Overcoming evil with good
Rowland Ward writes on the Melbourne Religious Vilification case
From The Presbyterian Banner [PCEA Magazine] Jan/Feb 2005 pp. 5-8.
On March 9, 2002 at Full Gospel Assembly in Surrey Hills, Victoria, Catch the Fire Ministries
Inc. [CTFM] ran a public seminar entitled Insight into Islam with Assemblies of God pastor
Daniel Scot of Queensland as speaker. Between 200-250 people were present, including at
various times during the day and unknown to the organizers, three recent Islamic converts
from the Australian community. The topics addressed by Pastor Scot were:
10:00am to 12:00 noon: What is Jihad, and the affect on the future of Australia?
1:00pm to 3:00pm: The Bible versus The Qur’an;
3:30pm to 5:00pm: How to witness effectively to a Muslim.
Scot was born of a Christian family in Pakistan in 1951 and was a mathematics teacher for 12
years when he became the first person accused under Pakistan’s Blasphemy law in 1986. He
was able to come to Australia in 1987, the year he secured a BTh from Gujranwala Seminary
in Pakistan following 10 years part-time study. A Presbyterian (ARP) in Pakistan, Scot became
an AOG pastor about 1995. He certainly knows the Qur’an.
The Catch the Fire Ministries President is another AOG Pastor, Danny Nalliah, who also edits
the organization’s Newsletter sent to 4000 people. Nalliah was born in Sri Lanka in 1964,
prayed over by the late Frank Houston of Sydney at age 12, and later responded to the call to
Christian service. He married in 1987 and served the underground church in Saudi Arabia from
1995-97. In obedience to ‘an encounter with Jesus’ on 21/7/1997 he came to Australia and set
up Catch the Fire Ministries. He does not appear to have formal theological qualifications.
However, he claims Jesus appeared to him in a dream on 9/4/2002 to assure him that a
proactive church would stop the coming disaster of the Islamisation of Australia.
Pastor Scot presented as the authentic interpretation of Islam an interpretation that would be
recognized by the Saudi-based Wahhabists and their sympathizers, but which is not held by
the majority of Muslims. A legal case resulted when three recent Muslim converts who
attended the seminar complained and their cause was taken up by the Islamic Council of
Victoria. The fact that in some respects the complaints were engineered doesn’t alter the fact
that one should not vilify others. On the other hand it might indicate motives for the complaint
are more complex.
We might well think the experiences of the two pastors coloured their presentation, but that
does not justify the breach of the 9th commandment involved. Or we might think instilling fear
and alarm was good for fund-raising, and appealed to people whose insecurity is such that
they cannot move beyond the self-imposed boundary of fear of those who are different. If so,
this only adds to their culpability. But whatever, Pastor Scot went over the top, and so did
Pastor Nalliah in the CTFM Newsletter. A civil action was not necessary to show that.
Gross misrepresentation of others on religious or racial grounds is not something Christians
should turn a blind eye to. Where were most Christians when Hitler was demonizing the Jews?
Let’s not repeat that failure. Which leads one to ask about accountability in the Christian
community. The ‘Christian Right’ in Australia has generally attacked the judge’s decision, and I
have serious criticisms myself. But if we ask for Muslims to counter extremists should we not
set an example ourselves. [Or is that like asking the Roman Church to excommunicate IRA
terrorists?] The two pastors, however sincere and well-meaning they may be, are not
ornaments to the Assemblies of God, and have brought evangelical religion into disrepute.
One recalls that the town clerk of Ephesus quieted a riotous crowd by reminding them that
Paul had neither robbed the temple nor blasphemed the goddess as he preached Christ (Acts
19:37). I believe that the AOG should counsel the two Dannys and rebuke them appropriately.
Do we want to understand our Muslim fellow-Australians and win a hearing for the claims of
Christ, or not? All the protestations of love for Australian Muslims means little if they are
vilified. By vilification I do not mean that they feel offended (a very subjective thing), but that
the beliefs typical of Australian Muslims are seriously misrepresented.
The legal position
The Racial and Religious Tolerance Act 1901, which came into force on 1 January 2002, has
the following objects
‘(a) to promote the full and equal participation of every person in a society that values freedom of
expression and is an open and multicultural democracy;
(b) to maintain the right of all Victorians to engage in robust discussion of any matter of public interest or
to engage in, or comment on, any form of artistic expression, discussion of religious issues or academic
debate where such discussion, expression, debate or comment does not vilify or marginalise any person or
class of persons;
(c) to promote conciliation and resolve tensions between persons who (as a result of their ignorance of the
attributes of others and the effect that their conduct may have on others) vilify others on the ground of
race or religious belief or activity and those who are vilified.’
