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<ref>{{citation|author=Rosy Kumar|title=A question of jurisdiction|url=http://indiatoday.intoday.in/story/jurisdiction-issue-consumer-protection-and-trade-practices/1/165951.html|newspaper=[[India Today]]|date=26 December 2011}}.</ref>
*{{citationllast=Kumar|first=Rosy||title=A question of jurisdiction|url=http://indiatoday.intoday.in/story/jurisdiction-issue-consumer-protection-and-trade-practices/1/165951.html|newspaper=[[India Today]]|date=26 December 2011}}.


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Background

According to the Diceyan model of separation of powers, the Executive govern according to a framework of general rules in society established by Parliament, and the Judiciary ensures that the Executive acts within the confine of these rules through judicial review.[1] Therefore, part of the role of the judiciary is to ensure that public authorities act lawfully and to serve as a check and balance on the government’s power. However, the Parliament may exclude the jurisdiction of the courts by the inclusion of an ouster clause in the statute.[2] These ouster clauses may be total or partial.


Examples of ouster clauses found in Singapore’s statutes include:

Constitution of the Republic of Singapore (1999 Reprint), Art 18(9):[3]
A decision of the Presidential Elections Committee as to whether a candidate for election to the office of President has fulfilled the requirement of paragraph (e) or (g)(iv) of Article 19(2) shall be final and shall not be subject to appeal or review in any court.
Industrial Relations Act (Cap 136, 2004 Rev Ed), s. 47:[4]
(1) Subject to the provisions of this Act, an award shall be final and conclusive.
(2) No award or decision or order of a Court or the President or a referee shall be challenged, appealed against, reviewed, quashed, or called in question in any court and shall not be subject to any Quashing Order, Prohibiting Order, Mandatory Order or injunction in any court on any account.
Maintenance of Religious Harmony Act (Cap 167A, 2001 Rev Ed), s. 18: [5]
All orders and decisions of the President and the Minister and recommendations of the Council made under this Act shall be final and shall not be called in question in any court.


If ouster clauses achieve their desired effect in the exclusion of the courts, it will serve as a clear signal to decision maker that they may operate without fear of intervention by the courts at a later stage.[2] However, ouster clauses have traditionally been viewed with suspicion of the courts.[6] According to the nineteenth century laissez-faire theory championed by Dicey, which Carol Harlow and Richard Rawlings termed as the red-light approach in their 1984 book Law and Administration,[7] there should be a deep-rooted suspicion of governmental power and a desire to minimise the encroachment of the state on the rights of the individuals.[1] Consequently, the courts should be allowed to act as a check on the executive's actions.


On the other end of the spectrum, there is the green-light approach derived from the utilitarian school of thought associated with legal philosophers such as Jeremy Bentham and John Stuart Mill.[8] The green-light approach regards state involvement as an effective means to facilitate the delivery of communitarian goals,[8] therefore ouster clauses is regarded as a useful device to keep a conservatively inclined judiciary at bay. One such communitarian goal achieved by ouster clauses is that it results in consistency and finality in the implementation of policy consideration by encouraging specialist bodies to act as adjudicators in certain areas of administration.[9]

Total Ouster Clause

Total ouster clauses seek to exclude the supervisory jurisdiction of the courts. Before the seminal decision of Anisminic Ltd v. Foreign Compensation Committee (“Anisminic”),[10] there was a distinction between errors of law made within the statutory powers conferred upon the public body, and errors of law that exceeded the jurisdiction. In the former, the courts are precluded from exercising their supervisory function and issue any prerogative order by the total ouster clauses. The courts could only step in if the error of law that went to the jurisdiction, such as an erroneous interpretation of the powers conferred upon the public body by the statute.

