Only two High Court decisions are featured. The first and most important is Redland City Council v Kozik (§23), to which we alluded (but which we did not fully report) in our analysis in the 2024 digest: [2024] LMCLQ 304, pp 304–305. In that case, the High Court granted special leave for argument to be made for the introduction in Australia of the special, strict liability ground of recovery against public authorities previously recognised by the House of Lords in Woolwich v IRC [1993] AC 70 (HL). Commonwealth and Queensland Attorneys-General intervened, but it soon became apparent during trial that the court had no real intention of taking the point and in the end all members of the bench deferred the Woolwich issue to a future case in which it was more likely to prove material. As we note below, it may be some time before such a case reaches the court, since the existing battery of restitutionary causes of action based upon a payer’s impaired consent (such as mistake, in Kozik itself, or failure of basis) will cover virtually all of the circumstances in which a claim for the recovery of unlawful tax is needed in practice; and lower courts will be reluctant to recognise the cause of action when the High Court has signalled that “large questions” are involved. More immediately, Kozik is important for the way in which the court saw off a brazen and puzzling attempt by government to argue that it had given “good consideration” for its unlawful receipt of special rates charges by spending them on public services that the payers of those charges had never requested and which it was under a prior, statutory obligation to provide. The “defence” was something of an enigma from the start and had caused considerable confusion in the Court of Appeal, where it had previously also been rejected. The best understanding of the Council’s argument (based on a line of reasoning in David Securities Pty Ltd v Commonwealth Bank of Australia (1992) 175 CLR 353) is that it was in fact asserting a type of restitutionary counterclaim to the ratepayers’ claims for mistake, or (more likely) a counter-restitutionary set-off for reciprocal benefits that it claimed (but could not in fact prove) to have provided to the ratepayers that were conditional on the latter’s payments. However, although the plurality judgment is in its substance consistent with this understanding of the argument, their