Mel Cousins Access

8/19/2019 Mel Cousins Access....

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Dublin University Law Journal 2012, 35(1), 292-299

Dublin University Law Journal

2012

*292 ACCESS TO QUASI-JUDICIAL DECISIONS – JAMA

MINISTE! "O! SOCIAL #!OTECTION$ -

MEL COUSINS*

This note considers the Jaa case, which concerns the issue of access to the

decisions of social welfare aeals officers! The "i#h Court ruled that there was no

dut$ on the %eart&ent of Social 'rotection to &aintain a data(ase or oen li(rar$

of decisions to which the u(lic &a$ ha)e access and, therefore, no +uestion of a

ri#ht of access thereto arose! hile the decision &a$ ha)e (een correct on the facts

of the case, the Court-s aroach to the (roader issue of access to social welfare

aeals decisions is rather de(atea(le and it is ar#ua(le that, consistent with the

Sure&e Court-s decision in !tanasov ,2social welfare aellants should also (e

entitled to access to rele)ant decisions as a &atter of constitutional .ustice!

Conte%t/eals concernin# entitle&ent to social welfare a$&ents are heard ($ aeals

officers of the Social elfare /eals Office S/O!The Irish courts ha)e held that

there is a constitutional ri#ht to a reasoned decision ($ a court or tri(unal at least in

order to allow an unsuccessful articiant to consider an aeal! 3The reasons

should &a4e clear to the unsuccessful aellant in 5#eneral and (road ter&s6 the

#rounds of the decision! 7The Euroean Court of "u&an 8i#hts has also consistentl$

held that /rticle 9 of the Con)ention on "u&an 8i#hts includes the ri#ht to reasons

for a decision! 9In an$ case, Ministerial re#ulations ro)ide that when an aeals

officer-s decision is not in the clai&ant-s fa)our, the aeals officer &ust #i)e a note

of the reasons for the decision, and this *293 will (e sent to the clai&ant! :Unli4ethe osition in the U;,


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resident and her clai& was refused! "owe)er, on aeal, the aeals officer found

that Ms >a&a was ha(ituall$ resident fro& ?e(ruar$ 2009 and awarded child (enefit

fro& that date a(out four &onths after the (irth of her child! 11She re+uested a

re)iew of that decision ($ the chief aeals officer under section 1< of the /ct on

the #rounds that the aeals decision was wron# in fact or in law! 12

Ms >a&a-s le#al ad)isers (elie)ed that there were decisions of other aeals officers

which were rele)ant to this issue and which would assist the& in &a4in# her case!

/ccordin#l$, the$ sou#ht coies of an$ re)ious decisions of an aeals officer

rele)ant to the date fro& which refu#ees are re#arded as satisf$in# the ha(itual

residence condition! "owe)er, it aears that, other than in li&ited circu&stances,

the S/O did not 4ee a re#ister, or coies, of decisions which are re&itted to the

%eart&ent of Social 'rotection!1/ccordin#l$ it had no &eans of ro)idin# such

decisions! It further aears that the %eart&ent also did not 4ee a re#ister of

decisions and it was also una(le to identif$ an$ such decisions! Ms >a&a (rou#ht

.udicial re)iew roceedin#s see4in# an order

0i) that the %eart&ent ro)ide her with access to coies of rele)ant reasoned decisions

of the Social elfare /eals Office and

0ii)directin# the Minister to u(lish such reasoned decisions and to esta(lish a s$ste&

ena(lin# such decision to (e accessi(le to the arties to social welfare aeals!

*294 T(e Ju')*ent

Criticall$, in his consideration of the case, "edi#an > re)ersed the order of these two

issues and focussed first on 5whether there is a dut$ to &aintain so&e for& of oen

data(ase recordin# decisions, and, second, whether the alicant was entitled to

ha)e access thereto!13

Ms >a&a ar#ued that the constitutional re+uire&ent of fair rocedures re+uired that

she ha)e access to such decisions! This relied, in articular on the !tanasov case in

which the Sure&e Court had ruled that the refusal of the 8efu#ee /eals Tri(unal

8/T to &a4e a)aila(le rele)ant tri(unal decisions was a (reach of the alicant-s

ri#hts to fair rocedures and natural and constitutional .ustice under /rticle 30! of

the Constitution!17She acceted that not all decisions should (e u(lished, as &an$

are of a routine nature, (ut contended that all decisions which address issues of

5rincile, law or olic$ should (e u(lished6! 19"owe)er, Ms >a&a was faced with the

difficult$ that no co$ of a rele)ant decision could (e found! "er solicitor a)erred that

he was aware of at least one such rele)ant decision, (ut "edi#an > stated that this

was onl$ a (elief and was contradicted ($ %eart&ental e)idence! 1:

