A police officer who provides a statement as required by a direction from a superior officer is not a 'complainant' under s 169A of the Police Act 1990 (NSW), but the Police Regulations independently protect the identity of persons making allegations about police misconduct, and procedural fairness in police disciplinary matters requires disclosure of all adverse material that is credible, relevant and significant — not the identities of makers or the investigator's deliberative processes.
The full text is available to signed-in members, including the 3 later cases that cite this judgment.