Group 4 final presentation
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Transcript of Group 4 final presentation
Cases of Rau and Levi
NRS 190 Paramedic Law and Ethics
Group 4 Presentation
Debby Foster
Eva Rosenbaum
Emily George
Kelly Hastie
Introduction
• The following presentation discusses the legal and ethical
issues pertinent to the cases of Cornelia Rau and Roni Levi
– two individuals suffering serious mental health problems,
who were both tragically let down by the legal system and
health care system.
• Their cases have received significant media attention, and
have led to numerous legislative changes in response to the
stark failure of either system to provide them with the care
they so desperately required.
Cornelia Rau
THE CASE
Cornelia Rau was an Australian permanent resident who had resided in
Australia from 18 months old. Beginning in 1998, Rau disappeared many times,
and was diagnosed with bipolar disorder. In 2002, she lodged an application for
a false passport, at which point she was diagnosed with schizophrenia. She had
frequent hospital admissions as a result of her mental illnesses, culminating in
her absconding from the Manly Hospital Psychiatric Ward on the 17th of May
2004. Later that month she was seen at a Queensland pub by locals, who called
the police due to significant concerns for welfare. When questioned by police,
Rau told them she was a German woman named Anna Brotmeyer, and that she
had lost her passport.
(Freckelton, 2005, pp. 2-4)
Cornelia Rau
THE CASE
Rau was detained by police under the Migration Act from March 31st until
April 5th at which point she was transferred to Brisbane Women’s Correctional
Centre, where she was held for another 6 months. Staff and other prisoners
frequently expressed concerns about her behaviour, culminating in her transfer
to Brisbane’s Princess Alexandra Hospital for psychiatric assessment in August.
Despite the fact that Rau “attract[ed] the diagnosis of having a personality
disorder” (Freckelton, 2005, p. 2) she was not classified as mentally ill. On the
6th of October Rau was transferred under sedation, to South Australia’s Baxter
Detention Centre, where her behaviour continued to disturb staff and fellow
detainees.
(Freckelton, 2005, pp. 2-4)
Cornelia Rau
THE CASE
On the 6th of November, a further psychiatric assessment found Rau was
suffering from either schizophrenia or a personality disorder. It was
recommended that she should be hospitalised for further observation and
treatment. This was however ignored. It was not until the Sydney Morning
Herald publicised Rau’s case that her sister was able to correctly identify her
and she was removed from immigration detention and transferred to Glenside
Psychiatric Hospital.
(Freckelton, 2005, pp. 2-4)
Legal issues in the case of Cornelia Rau
THE LEGISLATION
Migration Act 1958
The Migration Act 1958 has specifications regarding the type and length of
permissible detention of unlawful non-citizens, specifically:
•“If an officer… reasonably suspects that a person… is an unlawful non- citizen”
they may detain the person (Migration Act 1958, Section 189, [1]).
•“An unlawful non-citizen detained under Section 189 must be kept in immigration
detention until he or she is: removed from Australia under Section 198 or 199, or
deported under Section 200, or granted a visa” (Migration Act 1958, Section 196,
[1]).
•Any treatment that is punitive in nature during immigration detention is “in
breach of the Constitution” (Parliament of Australia, 2005, p. 18).
Legal issues in the case of Cornelia Rau
THE LEGAL ISSUES
Migration Act 1958
Rau was not in fact an unlawful non-citizen, however even if she had have been, as was suspected,
her ongoing detention was not justified by the legislation for 2 reasons:
1. An officer must “reasonably suspect” the person is an unlawful non-citizen. Rau’s claims
that she was who she said she was were never verified (Parliament of Australia, 2005, p.
9).
and
2. An unlawful non-citizen can only be detained whilst one of three arrangements are being
made: removal from Australia, deportation, or the granting of a visa. Rau was detained
indefinitely with no plans for any of these arrangements, whilst officers were still trying to
establish her identity (Parliament of Australia, 2005, p. 7).
Furthermore, Rau was twice subjected to “confinement, isolation and punishment” (Parliament of
Australia, 200, p. 20) to control her behaviour, despite the fact that immigration detention
is not meant to be punitive.
Legal issues in the case of Cornelia Rau
THE LEGISLATION
Migration Series Instruction 371
Specifies that any employees or agents of the Commonwealth have a duty of care to
ensure all health related necessities of any detainee are met whilst in immigration
detention, which is enforceable by common law (Freckelton, 2005, p. 5).
