Revealed: Vic govt's flawed claims on $370m Horsham solar hub

No Victorian solar farm has ever reached the power levels promised for SEC's new $370m Horsham development, market data reveals.

It was former Victorian Premier Daniel Andrews who promised to bring back the SEC, but it’s Energy Minister Lily D’Ambrosio who has been left to deliver.

The SEC is spending $370m of Victorian taxpayers’ funds building a 212,000 solar panel development at Horsham, which industry analysis shows will generate just half the power the Allan government claims.

Construction has already started on the project, which Premier Jacinta Allan and Energy Minister Lily D’Ambrosio said would generate 242,000 megawatt hours of renewable energy a year – enough to power 51,000 homes.

But the estimate is based on the development operating at 23 per cent of its 119MW capacity, something no other solar farm in Victoria has achieved.

Australian Energy Market Operator data, collated by the Open Energy group, shows the Cohuna solar development, which has been operating since March 2020, generates at 7.8 per cent of its 31.1MW capacity.

Further east the Wunghu development north of Shepparton generates 10.2 per cent of its 93.5MW capacity, while further east the Winton solar farm’s 246,624 solar panels generate at an average 14.3 per cent of their capacity since it started operations in March 2021.

Not even the solar farms in Victoria’s far sunnier north-west can match the government’s generation forecast for Horsham, with Kiamal sitting at 14.9 per cent, Karadoc at 17.6 per cent and Yatpool at 15.5 per cent of their capacity.

AEMO national electricity market data also shows that much of the time solar developments are generating electricity when the market price is negative, due to oversupply.

Centre for Independent Studies energy research director Aidan Morrison said it was “nuts and completely economically backwards” for the SEC to be investing in even more solar generation capacity.

“Everyone is screaming for investment in solar to stop, Mr Morrison said. “They’re (the government) getting the SEC to take on things that the market will not.”

Ms D’Ambrosio has previously stated Labor was “investing in renewable energy projects for people, not profit”.

Victorian Energy Policy Centre director Bruce Mountain questioned why the public sector was involved in the Horsham project at all, given it sat on the shelf undeveloped since 2022, when it was named a winner in the Victorian Government’s second renewable energy auction.

The scheme guarantees winning bidders a floor price, under which Victorian taxpayers pick up any market shortfalls.

The SEC is also investing $245m in the Melbourne Renewable Energy Hub – a 600MW big battery - and entered contracts to supply Victorian schools, hospitals, museums, trains and its offices, with what Ms D’Ambriso said was 100 per cent renewable energy from the beginning of last month.

Asked how the SEC could supply 100 per cent renewables on cloudy days or when the sun went down, Ms D’Ambrosio’s office said: “The SEC has bulk purchasing contracts for renewable energy the equivalent to the amount of electricity the government will use over the next financial year”.

Source:supplied

Scammers, fraudsters and the tax office’s missing $50 billion

The ATO (Australian Tax Office) is one of the colony's most secretive and corrupt organisations.

First and foremost, Australia's Anglo-Masonic system looks after its 'brethren', where case in point, it waived ex PM Paul Keating's tax bill of almost $1 million.

SO who has to mop up the rest?

Why the serfs/(tax) slaves do, of course!

See the Four Corners documentary:

What will the ATO do now?

It will surely harass the serfs in unlawful conduct to recoupe it's (alleged) 'losses', where it will 'require' taxes on unrealised profits, from plebs that own businesses, as the ATO is doing at this very moment.

There really should be a class action lawsuit against the ATO.

Will it ever happen? Probably not, but if it does, then it will be designed to fail.

Law and order is so bad we’re being told to lock our doggie doors

A deliberate 'failure of government', as described by Stever Price:

Law and order in our state is now so bad one local council is buying ads warning residents to lock up their doggie doors. Is that really where we are at in the great state of Victoria?

Law and order in Victoria now is so out of control one local council is buying ads warning you to lock your doggie door.

I’m not kidding. It follows mobile signs on freeways with police telling you to lock your doors at night.

A sign on the gate of a local park near me poses this question: “Going out – have you locked your doggie door?” Authorised by the Victoria Police and Stonnington Council.

Is that really where we are at in the great state of Victoria, a council warning that your home could be robbed by some scumbag crawling through a doggie door.

The sign goes on to warn about intruders and advises you to lock your doggie door at night and when you are not at home. Who wants to live in a place where home security involves putting a latch on a pet door and securing it when you go for a morning walk.

The Stonnington Council sign warning pet owners to lock doggie doors to avoid break ins.

Victoria, thanks to a politically correct government that wants to avoid at any cost locking up young offenders, preferring to bail repeat criminals, is paying the price. Ignoring petty crime has a cascading effect with respect and fear of police disappearing.

A place like Chapel St has become ground zero for this type of offending.

Drug affected and mentally unstable people who are often homeless treat retail businesses as their personal property.

A Liquorland bottle shop between High Street and Dandenong Rd now has a daylight locked door policy after a recent spate of snatch and grab robberies. In one week, the store was hit 30 times, traumatising the shop attendant and forcing the lockdown.