Position in UK

Before Anisminic

In R v. Medical Appeal Tribunal, ex p. Gilmore,[6] the legality of the total ouster clause in the National Insurance (Industrial Injuries) Act 1946, s. 36(3), was doubted by the Court of Appeal, which issued a certiorari against the Medical Appeal Tribunal for an error of law on the face of the record. Denning L.J. (as he then was) stated at p. 583 that the words “any decision of a claim or question … shall be final” only excluded an appeal but not judicial review:

"I find it very well settled that the remedy by certiorari is never to be taken away by any statute except by the most clear and explicit words. The word "final" is not enough. That only means "without appeal." It does not mean "without recourse to certiorari." It makes the decision final on the facts, but not final on the law. Notwithstanding that the decision is by a statute made "final," certiorari can still issue for excess of jurisdiction or for error of law on the face of the record."[11]

Anisminic

In Anisminic, the House of Lords held that any error of law made by a public body will render the decision a nullity and the ouster clause does not oust the courts’ jurisdiction in judicial review unless it clearly states so.[12] The Foreign Compensation Commission misinterpreted the order as meaning that not only the applicant had to be British, but also its successors in title had to be British. This interpretation would defeat almost all claims since the successors in title would likely be the Egyptian sequesters. Their Lordships held that this misconstruction rendered the decision ultra vires, and since the Parliament could not have intended for the ouster clause to protect an ultra vires determination, judicial review was not precluded.


Though Anisminic did not expressly abolish the distinction between jurisdictional and non-jurisdictional errors of law, the House of Lords in R v. Lord President of the Privy Council, ex parte Page (“Page”)[13] noted at 701 that:

[T]he decision in [Anisminic] rendered obsolete the distinction between errors of law on the face of the record and other errors of law by extending the doctrine of ultra vires. Thenceforward it was to be taken that Parliament had only conferred the decision-making power on the basis that it was to be exercised on the correct legal basis: a misdirection in law in making the decision therefore rendered the decision ultra vires.[14]

All errors of law are now to be considered as jurisdictional and ultra vires in the broad sense of the term. This implies that ouster clauses should not be effective against any error of law.

Current Position

The principles of Anisminic was recently upheld by the Supreme Court in R (Cart) v. Upper Tribunal[15] so as to promote the rule of law. Since it is practically immaterial to the victim of an error of law whether it is a jurisdictional error or otherwise, it would be manifestly unjust that judicial review would be precluded when non-jurisdictional errors may be egregious and obvious, but allowed for a small jurisdictional error.[16]


Exceptions to Anisminic

Though the scope of judicial review has been expanded considerably following Anisminic, there are still two exceptions where the courts are precluded from exercising their supervisory function in a judicial review.

Courts of Law

The principles of Anisminic only apply to a public body exercising its executive function where the courts exercise its supervisory role and have the power to decide questions of law, unless expressly excluded by the statute. However, the superior courts do not have supervisory function in relation to inferior courts, and whether the decision of a court of law is final and not subject to judicial review depends on a construction of the statute. In re Racal Communications Ltd,[17] Lord Diplock noted at 382–383 that if a statute provided that the court’s decision should be final and conclusive, the “subtle distinctions formerly drawn between errors of law which go to jurisdiction and errors of law which do not” would survive. Hence, any non-jurisdictional errors of law made by a court can only be corrected by appeal alone, if the statute provided for it.

Internal Regulations

If a decision-maker is applying some ‘domestic law’ or internal regulations instead of a general law of the land, then an ouster clause is effective unless the decision-maker acts outside jurisdiction (ie, he has no power to enter into the adjudication of the dispute), abuses his power or acts in breach of natural justice. Thus, it was held in Page[13] that a university visitor appointed by the founder of a charitable institution to regulate its internal affairs has exclusive jurisdiction to decide disputes arising under the domestic law of the university that has been laid down by the founder in the constitutive documents establishing the university.


Other Jurisdictions

The decision of Anisminic has been described as a piece of judicial creativity because UK observes the doctrine of parliament supremacy and cannot render the ouster clause ineffective through a constitutional challenge. (citation required) However, in countries with a written Constitution and hence constitution supremacy, the courts can exclude the application of the ouster clauses by pronouncing that the provision is unconstitutional and thus null and void.

