Non Raceday Inquiry – Written Penalty Decision dated 16 July 2025 – Darrell Bryce Hollinshead

Introduction

[1] The Applicant in this matter, the Racing Integrity Board (RIB) filed Information No. A17989 which relates to a Prohibited Substance charge against Licensed Class A Trainer, Mr Darrell Bryce Hollinshead (the “Respondent”). The Respondent is the Trainer of BAK DA ANGEL who finished in first place in Race 6, the KRA Trophy, at the Auckland Thoroughbred Racing Club meeting at Ellerslie on 19 April 2025.

Particulars of the Charge

[2] Dr E Forbes, the RIB Chief Executive authorised the filing of the charge. The charging document, via Information No. A17989 provides that:

On 19 April 2025 at the Auckland Thoroughbred Racing Club meeting at  Ellerslie, Darrell Hollinshead being the registered trainer of the horse, presented BAK DA ANGEL for the purpose of engaging in and did engage in Race 6 being the KRA Trophy, 1400 metre, failing to present the said horse, free of the Prohibited Substance Ketoprofen in breach of Rule 804(2) and liable to the penalty imposed pursuant to Rule 804(7) & 804(1)(i)  of the Rules.

Plea

[3] The Respondent has admitted the charge and accepted the Summary of Facts, which sets out the factual situation that gave rise to the breach and the charge. By agreement, this Penalty Decision has been dealt with ‘on the papers,’ thus negating the need for a formal ‘in person’ hearing.

[4] The Applicant and the Respondent have lodged written penalty submissions, which have been considered, along with other supporting documentary evidence including: (1) the charging documents, (2) NZ Racing Lab Certificate of Analysis dated 9 May 2025, (3) Racing Analytical Services Lab (RASL) Analytic Report dated 16 June 2025, and (4) the Summary of Facts.

Disqualification of BAK DA ANGEL

[5] By way of a separate Decision published on the RIB Website on 1 July 2025, pursuant to Rule 804(1)(i), BAK DA ANGEL was disqualified from the said race. It is to be noted that in circumstances where a Rule provides for the disqualification of a horse if a person commits a breach in respect of such Rule, or any such part, the liability to disqualify the horse, shall not be regarded as a penalty for the person. Thus, the disqualification should in no way, be construed as a penalty.

Decision

[6] After considering the circumstances of the breach and the submissions, the Adjudicative Committee determined that although disqualification/suspension were penalty options, a monetary fine was considered the more appropriate sanction. Accordingly, a fine of $4,500 was imposed. The reasons for this penalty are outlined in the body of this Decision.

The Relevant Rules

[7] Rules 804(1) and 804(2) provides that:

(1) A horse which has been brought to a Racecourse or similar racing facility and which is found by a Tribunal conducting an inquiry to have had administered to it or have had present in its metabolism a Prohibited Substance shall be, in addition to any other penalty which may be imposed, disqualified for any race or trial to which the Third Appendix hereto applies in which it has started on that day.

(2) When a horse which has been brought to a Racecourse or similar racing facility for the purpose of engaging in a Race or trial to which the Third Appendix hereto applies is found by a Tribunal conducting an inquiry to have had administered to it or have had present in its metabolism a Prohibited Substance, as defined in Part A of Prohibited Substance Regulations, the Trainer and any other person who in the opinion of such Tribunal conducting such inquiry was in charge of such horse at any relevant time commits a breach of these Rules.

Penalty Provisions

[8] Rule 804(7) provides that:

A person who commits a breach of sub-Rule (2) or (3) or (4) or (5) or (5A) or (6) of this Rule shall be liable to:

(a) be disqualified for a period not exceeding five years; and/or

(b) be suspended from holding or obtaining a Licence for a period not exceeding 12 months. If a Licence is renewed during a term of suspension, then the suspension shall continue to apply to the renewed Licence; and/or

(c) a fine not exceeding $25,000.

The Summary of Facts

The salient facts are summarised as follows:

­­­­­­­­­­­­­­­[9] The Respondent is the holder of a Class A Trainers Licence issued by New Zealand Thoroughbred Racing [NZTR]. He operates a training facility in Te Awamutu and currently has eight thoroughbreds registered as being in training with NZTR.

[10] BAK DA ANGEL is a 4-year-old brown mare trained by the Respondent at his Te Awamutu facility. The horse is co-owned by multiple owners, including the Respondent, who holds approximately 10% ownership.

