These conflicts have generally not reached appellate level. In "Ingot Capital Investments v Macquarie Equity Capital Markets", Justice Bergin of the Supreme Court of New South Wales held that privilege did not apply to proceedings in the Administrative Appeals Tribunal. Justice Bergin's reasoning was that the AAT was not a court and stood outside the adversarial system of justice as an inquisitorial administrative body not bound by the rules of evidence. The AAT itself departed from and strongly criticised "Ingot" in a decision handed down by Justice Downes in his capacity as President of the AAT. In "Farnaby and Military Rehabilitation and Compensation Commission", Justice Downes held that the litigation limb of the privilege applied to AAT proceedings and took the step of directing all future claims for privilege in the AAT to be handled accordingly. The ALRC recommends extending legal professional privilege to non-judicial proceedings. On 29 November 2006, Attorney-General Philip Ruddock asked the ALRC to inquire into legal professional privilege in the context of coercive information-gathering powers held by Commonwealth agencies. A Discussion Paper was released by the ALRC on 26 September 2007, noting the need for a clear and consistent approach to legal professional privilege in Australia and its states and territories. In April 2011, Assistant Treasurer Bill Shorten announced a consultation on extending privilege to accountants providing tax advice, like their American counterparts. While the main perception of professional legal privilege is the client lawyer relationship some Australian States in particular NSW have extended this privilege to 'protected confidences' defined as" "communication made by a person in confidence to another person ... in the course of a relationship in which the confidant was acting in a professional capacity"." The Division in the Evidence Act 1995 (NSW) for 'Professional confidential relationship privilege' and how it is excluded or lost is at Division 1A This is often interpreted as being between a health professional and their patient. It may however, extend to confidential advice from social workers, and accountants.. NSW has also added a 'Sexual assault communications privilege' at Division 1B Therefore, when considering the access and adducing decisions for medical records that may also cover sexual assault records, the first consideration of course will be relevance, and then any NSW court or tribunal may exclude any evidence of either 'Professional confidential relationship privilege' or 'Sexual assault communications privilege' or both. These sections of the Act aimed to provide further restrictions and protections against oppressive discovery that can cause undue harm to a party in court and may dissuade them from seeking medical care or counselling or damage those relationships, see for example, "R v A and B"  for an appeal on an application in a case for access to discovery across 'Professional confidential relationship privilege' and 'Sexual assault communications privilege' and how the exclusions are decided.