CCTV captured the moment thieves broke into an Armadale home through a doggie door last year. Picture: Supplied

Despite providing police with CCTV footage and identifying the culprit, nothing has happened. This is a stark example of a statewide government failure to protect Victorians as repeat offenders know there is no punishment for so called minor crimes. Major supermarkets have posted security guards in stores like Coles or Woolworths, but they are instructed not to intervene if someone walks out with arm loads of stolen groceries.

So bad has retail theft become that the Australian Retailers Association has this week put a price of $9bn a year on the cost to business and want the issue raised at next month’s roundtable meeting in Canberra.

Ironically that same Victorian government that does nothing about this increases fines for minor traffic offences like travelling at 45km/h in a 40km zone with onerous fines and a heavy loss of demerit points. Rob a bottle shop, crawl through a doggie door and steal a car and you are likely back on the street the same day.

Chapel St has become ground zero for petty crime. Picture: Grace Frost

Dare use a mobile phone by touching it sitting at a traffic light – which you shouldn’t do – and you will be fined a whopping $611 and lose four demerit points. Steal a bag full of bourbon and coke cans from a bottle shop or fill a shopping trolley with stolen groceries and walk out without paying and you are home free.

Police are too stretched and the crimes so rampant that criminals know it’s a free for all.

Now, so worried that law and order could cost her another election victory for Labor in November next year, Premier Allan has decided to make another change to existing bail laws.

Bail laws were tightened back in 2018 but under sustained pressure from activists they were loosened in 2023 and the sort of crime I’ve described exploded.

An individual threatening a team member with a knife at a store in Melbourne. Picture: Supplied.

Police were then told the crime of public drunkenness was no longer to be policed and the useless drunk tanks were established which are nothing more than virtue signalling.

The toughened bail laws that went before parliament this week are of course useless unless magistrates and judges follow them.

Already Indigenous justice advocates have called the tougher laws a “disaster waiting to happen”. They claim the laws will “inevitably result in more Aboriginal deaths in custody”, a big claim that will scare the hell out of Allan and her frontbench including Attorney-General Sonya Kilkenny and Police Minister Anthony Carbines.

It was activism from Indigenous groups that led to the bail laws being softened in 2023. Again, those same activists are making claims that tougher laws will drive up the number of people in prison (isn’t that the idea) and then this outrageous claim where they say the laws will condemn generations of Indigenous children and adults to the trauma of pre-trial detention.

How about trying this idea: use your activism and government funding to convince Indigenous people not to break the law and then they won’t end up in jail, waiting to go to court.

Mike Bush needs to come out swinging against crimes against innocent Victorians. Picture: Jason Edwards

 

Dumped in the middle of this crime and bail mess is our new Police Commissioner, Kiwi Mike Bush.

He did the media rounds this week on radio, TV and in print and probably wisely batted away any tough questions and answered pretty much with platitudes. My worry with the new Commissioner is his time serving as the national head of police in NZ under one of the wokest politicians of all time, Jacinda Ardern, pretty much a national version of Jacinta Allan.

Bush now needs to come out swinging against crimes against innocent Victorians, like home invasions, and get his suburban stations to patrol shopping strips and shopping centres with a zero tolerance towards retail theft.

He also needs to ignore calls from vocal activists who have contributed greatly to the mess we are in today.

Most importantly he has to have the courage to stand up to the Jacinda Ardern version of politics in Victoria Jacinta Allan. Good luck with that.

Likes

• Olympians from the 1980 Moscow Games honoured in federal parliament this week.

• Victorian farmers making it clear with another protest this week that they are not going to surrender their properties to transmission lines.

• Oscar Piastri’s turn five trouncing of teammate Lando Norris at Spa.

• Donald Trump’s driver splitting the fairway on the opening shot of his new Scottish golf club.

Dislikes

• The amount of scoreboard advertisements now allowed after every break in play at the MCG.

• Prime Minister Albanese standing in front of just the Torres-Strait Islander flag telling the world of our social media ban.

• That same ban nothing more than virtue signalling young people will work their way around it easily.

• Pro-Palestinian protesters allowed to force a weekend shutdown of the NGV.

Source: Herald Sun 

The COVID-19 FOI the government does not want you to know about.

A grim reality was that people got conned by the Australian governments (both state and federal),

that the test for COVID-19 they were conducting on the masses, gave an accurate result.

The Department of Health and Human Services has stated under a FOI (Freedom Of Information) request that:

“there is currently no test available that 100% positively identifies COVID-19 in a living human beyond any reasonable doubt…”

Despite knowing this, the governments have taken action against ‘persons’ that have tested positive in a detrimental manner to their existence.

Have these ‘persons’ obtained a remedy?

Can they sue the goverment for action that was detrimental to their livelihood, without costing them their house in legal fees?

Looks like another thing to be swept under the rug of a corrupt government's actions.

See actual COVID-19 test result within the link:

COVID test useless: “Faith in Quick Test Leads to Epidemic”

Next Level of fake videos - Veo 3

A.I. is increasing in leaps and bounds in what can be done with it.

As usual humans find ways to use technology for nefarious purposes.

Here is a benign example of a 'video' created totally by A.I.

This now at a new level, where can you truly tust what you see in 'social media' clips or even YouTube?

