demand to pay any subscription or any fee or other charge payable to the Council in terms of the Act. |
| 38.3 | The Council shall assign its duties in relation to the exercise of its disciplinary functions to a committee established by it in terms of section 37(1) or section 37(4) of the Act, subject to the provisions of the Act and these rules. |
| 38.4 | An investigating committee established by the Council shall consist of one or more legal practitioners, of whom at least one shall be an attorney where the respondent is an attorney or a candidate attorney or a juristic entity, and at least one shall be an advocate where the respondent is an advocate or a pupil. |
| 38.5 | A disciplinary committee established by the Council shall consist of the individuals provided for in sections 37(4) and 37(5) of the Act; provided that where more than two legal practitioners have been appointed to serve on a disciplinary committee: |
| 38.5.1 | where the respondent is an attorney or a candidate attorney, the majority of legal practitioners serving on the committee shall be attorneys; |
| 38.5.2 | where the respondent is an advocate or a pupil, the majority of the legal practitioners serving on the committee shall be advocates. |
| 39. | Commencement of enquiry into alleged misconduct |
| 39.1 | If an allegation of misconduct against a respondent comes to the attention of the executive officer or the legal officer, he or she must refer the allegation to the investigating committee if— |
| 39.1.1 | the allegations are in the public domain and he or she on reasonable grounds suspects that a respondent may be guilty of misconduct; or |
| 39.1.2 | a court, or another tribunal or forum sends, or directs to be sent, a record of proceedings in that court, tribunal or forum; or |
| 39.1.3 | a member of the public lodges a complaint with the Council and the executive officer or the legal officer is of the opinion that the complaint of misconduct appears to be justified. |
| 39.2 | Members of the public who wish to lodge a complaint of misconduct against a respondent must do so in writing. A complaint shall set out clearly and concisely the specific acts or failures to act which give rise to the complaint of misconduct. |
| 39.3 | In order to establish whether grounds for referring the complaint to the investigating committee exist, the executive officer or the legal officer, or any other person in the employ of the Council to whom the authority has been delegated by the Council, may, in his or her discretion: |
| 39.3.1 | notify the respondent in writing of the nature of the complaint and call upon the respondent to furnish a written explanation in answer to the complaint within 30 days of such notice; and |
| 39.3.2 | request the complainant to provide further particulars on any aspect of the complaint. |
| 39.4 | If the executive officer or the legal officer, or any other duly authorised official as contemplated in rule 39.3, or the investigating committee, is of the view— |
| 39.4.1 | that the complaint is of such a nature as is likely to have arisen from a misunderstanding on the part of complainant or the respondent, or both; and |
| 39.4.2 | that in the event of the respondent being found guilty, a sanction other than a caution or reprimand or warning, as contemplated in section 40(3)(a), 40(3)(b) or 40(3)(c) is unlikely to be imposed, |
the officer or individual concerned, or the investigating committee, as the case may be, may in their discretion, at any time following receipt of the complaint or of the respondent's response to the complaint, or the referral of the complaint to the investigating committee, call upon the complainant and the respondent to attend an ADR meeting, at a time convenient to the complainant and the respondent, to discuss the complaint in an attempt to resolve the issues between them.
