Key legal question
Whether reimbursement claims under § 44(1) of the Welfare Act must be pursued exclusively by action proceedings.
Extracted holding
No. Where subsequent administrative judicial review exists, administrative authorities may generally issue binding decisions even in proprietary public-law matters, including welfare reimbursement claims.
Extracted reasoning
After the development of subsequent administrative jurisdiction and the abolition of the former special civil action route, there is no reason to treat reimbursement claims differently. A decision procedure is permissible unless a special rule or the nature of the matter requires an action procedure exclusively.