Section 8 provides that:
‘(1) A person must not, on the ground of the religious belief or activity of another person or class of
persons engage in conduct that incites hatred against, serious contempt for, or revulsion or severe ridicule
of, that other person or class of persons.’
Section 9 provides that the person’s motive in engaging in such conduct is irrelevant, but
Section 11 provides that a person does not contravene Section 8
‘if the person establishes that the person’s conduct was engaged in reasonably and in good faith -
(a) In the performance, exhibition or distribution of an artistic work; or
(b) In the course of any statement, publication, discussion or debate made or held, or any other conduct
engaged in, for -
(i) any genuine academic, artistic, religious or scientific purpose; or
(ii) any purpose that is in the public interest; or
(c) In making or publishing a fair and accurate report of any event or matter of public interest.’
There is a further exemption (Section 12) for private conduct. This exemption does not apply
in relation to conduct in any circumstances in which the parties to the conduct ought
reasonably to expect that it may be heard or seen by someone else. The Seminar was a public
The Judge considered that ‘there is a balance to be struck between free speech which is the
right of all Victorians to engage in robust discussion, but that such a freedom is not to be
abused’ but was in fact abused. In substance I believe the Judge was right. Scot read and
explained sections of the Qur’an and the Hadith. The vilification was not at that point, as some
Christian commentators seem to imply, but in that he did not qualify his explanations so as to
allow sufficiently for other viewpoints among Muslims. It was like a person explaining the Old
Testament according to a strong theonomist/reconstructionist position, saying that that
viewpoint was characteristic of all true Christians, and that they hid their real views until they
could get into a position to impose them.
But does the legal action help anyone, least of all the ICV?
The legal case
In a hearing brought on behalf of the three Muslim converts by the Islamic Council of Victoria,
the ICV case was initially rejected but was heard on appeal to VCAT in a case which took
months and concluded last March. Shortly before Christmas (17/12) Judge Higgins found for
the complainants. His 140 page extremely poorly proof-read judgment is at
<http://www.vcat.vic.gov.au>. I have also read the 110 page transcript of the lecture by Dr
Mark Durie which all recognized as accurate. Orders for remedies are to be made shortly. An
appeal has been indicated.
The legal representation for CTFM was not of the highest order, and the attempt to introduce
the Rev Dr Mark Durie, an Anglican priest in Melbourne, as an expert witness was bungled,
both because the Judge considered he lacked such a qualification and also had sought to hide
his active involvement in the preparation and management of the CTFM case (para 351). One
wonders, though, how independent and expert some of the witnesses for the ICV were.
Indeed, do you need to be involved in inter-faith discussions to be qualified as the judge
seems to suggest? Surely a religious faith and teaching can be described accurately by those
who are not adherents of it.
The Judge summed up the seminar thus:
‘Pastor Scot, throughout the seminar, made fun of Muslim beliefs and conduct. It was done, not in the
context of a serious discussion of Muslims’ religious beliefs; it was presented in a way which is essentially
hostile, demeaning and derogatory of all Muslim people, their god, Allah, the prophet Mohammed and in
general Muslim religious beliefs and practices. Time and again this occurs and, on any view, produces a
response from the audience at various times in the form of laughter.
Pastor Scot, during the course of the seminar, made statements -
(1) that the Qur’an promotes violence, killing and looting;
(2) that it treats women badly; they are to be treated like a field to plough, “use her as you wish”.
