SUPREME COURT OF QUEENSLAND

Similar documents
SUPREME COURT OF QUEENSLAND

SUPREME COURT OF QUEENSLAND

FEDERAL COURT OF AUSTRALIA

SUPREME COURT OF QUEENSLAND

HIGH COURT OF AUSTRALIA

Professional Indemnity Insurance - Claims made and notified policies - Sections 54 and 40(3) of the Insurance Contracts Act 1984 (Cth)

SUPREME COURT OF QUEENSLAND

SUPREME COURT OF QUEENSLAND

SUPREME COURT OF QUEENSLAND

FEDERAL COURT OF AUSTRALIA

Professional Standards Scheme Briefing paper for lawyers August 2017

SUPREME COURT OF QUEENSLAND

THE CPA AUSTRALIA LTD PROFESSIONAL STANDARDS (ACCOUNTANTS) SCHEME

HIGH COURT OF AUSTRALIA

THE YEAR THAT WAS. Important High Court Insurance Cases In 2010

FEDERAL COURT OF AUSTRALIA

SUPREME COURT OF QUEENSLAND

VENTURE CAPITAL LIMITED PARTNERSHIPS

SUPREME COURT OF QUEENSLAND

UPDATE LITIGATION DECEMBER 2012 HUNT & HUNT LAWYERS V MITCHELL MORGAN NOMINEES PTY LTD & ORS

C.J. PARKER CONSTRUCTION LIMITED (IN LIQUIDATION) Appellant. Winkelmann, Brewer and Toogood JJ

Determination. 17 December 2014

Case Note. Michele Muscillo * The Lesser of Two Evils: FAI General Insurance Co Ltd v Australian Hospital Care Pty Ltd

IN THE SUPREME COURT OF NEW ZEALAND SC 78/2014 [2014] NZSC 197. Appellant. Elias CJ, McGrath, William Young, Glazebrook and Arnold JJ

SUPREME COURT OF QUEENSLAND

SUPREME COURT OF QUEENSLAND

SALVAGE THROUGH LITIGATION IN INSOLVENCY: CONSIDERING THIRD-PARTY FUNDING VANNIN CAPITAL

Tax Time Monthly NOVEMBER 2017 INCOME TAX SUPERANNUATION STATE TAXES

LAND COURT OF QUEENSLAND

The Commissioner of Taxation of the Commonwealth of Australia v Thomas [2018] HCA 31 August 2018, Judicial Review & Administrative, Tax

An Analysis of the Concepts of 'Present Entitlement'

SUPREME COURT OF QUEENSLAND

VICTORIAN CIVIL AND ADMINISTRATIVE TRIBUNAL CIVIL DIVISION DOMESTIC BUILDING LIST VCAT Reference: D202/2004. Noreen Cosgriff.

SUPREME COURT OF QUEENSLAND

SUPREME COURT OF QUEENSLAND

SUPREME COURT OF QUEENSLAND

IN THE COURT OF APPEAL OF NEW ZEALAND CA112/06 [2007] NZCA 479. Appellant. Hammond, Chambers and Arnold JJ. Judgment: 1 November 2007 at 11.

OUTLINE OF WGG s SUBMISSIONS ON COSTS

SUPREME COURT OF VICTORIA COURT OF APPEAL

SUPREME COURT OF QUEENSLAND

FEDERAL COURT OF AUSTRALIA

SUPREME COURT OF QUEENSLAND

FEDERAL COURT OF AUSTRALIA

SUPREME COURT OF QUEENSLAND

SUPREME COURT OF QUEENSLAND

Case Note September 2007

Stamp Duty on Transfers of Land

30 DAY CREDIT ACCOUNT APPLICATION PLEASE COMPLETE ALL INFORMATION Customer details:

THE SUPREME COURT OF APPEAL OF SOUTH AFRICA JUDGMENT DAVID WALLACE ZIETSMAN MULTICHOICE AFRICA (PTY) SECOND RESPONDENT

CASE NO: 554/90 AND A B BRICKWORKS (PTY) LTD VAN COLLER, AJA :

