An incorporated environmental association challenging administrative decisions under the Forest Practices Act 1985 (Tas) must demonstrate a special interest distinct from the general public, and the subject matter of the litigation (here, apprehended bias in certification) must be connected to that interest. The self-regulatory design of the forest practices system, with its emphasis on delegated and decentralised approvals by officers who may be employed by harvesting entities, excludes the implication that the delegated power to certify is conditioned on the absence of apprehended bias. An appellate court may reconstitute with fewer members where a judge becomes unavailable after hearing, provided a quorum is maintained and the interests of justice favour proceeding.
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