/s to the (roader issue of whether there was an o(li#ation to &aintain a data(ase of

decisions, "edi#an > distin#uished the !tanasov "ase and the En#lish decision in

#an$e%e1


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of an anon$&ised data(ase would (e 5)er$ eAensi)e6 and of 5so&ewhat dou(tful

(enefit6 to alicants for social welfare (enefits! "e ruled that

*295 'u(lic olic$, nota(l$ in these straitened ti&es, &ust surel$ outwei#h a

ri#ht of access to such infor&ation!21

"edi#an > su##ested that the (est course of action, where an alicant did not a#reewith the criteria alied ($ the S/O, was 5to a)ail of the secial for& of aeal

ro)ided in the statutor$ fra&ewor46 !22"e concluded that there was no dut$ on the

%eart&ent to &aintain a data(ase or oen li(rar$ of decisions to which the u(lic

&a$ ha)e access and, therefore, no +uestion of a ri#ht of access thereto arose! 2

Dis&ussion

It would aear that "edi#an > would ha)e (een correct to re.ect this alication, on

his understandin# of the facts, on the (asis that there was no e)idence that an$

rele)ant decisions eAisted and, therefore, no +uestion of ha)in# access to the& could

arise!23"owe)er, the Court-s aroach to the (roader issue of access to such

decisions is rather worr$in# see (elow!

E)en if related decisions did eAist, it is not clear that these would (e )er$ rele)ant to

the actual alication for re)iew!27Ms >a&a had ar#ued that her aeal turned on an

issue of law and that, #i)en she had (een declared a refu#ee, entitle&ent to child

(enefit should (e (ac4dated to the (irth of the child! 29This see&s dou(tful at (est!

hether a erson is ha(ituall$ resident or not is (asicall$ a +uestion of fact

deendin# on the articular circu&stances of the case! /lthou#h we do not 4now the

details of the aeals officer-s decision, there is no indication that she too4 the )iew

that a le#al issue arose, and she clearl$ did not decide that Ms >a&a could not (e

entitled to child (enefit until her refu#ee status had (een declared ($ the 8efu#ee/eals Tri(unal as she dated entitle&ent fro& ?e(ruar$ 2009 while Ms >a&a was

not reco#nised as a refu#ee until ?e(ruar$ 200:! 2:In fact, the aeals officer found

Ms >a&a to (e ha(ituall$ resident within a(out 9 &onths of her arri)al in Ireland!

hile *296 we do not 4now whether the alicant had an$ eAistin# lin4s with

Ireland, in the a(sence of such lin4s, a siA &onth eriod to esta(lish ha(itual

residence is not eAcetionall$ lon#! E)en if an$ decisions of the S/O eAisted, and

e)en if these showed a attern of accetin# that refu#ees are ha(ituall$ resident in a

shorter eriod than siA &onths which see&s hi#hl$ unli4el$, an$ decision as to

whether Ms >a&a was ha(ituall$ resident would still ha)e to (e deter&ined on the

(asis of the facts of her own case, and in the li#ht of decisions of the Euroean Court

of >ustice as the Irish definition of ha(itual residence is deri)ed fro& EU law! 2<

Ms >a&a referred to the 1=71 Bene)a Con)ention on the status of refu#ees and

ar#ued correctl$ that a erson is a refu#ee fro& the &o&ent that the conditions set

out in international law are satisfied, i!e! a erson does not (eco&e a refu#ee

(ecause of reco#nition, (ut is reco#nised (ecause she is a refu#ee! She further

referred to /rticle 23 of the 1=71 Con)ention, which re+uires a State to accord to

refu#ees lawfull$ sta$in# within its territor$ the sa&e treat&ent as is accorded to its

own nationals with resect to social securit$!2="owe)er, this ro)ision would not

aear to assist the alicant! Section 2 of the 8efu#ee /ct 1==9 in

i&le&entation of this ro)ision ro)ides that a refu#ee in relation to who& a

declaration is in force

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shall (e entitled to recei)e, uon and su(.ect to the ter&s and conditions

alica(le to Irish citiens, D the sa&e social welfare (enefits as those to which

Irish citiens are entitled D

"owe)er, the ha(itual residence condition also alies to Irish nationals and so

re+uirin# the alicant to satisf$ this condition in)ol)es no direct discri&ination!0

Turnin# to the (roader issue of access to decisions &ore #enerall$, one *297 &a$

ha)e so&e concerns a(out the aroach adoted ($ the Court! Indeed it is erhas

surrisin# that the alicant sou#ht an order directin# the esta(lish&ent of a s$ste&

allowin# access to decisions, #i)en that in !tanasov , in resonse to the ar#u&ent

that the Court should hold that there was an o(li#ation to ro)ide an 5oen li(rar$6 of

decisions, Beo#he#an > stated that

I do not thin4 that it would (e the function of this court or of an$ other court to

direct the esta(lish&ent of s$ste&s of that 4ind! hat this court is concerned

with is the ersonal ri#hts of the articular alicants (efore it! 'ro)ided each of

those alicants is #i)en reasona(le access in whate)er for& the Tri(unalconsiders fit to re)ious decisions which are (ein# reasona(l$ re+uired for le#al

rele)ance within the &eanin# which I ha)e indicated, that asect of the dut$ to

ro)ide fair rocedures is co&lied with!

