When an agency does not act on the NSW Ombudsman's findings, the Ombudsman's last resort is section 27 of the Ombudsman Act: a report to Parliament, to which the Minister must respond within 12 sitting days.
A search of all 25 annual reports from 2000-01 to 2024-25 found one. In May 2022 the Office reported that it was "not satisfied that sufficient steps had been taken" after its report on strip searches of children at Frank Baxter Youth Justice Centre. The Minister responded in Parliament on 11 August 2022, "noting that the government rejects the recommendations made in our report".
The second came in March 2026: "'The progress of NSW's inmate discipline system reform' report has been published under section 27 of the Ombudsman Act 1974". Asked about it by a parliamentary committee in May 2026, the Ombudsman said: "Ultimately the only sanction that the NSW Ombudsman has under the legislation is to publish a section 27 report, which is what we did".
Both reports were made by the current Ombudsman, Paul Miller, and both concern people held in custody. Whether two reports in four years marks a change in practice will be clearer when the Minister's response to the 2026 report is known.
Sources: Annual Report 2021-22 pp 38, 50; NSW Ombudsman media release, 2 March 2026; transcript of 8 May 2026, pp 32-35; Ombudsman Act 1974 s 27.