This time the collusion between CX & CAD has actually broken the letter of the law.
Maybe, maybe not. An Operations Dispensation is issued by the company as a temporary exemption against an Operations Manual requirement. True, the company doesn't have the authority to grant a dispensation against the legal requirements of the AFTLS, but in this case the dispensation was granted by the HKCAD, not the company.
The AFTLS is an agreed scheme between the company and the HKCAD to satisfy the requirements of the AN(HK)O regarding fatigue. HKCAD approved the AFTLS, so they obviously believe they have the authority to grant a dispensation against that scheme. The purpose of the judicial review is to decide whether or not they had that authority.