Whether the tenant was entitled to court-appointed counsel in the conciliation stage of a tenancy dispute.
No. Although the tenant had limited means, the appointment of counsel was not necessary in the circumstances of this conciliation procedure.
The court held that legal aid and appointed counsel are cumulative requirements, and appointed counsel is justified only if professional representation is necessary. Here the dispute was not complex, the conciliation authority could provide guidance, the landlord was not represented by a lawyer, and no case-specific factor showed an unequal-arm situation requiring state-funded counsel.