17 February 2015

Gambling: Pub Charity v. Internal Affairs

Pub Charity has been accused of gaming the legal system, using a legal subterfuge when trying to wriggle out of a one day suspension of its operations imposed as a penalty way back in 2011 for breaching its gaming licence.  The High Court has ordered Pub Charity serve its one day penalty on 30 March 2015.
Pub Charity was set up in 1987.  By 2008 it was operating over 1700 gaming machines at nearly 180 pubs and clubs.  The High Court was told Pub Charity had gross revenue of over $69 million for the year ending September 2008, making donations of more than $25 million to community groups.
Under its gaming licence, Pub Charity is required to limit venue costs to 16 per cent of its profits.  Gaming legislation seeks to maximise net proceeds for distribution to community groups, minimising operating costs. Internal Affairs took an interest when Pub Charity overshot this limit by $286,200 for the twelve month period ending July 2009.  This overspend breached the limit by 0.46 per cent.  Pub Charity said in its defence that it was difficult to monitor expenditure centrally when it operated from so many venues.  Evidence before the court indicated that Pub Charity’s business approach is to maximise venue costs up to the allowed limit, not to reduce expenditure as much as possible.
Internal Affairs imposed a one day suspension of Pub Charity gaming machines as penalty.  Penalties of up to six months suspension can be ordered. Pub Charity’s one day suspension was to have occurred in July 2011.  No suspension took place while Pub Charity fought a series of appeals through the Gambling Commission, the High Court and the Court of Appeal.  Internal Affairs won the final round.  The Court of Appeal sent the case back to the Gambling Commission to set the penalty.  Pub Charity promptly withdrew from the field of battle, declaring it had withdrawn from the case.  There were no longer any legal proceedings on foot, and Pub Charity challenged Internal Affair’s ability to reset a suspension date.
Back in the High Court, Pub Charity was arguing it was off the hook: first because the earlier litigation had collapsed and secondly because Internal Affairs had issued a written warning which Pub Charity said served as a substitute for the ordered suspension.  In June 2013, Internal Affairs had placed on record with Pub Charity a formal warning in respect of three breaches: the overspend of $286,200; a grant of $220,000 for the running of the Queenstown National Sevens Tournament as not being a grant for a charitable purpose; and costs of some $52,500 for what was considered unnecessary building alterations at four gambling venues.
Justice Mallon ruled that Internal Affairs could set a new date for the suspension, regardless of Pub Charity deciding to abandon its appeal.  She said the date for suspension would be Monday 30 March 2015, unless Pub Charity and Internal Affairs agree to a different date.  Evidence was given that Mondays are the quietest days for gambling.  Justice Mallon suggested Internal Affairs remove from its files the Pub Charity warning letter.  This avoids any suggestion that Pub Charity is receiving both a suspension and a warning in respect of the same breach.
Pub Charity v. Internal Affairs – High Court (17.02.15)

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