Legal issues in the case of Cornelia Rau
THE LEGAL ISSUES
Migration Series Instruction 371
On numerous occasions staff and fellow detainees noted Rau’s behaviour was concerning. (Freckelton,
2005, p. 2).
These observations included:
•Rau would cry all day long (Freckelton, 2005, p. 2)
•Psychiatrist’s report stating her behaviour was “very unusual… inappropriate towards male officers…
laughs to herself, stands for hours staring at the wall or pacing up and down… presentation is consistent
with psychotic disorder” (Freckelton, 2005, p. 2).
•Rau was “stripping off her clothes and wandering in and out of the family quarters… [not] cleaning
herself properly… and stealing other people’s food” (Marr, Metererell & Todd, 2005, p. 34).
Despite these observations Rau was not appropriately treated or assessed for her current mental health
status. “The mental health care delivered to Cornelia Rau while she was detained at Baxter was
inadequate” (Palmer, 2005, p. xii). It can be concluded that the Commonwealth failed in their common law
duty of care.
Legal issues in the case of Cornelia Rau
THE LEGISLATION
Mental Health Act South Australia 1993 and
Mental Health Act Queensland 2000
These acts have two significant differences with regards to detaining an
involuntary patient:
1.The Queensland Act makes it easier to detain because the patient must only
appear to have a mental illness, whereas the South Australian act requires that
the person actually has a mental illness (Palmer, 2005, p. 158).
2.The South Australian Act makes it more difficult to detain a patient who
lacks the “capacity or willingness” to consent to treatment (Palmer, 2005, p.
158).
Legal issues in the case of Cornelia Rau
THE LEGAL ISSUES
Mental Health Act South Australia 1993 and
Mental Health Act Queensland 2000
•Rau was quite easily admitted to a psychiatric facility in Queensland for involuntary
assessment, due to the allowances made by the legislation (Palmer, 2005, p. 156).
• In South Australia, the staff at Baxter Detention Centre tried for some time for Rau’s
mental health status to be assessed, however organising this assessment was complicated
due to the stipulation in the legislation that the patient must have a diagnosed mental
illness in order to be detained as an involuntary patient (Palmer, 2005, p. 158).
Legal issues in the case of Cornelia Rau
LEGISLATIVE CHANGES AND RECOMMENDATIONS
Indefinite detention was ceased
The Department of Immigration and Citizenship (DIMIA) changed their procedures so
that a limit of 28 days was applied to how long people can be detained in a state prison
(Parliament of Australia, 2005, p. 7).
Mental Health Act 1993 (South Australia) replaced by Mental Health Act 2009
(South Australia)
Requirements for detaining an involuntary patient changed so that “a person [can] be
detained and receive treatment in a treatment centre… if it appears to the medical
practitioner or authorised health professional, after examining the person, that… the
person has a mental illness (Mental Health Act, 2009, p. 17).
Legal issues in the case of Cornelia Rau
LEGISLATIVE CHANGES AND RECOMMENDATIONS
Migration Act 1958 (section 189)
The Palmer Inquiry (Palmer, 2005, p. xv) recommended the implementation of a
legislative training package to better equip DIMIA officers to exercise their power under
Section 189 of the Migration Act 1958 in a more thorough and lawful fashion, addressing
all procedures relating to official identification of detainees.
Migration Series Instruction 371
A Select Committee on Mental Health was established to investigate the overall provision
of mental health services in Australia (Parliament of Australia, 2005, p. 6). Perhaps the
“inadequacies of resources that afflict the [Australian] public mental health system”
(Freckelton, 2005, pp. 10-11) contributed significantly to the delay in providing Rau with
appropriate mental health care.
Ethical Issues in the case of Cornelia Rau
PRINCIPLE OF BENEFICENCE
“The principle of doing good and providing care for others”
(Berglund, 2007, p. 12).
BREACHES OF THIS PRINCIPLE
•When Rau was finally assessed by a psychiatrist, numerous possible diagnoses were
given, with a recommendation for Rau to be transferred to Glenside Psychiatric Hospital
for further assessment and treatment. The recommendation was ignored, and clearly
breaches the principle of beneficence. The care Rau so desperately needed was not
provided.
