1Under ss 41(8) and 41(9) of the Associations Incorporation Act 1985 (SA), a winding up on the certificate of the Commission does not commence merely upon filing the application and lodging the certificate; rather, those steps fix the date from which the winding up is taken to commence only once the Court makes a winding up order.
2The 1993 amendments to s 41 conferred on the Supreme Court a substantive discretionary role in determining whether a winding up order should be made on a Commission certificate, not merely a power to appoint a liquidator and supervise the liquidation.
3The word 'including' in s 41(9) ('including a winding up on the certificate of the Commission') signifies that certificate-based windings up fall within the category of windings up by order of the Court, rather than adding a separate extra-curial category.
