Recovery of costs in SAT proceedings – hourly rates for self-represented parties?

Recovery of costs in SAT proceedings – hourly rates for self-represented parties?

In Godwin v Keet [2025] WASAT 93 (S), the State Administrative Tribunal (SAT) awarded costs for a self-represented party’s loss of time in connection with proceedings in which that party was substantively successful.

In the case, a strata manager was awarded a nominal rate of $25 per hour for the time he spent in connection with representing himself in the proceedings, which amounted to 133.5 hours.

SAT effectively held that it has the power under section 87 of the SAT Act 2004 (WA) to compensate a self-represented party for loss of time suffered in connection with proceedings in its jurisdiction. Whilst the starting position in SAT proceedings is for parties to bear their own costs, this judgment confirms that SAT’s power to award recovery of ‘costs’ is not limited to the traditional notion of legal costs. The basis upon which ‘hourly rates’ for self-represented parties can be identified and substantiated, if ever moving beyond nominal amounts, will be an interesting thing to follow.

This poses a particularly thought-provoking possibility for strata managers who self-represent in SAT proceedings: to what extent can they seek compensation for time spent in connection with SAT proceedings and how can they establish an appropriate rate or amount for that time? On the other side of the coin, parties in SAT proceedings need to be aware that SAT has the power to award costs for loss of time in favour another party, even if they are not legally represented.

Should you need advice or representation in connection with SAT proceedings, do not hesitate to contact the team at Bugden Allen’s Perth office.

This article was first published on 13 February 2026 and was written by Jonathan O’Connor, Senior Associate, in our Perth office.

© Bugden Allen Group Legal Pty Ltd. This is general information only and not legal advice. You should not rely on this information without seeking legal advice tailored to your specific circumstances.