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"I don't agree with it," Mr Sara said.
Proposed changes linked to the Tribunals Powers and Procedures Legislation Bill, still at the second reading stage in Parliament, allow for regulations to be created to require a filing fee for ACC district court appeals.
It is understood the proposed law changes are Ministry of Justice-led, and that introducing any ACC-related fee regulations would require Cabinet approval.
Mr Sara agreed with critical submissions made by Dunedin-based ACC claimant support group Acclaim Otago over the proposed law change, which said it was a "disappointing" development.
"You've got no choice to be part of it."
It was wrong in principle for injured people who often had no ACC-related income and were in tough financial circumstances to be charged a filing fee for appealing against the actions of a powerful corporation with huge resources.
Several reports supported by Acclaim Otago and a previous government review have highlighted the need to overcome barriers to justice for ACC claimants.
But Mr Sara said this proposed change was "a further barrier to justice", and he had not seen any "logical, reasonable argument" in favour of it.
Claimants won at least about 30% of district court appeals, and the possibility of a filing fee raised a further "spectre" of adding further costs to what was already a "horrendously expensive" process for many appellants, he said.
Approached for comment, ACC Minister Iain Lees-Galloway said the provision was an enabling one only and "no fee would be introduced until a decision was made to make regulations prescribing a fee".
If regulations were made, the fee would be about $20-$30, "in line with other civil jurisdictions", he said.
"The decision to introduce the enabling provision was part of a wider civil fees review.
"Currently ACC is inconsistent with other civil jurisdictions who all have a small filing fee.
"Access to justice for ACC claimants must be balanced with considerations of equity and constancy across the court system as a whole."
ACC claimants could still participate in alternative dispute resolution and the independent review process at "no additional cost," Mr Lees-Galloway said.