Source: László Gaál

Apple's tax woes in Ireland are officially over

Apple's €14.3 billion Irish tax break fine is officially one for the history books now, as the Irish government has announced that it's withdrawn all the money from the escrow account Apple set up back in 2018. That's when it deposited the aforementioned sum after being fined by the European Commission (EC) for receiving unfair tax breaks from Ireland.

The amount is judged to be what Apple would have paid in taxes in Ireland had it not received a "sweetheart deal" in the form of "illegal state aid" from the Irish government in exchange for setting up its European HQ in the country.

Now that Ireland has moved the money from the escrow account into its central fund, the escrow account has been closed and Apple's saga regarding these back taxes allegedly owed can finally be put to rest.

The timeline goes like this: in 2013 the EC launched an investigation into Apple and found that the tax breaks it received from Ireland were illegal, and in 2016 it ruled that Apple had to pay back the "state aid" it was deemed to have received over a 10-year period before the probe was launched, since it was allegedly given "significant advantage" over its competitors.

In 2018, Apple set up the escrow account and paid the amount it was deemed to owe into it. In 2020, the EU's General Court ruled in Apple's favor, but in 2024, the European Court of Justice overturned that decision and confirmed the EC's original ruling from 2016. Hence why the Irish government has now finally taken possession of the money.

Source:  (Department of Finance) www.gov.ie

Corrupt police, the unlicenced ones that get away with it

It’s a real fact that not every person is equal before the law, where corruption is at play in the Judiciary arm of the government, also including the administration of the courts, ‘members’ within tribunals and also police.

Victoria Police as an organisation is corrupt in its day to day business, where if a private corporation operated as such it would be fined, criminalised or shut down, but this is not the case with this taxpayer funded body.

Persons within this organisation have a duty to pursue criminal actions where charges are brought forward before the courts.

Victoria Police Manual – Policy Rules also states that the 

“members have a duty to preserve the peace, protect life and property, prevent offences…” 

and most importantly “apprehend offenders”, meaning 'persons' that commit criminal offences.

Road traffic offences in this colony are classified as criminal and not civil.

Quite simply put VicPol are going against their “Policy Rules”.

Police and the media go hand in hand in portraying a false narrative that the law comes down hard on dangerous or even unlicenced drivers, but the reality is much more shocking.

Documents have been seen, show that unlicenced drivers that have been caught have not been prosecuted, where even in socking circumstances they have caused accidents, yet have not been pursued by police.

It is also noted that a certain migrant minority is left untouched.

The source requires to be anonymous, as the publishing of any documents may reveal the identity of the person exposing police corruption.

What police don’t want you to know about speed measuring devices

The colony’s police forces do not act honourably or honestly when it comes to measuring motorist's ‘speed’ or more accurately, velocity.

In Victoria, many officers do this ‘illegally’ where they get away with it in court.

Victorian driver’s get conned by police and the courts and they don’t even know it, as it’s all about the generation for revenue for the government, that’s all.

An allegation of travelling quicker than a predetermined limit is not treated as a civil offence but rather a criminal one meaning the law is stacked up against you from the start.

As always, in a criminal offence the burden of proof, beyond reasonable doubt, is entirely on the prosecution meaning every aspect of the allegation must be proven.

Victoria Police generally use the ProLaser 4 ‘High Performance Handheld LIDAR’ (LIght  Detection And Ranging), distance measuring device from KUSTOM SIGNALS INC, based in the United States.

What Victoria Police does is it conceals evidence if one decides to challenge the allegation of ‘speeding’.

When one recieves a "Preliminary Brief" vital infomration does not get provided to your 'person'.

Even when one request a "Full Brief" that information is also kept from you.

Therefore it is strongly suggested that a supoena is issued for the information.

What is this information?

This information is called 'metadata'.

This metadata is attached to every photo taken of an alledged speedster.

Victoria Police stated in court that the ProLaser 4 can hold 1000 instances of metadata.

This metadata is downloaded at the officer's workplace via the 'back office' through a USB cable plugged into the workstation.

Victoria Police is inherently corrupt, but the bigger problem is that they have the full support of the judiciary in their corruption.

Another aspect of the law that the police don't want you to know about is a little known law from 1984 called the INTERPRETATION OF LEGISLATION ACT 1984, as seen in the screen capture below:

In particular Section 43 which states the following, in relation to the measurement of distances:

In the measurement of a distance for the purposes of an Act or subordinate instrument, the distance shall, unless the contrary intention appears, be measured in a straight line on a horizontal plane. 

Unbeknown to many motorists this law has been in place for 41 years.

Keep in mind that the ProLaser 4 measures distance divided by time, therefore the above law applies.

The metadata from the ProLaser 4, also contains the parameters of taking a measurement at 0 degrees or a 'horizontal plane', and even if the vehicle they surveyed is factually yours.

A significantly high portion of police in instances of handheld and stationary detection do not follow the above mentioned law meaning they take measurements illegally.

Do they know about this law?

Of course they do, just like they know about the 'KABA' ruling from 2013 on random vehicle stops.

So if you're challenging an allegation of 'speeding' don't ask for the documentation, supoena it, meaning fill out a "Subpoena to produce - Form 42B" from the Magistrates Court of Victoria.