[11] On 19 April 2025, BAK DA ANGEL won Race 6, the KRA Trophy 1400, at the Auckland Thoroughbred Racing Club meeting at Ellerslie. The gross stake money for 1st was $23,000. Post race, BAK DA ANGEL was swabbed.

[12] On 9 May 2025, New Zealand Racing Laboratory Services (NZRLS) issued a Certificate of Analysis detailing that the sample obtained from BAK DA ANGEL was positive for the Prohibited Substance – Ketoprofen.

Ketoprofen

[13] Ketoprofen is defined as a Prohibited Substance under the Prohibited Substance Regulations of the NZTR Rules of Racing, falling under category Part A (1.2.21) anti-inflammatory agents, when present above the regulatory limit of 100 micrograms per litre in urine (clause 4.1.3 refers).

[14] Ketoprofen is a non-steroidal anti-inflammatory drug (NSAID) used in veterinary medicine to relieve pain, reduce inflammation, and control fever. It is commonly administered intravenously in horses at a standard dose of 2.2 mg/kg body weight, with a withholding period of 4.2 days as per the New Zealand Equine Veterinary Association (NZVA) guidelines.

[15] Ketoprofen is classed as a therapeutic substance and permitted in raceday samples with a regulatory limit of 100 micrograms per litre in urine. The NZRLS reported that the level in this sample exceeded 200 micrograms per litre, (upper level of calibration) significantly above the regulatory limit.

[16] The presence of Ketoprofen above the regulatory limit of 100 micrograms per litre of urine in a race-day sample is, prima facie, a breach of Rule 804(2) of the NZTR Rules of Racing.

[17] On 10 May 2025, an Investigator from the Racing Integrity Board conducted an interview with the Respondent at his training facility. He denied ever administering Ketoprofen to BAK DA ANGEL, stating he had never heard of the substance until informed of the positive test. He reported using Phenylbutazone (Bute) and Meloxicam sparingly, with the last administration of Bute to BAK DA ANGEL, approximately 12 months prior to the race.

[18] Scene enquiries at the Respondent’s stables failed to identify any products containing Ketoprofen. Medications found on-site included Meloxicam and Bute paste.

[19] Inquiries with the Respondent’s veterinary provider, VE Veterinary Services Ltd, found no evidence indicating that Ketoprofen was prescribed or administered to BAK DA ANGEL.

[20] The Respondent maintains minimal medication use, supported by limited veterinary involvement and no formal treatment records for BAK DA ANGEL in the relevant period.

[21] Inquiries with NZTR Chief Veterinarian, Dr Andrew Grierson, indicate that the detected Ketoprofen concentration could suggest administration 4–8 hours before swabbing, likely via intravenous or intramuscular injection. Oral or topical administration is unlikely to produce such high urinary levels. However, it cannot be ruled out that the dose was double the recommended amount, (as some Veterinarians or Trainers may use higher doses), potentially leading to elevated urinary levels beyond 8 hours. Environmental contamination is considered highly unlikely, due to the significant concentration observed.

[22] The Respondent raised concerns about potential interference by a third party, against whom he has a protection and trespass order. He reported past incidents of theft by his third party approximately three years ago, captured on cameras that have since been removed, but no recent incidents were confirmed. There is no evidence to suggest the third party was responsible for this breach.

[23] The Respondent’s stables are located on a 30-acre property, with racehorses kept in paddocks near the stable area. At the time of the incident and stable visit by the RIB, no security cameras were in place, and medications are stored on an open bench, not in a locked cupboard.

[24] The RIB requested independent testing of the ‘B Sample’ in Victoria, Australia by Racing Analytical Services Ltd (RASL). RASL have confirmed that their analysis of the ‘B Sample’ has shown the presence of Ketoprofen well in-excess of the regulatory limit.

[25] It is the RIB’s position, that the presence of Ketoprofen at such a high concentration, suggests potential deliberate administration, though the source remains unidentified. Negligence on behalf of the Respondent, including inadequate security measures, or failure to maintain proper medication records, may have contributed to the breach.

[26] Throughout the investigation, the Respondent has been cooperative and respectful.

Penalty Submissions (Applicant)

Context

[27] The Respondent has been a Licensed Class A Trainer since 1993 and has no previous breaches of the Prohibited Substance Rule.