| 39.5 | If the complainant and the respondent agree in writing to the ADR procedure, the executive officer or the legal officer or the individual referred to in rule 39.3 must arrange for a meeting to be held on an informal basis in the presence of and under the guidance and supervision of a mediator, and at the cost of the Council, to discuss the matters which are the subject of the complaint. |
| 39.6 | The proceedings before the mediator will be without prejudice to the rights of the complainant or the respondent and will not be recorded. Neither party will be entitled to call witnesses to give evidence in the ADR proceedings. |
| 39.7 | At the conclusion of the ADR proceedings the mediator shall prepare a written report to the executive officer, which report shall contain a recommendation by the mediator as to whether or not the complaint should follow the disciplinary process provided for in the rules, or whether the investigating committee should not proceed with disciplinary proceedings. |
| 39.8 | Notwithstanding anything in these rules, the investigating committee is not bound to follow the recommendation of the mediator, nor does the withdrawal of the complaint by the complainant imply that the Council may not enquire into the conduct of the respondent which formed the subject of the complaint. |
| 40. | Investigation of alleged misconduct |
| 40.1 | When a complaint or allegation of misconduct against the respondent is referred to the investigating committee, that committee must investigate the complaint or allegation or cause the complaint or allegation to be investigated by the legal officer or by a legal practitioner appointed by the Council for that purpose. |
| 40.2 | For purposes of carrying out its responsibilities in terms of rule 40.1 the investigating committee may: |
| 40.2.1 | take any steps which are not prohibited by law to gather information with regard to the complaint or allegation; |
| 40.2.2 | request a complainant to provide further particulars on any aspect of the complaint; |
| 40.2.3 | request the respondent to appear before the investigating committee in order to assist it to formulate its recommendations to the Council by notice, specifying the time and place of the meeting of the investigating committee. That notice shall inform the respondent: |
| 40.2.3.1 | that the respondent has the right to be assisted or represented by another person; |
| 40.2.3.2 | that any statement made by the respondent to the investigating committee may be used in evidence and that the proceedings of the investigating committee will be recorded; and |
| 40.2.3.3 | that section 40(4)(b) of the Act provides that a respondent may be ordered to pay the cost of the investigation or of any disciplinary hearing; |
| 40.2.4 | by notice in writing require the respondent, or any employee of the respondent, to produce to the investigating committee at a time and place stipulated in the notice, any information relating to the complaint including, but not limited to, files, statements, correspondence, accounting records or other documents which are in the possession of or under the control of the respondent or that other person and which relate to the subject matter of the complaint; |
| 40.2.5 | request the Council to institute legal action against any person referred to in rule 40.2.4 who fails to produce to the investigating committee the information referred to in that rule at the time and place stipulated in the notice; and |
| 40.2.6 | inspect and, if the investigating committee considers it appropriate, retain any information obtained pursuant to rules 40.2.4 and 40.2.5, and make copies of and take extracts from such information. |
| 40.3 | Notwithstanding the provisions of rules 40.2.3.1 and 40.2.3.2, where the conduct of the respondent which forms the subject of the complaint is not such as, in the opinion of the investigating committee, is likely to lead to an application for the suspension from practice or to the removal from the roll of the respondent in the event of a conviction, the investigating committee and the respondent may agree to declare any appearance or part of an appearance of the respondent before the committee to be "without prejudice". In such a case: |
| 40.3.1 | the evidence presented or the discussions at such appearance or part of the appearance will not be recorded; |
| 40.3.2 | the discussions between the investigating committee and the respondent will not be used in evidence against the respondent; |
| 40.3.3 | the complainant will not be entitled to attend the proceedings. |
| 40.4 | If, in the course of the investigations, the respondent admits to the investigating committee that the respondent is guilty of misconduct, and the investigating committee and the respondent agree on an appropriate punishment to be imposed for that misconduct, or if it appears to the investigating committee to be appropriate, the investigating committee may recommend to the Council that a specific sanction be imposed on, and the payment of a specific amount in respect of costs be required from, the respondent; provided that such a recommendation will not be binding on the Council or on a disciplinary committee, which will be entitled to impose its own punishment after conducting an enquiry in accordance with this rule. |
| 40.5 | If after investigating allegations of misconduct against the respondent the investigating committee is satisfied: |
| 40.5.1 | that the respondent, on the basis of available prima facie evidence, is guilty of misconduct which, on account of the nature of conduct, warrants misconduct proceedings, the investigating committee must refer the matter to the Council or to a committee of the Council established for that purpose for adjudication by a disciplinary committee; |
| 40.5.2 | that the complaint should be dismissed on the grounds that the conduct in question does not necessarily warrant misconduct proceedings, it must dismiss the complaint and inform the Council, the complainant and the respondent of its decision and the reasons for it. Without limiting the discretion of the investigating committee, the following may be grounds for determining that the conduct in question does not warrant misconduct proceedings: |
| 40.5.2.1 | that the respondent is not guilty of misconduct; or |
| 40.5.2.2 | that the respondent has given a reasonable explanation for his or her conduct; or |
| 40.5.2.3 | that the conduct of which the respondent may be guilty is of an inconsequential nature; or |
| 40.5.2.4 | that there is no reasonable prospect of success in preferring a charge of misconduct against the respondent; |
| 40.5.2.5 | that the complaint is vexatious or that in all the circumstances it is not appropriate to charge the respondent with misconduct. |
| 40.6 | If a complainant is aggrieved by: |
| 40.6.1 | the manner in which the investigating committee conducted its investigation; or |
| 40.6.2 | the outcome of the investigation, |
he or she may appeal to the appeal tribunal in terms of section 41 of the Act.