Google loses $314 million lawsuit over data transfers when Android phones are idle

Google just lost the class action suit against it in California – the suit was filed on behalf of an estimated 14 million Californians in 2019 and alleged $800 million in damages over Android phones collecting and transmitting data to Google while idle.

The jury sided with the plaintiffs and awarded them $314.6 million (that’s almost pi!). More specifically, Android phones collected data that would be used for targeted advertising and transmitted it to Google’s servers over cellular data – at the phone owner’s expense.

Google will appeal this verdict as it claims that users were not harmed by these data transfers and that users consented to this when they agreed to Google’s terms of service and privacy policies. A spokesperson for the company stated that the verdict “misunderstands services that are critical to the security, performance, and reliability of Android devices”.

Another group has filed a separate lawsuit, this time on behalf of Android users in the other 49 US states – this trial will begin in April.

Source: retuers

Shocking hidden recording reveals corrupt police on Good Friday

A reality that many do not want to wake up to, is the fact that Austalians live in a police state.

In this exposé, Victoria Police have arrested a motorist under false pretences on Good Friday.

The claim by police was also made that the person is "very sovereign citizeny" DESPITE there being no proof of this.

They wanted to cause physical injury by driving dangerously while he was placed in custody in the back of the divisional van.

They wanted to damage his property, that being his watch that they held.

This is not a unique or isolated example of what sort of scum is in the state's and territory's police forces of Australia.

Police can make all sorts of false claims, where there is little chance of a remedy for victims of police or if there is it's a great finanical cost, where the system is deliberately rigged against people seeking 'justice'.

See video of the title The video these INCOMPETENT COPS don't want you to see :

NEVER trust the police and record all interactions with them.

LIES about fuel price, cost before and after US attack on Iran

People in corporations and governments lie to the general population every single day, where the lies will never stop.

Those in government have preplanned agendas that even span decades where the serfs are none the wiser, pity.

On Monday, the 23rd of June 2025, Rupert Murdoch’s publication mentioned that NRMA spokesperson stated that “drivers likely to pay 8 cents more a litre when fuelling up".

One would expect that to be nationwide, albeit a small difference from one state or territory.

On that day, in Melbourne unleaded fuel was 159.9 c/litre as seen by the receipt below, where certain identifying factors have been blocked out:

After the US attack on Iran, the price of fuel from the same supplier skyrocketed, or rather the motorists were bombed with a price of 219.9 cents per litre, as seen in the headline photo above.

That is an increase of 60 cents per litre or a 37.5% price hike.

The good motorists of Australia are being extored to pay for an overseas attack on another country with full support of this by our colonial govenrment.

Australia, the 'lucky' country... NOT!

16 billion password data breach hits Apple, Google, Facebook and more — LIVE updates and how to stay safe

Latest updates on one of the largest data breaches

The news of a massive 16 billion data breach that exposed login credentials from Apple, Google, Facebook has made record as one of the largest data breaches in history.

Cybernews reports that records from over 30 databases have been stolen, with each containing up to 3.5 billion passwords from social media and VPN logins to corporate platforms and developer platforms.

The recent data breach contains a massive amount of information that can affect billions of online account, as cybercriminals now have access to a mass amount of login credentials. This puts users at risk of further malicious behavior from phishing attacks, social engineering and identity theft.

Here are the latest updates on what we know about the data breach, how to find out if you're affected and how to stay safe.

What's exposed?

Currently, nearly all major platforms have been affected by the breach, including Apple accounts (formerly Apple IDs), Gmail, Facebook accounts and GitHub as well as instant messaging platforms like Telegram and both commercial and government platform portals.

The data appears to contain URLs, usernames and passwords. However, with the unfathomable size of the data that's been exposed, there's no way to tell how many accounts are currently under threat.

The stolen data appears to come from several infostealers, and while the datasets are new, the sheer amount of info could also be from a mix of different datasets from previous breaches, including a database containing 184 million records discovered in May this year.

How to stay safe

With the 16 billion login credentials now being exposed, it's important to check if your account has been exposed and to stay safe.

First, the best way to keep your account secure is to enable two-factor authentication (2FA). This will stop threat actors from easily accessing your online accounts, as a second form of authentication through an app, phone, passcode or a physical USB key will need to be approved by you. If you haven't already, find out how to enable 2FA right now.

Second, to find out if your login credentials have been affected, use Have I Been Pwned and check if your email is in the clear. If you are at risk, immediately change your password, delete unused accounts and consider using one of the best password managers to secure your online accounts.

Source:tomsguide

Anticompetitive Practices

The FTC takes action to stop and prevent unfair business practices that are likely to reduce competition and lead to higher prices, reduced quality or levels of service, or less innovation. Anticompetitive practices include activities like price fixing, group boycotts, and exclusionary exclusive dealing contracts or trade association rules, and are generally grouped into two types:

• agreements between competitors, also referred to as horizontal conduct
• monopolization, also referred to as single firm conduct

The FTC generally pursues anticompetitive conduct as violations of Section 5 of the Federal Trade Commission Act, which bans “unfair methods of competition” and “unfair or deceptive acts or practices.”

Search Cases

Use our Advanced Search page to find a specific antitrust case. To see all antitrust cases, select “Competition” in the mission field. To see a specific type of competition case, select from the list of available topics in the competition topics field.

