In civil enforcement proceedings under ss 122-124 of the Environmental Planning and Assessment Act 1979 (NSW), it is sufficient to prove that a breach of development consent or building approval has occurred; it is not necessary to prove that the respondent personally committed the breach. An owner who is the recipient of consent is in a position to remedy or restrain breaches. An injunction requiring a party to take 'all reasonable steps' to satisfy consent conditions is not void for uncertainty, even where compliance requires the co-operation of a third party.
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