[28] The details of the offence are contained in the agreed RIB Summary of Facts.

[29] The Summary of Facts outline in detail, the common use and application of Ketoprofen.

[30] The RIB investigation failed to identify how the Ketoprofen came to be in the horse’s system. Inquiries revealed no evidence of Ketoprofen being prescribed to the Respondent,  or being found at his stables.

[31] Wagering analysis of the race, revealed no irregularities.

Penalty Provisions

[32] The range of penalties which may be imposed, are detailed in the Penalty Provisions set out in paragraph 8 of this Decision.

Sentencing Principles

[33] The RIB referred to the four principles of sentencing summarised as follows:

• Penalties are designed to punish the offender for his / her wrongdoing. They are not meant to be retributive in the sense the punishment is disproportionate to the offence, but the offender must be met with a punishment.
• In a racing context, it is extremely important that a penalty has the effect of deterring others from committing similar offences.
• A penalty should also reflect the disapproval of the RIB for the type of behaviour in question.
• The need to rehabilitate the offender should be considered.

[34] The RIB submits that the first three principles apply in this matter.

Previous/Precedent Cases

[35] The RIB advised that there have been no recent Thoroughbred cases of Ketoprofen positives, however, there have been three relatively historic cases in the Harness Code. These include:

RIB v Yesberg (2021)

[36] Two horses presented to the trials positive to Phenylbutazone, Ketoprofen and Furosemide (one of the two), the Trainer having opted to start the horses at an earlier trial, in the knowledge the WDT may be compromised. The Adjudicative Committee adopted a starting point of $5,000, when concluding a $3,500 fine.

RIU v Negus (2018)

[37] Raceday positive to Ketoprofen, with no obvious source identified. Admitted breach with the JCA adopting the Guideline starting point and considering mitigating factors, concluding a fine of $5,500.

RIU v Townley (March 2018)

[38] Raceday positive to Ketoprofen, with the probable cause being the injection of the drug, in breach of the recommended WDT. The JCA adopted the Guideline starting point and considered aggravating and mitigating factors, in issuing a $7,000 fine.

[39] The RIB also referred to other recent Thoroughbred Prohibited Substance cases involving raceday positives; namely:

RIB v Hocquard (2025)

[40] Positive to Cetirizine, suspected to be caused by environmental contamination following a course of tablets used well inside the WDT. The Adjudicative Committee adopted a starting point of $2,500 and concluded in an $1,800 fine.

RIB v Walker (2023)

[41] Positive to the NSAID Meloxicam, through a staff member incorrectly administering the drug to the wrong horse. The Adjudicative Committee adopted a starting point in line with the Guideline and concluded a $7,000 fine, after allowing for aggravating factors ($2,000) and mitigating factors ($3,000).

RIB v Quinn (2023)

[42] Positive to Prednisolone, a corticosteroid used to treat allergies or immune disorders. No source of the drug identified, and the horse had been in the care of another Trainer in the days leading up to the race. The Adjudicative Committee adopted a $2,500 starting point and after considering mitigating factors, issued a $1,500 fine.

RIB v Miller (2023)

[43] Positive to the NSAID Diclofenac. The source of the positive was identified as the application of Voltaren Emugel to the horse’s legs. The Adjudicative Committee determined a starting point of $3,300 and factored an uplift of $1,200, due to the Trainer’s culpability. In consideration of mitigating factors, the fine was set at $3,500.

RIB v Clement (2023)

[44] Positive to Dexamethasone, a corticosteroid used in horses to treat allergic reactions and inflammatory disease. No obvious source of the positive identified. The Adjudicative Committee adopted a starting point of $2,500 and with no aggravating factors, concluded a $2,000 fine.

Mitigating Factors

The RIB submitted the following mitigating factors:

[45] The Respondent has admitted the charge at the earliest opportunity and has been cooperative and respectful throughout the investigation process.

[46] NZTR statistics indicate that the Respondent has had 1584 career starters, for 112 wins and has maintained an unblemished record, with no prior breaches of the Prohibited Substance Rule (or any other NRI breach) in his 32 years as a Licence Holder.

[47] There is no evidence of an intent to deceive, any recklessness or any deliberate act by the Respondent, that gave rise to this breach.