| 40.7 | When the Council, or a committee of the Council established for that purpose, receives a referral from the investigating committee in terms of rule 40.5.1 that the legal practitioner be charged with misconduct, it must refer the matter to a disciplinary committee for adjudication. |
| 41. | Disciplinary procedure |
| 41.1 | A disciplinary enquiry shall be commenced by way of a notice to the respondent requiring the attendance of that respondent at the enquiry before a disciplinary committee. The notice shall be sent by pre-paid post or by email or facsimile transmission, or shall be delivered personally, and the enquiry shall proceed if the committee is satisfied that the notice has been received by the respondent. |
| 41.2 | The notice shall be issued under the hand of the executive officer or the legal officer or some other duly authorised employee of the Council and shall be served not less than 10 days before the date appointed for the hearing, in the computation of which period weekends and statutory public holidays shall be excluded. |
| 41.3 | The notice shall set out the place, date and time of the hearing and shall contain the charge or charges of unprofessional or unworthy or dishonourable conduct alleged against the respondent. |
| 41.4 | At an enquiry conducted under this rule the respondent— |
| 41.4.1 | may be present at the hearing of the proceedings; provided that if the respondent is not so present, the hearing may proceed in his or her absence if the committee is satisfied that the notice of the enquiry has been received by the respondent; |
| 41.4.2 | may be assisted or represented by another person or by a legal practitioner in conducting his or her defence; |
| 41.4.3 | has the right to be heard; |
| 41.4.4 | may call witnesses; |
| 41.4.5 | may cross-examine any person called as a witness in support of the charge; and |
| 41.4.6 | may have access to any book, document or object produced in evidence; |
| 41.5 | A respondent appearing at an enquiry— |
| 41.5.1 | may admit at any time before a conviction that he or she is guilty of the charge; and |
| 41.5.2 | may, in the case where he or she makes an admission of guilt, be deemed to be guilty of misconduct as charged. |
| 41.6 | The complainant in the matter shall be entitled to be present during all proceedings in the disciplinary enquiry relating to his or her complaint in the same manner as a complainant in criminal proceedings. |
| 41.7 | The Council may appoint a practising attorney or advocate, or an employee who is admitted as an attorney or advocate, to act as a pro forma prosecutor in the leading of evidence against, and the presentation of the case against, the respondent at the enquiry, and to examine and cross-examine witnesses. |
| 41.8 | The duties, functions and powers of the disciplinary committee relating to the conduct of an enquiry shall be the following, namely: |
| 41.8.1 | to determine through its chairperson and, subject always to the provision of these rules and to the Act, the manner in which the enquiry shall be conducted; |
| 41.8.2 | to exercise the powers vested in the Council in terms of the Act in relation to its disciplinary functions; |
| 41.8.3 | to dispense with any requirements regarding summonses, notices, affidavits, documents, service or times in any case where it appears to be just to do so, or to extend the time for doing anything in connection with the conduct of the enquiry; |
| 41.8.4 | of its own accord, or upon the application of any affected person, to adjourn the enquiry upon such terms as to costs or otherwise as it deems fit; |
