Neil Paterson alleges he and Shane Patton were victims of an ‘unlawful’ conspiracy

Ousted deputy commissioner Neil Paterson has filed an explosive complaint, accusing Premier Jacinta Allan and Police Minister Anthony Carbines of “corruption and misconduct in public office”.

Premier Jacinta Allan and Police Minister Anthony Carbines have been accused of “corruption and misconduct in public office” over the axing of the state’s two top cops.

Ousted deputy commissioner Neil Paterson has filed an explosive complaint to the Independent Broad-based Anti-corruption Commission, alleging he and dumped chief commissioner Shane Patton were victims of an “unlawful” conspiracy.

In the complaint to IBAC and the State Ombudsman, Mr Paterson calls for an investigation into whether the Allan government approached Rick Nugent to take over the police chief commissioner role before moving to ditch Mr Patton.

When the Herald Sun revealed last month that Mr Patton would be axed, Ms Allan insisted the government had been forced to take the drastic action as a result of an “unprecedented” vote of no confidence in him by police members.

Neil Paterson's complaint accuses Premier Jacinta Allan of ‘corruption and misconduct in public office’. Picture: David Geraghty

But Mr Paterson alleges in his complaint that Mr Nugent had been approached by the government “week/s before” the vote of no confidence.

The central allegation in his complaint to IBAC is that Ms Allan, Mr Carbines, Department of Premier and Cabinet secretary Jeremi Moule and Mr Nugent “conspired’’ to get rid of Mr Patton and Mr Paterson because the pair had given “frank and fearless’’ advice to government in a bid to “protect” the community.

“The actions by government of not renewing my appointment are clearly infected by retribution,” Mr Paterson says in the complaint, which has been seen by Herald Sun.

“I believe the actions of the Premier Jacinta Allan, the Minister for Police Anthony Carbines, the secretary DPC (Department of Premier and Cabinet) Jeremi Moule and Rick Nugent amount to a significant breach of public trust and indeed amount to corruption and misconduct in public office.”

Mr Paterson filed an explosive complaint to the Independent Broad-based Anti-corruption Commission. Picture: Ian Currie

The complaint was lodged on Friday, with Mr Paterson asking IBAC to review emails and phone calls ­between Mr Nugent and government officials.

“I hold the view that the Premier and Minister for Police had already commenced discussions with Rick Nugent early in the week commencing Monday, 10 February 2025, about imminently returning to Victoria Police as Acting Chief Commissioner, with a view to installing him as the next Chief Commissioner,’’ Mr Paterson states.

“I also hold the firm view that in those discussions Rick Nugent agreed that he would return, but on the condition that I was not one of his Deputy Commissioners.’’

Mr Carbines allegedly told Mr Patton in the week leading up to the no-confidence vote that his deputy Mr Paterson would not be reappointed.

Police Minister Anthony Carbines allegedly told Mr Patton that Mr Paterson would not be reappointed. Picture: David Geraghty

When Mr Carbines is claimed to have delivered the shock news, Mr Patton pushed back, postponing discussions on the issue until their next scheduled meeting.

But Mr Patton was axed before that meeting could take place, and later ­divulged the alleged conversation to Mr Paterson.

When dumping Mr Patton, Ms Allan repeatedly cited the vote of no confidence by 12,000 police members as pivotal, saying the poll was “overwhelming” and could not be ignored.

The decision came less than 10 days after government sources had told the Herald Sun that Mr Patton’s contract was set to be renewed.

Mr Paterson has also told the Herald Sun that Mr ­Nugent blamed Mr Carbines for the decision not to ­reappoint him to a second five-year term.

Shane Patton was dumped as Chief Commissioner days after government sources said his contract would be renewed. Picture: Nadir Kinani

“There has never been another example of a deputy commissioner who has sought reappointment, not being reappointed,’’ Mr Paterson says in his complaint.

“By his own admission, Rick Nugent apparently took no steps to advocate for my reappointment, despite there being no reason under the VP (Victoria Police) Act to dismiss me.’’

Mr Paterson states that under the Act, a police minister cannot give a direction to the chief commissioner on “decisions about individual members or personnel’’.

“Rick Nugent appears to have devolved this power of the chief commissioner to the government, which he cannot do and would open the government up to the claim of gross interference and politicisation of police function,’’ Mr Paterson states.

“The alternative is that the decision not to reappoint me was made by Rick himself and has apportioned blame on someone else (the Minister of Police).”