Further, in Hadith Bukhari, women, dog and donkey are of equal value;
(3) that domestic violence in general is encouraged;
(4) that Muslims are liars;
(5) that Allah is not merciful and a thief’s hand is cut off for stealing;
(6) that Muslims are demons;
(7) the practice of abrogation that is cancellation of words from the Qur’an and the Hadith solely to fit
some particular purpose or personal need;
(8) that Muslims operate a silent six jihad, which is the use of business connections; using money to
induce people to convert to Islam, and the training of Muslims in Madrassihs and the statement there are
millions of people right now under training in these schools, implying a threat to Australia;
(9) that Muslims have a plan to overrun western democracy by the use of violence and terror, and to
replace those democracies with oppressive regimes;
(10) that people study for six to seven years and they become true Muslims, and we call them terrorists,
but they are true Muslim; they have read the Qur’an, they have understood it and they are now practising
it, that is the connection between the Qur’an and terrorism;
(11) Muslims intend to take over Australia and declare it as an Islamic nation;
(12) Muslim people have to fight Christians and Jews, humiliate them and fight them until they accept true
(13) Muslims in Australia are increasing at substantial rates and have influence or control over the
migration of people to Australia. Figures are quoted which are wrong. It is said the figures are produced
by the Bureau, implying the Bureau of Statistics, whereas they came from a different source, and that
they are increasing at a rate which was incorrect.
There are many other references to the Qur’an and Muslims who are said to follow its teachings. The
seminar was not a balanced discussion. It was a process of taking literal translations from the Qur’an and
making no allowance for their applicability to modern day society. The ordinary, reasonable reader would
understand from the public act that he or she was being incited to hatred towards or serious contempt for
or serious ridicule of a person on the ground of race.’ [I assume the last word should actually be ‘religion’
RSW]. [pp. 234-5]
The Pastors did not say that all Muslims are extremists. Obviously they are not. Indeed, the
pastors emphasised that most Muslims are ignorant of the Qur’an. It was certainly painfully
obvious that the converts who complained knew little of it, and even an expert witness for the
ICV, a Catholic priest, had only read parts of it. Scot’s aim was to explain what the Qur’an
really taught, and therefore what true Muslims should believe, and in that respect he did a
sufficiently accurate job for the Judge to state: ‘I find that Pastor Scot failed to differentiate between
Muslims throughout the world, that he preached a literal translation of the Qur’an and of Muslims’ religious
practices which was not mainstream but was more representative of a small group in the Gulf states.’
(Summary of Reasons, #8)
One doubts the Wahhabis of Saudi Arabia think their view small and unrepresentative (more
on this below). It was also noteworthy that the mere quotation of certain verses from the
Qur’an by Scot in the hearing was objected to by counsel for ICV, a strange reaction given
Muslim reverence for the text. Of course, one can understand that there are statements in it
that are somewhat embarrassing for moderate Muslims. This embarrassment is not easily
dismissed by reference to the circumstances of the 7th century. Will these verses be omitted
from Australian mosques in future?
If Scot had been more careful, valid points concerning the Qur’an and the Hadith could have
been brought out rather effectively, since much of what Scot said is in line with classical
Muslim teaching. Mind you, the Judge gives the impression he doesn’t always grasp the
context or that he makes mountains out of molehills. Is point 1 above incorrect? One can
affirm it as a fact while fully acknowledging that most Muslims today are peace-loving. Under
point 5, the judge seems to have got it wrong: Allah is merciful only after atonement by
cutting off the hand. At point 6 Scot described how certain demons are called Muslims - he
didn’t say Muslims are demons. The drafting of point 8 is hopelessly unclear (although the
evidence in the case makes things clearer). Under point 11, the claim was not expressly
denied by the ICV (see further below). At point 13, Scot had claimed an increase in Muslims in
Australia from 202,000 to 350,000 between 1996-2001. The real figures are 202,000 to
280,000. However, Scot was doubtless quite right to state that much higher figures are
commonly (but in my view wrongly) claimed in the Islamic community (as in other migrant
communities). Even if the rhetoric of ‘control’ was over the top, was Scot’s carelessness really
vilification? Importantly, the Judge seems quite ignorant of Islam as it exists in Australia,
makes no use of truly independent and objective experts and gave no attention to the stress
on reaching out in love to Muslims which featured in the seminar.
But where will such disputes end? The Age published a piece on 30/12 arguing that belief in a
caring, all-powerful interventionist God sits ill given the apparently wanton destruction
wrought by the tsunami. Its tenor can be gathered by my response printed in the issue of 1/1:
‘If Catch the Fire Ministries and its pastors were justly found to have vilified Muslims because they
attributed to all true Muslims the views of extremists, then perhaps Kenneth Nguyen (Opinion 30/12)
should be charged with vilification for an exposition of Christian views on God’s role in natural disasters,
which is quite unrepresentative of what we actually think. At a time when many are hurting and when
your agnostic columnist has nothing to offer, might we have a little more respect for theists, and
particularly for Christians whose central conviction is that God intervened in our sorrow and pain in the
Cross of Christ?’
