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How Do I Appeal a Judicial Review Decision to the Supreme Court?

By notice of motion in Form 15 under Order 10 of the Supreme Court Rules 2012, not by the ordinary notice of appeal. Order 10 applies to appeals from orders made under Order 16 (judicial review) and Order 17 (habeas corpus) of the National Court Rules. The motion is filed within the 40 days allowed by section 17 of the Supreme Court Act, shows the particulars a notice of appeal would, annexes the documents that were before the Judge and a certified copy of the order, and takes the SCM file prefix. Leave is needed under section 14 for a ground of fact or for an interlocutory decision, including a refusal of leave for judicial review, which the Court treats as interlocutory.

The Supreme Court practice series, no. 147 · Review where no appeal lies · 5 min read

Judicial review in the National Court runs under Order 16 of the National Court Rules, starting with an application for leave and ending with a substantive hearing on the statement filed. The Supreme Court treats orders made in that process, and under Order 17 on habeas corpus, as a class of their own, with a separate procedure in Order 10.

Order 10 and Form 15

Supreme Court Rules 2012, Order 10 Rules 1, 3 and 5

1.(1) An appeal under this Order shall be instituted by a notice of motion. (2) Where the appeal lies only with leave the provisions of Order 7 Division 2 shall apply. 3. The notice of motion shall (a) show where appropriate the particulars set out in a notice of appeal under Order 7 Rule 9; and (b) have annexed (i) copies of all documents which were before the Judge of the National Court appealed from; and (ii) a copy of the order made, certified by the Judge’s Associate or the Registrar; and (c) be in accordance with form 15; and (d) be signed by the appellant or his lawyer; and (e) be filed in the registry. 5. Where leave to appeal is required pursuant to s14 of the Supreme Court Act, application shall be made in Form 7.

Supreme Court Rules 2012

Order 10 Rule 4 applies Order 7 Division 4 on filing and service, Rules 56 to 59 on affidavits, Rule 6 on the time to file after leave and Rule 11 on a notice deemed given on filing a leave application. Order 13 Rule 3 gives the file the prefix SCM. Objection to competency and want of prosecution apply through Order 11 Rule 28, and the Listings Rules in Order 13 apply to every proceeding. See what the file numbers mean.

Why the form matters

Notice of appeal instead of notice of motion

The Supreme Court has repeatedly upheld objections to competency where a judicial review judgment was appealed by a Form 8 notice of appeal under Order 7, or an ordinary judgment by a Form 15 motion under Order 10. The Rules prescribe the process, Order 7 Rule 15 makes competency a threshold question, and the 40 days will usually have expired before the mistake is found. Check the process below: if the order was made in an OS (JR) judicial review under Order 16, or on a habeas corpus application under Order 17, use Order 10. If it was any other judgment, including one on an ordinary originating summons, use Order 7. See what makes a ground of appeal incompetent.

When leave is needed

Leave requirements for appeals from judicial review decisions
National Court decisionLeave?Why
Final judgment on the substantive review, on law or mixed fact and lawNoSection 14(1)(a), (b)
Any ground that is a question of fact aloneYesSection 14(1)(c)
Refusal of leave to apply for judicial review under O 16 r 3YesTreated as interlocutory: it does not finally decide the rights in issue; section 14(3)(b)
Grant of leave for judicial reviewYesInterlocutory; and the Court is reluctant to intervene before the substantive hearing
Interim stay or injunction under O 16 r 3(8)NoSection 14(3)(b)(ii) excepts injunctions from the leave requirement
Dismissal of the review for want of prosecution or as an abuseGenerally noIt finally disposes of the proceeding
Costs onlyYesSection 14(3)(c)

Where leave is needed, file Form 7 under Order 7 Rule 3 within the 40 days, and, to save time, a Form 15 motion conditional on leave. A single Judge decides leave under section 10(1)(a). See whether you need leave to appeal and how to tell if a judgment is final or interlocutory.

Framing the grounds

A judicial review judgment decides whether the decision-maker acted within power, fairly and reasonably; it does not decide the merits of the underlying decision. The grounds of the Supreme Court appeal must therefore attack the Judge’s reasoning on those questions: that the Judge applied the wrong test for error of law, misread the statute conferring the power, wrongly found or failed to find a breach of natural justice, or granted or refused relief on a wrong principle. Grounds that simply re-argue why the original decision was bad invite an objection. Judicial review relief is discretionary, so a refusal of relief is reviewed on the Curtain Bros principles. See how the Supreme Court reviews a Judge’s discretion and drafting grounds of appeal.

The appeal book and the record

The book contains the Order 16 statement, the leave affidavit and any affidavits relied on below, the decision under review and the record of the decision-maker, the transcript of the substantive hearing, and the judgment. Because judicial review is decided on affidavit, the transcript is often short and the book is dominated by the exhibits. The appellant certifies and files it under Order 7 Rules 43 to 47. See what goes into an appeal book.

The decision meanwhile

An appeal does not stay the National Court judgment, and where the judgment quashed a public decision the public body may need a stay to keep the position stable. Apply to a Judge under section 5(1)(b) and section 19 of the Act. See applying for a stay pending appeal.

Sources

Check the section yourself

Before relying on anything here, read the current text of the Supreme Court Rules 2012 and check for later amendments. If a decision matters to you, get advice — start with the Office of the Public Solicitor, or find a firm in the law firms directory.

Disclaimer: This article provides general information about Papua New Guinea law and does not constitute legal advice. Laws may change, and their application depends on individual circumstances. You should obtain professional legal advice for your specific situation. Read the full disclaimer.