India

Supreme Court of India

India embraces the basic structure doctrine, which is based on the principle that while the Constitution may be amended, its basic structure must remain the same. In India, judicial review has been included as a basic feature since the case of Minerva Mills v. Union of India (“Minerva Mills”)[18] and affirmed by Sampath Kumar v. Union of India[19] and S. R. Bommai v. Union of India:[20]

The power of the judicial review is an integral part of our constitutional system and without it, there will be no Government of Laws and the rule of law would become a teasing illusion and a promise of unreality. If there is one feature of our Constitution which, more than any other, is basic and fundamental to the maintenance of democracy and the rule of law, it is the power of judicial review and it is unquestionably a part of the basic structure of the Constitution.[21]


The Parliament’s “power to amend is not the power to destroy”[22] and hence these aspects of the basic structure may not be abrogated by way of either ordinary process of legislation or through the procedure of constitutional amendment. Therefore, ouster clauses, which work to finalise decisions made by decision-makers and public authorities, would be rejected and held void and ineffective as they deprive the aggrieved party of an avenue of seeking judicial review.


However, it was held in A.B.C Laminart Pvt. Ltd. v. A.P Agencies, Salem[23] that where there are 2 or more courts with jurisdiction on the matter, and the ouster clause merely limits the jurisdiction to a particular court, the ouster clause would be valid as the aggrieved party is still left with an avenue to proceed with his claim:

"[w]hen the clause is clear, unambiguous and specific accepted notions of contract would bind the parties and unless the absence of ad idem can be shown, the other courts should avoid exercising jurisdiction ... [especially] when words like 'alone', 'only, 'exclusive' and the like have been used."[24]


To summarise the treatment of ouster clauses in India:

  1. Ousting jurisdiction of a court, which otherwise would have jurisdiction, by a contract, is void.
  2. Conferring jurisdiction on a court, which otherwise does not have any jurisdiction, by a contract, is void.
  3. Where 2 or more courts have jurisdiction to try a matter, then limiting the jurisdiction to a particular court is valid. However, such contract should be clear, unambigous and specific. Ouster clauses may use the words 'alone', 'exclusively' and 'only' and the same pose no difficulty in interpretation. Even in the absence of such words, the ouster may be inferred from the terms of the contract.


Singapore

Old and New Supreme Courts of Singapore

The state of law regarding effectiveness of ouster clauses is still unclear in Singapore’s judicial realm. Whether Singapore adopts the basic features doctrine is unclear as it was rejected in the High Court in Teo Soh Lung v. Minister for Home Affairs but the Court of Appeal did not make a ruling on it. [25] In addition, unlike England, which has abolished the distinction between non-jurisdictional and jurisdictional errors of law and affirmed that ouster clauses are ineffective against any errors of law, Singapore seems to adopt a different approach. Singapore seems to follow the traditional pre-Anisminic approach – recognising the distinction between jurisdictional and non-jurisdictional errors of law and that ouster clauses are only effective with respect to non-jurisdictional errors of law. This approach is exemplified in the local cases of re Application by Yee Yut Ee (“Yee Yut Ee”),[26] and more recently, Stansfield Business International Pte Ltd v Minister for Manpower (“Stansfield”).[27]


In Yee Yut Ee, the court neither expressly rejected nor affirmed the abolishment of the distinction between jurisdictional and non-jurisdictional errors of law in Anisminic and its effect on the effectiveness of ouster clauses. Instead, the court cited numerous authorities, namely R v. Hurst, ex parte Smith[28] and ex parte Gilmore,[6] which held that ouster clauses should be ineffective when there has been an absence of jurisdiction or an excess of jurisdiction on the part of the decision-maker, respectively.[29] Although Anisminic was referred to at [29], there was no pronouncement on whether the distinction between the two species of errors of law was abolished. Further, the order was quashed because it contained an error of law which cause the Industrial Arbitration Court to exceed its jurisdiction.[30]


In Stansfield, an employee of Stansfield alleged that he was dismissed from his employment without just cause and complained to the Minister of Manpower. The Minister eventually reinstated his employment but Stansfield applied for judicial review by way of certiorari against the decision. Even though s 14(5) of the Employment Act provides that any decision of the Minister be final and shall not be challenged in any court of law, the ouster clause was ineffective in this case. The court cited the principle on the effectiveness of ouster clauses as enunciated by the Privy Council on appeal from Malaysia in South East Asia Fire Bricks Sdn Bhd v Non-Metallic Mineral Products Manufacturing Employees Union (“South East Asia Fire Bricks”):[31]

