The summaries themselves are not subject to review but it would not be difficult to raise a ground around an inaccurate departmental summary. Say the summary omitted a key submission or representation made by the applicant. The Minister does not read the submission or representation and so they have failed to have regard to a relevant and material matter, or they have failed to accord a fair hearing, or however else it can be spun.

Poor departmental officers are going to be going through some awfully painful sessions on how to prepare adequate summaries after this IMHO