Aggravating Factors

The RIB submitted the following aggravating factors:

[48] NZTR Chief Veterinarian Dr A Grierson opined the following:

• The detected Ketoprofen concentration could suggest administration 4–8 hours before swabbing, likely via intravenous or intramuscular injection.
• Oral or topical administration is unlikely to produce such high urinary levels; however, it cannot be ruled out that the dose was double the recommended amount potentially leading to elevated urinary levels beyond 8 hours.
• Environmental contamination is considered highly unlikely due to the significant concentration observed.

[49] The RIB submits that the presence of Ketoprofen at such a high concentration, suggests potential deliberate administration, but emphasises that the source remains unidentified. However, the Respondent is culpable of a degree of negligence, due to inadequate security measures and failure to maintain proper medication records.

[50] A horse running, while medicated with anti-inflammatory drugs at the level detected, has serious implications on the integrity of the Racing Industry. Such medications can conceal underlying injuries, thereby elevating the risk of accident and injury to horse and Jockey.

Conclusion

[51] When determining penalty, the RIB submits that the Adjudicative Committee should have regard to the purpose of the proceedings; which include: to ensure the Rules are complied with; to uphold and maintain the high standards expected of Trainers; and to protect the integrity of Thoroughbred Racing.

[52] The RIB submits that the Adjudicative Committee may view the Negus and Clement cases as being of the most guidance, as in those cases, no obvious source of the drug was identified, albeit in Negus, it was established the drug was present at the stables.

[53] The RIB submits that in the cases referred to, given the divergent adopted starting points of $2,500 – $8,000; the mitigating and aggravating factors as listed and the overall circumstances considered in this case, the RIB recommends that a fine of $4,000 is appropriate.

Costs

[54] Because the matter has been determined ‘on the papers’, costs are not sought by the RIB.

Penalty Submissions (Respondent)

The Respondent provided the following response to the Applicant’s (RIB) submissions:

[55] The Respondent apologised for what had occurred. He said that he acknowledged his guilt in taking BAK DA ANGEL to the races with Ketoprofen at a level above the allowable level (that being a mass concentration 100.0 micrograms per litre in her urine sample), of which he was unaware.

[56] He submitted that he has suspicions regarding how it happened, as he previously caught a third-party stealing horse feed in the middle of the night a couple of years ago. This, he said, was captured on borrowed cameras and the perpetrator has since been trespassed from his property by the Police.

[57] He submitted that he would prefer a reduced fine, as significant costs have already been incurred with the security measures that are currently being implemented. Additionally, he said that he will be providing the Owners with a few months of free training, to help resolve the situation.

[58] In concluding his submission, the Respondent said that ultimately, he will accept the fine determined by the Adjudicative Committee. He also wished to extend his gratitude to RIB Investigator Mr Richard Carr, who he said, “in recent times was very good to deal with and certainly helped.”

Decision and Reasons

[59] The Respondent admitted to committing an offence under Rule 804(2). The particulars of the charge are set out in paragraph 2.

[60] As a consequence, BAK DA ANGEL was disqualified from the race in question, as per the Adjudicative Committee’s Written Decision dated 1 July 2025 (refer paragraph 5 of this Decision). The disqualification of BAK DA ANGEL must not be regarded as a penalty, as all horses participating in races must be presented free of Prohibited Substances.

[61] After evaluating the facts and the submissions, the Adjudicative Committee decided that a $4,500 fine was appropriate for this case.

Reasons

[62] NZTR Rules provide for a disqualification, suspension or fine for a breach of this nature (refer paragraph 8). The Penalty Guide recommends a starting point fine of $8,000 for a first offence. This is the Respondent’s first breach of the Rule.

[63] In making its decision, the Adjudicative Committee concluded that a fine was an appropriate penalty, instead of disqualification or suspension of the Respondent’s License. The determinative factors considered by the Adjudicative Committee:

• The Penalty Guide’s starting point fine of $8,000 and the specific nature of the breach.
• The Respondent’s degree of responsibility.
• Relevant precedent cases and penalties to maintain consistency.
• Adjustments made for mitigating and aggravating factors.

Sentencing Principles

[64] In addition, due consideration was given to the applicable sentencing principles highlighted by the RIB in their penalty submission, as well as the well-known and often-quoted paragraphs in the Appeals Tribunal Ruling in RIU v L and in the case of Z v Dental Complaints Committee [2008] NZSC 55, [2009] 1 NZLR 1.