IN THE MATTER OF WILLMOTT FORESTS LIMITED (RECEIVERS AND MANAGERS APPOINTED) (IN LIQUIDATION) (ACN )

SUPREME COURT OF QUEENSLAND

CONTENTS. Vol 30 No 3 April In summary

Conveyancing and property

SUPREME COURT OF QUEENSLAND

Max Factor and Co. v. F.C. of T. Max Factor and Co. v. Federal Commissioner of Taxation. [4060]

Tax Brief. 7 June GST-Free Supplies of Services to Non Residents Court Supports Commissioner s Draft Ruling. The Facts

APPORTIONMENT OF LIABILITY BETWEEN INSURERS AND CONTRACTORS

9 March Geoffrey Hancy. Barrister Mezzanine Level, 28 The Esplanade, Perth

FEDERAL COURT OF AUSTRALIA

AG2013/12223 APPLICATION FOR APPROVAL OF THE PEABODY ENERGY AUSTRALIA MOORVALE ENTERPRISE AGREEMENT 2013

Facton Ltd (formerly known as G-Star Raw Denim KFT) v Seo [2011] FCA 344 (Gordon J, 12 April 2011)

SUPREME COURT OF QUEENSLAND

IN THE SUPREME COURT OF NEW ZEALAND SC 57/2016 [2016] NZSC 107. DAVID CHARLES BROWNE First Applicant

THIRD PARTY CLAIMS ON INSURANCE FUNDS: THE CHARGE IS OVER. Ivan Griscti Level 22 Chambers 22/52 Martin Place

SUPREME COURT OF QUEENSLAND

SUBMISSION TO THE AUSTRALIAN TAX OFFICE DRAFT SUPERANNUATION GUARANTEE RULING SGR 2008/D2

BERLINWASSER INTERNATIONAL AG MAURITIUS v BENYDIN L.R IN THE SUPREME COURT OF MAURITIUS. Berlinwasser International AG Mauritius

I TE KŌTI PĪRA O AOTEAROA CA35/2018 [2018] NZCA 240. OMV NEW ZEALAND LIMITED Appellant

Land Rich Duty 1. Peter Allen and Katrina Parkyn, Allens Arthur Robinson

TRIBUNAL D APPEL EN MATIÈRE DE PERMIS

Seymour Whyte Limited. Scheme Participants. Scheme of Arrangement. Corrs Chambers Westgarth

SUPREME COURT OF QUEENSLAND

In The Supreme Court of Belize A.D., 2010

- and THE COMMISSIONERS FOR HER MAJESTY S. David Southern QC and Denis Edwards, counsel, instructed by BDO LLP, for the

I TE KŌTI PĪRA O AOTEAROA CA416/2017 [2018] NZCA 239

THE HUMAN RIGHTS REVIEW TRIBUNAL & ORS Respondents

INDUSTRIAL COURT OF QUEENSLAND

SUPREME COURT OF VICTORIA COURT OF APPEAL

Bond University Julie Cassidy Deakin University

ACE INSURANCE LIMITED ABN and CHUBB INSURANCE COMPANY OF AUSTRALIA LIMITED ABN

SUPREME COURT OF QUEENSLAND

Superannuation Case Law Update

Construction Projects and the Apportionment of Liability

Charities Alert. The Hunger Project the most significant case ever on what is a PBI? September The Facts. Introduction.

SUPREME COURT OF QUEENSLAND

SUPREME COURT OF QUEENSLAND

SUPREME COURT OF QUEENSLAND

SOCIAL SECURITY TRIBUNAL DECISION Appeal Division

Constitutional issues raised by South Australia s proposed major bank levy

IN THE EMPLOYMENT COURT AUCKLAND [2018] NZEmpC 33 ARC 98/13 ARC 22/14. LSG SKY CHEFS NEW ZEALAND LIMITED First Defendant

Before : MR JUSTICE FANCOURT Between :

CONSTITUTION COMMONWEALTH BANK OF AUSTRALIA

International Commercial Arbitration in Australia

Cover sheet for: TD 2012/21

SUPREME COURT OF QUEENSLAND

S6 of the Law Reform (Miscellaneous Provisions) Act Its wings are clipped.