(Freckelton, 2005)
Ethical Issues in the case of Cornelia Rau
PRINCIPLE OF NON-MALIFICENCE“The principle of not harming others, and of minimizing harm to them”
(Berglund, 2007, p. 12).
BREACHES OF THIS PRINCIPLE•Dr. Newman, chair person of the Royal Australian and New Zealand College of Psychiatrists
asked to examine Cornelia in 2005. His request was refused as Cornelia was unable to give
written consent for him to see her.
•Cornelia was watched by male guards whilst she used the toilet and the shower. The guards
would laugh at her behavior shamelessly, not once considering it may be indicative of a
serious mental illness, or that they may be exacerbating her already fragile state.
•Cornelia was detained in Red One, where she was the only female despite the fact that one of
the reasons she was sent there was for constant and inappropriate undressing.
(Freckelton, 2005)
Ethical Issues in the case of Cornelia Rau
PRINCIPLE OF AUTONOMY“The principle of allowing and promoting self-rule, of people making decisions about their
lives”
(Berglund, 2007, p. 12).
BREACHES OF THIS PRINCIPLE•The harsh reality of the case of Cornelia Rau – that an ordinary, yet mentally ill
Australian resident could be lost in the detention system for months, resonated
significantly in the community. The government knew the danger of the Rau case
spurring the wider argument over detention policy; it tried to limit the debate. It
couldn’t.
•The governments attempt to silence what had transpired in this case is a clear breach of
the principle of autonomy. The public have a right to know about system failures of any
kind.
(Freckelton, 2005)
Ethical Issues in the case of Cornelia Rau
PRINCIPLE OF JUSTICE
“The principle of fair allocation of community resources and burdens”
(Berglund, 2007, p. 12).
BREACHES OF THIS PRINCIPLE
•“Immigration detainees appear to have lesser rights and are held in an environment which appears
to involve a weaker accountability framework”
Commonwealth Ombudsman 2001.
•Detainees are disadvantaged with the rights to medical support and psychiatric treatment.
•Despite the high levels of disturbed behavior amongst the detainees at Baxter, there would be only
be a visit every six to eight weeks by the psychiatrist, Dr. Frucasz.
(Freckelton, 2005)
Roni Levi
THE CASE•On 27 June 1997, 33 year old Roni Levi voluntarily admitted himself to St Vincent’s hospital. He
was suffering from delusional thought processes.
•Around 4.30am on the 28th, hospital staff noticed he was missing.
•In the cold winter morning he walked 7km from hospital to his flat in Bondi, wearing only light
clothing.
•At 6.30am he took a knife from his flat despite his flatmate’s attempts to dissuade him.
•His flatmate followed him for about half an hour; he then ran to the Bondi Police station to report
the situation.
•At 7.00am, the police received reports that there was a man with a knife in the water at Bondi
Beach.
•By the time police arrived, he was heading up the beach, but when he saw them he turned and ran
back into the water. The police pursued him, and in the chase Levi lost his glasses. He was almost
blind without them.
•For half an hour Levi walked up and down the beach, while police attempted to persuade him to
drop the knife.
(Goodsir, Urquhart, 2001)
Roni Levi
THE CASE
•At 7.31am 2 police officers shot Levi after he suddenly lurched towards them.
•Constable Rodney Podesta and Senior Constable Anthony Dilorenzo fired two shots each, three of the four shots hit Levi in the chest; the fourth hit him in the lower back.
•Although paramedics were attending to Levi within seconds, he quickly had no pulse. He was pronounced dead on arrival at St Vincent’s hospital.
(Goodsir, 2001)
Legal issues in the case of Roni Levi
BEFORE THE SHOOTING
•May 1996 the Internal Affairs Branch of the NSW Police began to investigate an allegation that
Senior Constable Anthony Dilorenzo had an improper association with known drug dealers. This
investigation had the code name Operation Addlestone.
•May 1997 the Internal Affairs Branch of the NSW Police began to investigate an allegation that
Constable Rodney Podestra used and supplied prohibited drugs. This investigation had the code
name Operation Borden.
•May 1997 Operations Addlestone and Borden were combined.
(Urquhart, 2001)
Legal issues in the case of Roni Levi
Senior Constable Anthony Dilorenzo and Constable Rodney Podesta (Picture from Goodsir, 2001)
Legal issues in the case of Roni Levi
LEGAL ISSUES
•Were the police officers justified in taking the action they did?
•Were the officers affected by drugs or alcohol?