The ability to launch a case that can cost mega-bucks to defend, is surely a dangerous tool. It
has the potential to be an inhibiter of freedom of speech. The well-known commentator Terry
Lane, ex Church of Christ pastor turned atheist, thinks ‘two ridiculous systems of religious
superstition and myth went head to head’ in the Victoria Civil and Administrative Tribunal
[VCAT] hearing. He makes the point that ‘Vilification is simply a word, like blasphemy,
obscenity, sedition or contempt, used to lend some sort of mystical weight to censorship of the
powerless by the powerful.’ In part he has a point. Do we need specific religious vilification
laws to control religious slander? I doubt it, especially when motive is irrelevant under such
The pastors’ credibility
The judge’s assessment of the credibility of the pastors is damning: He found Pastor Scot’s
evidence was ‘evasive, inconsistent and exaggerated.’ He also said of Pastor Nalliah, ‘I found
his evidence with regard to the newsletter of 2001 nothing short of a refusal to accept what he
had written and what he meant by those comments. The document speaks for itself. His
answer to questions in cross-examination and general demeanour were totally
unsatisfactory…(p.120). In my view, he was not subjectively honest and the newsletter, when
viewed objectively, does not satisfy me that it was engaged in ‘good faith’ (p.139).
In the hearing the ICV was at pains to reject the Wahhabist line of interpretation as at all
typical of mainstream Islam, and was anxious to stress the need for contextual interpretation
of Qur’anic texts cited by the defendants. As already mentioned, the hearing brought out how
little most Muslims know the Qur’an, and how the Hadith [traditional interpretations] are more
significant although also variable, there being no Pope in Islam to determine all issues.
One finds it very interesting that no Muslim cleric was called to speak on spiritual matters on
behalf of all Muslims. The judge said he thought the only inference he could draw is that such
witness may have been adverse to the ICV’s interests (para 379). I imagine this is correct,
since there are wide differences in the very ethnically and sect divided Islamic community, but
any criticism of the Qur’an would not be acceptable. My guess is the ICV are the more
articulate, liberal and progressive trying to hold a diverse community together, and presenting
the best face. That’s understandable of course.
[In 1991 there were about 70 different countries of birth of Australian Muslims. Although most
Arabic speakers in Australia are Christians, about 40% of the Muslim community was Arabicspeaking
and 25% Turkish. Regular mosque attendance was estimated at about 15% of adult
The Judge took the view that the interpretation of the Qur’an by Pastor Scot ‘represented the
views of a small group of fundamentalists, namely, Wahabbists [sic], who are located in the
Gulf states and who are a minority group, and their views bear no relationship to mainstream
Muslim beliefs and, in particular, Australian Muslims.’ One wonders just how true this is: as
one instance, Saudi Arabia has a population of some 23 million and Wahhabism is the official
position, and is exported significantly to other countries, financed by petro-dollars. Is there ‘no
relationship’ to mainstream beliefs? On some estimates ‘fundamentalists’ are 25% of Muslims
in some Islamic societies where inequality and poverty breed extremism. [Bin-Laden is merely
the extreme form of Wahhabism unpalatable to the Saudis themselves.]
Back in the October 2001 issue I suggested that Christianity cannot claim endorsement of
violence by its founder but Islam can, and that is one (only one) of the reasons bin-Laden has
appeal to many Muslims. There is a connection, however much many or most Muslims do not
wish to make it today.
As a beginning, we need honesty and clarity. In the November 2001 issue of The Presbyterian
Banner I noted that I had found the Islamic Information Centre to be a cell of Taliban
supporters. They get a brief mention in the trial but are dismissed as of no account. May be
so. But what about the presentation in June 2003 by two very fine Muslims at the Knox
Interfaith Network (covering the City of Knox) of which I was then Secretary and am currently
Chairperson? After giving a presentation which stressed the peaceful nature of Islam and
belief in the rights of the individual, and emphasized that all the bad things Westerners
perceive are not true Islamic teaching but cultural or other corruptions, we were invited to
avail ourselves of literature on various subjects. It seemed very reassuring at first glance.