Victoria Police Acting Chief Commissioner Rick Nugent allegedly took no steps to advocate for Mr Paterson’s reappointment. Picture: AAP

Referencing the alleged dealings between Mr Carbines and Mr Nugent on his future prior to the vote of no confidence, Mr Paterson asks in his complaint: “If it is the case that Rick has made this decision regarding my reappointment, how is it that he was able to do so a week before he claims to have been approached for the Acting Chief Commissioner’s role?”

Mr Paterson further details how he believes he and Mr Patton were targeted by the government because they railed against its soft stance on several law-and-order issues such as the decriminalisation of public drunkenness, the ­increased minimum age of criminal responsibility, a lack of weapons control, bail laws and pill testing.

“On many occasions, despite providing strong frank and fearless advice, the minister and government have chosen to ignore this, resulting in significant harm to persons, society and the community,’’ Mr Paterson states.

“When chief commissioner Patton, for example, spoke with then premier Daniel Andrews about the changes his government were proposing to the Bail Act, Shane outlined to Andrews that it would directly lead to an increase in crime and recidivist offending.

“This opinion was noted and the possible outcome accepted by Andrews, however the government progressed with its intended changes to the Bail Act.

“As predicted by Victoria Police, these changes have ­directly resulted in the significant rise in crime and criminality that the community is currently experiencing.

“The reasons behind the ­decision not to renew the appointment of chief commissioner Patton is conveniently hidden behind the veil of the no-confidence vote,’’ Mr Paterson adds.

“The reasons behind the ­decision not to renew my ­appointment are completely hidden from myself and the public.”

Mr Paterson said Mr Patton was intending to reappoint him for a further five years as his deputy.

“The actions of Minister for Police Anthony Carbines are unlawful, amount to political overreach and are a breach of the Victoria Act,’’ he states.

“Lastly, the way Rick ­Nugent has been appointed by the government is frankly dishonest and completely disingenuous. The timeline as suggested by Rick, the Minister for Police and the government simply does not make sense.”

Mr Paterson says he and Mr Patton railed against the government’s soft stance on several law-and-order issues. Picture: Ian Currie

Mr Paterson further says in the IBAC complaint that he believes the Police Association of Victoria was “intimately ­involved in this collusion’’.

“It is my opinion that Rick Nugent was approached by the government in the week/s before the TPAV no-confidence vote, that he requested my dismissal and that the government used the no-confidence vote in Shane Patton to bring about a change in the chief commissioner,’’ Mr ­Paterson states.

“The government regularly and dishonestly vocalised support for Shane Patton and his reappointment, knowing that they were planning to remove him, thus lying to the Victorian public.”

Ms Allan on Wednesday took aim at Mr Paterson, accusing him of politicising the state’s integrity agencies.

“I want to be really clear — these allegations are baseless. Completely untrue,” she said on Wednesday.

“It is really disappointing that there are some people who are choosing to politicise IBAC, politicise an integrity agency, by making these absolutely baseless allegations.

“My focus is on the hard work, and supporting the hard work, of the men and women across Victoria Police.”

Ms Allan refused to answer repeated questions about both Mr Paterson’s dismissal and complaint to IBAC.

Instead, she opted to stick to her talking points that the allegations are both “baseless” and “disappointing”.

“I’m not going to go to baseless allegations that have been made by some people,” she said.

Moments after her press conference ended, Ms Allan issued a written statement.

“The allegations made in media reports today are completely untrue,” she wrote.

“I am disappointed that people are seeking to politicise IBAC and the important work they do by making these baseless allegations.

“My focus is always on supporting the hard working men and women of Victoria Police, and passing our tough new bail laws this week.”

Asked about his complaint to IBAC, Mr Paterson said on Tuesday: “Now that I have reported this to IBAC I fully expect they will undertake this investigation and I will not make any further comment, and ­respect the agency to do its job.’’

Acting Chief Commissioner Rick Nugent issued a statement on Wednesday denying Mr Paterson’s allegations.

“The allegations in today’s Herald Sun are completely untrue,” he said.

“There was absolutely no discussion between myself and government about me stepping into the Acting Chief Commissioner role prior to the weekend of 15-16 February.

“This was after the vote of no confidence result on 14 February.

“There was no condition Deputy Commissioner Paterson be removed for me to return to Victoria Police.

“I look forward to assisting IBAC and the Ombudsman to resolve this matter.”

Originally published as Neil Paterson alleges he and Shane Patton were victims of an ‘unlawful’ conspiracy