[W]hen words in a statute oust the power of the High Court to review decisions of an inferior tribunal by certiorari, they must be construed strictly... they will not have the effect of ousting that power if the inferior tribunal has acted without jurisdiction or if it has done or failed to do something in the course of the inquiry which is of such a nature that its decision is a nullity ... But if the inferior tribunal has merely made an error of law which does not affect its jurisdiction, and if its decision is not a nullity for some reason such as breach of the rules of natural justice, then the ouster will be effective.[32]


This affirmation of the principle in South East Asia Fire Bricks shows that Singapore courts continue to uphold the distinction between jurisdictional and non-jurisdictional errors of law. However, the court also mentioned that this was based on the broad principle in Anisminic,[32] which is conflicting as Anisminic abolished the distinction instead. Further, the court concluded that the ouster clause was ineffective due to breaches of natural justice because Stansfield was not given a fair opportunity to present its case with knowledge of the opponent’s allegations, instead of a jurisdictional error of law on the part of the Minister. The former Chief Justice of Singapore, Chan Sek Keong, in his lecture entitled “Judicial Review – From Angst to Empathy” observed that "strictly speaking, what Warren Khoo J said about Anisminic was obiter dicta because his decision was based on a breach of natural justice and not the doctrine of error of law."[33]


In the same lecture, CJ Chan put forth an academic argument that ouster clauses might be viewed as running contrary to Article 93 of the Constitution of Singapore,[34] which vests the judicial power of Singapore in the Supreme Court, because ouster clauses strip the Supreme Court of its supervisory jurisdiction. If the argument that the supervisory jurisdiction of the courts cannot be ousted holds, there would be no need to distinguish jurisdictional and non-jurisdictional errors of law.[35]

Partial Ouster Clause

Unlike a total ouster clause, which seeks to preclude judicial review, a partial ouster clause specifies a restricted period of time after which no remedy will be available. However, if the issue of bad faith arises, the decision would not be immune to judicial review notwithstanding the lapse of time. [36]

Position in UK

In Smith v. East Elloe Rural District Council ("Smith v. East Elloe")[37] the House of Lords concluded by a majority that they could not impugn the partial ouster clause because, according to Viscount Simonds, ‘plain words must be given its plain meaning” regardless of fraud.[38]


The consequences of such a narrow approach were recognised in the dissenting judgement by Lord Reid in which he doubted whether an order that had been obtained by corrupt or fraudulent means could be protected from being questioned in court. He wrote:

“In every class of case that I can think of the courts have always held that general words are not to be read as enabling a deliberate wrongdoer to take advantage of his own dishonesty.”[39]


The decision in Anisminic which held that complete ouster clauses will not be a safeguard against errors of law poses a challenge to the decision in Smith v. East Elloe, but the decision by Court of Appeal in R v. Secretary of State for the Environment, ex p. Ostler[40] affirmed Smith v East Elloe that there will be a very different approach when time limit clause are included in the legislation. It was held that a distinction could be drawn in that it was not a total ouster but a partial ouster since the applicants were given six weeks to challenge the decision.[41]

Rationale for adopting the strict view

The rationale for upholding time limit clauses is to promote certainty of the Executive's actions in the public’s interest. If the courts were to allow plaintiff to come to them for a remedy long after the time limit has expired, it would be productive of much disruption to the public good, in that the public authority would be held up or delayed by further evidence or inquiries.[42] This rationale analysed by Mann LJ in the Divisional Court was cited with approval by Simon Brown L.J. in the Court of Appeal in R v. Cornwall County Council, ex p Huntington:[43]

“The intention of Parliament when it uses an Anisminic clause is that questions as to validity are not excluded... When paragraphs such as those considered in ex p Ostler' are used, then the legislative intention is that questions as to invalidity may be raised on the specified grounds in the prescribed time and in the prescribed manner, but otherwise the jurisdiction of the court is excluded in the interests of certainty”[44]