IN THE COURT OF APPEAL [1] HONOURABLE ATTORNEY-GENERAL [2] THE HONOURABLE EDZEL THOMAS [3] MINISTER OF LABOUR

Case Name: Taggart v. Canada Life Assurance Co.

IN THE COURT OF APPEAL OF NEW ZEALAND CA253/04

Transcription:

SUPREME COURT OF QUEENSLAND CITATION: RJK Enterprises P/L v Webb & Anor [2006] QSC 101 PARTIES: FILE NO: 2727 of 2006 DIVISION: PROCEEDING: ORIGINATING COURT: RJK ENTERPRISES PTY LTD ACN 055 443 466 (applicant) v GARY JAMES WEBB (first respondent) and LYNN AIGA WEBB (second respondent) Trial Division Application DELIVERED ON: 5 May 2006 DELIVERED AT: Supreme Court at Brisbane Supreme Court at Brisbane HEARING DATE: 27 April 2006 JUDGE: ORDER: CATCHWORDS: Douglas J Application dismissed Further submissions as to costs invited EQUITY TRUSTS AND TRUSTEES POWERS, DUTIES, RIGHTS AND LIABILITIES OF TRUSTEES INDEMNITY, LIEN AND REIMBURSEMENT GENERAL PRINCIPLES where respondents are directors of a company which acted as trustee for a family trust where trustee company purchased a business where judgment made in the District Court against trustee company as a result of a default under agreement to purchase business where that judgment has not been satisfied where trustee company has been placed into liquidation by a previous application whether s 197 of the Corporations Act 2001 (Cth) as it then was applies whether directors of trustee company are personally liable for a debt incurred when there are insufficient trust assets to indemnify the trustee company Corporations Act 2001 (Cth), s 197 Trustee Act 1898 (Tas), s 27(2) Trustee Act 1925 (NSW), s 59(4)

2 COUNSEL: SOLICITORS: Trustee Act 1936 (SA), s 35(2) Trustee Act 1958 (Vic), s 36(2) Trustees Act 1962 (WA), s 71 Trusts Act 1973 (Qld), s 72 Allina Pty Ltd v Federal Commissioner of Taxation (1991) 99 ALR 295, cited Australian Securities Commission v Marlborough Gold Mines Ltd (1993) 177 CLR 485, cited Edwards v Attorney General (NSW) (2004) 208 ALR 605, cited Hanel v O Neill (2003) 48 ACSR 378, distinguished Intagro Projects Pty Ltd v Australia and New Zealand Banking Group Ltd (2004) 50 ACSR 224, cited Jones v Dunkel (1959) 101 CLR 298, cited Kemtron Industries Pty Ltd v Commissioner of Stamp Duties [1984] 1 Qd R 576, cited Saffron Sun Pty Ltd v Perma-Fit Finance Pty Ltd (in Liq) [2005] NSWSC 1317, cited Sit Simplex Stulte Pty Ltd (in liq) v Carter [2003] QSC 99, cited Young v Murphy [1996] 1 VR 279, cited D A Quayle for the applicant Charles C Wilson for the respondents MacGillivrays Solicitors for the applicant Attwood Marshall Lawyers for the respondents [1] Douglas J: This is an application for an order that the respondents pay the applicant the sum of $138,540.22 pursuant to s. 197 of the Corporations Act 2001 (Cth) as that section was before 18 November 2005. [2] The second respondent was a director of a company called LJAW Enterprises Pty Ltd which was the trustee for the Aiga-Webb Family Trust when it incurred a liability to pay the applicant, RJK Enterprises Pty Ltd, the sum of $105,000 provided by RJK as vendor finance for the completion of a purchase of a newsagency by LJAW from RJK. [3] LJAW did not repay that sum when repayment was due. It was sued by RJK which obtained judgment against it on 17 November 2005 for $138,540.22. That judgment has not been satisfied and on 26 April 2006 LJAW was placed into liquidation on the application of RJK. At the time of the judgment both the first respondent and the second respondent were directors of LJAW. [4] Section 197 provided at the relevant times: 197 Directors liable for debts and other obligations incurred by corporation as trustee (1) A person who is a director of a corporation when it incurs a liability while acting, or purporting to act, as trustee, is liable to discharge the whole or a part of the liability if the corporation:

3 (a) and has not, and cannot, discharge the liability or that part of it; (b) is not entitled to be fully indemnified against the liability out of trust assets. This is so even if the trust does not have enough assets to indemnify the trustee. The person is liable both individually and jointly with the corporation and anyone else who is liable under this subsection. (emphasis added) [5] It was a replacement for an earlier section of the Corporations Law, s. 233, which was itself based on s. 229A of the earlier Companies (Qld) Code. Those sections had been construed to apply to give a remedy against directors of a trustee company where an indemnity in their favour was not available against trust assets, but not simply because the trust had no assets or insufficient assets to afford the relevant indemnity. It had to be on some other ground that the indemnity was not available; see Young v Murphy [1996] 1 V.R. 279, 313. The natural reading of s. 197 and its legislative history do not suggest that parliament intended that there should be any change in the policy behind the section when it was compared to its predecessors. [6] The Full Court of the South Australian Supreme Court decided, however, in Hanel v O Neill (2003) 48 ACSR 378, by Mullighan J, that if there were no assets comprised in the trust fund, there was no entitlement to be indemnified, 1 and, in the case of Gray J that, properly construed, s. 197(1) had the result that a director of a corporate trustee was personally liable where a debt was incurred and there were insufficient trust assets to meet the debt. 2 Debelle J dissented on this issue. [7] The proposition of Mullighan J that if there are no assets comprising the trust fund, there is no entitlement to be indemnified is, in my view, plainly wrong. An entitlement normally refers to a legal right but not the value of that right. Mr Charles Wilson for the respondent submitted that the absence of a right of indemnity under s. 197(1)(b) may arise potentially in Queensland only as a result of a liability that was incurred by the trustee in breach of trust or beyond the powers given by the trust instrument. The statutory right of indemnity provided by s. 72 of the Trusts Act 1973 (Qld) cannot be overridden by contrary intention in the trust instrument denying or limiting the right of indemnity; see s. 65 and Kemtron Industries Pty Ltd v Commissioner of Stamp Duties [1984] 1 Qd R 576, 584-585. [8] The position in Queensland is similar in some other states such as New South Wales and South Australia 3. Conversely, the implied (statutory) right of indemnity in Victoria, Western Australia and Tasmania 4 may be overridden by contrary intention and, in those states, the absence of a right of indemnity potentially arises as a result of either or both disentitling conduct and a contrary intention in the trust instrument. In no case is the entitlement to an indemnity absent simply because of a lack of trust assets. 1 2 3 4 See at 381 [13]. See at 392 [71]-[74]. Trustee Act 1925 (NSW), s. 59(4) and Trustee Act 1936 (SA), s. 35(2). Trustee Act 1958 (Vic), s. 36(2), Trustees Act 1962 (WA), s. 71 and Trustee Act 1898 (Tas), s. 27(2).

