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    <description>A purposive construction of Section 3(2)(d) of the Protection of Human Rights Act, 1993 was applied to hold that the required knowledge or practical experience must relate to the protection and promotion of human rights; a former police officer was treated as outside that category because police service is directed to investigation and enforcement, not human rights adjudication, and public confidence concerns were relevant. The recommendation challenge based on consultation under Section 4 also failed: the statutory Committee&#039;s recommendation did not require consultation with the Commission&#039;s Chairperson, non-participation of one member after notice did not invalidate the process, and no binding convention of mandatory consultation was found, though such consultation was described as desirable.</description>
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