See also

Notes

  1. ^ a b P. Leyland; G. Anthony (2009), "Introduction, theory and history", Textbook on Administrative Law, Oxford; New York: Oxford University Press, p. 5-6 at 5, ISBN 978-0-199-21776-2(hbk.) {{citation}}: Check |isbn= value: invalid character (help).
  2. ^ a b Leyland & Anthony, "Express and implied limits on judicial review: ouster and time limit clauses, the prerogative power, public interest immunity", Textbook on Administrative Law, p. 392.
  3. ^ Constitution of the Republic of Singapore (1999 Reprint), Art. 18(9).
  4. ^ Industrial Relations Act (Cap. 136, 2004 Rev. Ed.) ("IRA"), s. 47.
  5. ^ Maintenance of Religious Harmony Act (Cap. 167A, 2001 Rev. Ed.) ("MRHA"), s. 7(1).
  6. ^ a b c R v. Medical Appeal Tribunal, ex p. Gilmore [1957] EWCA Civ 1, [1957] 1 QB 574, Court of Appeal (England and Wales).
  7. ^ Carol Harlow; Richard Rawlings (1984), Law and Administration, London: Weidenfeld and Nicolson, ISBN 978-0-297-78239-1.
  8. ^ a b Leyland & Anthony, "Introduction, theory and history", pp. 6-9 at 7.
  9. ^ Leyland & Anthony, "Express and implied limits on judicial review: ouster and time limit clauses, the prerogative power, public interest immunity", Textbook on Administrative Law, p. 393.
  10. ^ Anisminic Ltd. v. Foreign Compensation Committee [1968] UKHL 6, [1969] 2 AC 147, House of Lords (UK).
  11. ^ R v. Medical Appeal Tribunal, ex p. Gilmore, p. 583.
  12. ^ Anisminic Ltd v Foreign Compensation Committee, p. 167.
  13. ^ a b R v. Lord President of the Privy Council, ex parte Page [1992] UKHL 12, [1993] AC 682, [1993] 3 WLR 1112, House of Lords (UK).
  14. ^ R v. Lord President of the Privy Council, ex parte Page, p. 701.
  15. ^ R (Cart) v. Upper Tribunal [2011] UKSC 28, [2012] 1 AC 663, [2011] 3 WLR 107, [2011] 4 All ER 127, Supreme Court (UK).
  16. ^ R (Cart) v. Upper Tribunal, at [110].
  17. ^ re Racal Communications Ltd [1980] UKHL 5, [1980] 2 All ER 634, [1980] 3 WLR 181, [1981] AC 374, House of Lords (UK).
  18. ^ "Minerva Mills Ltd. and Ors. vs. Union Of India and Ors.". Indian Kanoon. Retrieved 2012-11-06. AIR 1980 SC 1789.
  19. ^ "S.P. Sampath Kumar Etc v. Union Of India & Ors". Indian Kanoon. Retrieved 2012-11-06. AIR 1987 SC 386, p. 441.
  20. ^ "S.R. Bommai v. Union Of India". Indian Kanoon. Retrieved 2012-11-06. AIR 1994 SC 1918 at [200] and [255].
  21. ^ Minerva Mills Ltd. and Ors. vs. Union Of India and Ors., p. 216.
  22. ^ Minerva Mills Ltd. and Ors. vs. Union Of India and Ors., p. 240.
  23. ^ "A.B.C. Laminart Pvt. Ltd. & Anr v. A.P. Agencies, Salem". Indian Kanoon. Retrieved 2012-11-06. AIR 1989 SC 1239.
  24. ^ A.B.C. Laminart Pvt. Ltd. & Anr v. A.P. Agencies, Salem at [21]
  25. ^ Teo Soh Lung v. Minister for Home Affairs [1989] 1 S.L.R.(R.) 461 (H.C.) at [47]; [1990] 1 S.L.R.(R.) 347 (C.A.) at [44]
  26. ^ re Application by Yee Yut Ee [1977–1978] S.L.R.(R.) 490, H.C. (Singapore).
  27. ^ Stansfield Business International Pte. Ltd. v. Minister of Manpower [1999] 2 S.L.R.(R.) 866, H.C. (Singapore).
  28. ^ R v. Hurst, ex parte Smith [1960] 2 Q.B. 133, High Court (England & Wales).
  29. ^ re Application by Yee Yut Ee, at [24].
  30. ^ re Application by Yee Yut Ee, at [31].
  31. ^ South East Asia Fire Bricks Sdn. Bhd. v. Non-Metallic Mineral Products Manufacturing Employees Union [1981] A.C. 363 at 370, Privy Council (on appeal from Malaysia), cited in Stansfield, p. 874, para. 21.
  32. ^ a b Stansfield Business International Pte. Ltd. v. Minister of Manpower at [22]
  33. ^ Chan Sek Keong (2010), "Judicial Review – From Angst to Empathy: A Lecture to Singapore Management University Second Year Law Students", Singapore Academy of Law Journal, 22: 476, archived from the original (PDF) on 1 December 2011 {{citation}}: Unknown parameter |month= ignored (help).
  34. ^ Constitution of the Republic of Singapore (1999 Reprint), Art. 93.
  35. ^ Chan Sek Keong at 477
  36. ^ Leyland & Anthony, "Express and implied limits on judicial review: ouster and time limit clauses, the prerogative power, public interest immunity", Textbook on Administrative Law, p. N.
  37. ^ Smith v. East Elloe Rural District Council [1956] UKHL 2, [1956] AC 736, [1956] 1 All ER 855, House of Lords (UK).
  38. ^ Smith v. East Elloe Rural District Council, p. 751
  39. ^ Smith v. East Elloe Rural District Council, p. 765
  40. ^ R v. Secretary of State for the Environment, ex p. Ostler [1976] EWCA Civ 8, [1977] QB 122, Court of Appeal (England and Wales).
  41. ^ R v. Secretary of State for the Environment, ex p. Ostler, pp. 128—130
  42. ^ R v. Secretary of State for the Environment, ex p. Ostler, p. N
  43. ^ R v. Cornwall County Council, ex p Huntington [1994] 1 All E.R. 694, Court of Appeal, Civil Div. (England & Wales)
  44. ^ R v. Cornwall County Council, ex p Huntington Simon Brown L.J. quoting with approval, Mann L.J.'s judgment in the Divisional Court [1992] 3 All ER 566, p. 575 (D.C.) at p. 698