•Did Roni Levi get appropriate care from the hospital staff?
The crucial Acts which apply in this case are:
-The Police Act 1990
-Drug Misuse and Trafficking Act 1985
-The Coroners Act 1980
-Police Integrity Commission Act 1996
-Mental Health Act 1990
Legal issues in the case of Roni Levi
WERE THE OFFICERS JUSTIFIED IN SHOOTING?•“It was justifiable shooting. He was coming faster and faster and more aggressive with
the knife until he actually lunged at me. And when he lunged I was probably about four
foot away and I fired off two rounds which struck him in the chest.” Tony Dilorenzo
•“There were 39 civilian witnesses, and only two of those said Roni lunged. The police's
own crime scene examiner did a measurement of the distance of Roni from the police
officers when they discharged their firearms and he measured that distance to be 5.2
metres - that's a long way.” Ray Watterson, professor, school of Law, Latrobe University
•A critical point is the distance between Levi and the officers who shot him.
•Another critical point is whether or not the use of firearms was in accordance with
police procedures.
(Four Corners interview)
Legal issues in the case of Roni Levi
THE CORONER’S ACT 1980
•The coroner suspended the inquest into the death of Roni Levi because:
“In my opinion the evidence establishes a prima facie case against known persons
[Podestra and Dilorenzo] with regard to the death of Roni Levi. Accordingly I am
required to terminate the inquest and refer the matter to the director of Public
Prosecutions.”
•This was because the Police’s internal investigation had evidence that Podestra
and Dilorenzo may have taken drugs on the night before the shooting. Under the
Coroner's Act, if known people may be charged with a criminal offence, he must
stop the inquest and not reconvene until after the trial; or reconvene once it is
clear that no charges will be laid.
(Hand, 2001)
Legal issues in the case of Roni Levi
THE MENTAL HEALTH ACT 1990•The Mental Health Act provides for the treatment and care of people with mental
illness. The care should place as little restriction on the rights and liberty of the patients
as possible.
- This means the hospital did not have to ensure Levi stayed for treatment, as he was a voluntary patient and it was his right to leave.
•Section 4 requires the protection of the civil rights of mentally ill or disordered people,
and states that they are to be given an opportunity to access appropriate care.
- Witnesses said the police were shouting “drop the knife, you f*&king dickhead”
- Other witnesses heard Levi being warned to drop the knife or they would shoot to kill him.
(Royal Commission into the NSW Police Force, 1997)
Legal issues in the case of Roni Levi
THE POLICE ACT 1990
•Despite the 2 officers being under active investigation for possible drug involvement, neither
was tested for drug or alcohol impairment after the shooting. (At that time, there was no legal
requirement for officers to be tested after critical events.)
•Section 7 – Each officer is to act in a manner which: a) places integrity above all, B) upholds
the rule of law
•Section 5 – Examples of police misconduct can include “the commission of a criminal offence
by a police officer” and it is misconduct “whether or not it occurs while the police officer is
officially on duty”
Legal issues in the case of Roni Levi
DRUG MISUSE AND TRAFFICKING ACT 1985
•“A person who has a prohibited drug in their possession is guilty of an offence”
•“A person who administers or attempts to administer a prohibited drug to
himself or herself is guilty of an offence.”
•Offences of entering, or being on, drug premises:
“A person who is found on, or who is found entering or leaving, drug
premises is guilty of an offence.”
Legal issues in the case of Roni Levi
POLICE INTERNAL INVESTIGATION INTO THE
SHOOTINGPolice procedure states that officers involved in an incident where a firearm is discharged will be interviewed by police from other stations. This did not happen, Podestra and Dilorenzo were interviewed by colleagues from their own station. The other 4 police involved in the incident were not interviewed at all; they wrote their own statements.
•This situation led to Levi’s family alleging there was a cover up.
•The investigation heard conflicting evidence from witnesses; some said that Levi lunged at the officers, others claimed he did not.
•The investigation found that it was unable to determine if the allegation that the officers were affected by drugs was true.
(Goodsir, 2001, Urquhart, 2001)
Legal issues in the case of Roni Levi
THE INTERNAL AFFAIRS CASE AGAINST CONSTABLE RODNEY PODESTA
Podestra admitted the following:
•He did not always enforce the law in relation to drugs
•He frequented a bar in Bondi The Liberty Lunch” despite all police being instructed by a senior
officer not to go there.
