A development consent incorporating a management plan is not invalid merely because minor details of the plan remain to be resolved, provided the unresolved matters do not leave open the possibility that the development will be significantly different from that applied for. The Land and Environment Court has power under s 23 of the Land and Environment Court Act 1979 to grant liberty to apply to work out the details of its orders granting development consent, and doing so does not render the Commissioner functus officio or constitute an impermissible reservation of power to refuse consent.
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