Competition Statutes

The primary statutes governing the FTC’s competition mission include:

•     FTC Act

•     Sherman Act
• Section 1
• Section 2

•     Clayton Act

Guidelines

    Antitrust Guidelines for Collaborations Among Competitors

    Statements of Antitrust Enforcement Policy in Health Care

    Antitrust Guidelines for the Licensing of Intellectual Property

    Guides for Advertising Allowances and other Merchandising Payments and Services – “Fred Meyer Guides”

Competition Advisory Opinions

The FTC provides guidance concerning proposed conduct in the form of advisory opinions. The process starts with a request for advice from the party proposing the conduct. Many advisory opinions are rendered by Bureau of Competition staff, and often involve issues in the health care field.  Commission advisory opinions are voted on by the Commission and are intended to address substantial or novel questions of fact or law, or subjects of significant interest.

FTC staff provides practical guidance for those who may want to request an advisory opinion. You also can review all previous advisory opinions, and filter them using the “Antitrust/Competition” tag.

Source: Federal Trade Commission

With Android 16 upgrade Google should be sued under anti-competative law!

Google is again engaging in anti-competative or in the United States, antitrust behaviour, which is against the law.

With this new action Google is getting rid of ALL competitors, where Android phones must run through Google (it's about 'forcing' the licencing of GMS (Google Mobile Services)), where they are not able to function under AOSP (Android Open Source Project), such as Lingeage OS and GraphenOS.

AOSP is a baseline operating system of Android which manufacturers (e.g Samsung, Motorola, Huawei, etc) use before they load up their hardware with their spyware bloated version of Android.

Lingeage and Graphene, are among a few custom open source Android operating systems called ROMs, that do not have highly invasive 'spyware' that Google and other phone manufaturers (e.g. Samsung) install on their phones, which can be a danger to people's lives where they require privacy or anonimity as a result of their job or for other reasons.

The tech and legal communites MUST take action against Google's latest 'illegal' practice.

Whether they will, is another story that time will tell.

See a Comparison of Android-based Operating Systems:

Source: https://eylenburg.github.io/android_comparison.htm

Most of these ROMs are privacy (and security) focused, where Google's actions are an attack on user's privacy and therefore security.

Google is deliberately killing off AOSP.

At the end of the day it's all about data collection by the giants Google and Apple, where the latest actions by Google are part of the global 'Nanny State' agenda where only duopoly powerhouses exist.

If you truly value your privacy, then Google products are not the ones that you will achieve privacy with.

See the following article by androidpolice.com of the following headline:

Google’s latest AOSP move spells doom for custom ROMs on Pixel phones

In March of this year, Google revealed it is changing its Android development process and will no longer make real-time code commits to public AOSP branches. The change barely had any public or development impact. But now, with the release of Android 16, Google is making a bigger change to AOSP that will affect the development of custom ROMs for Pixels.

For years, Google used its Pixel phones as reference devices for AOSP development. As part of this, the company also published the device trees and driver binaries, ensuring that developers could compile a fully working AOSP build of Android for Pixels. Custom ROM developers also relied on the same device trees and driver binaries to ensure core features worked properly in their ROMs.

This won't be the case going forward, though. While Google has already published the Android 16 source code, it won't be releasing the device trees and driver binaries for compatible Pixel phones. The Graphene OS team initially claimed that Google made this change as it planned to discontinue AOSP entirely.

However, Seang Chau, VP and GM of Android Platform, refuted such rumors and provided a clearer picture (via Android Authority). He made it clear that Google is not doing away with AOSP. But going forward, AOSP will use a reference target device "that is flexible, configurable, and affordable — independent of any particular hardware, including those from Google." And so, Google is switching from Pixels to Cuttlefish — a virtual Android device— as the reference AOSP device. Since it's a virtual platform, developers can run Cuttlefish remotely or locally.

Custom ROM development for Pixel phones just got a lot more difficult                

This move from Google will change the custom ROM development scene for Pixel phones forever.

 Unlike other Android devices, device trees and binaries made it relatively easier for developers to build ROMs for Pixel devices.

Without them, they would have to reverse-engineer prebuilt binaries to find out the changes that Google made — a challenging and time-consuming process. The lack of kernel source code commit history from Google only adds to the complexity.

Think of these device trees and binaries as the Android equivalent of drivers on a Windows PC — they ensure the operating system can properly communicate with the device's hardware.

Google's latest changes to AOSP will have a major impact if you run LineageOS or another custom ROM on your Pixel. That's a dwindling number, though, as custom ROMs are no longer as popular as they once were. Still, it's a major setback for leading custom ROM projects, like LineageOS and GrapheneOS.

See other related articles:

Privacy-Focused GrapheneOS Warns Google Is Locking Down Android

Comments from the above link:

Android’s open future questioned after Google withholds Pixel code

Android’s Impossible Deadline—3 Weeks To Update Or Stop Using Phones

A tricky dilemma for Android users this week, as both Google and Samsung release this month’s Pixel and Galaxy security updates with critical missing fixes. And with a June 24 deadline to secure phones or power them down, something needs to give. There are 30-plus important fixes that have been released, but not the ones that matter most.

