The Orange Grove affair was a political scandal in Australia concerning the dealings of the New South Wales state Australian Labor Party government with multinational corporation The Westfield Group. It resulted from a court decision in 2004 to force the closure of the Orange Grove shopping centre after a zoning dispute, with the loss of approximately 200 jobs. Westfield, which owned a nearby shopping centre, had challenged the legitimacy of the Orange Grove centre, which was operating on land not zoned for this purpose. When the courts ruled in Westfield's favour, Liverpool City Council sought State Government approval for a retrospective rezoning, to validate its earlier decision to approve the shopping centre. The State Government declined to intervene, despite a planning report suggesting that course of action, and the retail component of the Orange Grove centre was forced to close. The bulky goods component of the centre remained open, as the centre was legally zoned for bulky goods sales. However, the State Opposition subsequently unearthed information about a meeting between Premier Bob Carr's chief of staff and a prominent Westfield employee, sparking allegations that interference from Westfield had played a role in the government's decision not to intervene. As a result, a parliamentary inquiry was commissioned, and the Independent Commission Against Corruption announced an investigation. The investigation concluded in 2005, with no findings of corruption against any person. However, the Commission recommended that the NSW Government strengthen guidelines for public servants dealing with corruption allegations by lobbyists. Background In March 2002, Frank Mosca, an architect working on behalf of Sydney businessman Nabil Gazal, applied to change an existing development consent for a property in a light industrial area on Orange Grove Road in the Sydney suburb of Warwick Farm, just north of central Liverpool to change the permitted use of the site from "bulky goods/ warehousing" to "warehouse clearance outlet". This was intended to permit the building of an "outlet mall", mainly consisting of retailing, although described as "factory outlets", even though the area was zoned under its Local Environment Plan (LEP) for industrial uses, in which retailing was generally forbidden, except for a limited range of "bulky goods" or goods produced on the premises. The zoning was consistent with a long-standing policy of discouraging retailing away from established centres with good transport connections, currently embodied as a draft State Environmental Planning Policy: Integration of Land Use and Transport (SEPP