It is evident that legal action would not be taken explicitly due to the suspension of the title; rather the lack of due process that was afforded to the company and the financial ramifications (both booked and implied) that ensued. Refer to the requirements of the Minister under 22(6)(b). I would hazard to say that the company would take legal action against the Minister if they felt that he subverted the course of justice.
You will also find that section 22 is in Part 3 of the Petroleum (Onshore) Act 1991 and that you are in fact referring to subsection 5 of section 22.
ocsg statement, page-9
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