The fixes are long-awaited patches from Qualcomm, which warns Android users that “there are indications from Google Threat Analysis Group that CVE-2025-21479, CVE-2025-21480, CVE-2025-27038 may be under limited, targeted exploitation.” The flaw affects Adreno Graphics Processing Unit (GPU) drivers.

It is assumed but not known that exploitation would have been used in commercial spyware software, similar to the well publicized attacks outed by Amnesty International. Qualcomm says patches “have been made available to OEMs in May together with a strong recommendation to deploy the update on affected devices as soon as possible.”

The deadline which comes courtesy of America’s cyber defense agency is mandatory for federal staff and recommended for everyone else. CISA warns “multiple Qualcomm chipsets contain” these vulnerabilities, which it describes as follows:

• CVE-2025-27038: “A use-after-free vulnerability. This vulnerability allows for memory corruption while rendering graphics using Adreno GPU drivers in Chrome.”
• CVE-2025-21480: “An incorrect authorization vulnerability. This vulnerability allows for memory corruption due to unauthorized command execution in GPU micronode while executing specific sequence of commands.”
• CVE-2025-21479: “An incorrect authorization vulnerability. This vulnerability allows for memory corruption due to unauthorized command execution in GPU micronode while executing specific sequence of commands.”

CISA has slapped a 21-day mandatory deadline on federal agency employees to update phones by June 24 “or discontinue use of the product if mitigations are unavailable.” Right now, the window for June’s security updates has been missed, which means absent an out-of-band update that deadline will also be missed.

In the past, we have seen such updates make their way to Pixel faster than Galaxy, with Samsung phones lagging. The company warns patches from chipset vendors “may not be included in the security update package of the month. They will be included in upcoming security update packages as soon as the patches are ready to deliver.”

This plays into the challenge for Samsung in working around an OS and ecosystem it dominates but doesn’t control. In that regard, the more pressing issue for its users will be the speed with which Android 16 via One UI 8 reaches their phones. With a Pixel timeline expected any day now, the gap between the two phones will be critical.

While CISA’s deadline is only mandatory for federal staff, its remit is to operate “for the benefit of the cybersecurity community and network defenders — and to help every organization better manage vulnerabilities and keep pace with threat activity.” As such all users are urged to install these Qualcomm updates as soon as they’re available.

Source:Forbes

Procedural fairness: the duty and its content

14.11  ‘Procedural fairness’ means acting fairly in administrative decision making. It relates to the fairness of the procedure by which a decision is made, and not the fairness in a substantive sense of that decision.^[12] A person may seek judicial review of an administrative decision on the basis that procedural fairness has not been observed.^[13] In Re Refugee Tribunal; Ex parte Aala, the High Court held that the denial of procedural fairness by an officer of the Commonwealth, where the duty to observe it has not been validly limited or extinguished by statute, will result in a decision made in excess of jurisdiction and thus attract the issue of prohibition under s 75(v) of the Constitution.^[14]

14.12  In considering whether there has been a denial of procedural fairness, courts will examine two issues:

• whether a duty to afford procedural fairness exists; and

• if such a duty exists, the content of procedural fairness in the particular case.

Is there a duty?

14.13  In 2015, the High Court succinctly stated that, in ‘the absence of a clear, contrary legislative intention, administrative decision-makers must accord procedural fairness to those affected by their decisions’.^[15]

14.14  The manner in which a person’s interests are affected is relevant to whether a duty to afford procedural fairness exists. There is less likely to be a duty to afford procedural fairness where a decision affects a person as a member of the public or a class, rather than in their individual capacity.^[16] Procedural fairness may not apply where a decision ‘affects so many people that it is really a legislative act; or where the range of public policy considerations that the deciding body can legitimately take into account is very wide’.^[17]

14.15  A duty to afford procedural fairness may be excluded by legislation. This is a matter of statutory construction, the key question being whether legislation, ‘properly construed, limits or extinguishes the obligation to accord natural justice’.^[18] Professors Mark Aronson and Matthew Groves have suggested that courts increasingly construe legislation so as to imply that a duty to afford procedural fairness exists, particularly since the statement by the High Court in Saeed v Minister for Immigration and Citizenship (Saeed) that procedural fairness is protected by the principle of legality.^[19] This has made legislative exclusion ‘very difficult in practice’.^[20]

14.16  Courts have found that a duty to afford procedural fairness may be impliedly excluded where it would be inconsistent with the proper operation of the relevant statutory provisions.^[21]

14.17  Express statutory provisions that set out procedural requirements to be followed in the making of a decision may not establish with the requisite clearness an intention to exclude natural justice.^[22] Groves has observed that the ‘weight of more recent cases suggests that the courts are very reluctant to accept that a legislative code is exhaustive and therefore intended to exclude the implication of further common law hearing rights’.^[23] This may be the case even where the provisions are described as a ‘procedural code’.^[24] In Saeed, the High Court accepted that provisions stating that procedures contained in the Migration Act were ‘exhaustive’ statements of the natural justice hearing rule were effective to exclude the implication of natural justice, but only in relation to the matters to which the provisions referred.^[25]