•He used cannabis, cocaine and ecstasy before he joined the police.
•He attended nightclubs where drug use was prevalent, and had a group of friends who were known
to police as drug users.
•He continued to use cocaine and ecstasy after the shooting.
•In February 1998 he purchased a large quantity of cocaine with the intention of supplying it to
others.
•He resigned from the police in March 1998. He was convicted on 9 December 1999 and sentenced
to 4 months imprisonment on a charge of supplying a prohibited drug.
(Urquhart, 2001)
Legal issues in the case of Roni Levi
THE INTERNAL AFFAIRS CASE AGAINST SENIOR
CONSTABLE ANTONY DILORENZO
•Dilorenzo denied using drugs, but the investigation heard evidence from
surveillance tapes which strongly implicated him in drug use.
•An anonymous witness gave evidence that Dilorenzo used cocaine and ecstasy
while he was a member of the police.
•He was dismissed from the police in June 1999 on the grounds that the
Commissioner of Police had no confidence in his suitability to remain as a
police officer.
•He did not face criminal charges over the shooting of Roni Levi
(Urquhart, 2001)
Legal issues in the case of Roni Levi
THE FOLLOW UP
•The issues raised by Internal Affairs and the police investigation would not go away. In June
2001 the Police Commission tabled its final report to the NSW parliament.
•Its most damming finding was “that no orderly or structured control was taken of the
shooting immediately after it occurred and it is clear that there was a systemic failure to
comply with the then procedures, and there was a real risk that such an important
investigation may have been carried out by officers who might be perceived as not being at
arms length from Podestra and Dilorenzo.”
•The report also stated “that the allegations that both officers were affected by drugs and/or
alcohol were not adequately investigated by either Internal Affairs or the shooting
investigation team.”
(Goodsir, 2001)
Legal issues in the case of Roni Levi
LEGISLATIVE CHANGES AND RECOMMENDATIONS
•The coroner recommended that to avoid public allegations of cover up in fatal incidents
involving police, the investigation should be conducted by out of state police. That
recommendation has not been accepted by the NSW police.
•The coroner also recommended updated training for police officers to assist them with
dealing with mentally ill people.
•Another recommendation was that all hospitals have a protocol to notify family and police
when mentally unwell patients leave the hospital.
•There has been a change to the Police Act. Section 211A now requires police officers to
undergo alcohol and drug testing after “as soon as possible after a mandatory testing
incident” occurs. The coroner recommended this because he said it would “protect the
community and the police from unfounded allegations.”
One definition of a mandatory testing incident is one “where a person is killed or
seriously injured as a result of the result of a discharge of a firearm by a police officer.”
(Hand, 2001)
Ethical Issues in the case of Roni Levi
PRINCIPLE OF BENEFICENCE
“The principle of doing good and providing care for others”
(Berglund, 2007, p. 12).
BREACHES OF THIS PRINCIPLE
•Police were not beneficent. Part of beneficence is making sound judgments intended to
benefit all people involved. Police who choose to use drugs and alcohol before coming on
duty cannot later claim to act in the spirit of beneficence.
•Most people in society probably want the government to be beneficent and fair and
provide a good quality of health care for everyone.
Ethical Issues in the case of Roni Levi
PRINCIPLE OF NON-MALIFICENCE
“The principle of not harming others, and of minimizing harm to them”
(Berglund, 2007, p. 12).
BREACHES OF THIS PRINCIPLE
•It could be argued that Podestra and Dilorenzo were maleficent – that is, they intended
to do harm.
•Sometimes non-maleficence is defined that if someone cannot do good without also
causing harm, then that person should do nothing. In Levi’s situation, doing nothing was
not an option for the police, as doing nothing could have endangered others.
Ethical Issues in the case of Roni Levi
PRINCIPLE OF AUTONOMY
“The principle of allowing and promoting self-rule, of people making decisions about their lives”
(Berglund, 2007, p. 12).
BREACHES OF THIS PRINCIPLE•Autonomy allows people to have control over their own lives. One police officer was quoted as saying that
Levi chose “suicide by cop”, that is, he provoked the police into killing him.
•Respecting an individual’s autonomy does not come at the expense of other people’s rights. Autonomy
can be negated by other moral considerations. If a person’s choices endanger or potentially harm other
people, then their right to autonomy is void.