Further reading

Articles and websites

  • Fazal, M.A (1996), "Effectiveness of Ouster Clauses in India", Anglo-American Law Review, 25: 482-515.
  • Pillai, K. Muralidharan; Luo, Qinghua (2009), "Revisiting the High Court's Revisionary Jurisdiction to Enhance Sentences in Criminal Cases", Singapore Academy of Law Journal, 21: 135–160.
  • Singapore court system, Law Society of Singapore, retrieved 26 December 2009.
  • Tan, Eugene; Chan, Gary (13 April 2009), "The Judiciary", The Singapore Legal System, Singapore Academy of Law, retrieved 26 December 2009.

Newspapers

Books

  • Chan, Helena H[ui-]M[eng] (1995), "The Judiciary", The Legal System of Singapore, Singapore: Butterworths Asia, pp. 41–68, ISBN 978-0-409-99789-7 (pbk.) {{citation}}: Check |isbn= value: invalid character (help).
  • Kwek, Mean Luck [et al.], eds. (2006), Hall of Justice: Supreme Court Singapore, Singapore: Supreme Court of Singapore, ISBN 978-981-05-5356-2 {{citation}}: |first= has generic name (help)CS1 maint: multiple names: authors list (link).
  • Tan, Kevin Y[ew] L[ee] (2011), "Without Fear or Favour: The Judiciary", An Introduction to Singapore's Constitution (rev. ed.), Singapore: Talisman Publishing, pp. 107–131, ISBN 978-981-08-6456-9 (pbk.).
  • Tan, Kevin Y[ew] L[ee]; Thio, Li-ann (2010), "The Judiciary", Constitutional Law in Malaysia and Singapore (3rd ed.), Singapore: LexisNexis, pp. 505–630, ISBN 978-981-236-795-2 (hbk.).
  • Thian, Yee Sze; Chong, Chin Chin; Lim, Sharon (2002), In Session: Supreme Court Singapore: The Building, her Heritage and her People, Singapore: Supreme Court of Singapore, ISBN 978-981-047-671-7.
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