The focus of the case should rather ha)e (een as in !tanasov on whether or not

there was a ri#ht of access to rele)ant decisions! In !tanasov the Court was

o()iousl$ dealin# with issues concernin# refu#ee status and the +uite different

factual issues in)ol)ed there! It was also careful to confine the .ud#&ent to 5ersons

aearin# (efore the 8efu#ee /eals Tri(unal and to the o(li#ations of that

Tri(unal6!1Nonetheless, the !tanasov .ud#&ent is (ased on the rinciles of

constitutional .ustice and there are a nu&(er of stron# state&ents in that case a(out

the ad)anta#es of u(licall$ accessi(le decisions in ensurin# consistenc$ and e+ualit$

of ar&s!

The +uestion is, therefore, whether or not the social welfare decision@&a4in# rocess

can (e distin#uished such that access to rele)ant decisions is not re+uired! This turns

in art on the nature of the aeals rocess! "edi#an > stated that the alicant

considered the rocess to (e an ad)ersarial one leadin# to indicati)e, if not (indin#,

recedent, "e stated that the %eart&ent, in contrast, ar#ued that the rocess was

5&ore in the nature of an ad&inistrati)e alication6 resultin# in a 5(are

deter&ination recordin# the decision &ade6! Unfortunatel$, the Court did not ta4e the

oortunit$ to resol)e this disute (ut the answer is clear! More than 70 $ears a#o,

the Sure&e Court ruled that aeals officers erfor& a [email protected] function and

are 5re+uired to (e free and unrestricted in dischar#in# their functions6!2hile it is

indeed true that a &a.orit$ erhas a )ast &a.orit$ of cases raise onl$ issues of

fact, it is the case that, in ractice, aeals officers- decisions do act as a for& of

recedent! ?or eAa&le, in cases concernin# insura(ilit$ of wor4ers, sa&le cases

are often selected for hearin# where($ the outco&e will (e alied in relation to

other wor4ers in the *298 sa&e e&lo$&ent! /eals officers do refer to re)ious

decisions of aeals officers and co&&ent on whether the$ are followin# the& or not

and if not, wh$ not! 3The %eart&ent no&inall$ the Oireachtas recentl$

a&ended the social welfare code to ro)ide that as$lu& see4ers cannot (econsidered to (e ha(ituall$ resident, followin# a decision ($ the then chief aeals

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officer rulin# that the$ could and re.ectin# the %eart&ental )iew! ?ran4l$, the

ar#u&ent that the aeals s$ste& is si&l$ an 5ad&inistrati)e alication6 is an

untena(le one and should not (e entertained ($ the .udiciar$!

Can the aeals s$ste& (e distin#uished fro& the 8efu#ee /eals Tri(unal 8/T

(ased on the difference in issues in)ol)edF O()iousl$ the issues in)ol)ed in the

refu#ee aeals rocess are factuall$ )er$ different fro& those in)ol)ed in &ost

social welfare aeals! Nonetheless the social welfare aeals s$ste& in)ol)es the

interretation of a co&leA code of law and issues of le#al interretation fre+uentl$

arise! It would aear that the ad)anta#es of access to decisions outlined in

!tanasov would also al$ in relation to social welfare aeals and that, in an

aroriate case, a social welfare aellant should also (e entitled to access to

rele)ant decisions as a &atter of constitutional .ustice! "edi#an > su##ested that if

an alicant did not a#ree with the criteria alied ($ the S/O she should aeal

to the courts! Now, assu&in# that a ri#ht of aeal could act as a functional

alternati)e to access to decisions, one &i#ht dou(t whether a cost@(enefit anal$sis

would find that this was a cheaer otion!