Closer inspection of this literature, produced in Saudi Arabia, indicates it is written on the
presupposition that rights are controlled by shari’a, that is Islamic jurisprudence. Thus of
course there is no freedom to criticise or deny the prophet: that merits the death penalty
under all versions of shari’a law, as far as I know. Further, Saudi money has funded schools
and mosques in Australia.
It’s a bit of an enigma really. It seems that the Qur’an is not a closely understood text in
Islam, and, when it is, it needs much reinterpretation to avoid conclusions unpalatable in the
modern world. The Hadith (traditions) are variable, while the actual practice of Islam where it
is dominant generally has many bad elements/corruptions, and non-Muslims have a secondary
status as dhimmis. So what is true Islam? Is it a short creed (the Five Pillars), with allegiance
to a particular leader more significant in practice than the example and teaching of
Muhammed? Is that why Islam even in the Middle East is so faction ridden?
In this light, or lack of light, what are we to make of the Media Release by various Islamic
bodies including the ICV dated 6 November 2002 ‘Message to all the extremists of the world’?
[see www.icv.com.au/extremists.htm] It’s dated shortly after the Bali bombing. I would like to
think it embraces a commitment to freedom of religion but it does not state this. Rather, it
affirms such things as ‘never in our name or in the name of any religion or God, can you ever
be aggressive, unjust or hurt innocent people;’ and ‘there is no political, religious, racial,
ethnic or ideological position that can justify victimizing the innocent and the defenceless.’ It
adds, ‘This statement reflects mainstream Islamic teachings in every way and it is based on
the Quran. There is nothing in it which is open to challenge. This is what Islam clearly teaches
and what the overwhelming majority of Muslims believe.’
I’m glad to see this statement, but the signatories are not affirming rejection of shari’a law in
favour of a pluralistic society with a secular constitution such as in Turkey. They are not saying
that they think the death penalty for apostasy is hurting ‘innocent’ people, and that they are
opposed to it
The ‘Message’ does not identify Islamic terrorism by name but speaks generally of all
extremists and particularly ‘the random killing of unarmed and innocent people whom you
cannot identify and are not fighting you.’ That’s quite a limitation which you can take as you
like. It’s hardly condemning the Palestinians, is it? And maybe it is condemning the Americans
in Iraq. And one notices one signatory is the Sydney-based Mufti Sheikh Taj Aldin Alhilali, a
man of some note for extreme statements both here and more recently (March 2004) in
Lebanon. So there are credibility issues for the ICV which should have been explored, and
which suggest the judgment is unsafe. It’s an ‘evasive, inconsistent’ perhaps even
‘exaggerated’ statement, is it not? Is it a form of dissimulation, akin to Jesuitical practice,
called taqiyya in Islamic jurisprudence?
Similarly, the answer by Mr Solimon for the ICV to the allegation that Muslims aimed to
establish an Islamic state was quite disingenuous. (para 188) Why don’t they state plainly
that they would love to see Australia an Islamic Republic (as I’m sure they would) in which
there would nevertheless be complete freedom of religion? Is it because an Islamic Republic in
most/all examples does not allow the kind of freedom of religion that this country stands for?
Perhaps the ICV people stand for progressive Islam, but can’t be too open because their
communities are not yet liberal enough?
Second, Islam appears to have a singular incapacity for public self-criticism. Public criticism of
Muslim by Muslim is rare, since there is a tribal mentality. It has to change if we are to see
progress. The reluctance to make unequivocal commitments hurts the cause of good relations.
There is real diversity in the Muslim community. In private I have heard serious criticism by
Muslims of almost every Islamic regime, yet I do not hear that publicly.
Third, while vilification of anyone is objectionable, anti-vilification legislation is hardly the ideal
way to deal with it. The Islamic representatives, at our Knox Interfaith Network meeting in
December 2003, agreed that religious differences are not resolved in this way. Do we need
religious vilification laws? Perhaps, but they need to be clear and limited. There is no ‘true’
race, but there is truth and error in religion, and freedom to debate it is fundamental.
Interestingly, Amir Butler, executive director of the Australian Muslim Public Affairs
Committee, wrote in The Age June 4, 2004 that he had changed his mind on vilification
legislation. Public Islamic lectures now seemed always to include Christians taking notes, he
says. ‘These laws have only served to undermine the very religious freedoms they intended to
protect….Who after all would give credence to a religion that appears so fragile it can only
exist if protected by a bodyguard of lawyers?’ Elsewhere he writes: ‘If we believe our religion
is true then we are required to believe that others are false.’ Just so.
