With the exception of ground 1, which is directed to the role of Ms McColl in the preparation or making of the Report, each ground raises a basis upon which it is said the Commission made a material error of law in or in relation to its findings supporting one or more of the five "ultimate" findings that Ms Berejiklian had engaged in "serious corrupt conduct".
The principal issues raised by the 13 grounds are as follows:
(i) whether the assistance provided to the Commission by Ms McColl as a consultant in the preparation of the Report, and specifically in relation to findings involving the assessment of the credibility of witnesses, was outside the limits of her authority;
(ii) whether there was any evidentiary material to support the Commission's findings as to whether the applicant had a private interest in, and was influenced by a desire of, maintaining or advancing her close personal relationship with Mr Maguire;
(iii) whether under the general law and under the NSW Ministerial Code (the Code) a non-pecuniary personal relationship was capable of amounting to a "private interest" that could give rise to a conflict of interest and public duty;
(iv) whether the applicant as a Minister owed a legally enforceable positive duty to act only according to what she believed to be in the public interest, as opposed to a negative obligation not to use her position to promote her own pecuniary interest in circumstances of conflict;
(v) whether the applicant's non-disclosure of her personal relationship with Mr Maguire constituted a breach of public trust for the purposes of s 8(1)(c) of the Act;
(vi) whether the Commission exceeded its authority and institutional competence by purporting to make findings about the merits of the ACTA and RCM funding proposals;
(vii) whether s 7 of the Code and cll 10-12 of the Schedule to the Code (the Schedule) applied to and imposed obligations on the applicant whilst she was Premier;
(viii) whether the applicant's exercises of ministerial power in connection with the promising and awarding of funding were constrained by a legal duty to act impartially;
(ix) whether the Commission erred in finding that the applicant had engaged in partial exercises of her official functions within s 8(1)(b) of the Act in the absence of a finding that but for an unacceptable reason the applicant would not have engaged in that conduct;
(x) whether the Commission erred in finding that the applicant had engaged in partial exercises of her official functions without having first engaged in a comparative exercise addressing how she would have treated "relevantly identical" funding requests;
(xi) whether the duty to disclose in s 11(2) of the Act needs to be confined to a "matter" involving some specified subject matter;