Content of procedural fairness

14.18  There is no fixed content to the duty to afford procedural fairness. The fairness of the procedure depends on the nature of the matters in issue, and what would be a reasonable opportunity for parties to present their cases in the relevant circumstances. Mason J stated in Kioa v West that ‘the expression “procedural fairness” … conveys the notion of a flexible obligation to adopt fair procedures which are appropriate and adapted to the circumstances of the particular case’.^[26] In Re Minister for Immigration and Multicultural Affairs; Ex parte Lam, Gleeson CJ emphasised that ‘fairness is not an abstract concept’ and that the ‘concern of the law is to avoid practical injustice’.^[27]

14.19  Aronson and Groves have noted that the willingness on the part of the courts to imply a duty to afford procedural fairness, and reluctance to find that it has been excluded by statute, has meant that the crucial question will usually be the content of procedural fairness rather than whether the duty exists.^[28]

14.20  Procedural fairness traditionally involves two requirements: the fair hearing rule and the rule against bias.^[29] The hearing rule requires a decision maker to afford a person an opportunity to be heard before making a decision affecting their interests.^[30] In Kioa v West, Gibbs CJ said that the ‘fundamental rule is that a statutory authority having power to affect the rights of a person is bound to hear him before exercising the power’.^[31] The rule against bias ensures that the decision maker can be objectively considered to be impartial and not to have pre-judged a decision.^[32]

14.21  The content of the rule against bias is flexible, and determined by reference to the standards of the hypothetical observer who is fair minded and informed of the circumstances.^[33]

14.22  The specific content of the hearing rule will vary according to statutory context. However, a fair hearing will generally require the following:

• Prior notice that a decision that may affect a person’s interests will be made.^[34] This has been referred to as a ‘fundamental’ or ‘cardinal’ aspect of procedural fairness.^[35]

• Disclosure of the ‘critical issues’ to be addressed, and of information that is credible, relevant and significant to the issues.^[36]

• A substantive hearing—oral or written—with a reasonable opportunity to present a case.^[37] Whether an oral hearing should be provided will depend on the circumstances. The ‘crucial question is whether the issues can be presented and decided fairly by written submissions alone’.^[38] In some circumstances, there may be a duty to allow a person to be legally represented at a hearing.^[39]

14.23  The balancing of issues to determine what fairness requires in a particular case may have the result that the content of procedural fairness is greatly reduced. This may be the case, for example, where issues related to national security arise. In Leghaei v Director-General of Security, the Federal Court considered the duty to afford procedural fairness in the making of an ‘adverse security assessment’ by the Australian Security Intelligence Organisation (ASIO).^[40]

14.24  Adverse security assessments are relevant to administrative decisions related to visa status.^[41] In Leghaei, the receipt of an adverse security assessment resulted in the cancellation of the plaintiff’s residency visa.^[42]

14.25  The primary judge found that there existed ‘a duty to afford such degree of procedural fairness in the making of an adverse security assessment as the circumstances could bear, consistent with a lack of prejudice to national security’.^[43] However, upon considering the balance to be struck between the public interest in national security and a duty to disclose the critical issues on which an administrative decision is likely to turn, the primary judge held that the content of procedural fairness was ‘reduced, in practical terms, to nothingness’.^[44]

14.26  On the other hand, it may be that, where a decision ‘would have especially serious consequences upon a person affected, the hearing rule would require detailed procedural requirements’.^[45]

• [12]

  Aronson and Groves, above n 1, 399. However, a decision made without evidence, or contrary to evidence, will not generally be considered to have afforded procedural fairness: Bill Lane, ‘The “No Evidence” Rule’ in Matthew Groves and Hoong Phun Lee (eds), Australian Administrative law: Fundamentals, Principles and Doctrines (Cambridge University Press, 2007) 233, 241–2.

• [13]

  Australian Constitution s 75; Judiciary Act 1903 (Cth) s 39B; Administrative Decisions (Judicial Review) Act 1977 (Cth) s 5(1)(a). Judicial review is considered further in Ch 15.

• [14]

  Re Refugee Tribunal; Ex parte Aala (2000) 204 CLR 82, [17], [41] (Gaudron and Gummow JJ, Gleeson CJ agreeing); [132], [151]–[152] (Kirby J); [169]–[171] (Hayne J). Prohibition is a prerogative remedy issued by a court to prevent a tribunal or inferior court, which is acting or threatens to act in excess of its jurisdiction, from proceeding any further: Ray Finkelstein et al, LexisNexis Concise Australian Legal Dictionary (2015). Where there is a decision-making procedure that has been statutorily prescribed, failure to comply with it in making a decision may also amount to jurisdictional error, known as ‘procedural ultra vires’, and the decision will be invalid: SAAP v Minister for Immigration and Multicultural and Indigenous Affairs (2005) 228 CLR 294, [77] (McHugh J); [173] (Kirby J); [204]–[208] (Hayne J).

• [15]

  Minister for Immigration and Border Protection v WZARH [2015] HCA 40 (4 November 2015) [30] (Kiefel, Bell and Keane JJ). Procedural fairness will not be implied in relation to an exercise of legislative power by an administrator—that is, in the making of delegated legislation.