[65] In RIU v L, the Appeals Tribunal at [25] commented:

Proceedings under the Rules of Harness Racing, as is the position in all cases involving professional disciplines, are designed not simply to punish the transgressor, but crucially are to protect the profession/public/industry/and those who are to deal with the profession. Disciplinary sanctions are designed for some important different purposes, and although guidance can be gained from the criminal jurisdiction, there are broader considerations.

[66] In Z v Dental Complaints Committee, it was said that:

It is well established that professional disciplinary proceedings are neither civil nor criminal in nature …. because the purpose of disciplinary proceedings within various occupations is not to punish the practitioner for misbehaviour, although it may have that effect, but to ensure appropriate standards of conduct are maintained in the occupation….

[67] The Adjudicative Committee also factored into its decision making, the sentencing principles that were outlined in the RIU v L  (May 2019), in which it was said by the Adjudicative Committee, that it must endeavour to reach a proportionate balance between the public interest; the interests of the offender; the interests of the professional body as a whole; the seriousness of the offending; and any aggravating and mitigating factors. The Adjudicative Committee believes that it has achieved such a balance in the penalty it has imposed.

The Respondent’s Level of Responsibility / Culpability  

[68] The advice given by NZTR Chief Veterinarian, Dr Grierson, to the RIB Investigator, is compelling.

1. Dr Grierson advised that the detected Ketoprofen concentration could suggest administration 4–8 hours before swabbing, most likely via intravenous or intramuscular injection.
2. He suggested that oral or topical administration is unlikely to produce such high urinary levels. However, he said, it cannot be ruled out that the dose was double the recommended amount, as some veterinarians or trainers may use higher doses, potentially leading to elevated urinary levels beyond 8 hours.
3. He also added that environmental contamination is considered highly unlikely due to the significant concentration observed.

[69] Therefore, based on Dr Grierson’s advice, it is likely that Ketoprofen was administered 4 to 8 hours before the race started at 3:02. However, as indicated by Dr Grierson, he cannot rule out the possibility that the dose administered, was double the recommended amount. Also, although he believes environmental contamination is highly unlikely, it too, cannot be ruled out.

[70] There is no evidence that Ketoprofen was applied, or administered, to BAK DA ANGEL, by the Respondent, or persons from his stable, proximate to it racing. The Respondent raised the suggestion that an unnamed third party had previously been trespassed from his property. Similarly, this was raised by the RIB in the Summary of Facts at paragraph 22, and the RIB advised there is no evidence to suggest the third party was responsible for administering BAK DA ANGEL with Ketoprofen. Also, given the potential 4-to-8-hour timeline, from possible administration to swabbing, it seems unlikely that the third party could have gone unseen or undetected.

[71] So, as it stands, it remains somewhat of a mystery as to how, where, when, why and by whom the substance was applied or administered to BAK DA ANGEL. But by virtue of his admission of the breach and due to this being strict (arguably absolute) liability offence, the Respondent is liable and must be held accountable.

[72] During the RIB investigation, it was discovered that the Respondent had inadequate security measures in place and failed to maintain proper medication records. Certain medications were stored on an open bench, rather than being secured within a locked cupboard. It is the responsibility of Trainers to maintain a treatment logbook, as outlined in Rule 329(1) to (3), which specifies the obligations for maintaining all treatment records.

[73] On a positive note, the Respondent has since advised he is enhancing the security of his property, by installing security cameras.

Precedent Cases

[74] The Adjudicative Committee has noted and considered, the precedent cases submitted by the RIB – refer paragraphs 36 to 44.

[75] It is noteworthy, that according to the RIB, there have been no recent Thoroughbred cases of Ketoprofen positives, and three relatively historic cases in the Harness Code. The RIB also pointed out, that there has been quite a divergence of penalties imposed for like offending. The RIB suggested that the Negus and Clement cases provide the most guidance in assessing penalty, as in those cases, like this matter, no obvious means of applying or administering the drug was readily identified, albeit in Negus, it was established the drug was present at the stables. Given that the Penalty Guides for both Codes provide the same $8,000 penalty starting point, the Negus and Clement Penalty Decisions provide some assistance.

