"Conceptually, I accept CASA's view that the Ruling may reflect broader policy considerations.
"Nevertheless in my concluded view there was an administrative deficiency due to an absence of a direct relationship between the activity being regulated and the policy said to regulate it.
"This gave rise to ambiguity and uncertainty with the potential to cause detriment to those relying on the accuracy of the regime or, conversely, prevent detriment from occurring."
The Office of the Commonwealth Ombudsman is now proceeding with Phase Two of the investigation, which will investigate the CASA action of serving a seven-day cease notice on APTA in October 2018 and CASA informing Buckley's new employer in August 2019 that his new role was "untenable" due to comments Buckley was making publicly.