Manchee v Secretary, Department of Climate Change, Energy, the Environment and Water

[2026] NSWLEC 15

NSW Land and Environment Court

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Interrogate

Catchwords

1. Environmental Law
2. › Native vegetation
3. › Remediation orders
4. › Construction of remediation order issued under Native Vegetation Conservation Act 1997 (NSW)
5. › Whether remediation order applied to whole of land or only unlawfully cleared portion
6. › Whether land properly designated as Category 2 – Regulated Land
7. › Native Vegetation Conservation Act 1997 (NSW) (repealed), s 47
8. › Local Land Services Act 2013 (NSW), ss 60I, 60L, 60M
1. Statutory Interpretation
2. › Construction of statutory instruments
3. › Remediation order as exercise of statutory power
4. › Whether to be construed according to principles of statutory construction
5. › Natural and ordinary meaning of text understood in context and in light of purpose

Quick Take

A remediation order issued under s 47 of the Native Vegetation Conservation Act 1997 (NSW) that defines a 'Remediation Area' by reference to whole lots shown on an attached map applies to the entirety of those lots, not merely to sub-areas identified in specific management clauses within the order.