•The police had the right to decide that Levi’s right to autonomy was at an end, as his behaviour had the
potential to endanger others.
•They could have decided that he was obviously not thinking clearly, so was not able to make informed
decisions. In that case a paternalistic attitude would have been appropriate.
Ethical Issues in the case of Roni Levi
PRINCIPLE OF JUSTICE“The principle of fair allocation of community resources and burdens”
(Berglund, 2007, p. 12).
BREACHES OF THIS PRINCIPLE•What could “justice” have meant for Roni Levi?
•Justice in this case would have been recognition that he was not a well person, and that he
was entitled to a minimum standard of health care.
•John Rawls claims that the inequalities certain people experience in their lives are as a
consequence of a “social lottery”. It is not an individual’s fault if they are disadvantaged, so
society should support the person with health care or other measures to help them overcome
their disadvantages.
•This support would mean that the police could be well trained to recognise people in need,
and would have the training and resources to get the appropriate help for people in situations
like Levi’s.
(Rawls, 2001)
Conclusion
• Cornelia Rau and Roni Levi’s stories provoked intense media
coverage and in some quarters dissatisfaction with the way mentally
ill people are treated by officials. Their situations led to changes to
legislation; these changes were made in the hope that the mistakes
made in their cases will be learnt from and not made again.
• The situations they found themselves in were markedly different, yet
each serves to illustrate how mental illness polarises those around
them. Rau’s obvious distress was ignored, Levi’s behaviour although
threatening, could have been managed in an ethical manner to
ensure he received the medical attention he so obviously needed.
References
ReferencesAustralian Human Rights Commission. (2005). Palmer inquiry highlights immigration
detention and mental health services inadequacies in Australia. Retrieved from Australian Human Rights Commission website: http://www.hreoc.gov.au/about/media/media_releases/2005/27_05.html
Berglund, C. (2007). Ethics for Health Care (3 ed.). Melbourne: Oxford University Press.
Coroners Act 1980, NSW. Retrieved from Australian Legal Information Institute website: http://www.austlii.edu.au/au/legis/nsw/repealed_act/ca1980120
Drug Misuse and Trafficking Act 1985, NSW. Retrieved from Australian Legal Information Institute website: http://www.austlii.edu.au/au/legis/nsw/consol_act/dmata1985256/
Freckelton, I. (2005). Madness, migration and misfortune: The challenge of the bleak tale of Corenlia Rau. Psychiatry, Psychology and Law, 12(1), 1-14. Retrieved from http://search.informit.com.au/documentSummary;dn=763578568908540;res=IELHSS
Goodsir, D. (2001). Death at Bondi: Cops, cocaine, corruption and the killing of Roni Levi. Sydney: Pan McMillan Australia.
Hand, D., & Fife-Yeomans, J. (2001). The Coroner: Investigating sudden death. Sydney: ABC Books
References
References
Marr, D., Metererell, M., & Todd, M. (2005). Odyssey of a lost soul. Sydney Morning Herald, February 12-13.
Mental Health Act 2009, SA. Retrieved from Australian Legal Information Institute website: www.austlii.edu.au/au/legis/nsw/repealed_act/mha1990128/
Migration Act 1958, Commonwealth Consolidated Acts. Retrieved from Australian Legal Information Institute website: http://www.austlii.edu.au/au/legis/cth/consol_act/ma1958118/
Palmer, M. (2005). Inquiry into the circumstances of the immigration detention of Cornelia Rau. Retrieved from Australian Government Department of Immigration and Citizenship website: ww.immi.gov.au/media/publications/pdf/palmer-report.pdf
References
ReferencesParliament of Australia. (2005). The detention of Cornelia Rau: Legal issues. Retrieved
from Parliament of Australia website: http://www.aph.gov.au/library/pubs/rb/2004-05/05rb14.pdf
Police Act 1990, NSW. Retrieved from Australia Legal Information Institute website: http://www.austlii.edu.au/au/legis/nsw/consol_act/pa199075/
Rawls, J. (2001). Justice as fairness: a restatement. Cambridge: Harvard University Press
Royal Commission into the NSW Police Service. (1997). Police Integrity Report: Operation Saigon Phase II. Sydney.
Urquhart, P. (2001). Operation Saigon: Report to Parliament. Sydney: Police Integrity Commission.
http://www.abc.net.au/4corners/content/2009/s2724526.htm
http://www.policensw.com/info/gen/p3.html