Rule 4:69-1. Actions in Superior Court, Law Division Review, hearing and relief heretofore available by prerogative writs and not available under R. 2:2-3 or R. 8:2 shall be afforded by an action in the Law Division, Civil Part, of the Superior Court. The complaint shall bear the designation "In Lieu of Prerogative Writs". Rule 4:69-2. Motion for Summary Judgment If the complaint demands the performance of a ministerial act or duty, the plaintiff may, at any time after the filing of the complaint