Con&lusion

The #ood news fro& this case is erhas that the Social elfare /eals Office is

alread$ uttin# in lace a new IT s$ste& which records decisions and which will (e

used to increase the nu&(er of cases u(lished either in its annual reort or

online! In the current conteAt, online access see&s to (e the fastest and &ost cost@

effecti)e otion!7This should allow a &uch #reater *299 access to le#all$ i&ortant

decisions! 'resu&a(l$ aeals officers will (e a(le to su##est decisions for

u(lication (ut it &a$ (e left oen to other interested arties to su##est decisions

for u(lication! 9/s Beo#he#an > su##ested in !tanasov the definition of 5le#all$i&ortant6 should not (e construed too narrowl$ and should not (e confined to

narrow oints of law in a technical sense! /t the sa&e ti&e, while it &a$ (e

interestin# to see how aeals officers aroach cases, &an$ of the decisions

currentl$ u(lished are ri&aril$ of a factual nature and it &a$ (e i&ortant to focus

&ore closel$ on decisions of le#al i&ortance! "oefull$ the de)elo&ent of such a

s$ste& &a$ o()iate the need for further liti#ation!

This .ournal &a$ (e cited as e!#! 200= 1 %!U!L!>! ns 1 G$ear Holu&e nu&(er

%!U!L!>! ns a#e nu&(er

1!

This .ournal &a$ (e cited as e!#! 200= 1 %!U!L!>! ns 1 G$ear Holu&e nu&(er

%!U!L!>! ns a#e nu&(er

Dublin University Law Journal 2012, 35(1), 292-299

___________________________________________________________________________________________

0 *! Hisitin# Lecturer, National Uni)ersit$ of Ireland, Ma$nooth!

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0 2! /tanaso) ) 8efu#ee /eals Tri(unal 200' *+ 53.

0 ! See #enerall$ 'art 10 of the Social elfare Consolidation /ct 2007 the /ct as a&ended, discussed in Mel Cousins,o"ial e"urity in *relan. ;luwer Law International 2010 2== et se/.

0 3! State Creedon ) Cri&inal In.uries Co&ensation Tri(unal 19 * 51.

0 7! See i(id Cra4e ) Sule&entar$ Jenefits Co&&ission 192 1 !ll + &9.

0 9! See, for eAa&le, "ir)isaari ) ?inland, 3=9

0 10! s 233 of the /ct! See Cousins n 2

0 1=! ara 9!9!

0 20! Citin# State illia&s ) /r&$ 'ensions Joard 193 * 30.

0 21! ara 9!:!

0 22! ara 9!

the urose of the /ct! These include as$lu& see4ers in resect of who& a declaration of refu#ee status has not $et

(een #ranted! See the discussion in Jo( Clar4-s note on the /ct in the *ris6 urrent Law tatutes !nnotate. .

0 2


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alication or the date of a su(se+uent successful clai&! /#ain the case aears to ro)ide no assistance to Ms >a&a!

0 1! The Court eAlicitl$ stated that its rulin# did not concern alications to the Minister for >ustice for lea)e to re&ain!

0 2! McLou#hlin ) Minister for Social elfare 195 * 1.

0 ! /s in Jri#htwater Selection ) Minister for Social and ?a&il$ /ffairs 2011 *+ 510.

0 3! /s in Jri#htwater and ESJ ) Minister for Social, Co&&unit$ and ?a&il$ /ffairs 200' *+ 59.

0 7! See, for eAa&le, the we(site of the Jritish Uer Tri(unal for&erl$ the Social Securit$ Co&&issioners, which hasan eAcellent data(ase of decisions httKKwww!.ustice!#o)!u4K#uidanceKcourts@and@

tri(unalsKtri(unalsKaaKdecisions!ht&! Irish courts and tri(unals do not ro)ide &an$ eAa&les of #ood ractice! There

are fre+uentl$ lon# dela$s (efore decisions of the Irish "i#h Court are online and &an$ are still not in ara#rahed for&at

to allow eas$ reference online or an$ access to Circuit Court decisions is racticall$ non@eAistent the 8/T confines

access to decisions to 5aeal alicants- le#al reresentati)es6 the E&lo$&ent /eals Tri(unal ro)ides oen access to

all decisions (ut without an$ cate#orisation &a4in# location of rele)ant decisions )er$ difficult the 8e)enue /eals

Co&&issioners u(lish )er$ few decisions and so on! /s shown ($ U; ractice, this is reall$ not necessar$!

0 9! There are also a nu&(er of 5historic6 decisions that are, howe)er, of on#oin# rele)ance and &i#ht (e u(lished, suchas the '/8C /)iation decision concernin# a#enc$ wor4ers discussed in 8o(ert Clar4, 5/#enc$ or4ers and Social

Insurance6 (2003) 23 DULJ 19 or the &ore recent decision ($ the chief aeals officer concernin# as$lu& see4ers and

ha(itual residence su&&arised in a ?L/C 5Jriefin# Note6 at

www!flac!ieKdownloadKdocK0=P0=P01PhrcP(riefin#PnotePfinal!doc!

0 1!! 2011 *+ 349.

Q The /uthors and %u(lin Uni)ersit$ Law >ournal!
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