Christian leaders need to remember: “Not many of you should presume to be teachers, my
brothers, because you know that we who teach will be judged more strictly” (James 3:1). And,
more particularly, “Do not be overcome by evil but overcome evil with good” (Rom 12:21).
The pastors were careless at best, and deserved a rebuke. Still, the judgment does not seem
safe or fair, and thus it is unlikely to further the professed aims of the legislation. Some
modification of the Act is desirable.
The decision was given on 17 December 2004, there was a hearing concerning remedies on 4 May 2005 and the sentence was given 22 June 2005. It required the publication of a statement essentially the same as that submitted by the ICV in the CTFM Newsletter, on the CTFM website (for 12 months) and in advertisements in The Age and the Herald Sun on a Saturday and a Monday over two consecutive weeks, all by 31 August 2005. Also that within 30 days the respondents make an undertaking to the Tribunal that they will not make, publish or distribute in Victoria any statements or information that have the same or similar effect as those found by the tribunal to have breached the Act.
An application for judicial review had been lodged and a direction hearing was heard on 21 April 2005. The matter came before three justices of the Court of Appeal in August 2006, and was unanimously allowed on 14 December 2006. The Court held that VCAT had wrongly interpreted Section 8 of the Racial and Religious Tolerance Act, the basic section that sets out the offence of religious vilificationl. The Court gave orders that the Tribunal orders re 'penalties' (advertisement, not saying similar things) be set aside, and that the matter be sent back to VCAT to be heard by a different judge with no new evidence. The Court ordered that the costs relating to the previous Tribunal hearing and the next one be decided by the Member who hears it. The Court also ordered that the Islamic Council of Victoria pay half of the costs incurred by Catch the Fire Ministries and the pastors in conducting the appeal.
Back at VCAT, the parties agreed to go to a mediation prior to the re-hearing to see if the case could be resolved. The case was finally resolved at a Mediation at the Victorian Civil and Administrative Tribunal on Friday 22 June 2007. If mediation had not resolved the complaint it would have gone to a re-hearing at VCAT in December 2007.
The ICV has agreed to withdraw the complaint. A media release was issued as follows:
VCAT Media Release
Human Rights Division - Anti Discrimination List – VCAT Ref: A392/2002
Friday 22nd June 2007
Joint Statement of the Islamic Council of Victoria Inc.,Catch The Fire Ministries Inc., Daniel Nalliah and Daniel Scot
The Islamic Council of Victoria (the ICV) has reached an agreement with Catch the Fire Ministries, Pastor Daniel Scot and Pastor Daniel Nalliah about the complaint the ICV brought in the Victorian Civil and Administrative Tribunal (VCAT), concerning what it alleged were acts of religious vilification in contravention of s 8 of the Racial and Religious Tolerance Act 2001 (Vic).
Although some of the terms of that agreement are confidential, the parties have agreed to make this joint public statement.
Notwithstanding their differing views about the merits of the complaint made by the ICV, each of the ICV, Catch The Fire Ministries, Pastor Scot and Pastor Nalliah affirm and recognise the following:
1) the dignity and worth of every human being, irrespective of their religious faith, or the absence of religious faith;
2) the rights of each other, their communities, and all persons, to adhere to and express their own religious beliefs and to conduct their lives consistently with those beliefs;
3) the rights of each other, their communities and all persons, within the limits provided for by law, to robustly debate religion, including the right to criticise the religious belief of another, in a free, open and democratic society;
4) the value of friendship, respect and co-operation between Christians, Muslims and all people of other faiths; and
5) the Racial and Religious Tolerance Act forms part of the law of Victoria to which the rights referred to in paragraph 3 above are subject.
Issued by: Clare O’Dwyer, VCAT Media Liaison
Perhaps the only positive out of this unhappy affair is that the variuous other states and jurisdictions recognised the complications in religious vilification area, and in some case declined to legislate. The Victorian Goverment made some minor amendments to the legislation which have the effect of limiting somewhat the scope for frivolous and and expensive to defend complaints such as that in the case of Fletcher v. Salvation Army. VCAT is no longer obliged to hear a matter declared frivolous by the Equal Opportunity Commission.
Dr Rowland S. Ward is minister of
Knox Presbyterian Church of Eastern Australia,
Wantirna 3152 Victoria, Australia
Te: +613 9720 4871