• [16]

  Westlaw AU, The Laws of Australia (at 1 March 2014) 2 Administrative Law, ‘2.5 Judicial Review of Administrative Action: Procedural Fairness’ [2.5.150]. See also Aronson and Groves, above n 1, 428–36.

• [17]

  Smith and Brazier, above n 4, 570.

• [18]

  Aronson and Groves, above n 1, 454.

• [19]

  Ibid 455.

• [20]

  Ibid.

• [21]

  Ibid. See, eg, Plaintiff S10/2011 v Minister for Immigration and Citizenship (2012) 246 CLR 636.

• [22]

  Aronson and Groves, above n 1, 259–60.

• [23]

  Groves, above n 8, 310.

• [24]

  Re Minister for Immigration and Multicultural Affairs; Ex parte Miah (2001) 206 CLR 57, [90]–[95] (Gaudron J); [143] (McHugh J); [178] (Kirby J).

• [25]

  Saeed v Minister for Immigration and Citizenship (2010) 241 CLR 252.

• [26]

  Kioa v West (1985) 159 CLR 550, 585.

• [27]

  Re Minister for Immigration and Multicultural Affairs; Ex parte Lam (2003) 214 CLR 1, [37]. For a more detailed discussion of practical justice, see Ch 8.

• [28]

  Aronson and Groves, above n 1, 491. This echoes the language used by Mason J in Kioa v West, who said that the ‘critical question in most cases is not whether the principles of natural justice apply. It is: what does the duty to act fairly require in the circumstances of the particular case?’: Kioa v West (1985) 159 CLR 550, 585.

• [29]

  Plaintiff S157/2002 v Commonwealth (2003) 211 CLR 476, [25] (Gleeson CJ); Aronson and Groves, above n 1, 398–9.

• [30]

  Aronson and Groves, above n 1, 398–9.

• [31]

  Kioa v West (1985) 159 CLR 550, 563, quoting Mason J in FAI Insurances Ltd v Winneke (1982) 151 CLR 342, 360.

• [32]

  Aronson and Groves, above n 1, 399; Westlaw AU, The Laws of Australia (at 1 March 2014) 2 Administrative Law, ‘2.5 Judicial Review of Administrative Action: Procedural Fairness’ [2.5.20].

• [33]

  Aronson and Groves, above n 1, 609.

• [34]

  Westlaw AU, The Laws of Australia (at 1 March 2014) 2 Administrative Law, ‘2.5 Judicial Review of Administrative Action: Procedural Fairness’ [2.5.460].

• [35]

  Aronson and Groves, above n 1, 517.

• [36]

  Kioa v West (1985) 159 CLR 550, 587 (Mason J); Westlaw AU, The Laws of Australia (at 1 March 2014) 2 Administrative Law, ‘2.5 Judicial Review of Administrative Action: Procedural Fairness’ [2.5.530]; Aronson and Groves, above n 1, 517.

• [37]

  Aronson and Groves, above n 1, 549; Westlaw AU, The Laws of Australia (at 1 March 2014) 2 Administrative Law, ‘2.5 Judicial Review of Administrative Action: Procedural Fairness’ [2.5.630].

• [38]

  Aronson and Groves, above n 1, 564.

• [39]

  Ibid 567.

[40]

Leghaei v Director General of Security [2005] FCA 1576 (10 November 2005). An adverse security assessment is one that is prejudicial to the interests of the person, and contains a recommendation that prescribed administrative action, the implementation of which would be prejudicial to the interests of the person, be taken or not be taken: Australian Security Intelligence Organisation Act 1979 (Cth) s 35.

[41]

The exercise of any power, or the performance of any function, in relation to a person under the Migration Act falls within the definition of ‘prescribed administrative action’: Australian Security Intelligence Organisation Act 1979 (Cth) s 35(1).

[42]

Leghaei v Director-General of Security [2007] FCAFC 37 (23 March 2007) [14]. Additionally, a person who receives an adverse security assessment will not be eligible for a protection visa: Migration Act 1958 (Cth) s 36(1B)

[43]

Leghaei v Director General of Security [2005] FCA 1576 (10 November 2005) [83].

[44]

Ibid [88]. On appeal, the Full Federal Court considered that the balance struck by the primary judge was correct: Leghaei v Director-General of Security [2007] FCAFC 37 (23 March 2007) [51]–[55]. See also Plaintiff M47/2012 v Director General of Security (2012) 251 CLR 1. The situation for a non-citizen affected by an adverse security assessment has been described as a ‘legal black hole’: the person is ‘unable to know the case against them and thus unable to effectively challenge the unknown allegations; enjoying no right at all of merits review; and enjoying only a legal fiction of judicial review’: Ben Saul, ‘“Fair Shake of the Sauce Bottle”’ [2012] Alternative Law Journal 221, 222. A number of submissions addressed questions of procedural fairness in relation to the making of adverse security assessments: Councils for Civil Liberties, Submission 142; Legal Aid NSW, Submission 137; Refugee Council of Australia, Submission 41; Human Rights Law Centre, Submission 39; Gilbert and Tobin Centre of Public Law, Submission 22; UNSW Law Society, Submission 19.

[45]

Aronson and Groves, above n 1, 491, n 2.

Under the publication: Traditional Rights and Freedoms—Encroachments by Commonwealth Laws (ALRC Report 129)