| 41.8.5 | to cause the proceedings at the enquiry to be recorded in such a manner as shall enable a true and correct record of such proceedings to be available, and to procure that each of its decisions shall be recorded in writing, and shall be signed by the chairperson of the committee; |
| 41.8.6 | to procure that all decisions referred to in rule 41.8.5 shall be filed in the records of the Council; |
| 41.8.7 | of its own accord, to treat as a separate complaint of misconduct, any act or omission on the part of a respondent attending, or required to attend, an enquiry being conducted under these rules, where such act or omission is calculated to interfere with, or otherwise interferes with, its proper consideration, investigation and determination of the complaint for the subject matter of the enquiry, and to refer any such separate complaint to the Council for consideration and investigation in accordance with the provisions of these rules; |
| 41.8.8 | to exercise such ancillary powers as it shall consider reasonably necessary to enable it to discharge its duties, functions and powers under these rules; |
| 41.8.9 | to appoint a person or persons to assist it in the performance of its functions under these rules; |
| 41.8.10 | where any matter of procedure arises for which no provision is made in these rules, to determine through its chairperson in his or her discretion what procedure shall be followed. |
A subpoena issued by the disciplinary committee in terms of section 39(3) of the Act—
| 42.1 | shall be in the form of Schedule 4 to these rules; |
| 42.2 | shall be signed by the chairperson of the committee or, in the absence of the chairperson, any member of the committee; and |
| 42.3 | shall be served on the person concerned personally. |
| 43. | Proceedings after disciplinary hearing, and sanctions |
| 43.1 | After the conclusion of the hearing the disciplinary committee must, within 30 days, decide whether or not the respondent is guilty of misconduct. |
| 43.2 | If the disciplinary committee finds that the respondent is guilty of misconduct it must— |
| 43.2.1 | inform the respondent and the Council and the Provincial Council concerned of the finding; and |
| 43.2.2 | inform the respondent of the right of appeal as provided for in terms of section 41 of the Act; |
| 43.3 | A respondent found guilty of misconduct may— |
| 43.3.1 | address the disciplinary committee in mitigation of sentence; and |
| 43.3.2 | call witnesses to give evidence on his or her behalf in mitigation of sentence. |
| 43.4 | If the disciplinary committee finds the respondent guilty of misconduct it may call witnesses to give evidence in aggravation of sentence and may— |
| 43.4.1 | in the case of a legal practitioner: |
| 43.4.1.1 | order him or her to pay compensation, with or without interest, to the complainant, which order is subject to confirmation by an order of any court having jurisdiction in the circumstances in the prescribed manner, on application by the Council; |
| 43.4.1.2 | impose upon him or her a fine, payable to the Council, not exceeding the amount determined from time to time by the Minister by notice in the Gazette, on the advice of the Council; |
| 43.4.1.3 | temporarily suspend him or her from practising or from engaging in any particular aspects of the practice of law, pending the finalisation of an application referred to in rule 43.4.1.4; |
| 43.4.1.4 | advise the Council to apply to the High Court for— |
| 43.4.1.4.1 | an order striking his or her name from the roll; |
| 43.4.1.4.2 | an order suspending him or her from practice; |
| 43.4.1.4.3 | an interdict prohibiting him or her from dealing with trust money; or |
| 43.4.1.4.4 | any other appropriate relief; |