[76] There is a need for consistency with regards to like offending in comparable cases. This very point was reinforced in the Appeals Tribunal Decision M Anderson v RIB, published 18 May 2023. In that Decision, it was said by the Tribunal (at paragraph 29) …References and comparisons to other penalties which are imposed within the racing jurisdiction are common in order to achieve consistency in sentences which may be imposed.

[77] A common thread in each of the cases submitted, is that there was no intent to deceive involved, in the use of the Prohibited Substances. Similarly, intent to deceive, is not a factor in this case.

Aggravating and Mitigating Factors

[78] At paragraphs 45 to 50, the RIB outlined aggravating and mitigating factors for the consideration of the Adjudicative Committee. Similarly, the Respondent at paragraphs 55 to 58, has highlighted mitigating factors. These have been noted and considered. In addition, the Adjudicative Committee emphasises the following factors:

• Irrespective of how the Ketoprofen was applied or administered, the Respondent is responsible and accountable.
• Ketoprofen, at a level less than 100 micrograms per litre in urine, is a recognised therapeutic substance, as per paragraph 4.1.3 of the Prohibited Substance Regulations.
• The Respondent has fully cooperated with the investigation, he has accepted responsibility and has apologised for the lapse, albeit it remains unclear as where, when, and how the substance was applied or administered.
• The Respondent has an unblemished record for a breach of this nature, since being licensed in 1993.
• This is not a case where the substance, Ketoprofen, was applied with intent to enhance the performance of BAK DA ANGEL.
• The Respondent has taken pro-active steps to enhance security, and will no doubt ensure that he maintains a Treatment Logbook, as required by the Rules.

[79] As previously mentioned in this Decision, there is no suggestion whatsoever, that the substance was administered with any intent to deceive, or to improve the horse’s raceday performance. But it is a factor, that BAK DA ANGEL won the race and must be viewed more seriously than a non-raceday, Trials, detection. That in itself therefore, must be treated as an aggravated factor.

Starting Point Penalty

[80] In relation to fixing a starting point, the Adjudicative Committee takes some guidance from the Decision of the Appeals Tribunal, R DUNN, and J DUNN v RIU, dated 1 June 2018 (albeit a Harness related matter). This was an Appeal against the quantum of fine imposed. Although this case differs from this matter in several ways, some principles from the Appeals Tribunal remain useful for determining the penalty. In DUNN and DUNN, from a Harness Penalty Guide starting point of $8,000 (the same as Thoroughbred), the Appeals Tribunal adopted a $6,000 starting point and applied a third discount. Furthermore, the Tribunal in its Decision determined that “In considering an appropriate allowance for mitigation the Tribunal considers that there might properly have been greater recognition of the position arrived at by the RIU and the Dunns’ advisors, Dr Molloy, and Mr Dale. The extent to which the Appellants cooperated with RIU and the extent to which the RIU endeavoured to follow up the Appellants’ concerns is a situation for which both parties should receive recognition. That level of cooperation is seen all too infrequently within harness racing and the other two codes over which the JCA has authority. An appropriate figure to measure mitigation in the circumstances outlined would have been 40 per cent”. 

[81] Therefore, after considering what has been described as a divergence of penalties having been imposed for comparable cases and considering the particular circumstances of this case, a $5,500 starting point is adopted. This reflects the aggravating factors, including the fact that BAK DA ANGEL won the race. From that starting point, a $1,000 deduction is applied for the Respondent’s good record; his speedy admission and cooperation; and the steps he has now taken to strengthen security at his property.

[82] It is noted that the Respondent has offered to train the horse for a period free of charge. This will undoubtedly be a financial burden for the Respondent. However, it also reflects the consequences for all parties involved, particularly the connections of BAK DA ANGEL, due to its disqualification and the loss of stake money.

[83] Overall, mitigating factors outweigh the aggravating factors, and in recognition of this, the Adjudicative Committee imposes a fine of $4,500. The Adjudicative Committee is satisfied that the fine it has imposed, is reasonable and proportionate. It does not unduly penalise the Respondent, but it is sufficient to ensure he is held to account, it is a deterrent and ensures that the integrity of racing is maintained.

Conclusion

[84] In the final result, Class A Trainer Mr Darrell Hollinshead, is fined $4,500.

Costs

[85] Because the matter has been determined ‘on the papers’, no costs are sought by, or on behalf of, the RIB or the Adjudicative Committee.