Forced Administrative Exhaustion Delays Judicial Review

Businesses must exhaust proceedings before the executive-appointed Division before accessing courts (57(6)), with 2-working-day response deadlines (56(2)) and 5-working-day decision targets (58(5)). This creates regulatory uncertainty as compliance disputes are initially adjudicated by a non-independent body using vague standards like "significant public traction" to determine court referral (57(4)). The asymmetrical framework—where government allegations bypass Division jurisdiction (57(2)(c)) while businesses face mandatory administrative proceedings—creates unequal competitive conditions and delays access to impartial judicial review for potentially business-destroying decisions.