| 43.4.1.5 | advise the Council to amend or endorse his or her enrolment; |
| 43.4.1.6 | order that his or her Fidelity Fund certificate be withdrawn, where applicable; |
| 43.4.1.7 | warn him or her against certain conduct and order that such warning be endorsed against his or her enrolment; or |
| 43.4.1.8 | caution or reprimand him or her; |
| 43.4.2 | in the case of a juristic entity: |
| 43.4.2.1 | order it to pay compensation, with or without interest, to the complainant, which order is subject to confirmation by an order of any court having jurisdiction in the circumstances in a prescribed manner on application by the Council; |
| 43.4.2.2 | impose upon it a fine, payable to the Council, not exceeding the amount determined from time to time by the Minister by notice in the Gazette, on the advice of the Council; |
| 43.4.2.3 | warn it against certain conduct; |
| 43.4.2.4 | advise the Council to apply to the High Court for the winding up of the juristic entity; or |
| 43.4.2.5 | caution or reprimand the juristic entity; |
| 43.4.3 | in the case of a candidate legal practitioner: |
| 43.4.3.1 | cancel or suspend his or her practical vocational training; |
| 43.4.3.2 | impose upon him or her a fine, payable to the Council, not exceeding the amount determined from time to time by the Minister by notice in the Gazette, on the advice of the Council; or |
| 43.4.3.3 | caution or reprimand him or her. |
| 43.5 | The disciplinary committee may— |
| 43.5.1 | impose any combination of the sanctions in rules 43.4.1, 43.4.2 or 43.4.3; and |
| 43.5.2 | postpone the taking of any steps or suspend the imposition of any sanction on such conditions as it may determine; |
| 43.5.3 | in addition to the sanctions referred to in rule 43.4, order the respondent to pay the cost of the investigation or of the disciplinary hearing. |
| 43.6 | If the respondent fails to comply with any conditions determined by the disciplinary committee, the committee may impose a sanction for non-compliance or may execute the sanction which was originally imposed, unless the respondent satisfies the disciplinary committee that the non-compliance was due to circumstances beyond his or her or its control, in which case the disciplinary committee may impose such further conditions as it deems fit. |
| 43.7 | At the conclusion of a disciplinary hearing— |
| 43.7.1 | the disciplinary committee must notify the complainant, the respondent, the Council and the Provincial Council in writing of the outcome of the hearing; |
| 43.7.2 | if the disciplinary committee has found the respondent not guilty of misconduct it must inform the complainant of the right to appeal as provided for in terms of section 41 of the Act and of the time limit imposed by rule 44.2. |
| 44. | Appeal against conduct or finding of investigating committee or disciplinary committee |
| 44.1 | Subject to section 43 of the Act, a respondent may, within thirty days of being informed of the decision of a disciplinary committee, lodge an appeal with the appeal tribunal against the finding of the disciplinary committee or against the sanction imposed by the disciplinary committee, or both. |
| 44.2 | A complainant who is aggrieved by— |
| 44.2.1 | the manner in which an investigating committee conducted its investigation, or the outcome of the investigating committee; or |
| 44.2.2 | the outcome of a disciplinary enquiry. |
may lodge an appeal with the appeal tribunal, within thirty days of being informed on the decision of the investigating committee or the disciplinary committee, as the case may be, against the conduct or finding of the investigating committee or the disciplinary committee, as the case may be.
| 44.3 | The appeal referred to in rule 44.1 or 44.2 shall be by notice of appeal in writing, addressed to the Council, setting out— |
| 44.3.1 | in the case of an appeal by the respondent: |
| 44.3.1.1 | whether the appeal is against the finding of misconduct by the disciplinary committee, or against the sanction imposed, or both; and |
| 44.3.1.2 | the grounds of appeal in detail; |
| 44.3.2 | in the case of an appeal by the complainant: |
| 44.3.2.1 | whether the appeal is against the manner in which the investigating committee or the disciplinary committee, as the case may be, conducted the investigation or the hearing; and/or |
| 44.3.2.2 | whether the appeal is against the decision of the investigating committee or the disciplinary committee, as the case may be; and |
| 44.3.2.3 | the grounds of appeal in detail. |
| 44.4 | The Council shall forward a copy of the notice of appeal referred to in rules 44.3.1 or 44.3.2 to the complainant or to the respondent, as the case may be, and shall call upon the complainant or the respondent, as the case may be, to respond in writing to the notice of appeal within thirty days, or within such longer period as the Council may determine. |
| 44.5 | On receipt of the response from the complainant or the respondent, as the case may be, in terms of rule 44.4 the Council must forward the notice of appeal and the response to the appeal tribunal. If no response is received from the complainant or the respondent, as the case may be, the Council must send the copy of the notice of appeal to the appeal tribunal to be dealt with in accordance with these rules. |
| 44.6 | On receipt of the notice of appeal and, if applicable, the response to the notice of appeal the appeal tribunal shall advise the respondent and the complainant of the place and date, being a date not less than ten days after the date of the notice, at which the appeal will be heard by the appeal tribunal. |
| 44.7 | At the hearing of the appeal the respondent and the complainant may be present and may be assisted or represented by another person or by a legal practitioner. The proceedings before the appeal tribunal shall be conducted in such manner as the appeal tribunal shall determine. |
| 44.8 | After the conclusion of the hearing before the appeal tribunal the appeal tribunal must, within thirty days: |
| 44.8.1 | decide whether or not the finding of the disciplinary committee should be confirmed or set aside; or |
| 44.8.2 | decide whether or not the sanction imposed on the respondent should be confirmed or set aside; provided that if the sanction imposed by the disciplinary committee is to be set aside the appeal tribunal may impose its own sanction in respect of the misconduct, which sanction imposed by the appeal tribunal may be one which is more severe than that imposed by the disciplinary committee; or |
| 44.8.3 | if it decides that the conduct of the investigating committee or the disciplinary committee was unlawful or unfairly prejudicial to the respondent or to the complainant, or was in any other respect irregular or not in accordance with natural justice, it may refer the matter back to the Council to be dealt with as a new complaint before a different investigating committee or disciplinary committee. |
| 44.9 | At the conclusion of the hearing before the appeal tribunal the appeal tribunal must notify the respondent, the complainant, the Council and the Provincial Council in writing of the outcome of the appeal. |
| 44.10 | If a respondent who has been found guilty of misconduct lodges an appeal in terms of rule 44.1 the decision of the disciplinary committee may not be enforced before the appeal tribunal has decided the appeal. |
The Council shall cause particulars of all disciplinary hearings, including the particulars of:
| 44.11.1 | the allegations of misconduct dealt with; |
| 44.11.2 | the members of the disciplinary committee in question; |
| 44.11.3 | the respondent involved in the dispute; and |
| 44.11.4 | the outcome of the hearings and any sanction imposed, if applicable |
to be published on the website of the Council, to be updated at least once every month, and to be available for inspection by members of the public during business hours of the Council and of the relevant Provincial Councils.
| 45. | Manner and form in which complaints of misconduct must be lodged with the Council |
[section 109(2)(a)(vi)]
| 45.1 | A person wishing to lodge a complaint of misconduct against a legal practitioner, a candidate legal practitioner or a juristic entity must lodge the complaint in writing with the Council. |
| 45.2 | The complaint must be substantially in the form of Schedule 5 of these rules, must be signed by the complainant, and must be lodged with the Council; provided that the Council may in appropriate circumstances require that the complaint be lodged in a different format. |
| 45.3 | The Council, or a person to whom the function may be assigned by the Council, shall be entitled to dispense with the requirements of this rule in any specific case if in his or her view it is appropriate, and in the interests of justice, that the requirements of the rule be dispensed with. |
| 45.4 | The failure of a complainant to comply with the provisions of this rule shall not prevent the Council from exercising its powers to enquire into the conduct of a legal practitioner, a candidate legal practitioner or a juristic entity even in the absence of a formal complaint by a complainant. |
| 45.5 | The Council may require a complainant to provide, on affidavit, such further particulars in relation to any aspect of the complaint as it deems necessary. |