4 [9] The approach adopted by Gray J was developed with reference particularly to the sentence in s. 197(1) that I have emphasised above: This is so even if the trust does not have enough assets to indemnify the trustee. That sentence appears after subparagraphs 1(a) and (b) of the section. It has been described as an ambiguous sentence but Austin J of the New South Wales Supreme Court, when delivering a lecture in February 2004, gave an explanation which seems, to me, to be correct. He said: I suggest that the ambiguous sentence should be taken to mean that the director s liability (if it exists because the right to indemnity has been destroyed) is not diminished by reference to the fact that the trust has insufficient assets to indemnify the trustee. On its proper construction, s 197 should not be taken to render the director liable when the right of indemnity remains in place but there are insufficient assets to meet the indemnity. [10] That passage from the lecture was quoted by McDougall J in Intagro Projects Pty Ltd v Australia and New Zealand Banking Group Ltd (2004) 50 ACSR 224, 236 [53]. In that decision at 230-237 [24]-[62] his Honour canvassed many of the criticisms of the decision in Hanel. I agree with those criticisms and shall not repeat them here. [11] It is clear that his Honour thought that the majority view in Hanel was wrong. The reason that may have stopped his Honour from saying that the decision in Hanel was plainly wrong came from the procedural context in which he was considering the question. A defendant bank was seeking leave to amend its cross-claim by adding two directors of a trustee company as cross-defendants arguing that they were liable to discharge a trustee company s liability as a trustee under s. 197. Because of the decision in Hanel, McDougall J did not feel justified in refusing the amendment on the basis that, if the majority view in Hanel was correct, then it was fairly arguable; see at 237-238 [64]-[65]. The situation is different here because final relief is sought to require the respondents to pay the sum claimed. [12] The issue whether the decision is plainly wrong arises because of the decision of the High Court in Australian Securities Commission v Marlborough Gold Mines Ltd (1993) 177 CLR 485, 492 according to which State courts and all the more so a single judge should not depart from an interpretation placed on Commonwealth legislation by another Australian intermediate appellate court unless convinced that interpretation is plainly wrong. [13] Young CJ in Eq of the New South Wales Supreme Court in Edwards v Attorney General (NSW) (2004) 208 ALR 605, sitting as a member of the Court of Appeal of that Court, may well have yielded to the temptation so valiantly resisted by McDougal J in the Intagro case to say that Hanel was plainly wrong, had that Court needed to deal with s. 197 in that decision; see at 628 [150]-[152]. [14] Windeyer J, in Saffron Sun Pty Ltd v Perma-Fit Finance Pty Ltd (in liq) [2005] NSWSC 1317, was less inhibited in concluding at [31] that the decision in Hanel was wrong and should not be followed. He went on to say that if that required him to come to the conclusion that it was plainly wrong then I must do so. He relied on what had been said by Young CJ in Eq in reaching that conclusion.

5 [15] Before these controversies had arisen Helman J of this Court had decided in Sit Simplex Stulte Pty Ltd (in liq) v Carter [2003] QSC 99 at [14] not to allow an amendment to a pleading based on a submission that may have advanced a similar view of s. 197 and its predecessor to that which succeeded in Hanel. So the only relevant authority in this State is against the proposition advanced in Hanel. [16] The coup de grâce was delivered late in 2005 by the Commonwealth Parliament when it amended s. 197 so as to correct a perceived anomaly arising due to the interpretation placed upon the section by the Supreme Court of South Australia and to override the decision in Hanel to ensure that the liability of directors of trustee corporations will extend only so far as intended when section 197 was introduced in its original form in the corporations legislation ; see the Law and Bills Digest accompanying the Corporations Amendment Bill (No. 1) 2005. The explanatory memorandum for that bill also said of the decision in Hanel that the: South Australian Supreme Court departed from the longstanding interpretation of section 197 of the Corporations Act. The practical impact of the new interpretation is that the directors of corporate trustees may be held to be guarantors for any liability entered into by the trustee. As such, directors of corporate trustees are now exposed to greater potential for personal liability than directors of other companies. [17] There is no other judicial decision that supports the approach adopted in Hanel and, in spite of McDougall J s unwillingness in Intagro to go so far as to say that the decision was plainly wrong, it seems to me that the judicial and legislative developments since then justify me in reaching that conclusion. The subsequent statutory history in circumstances like this is also an available aid to construction to permit me to reach this conclusion; Allina Pty Ltd v Federal Commissioner of Taxation (1991) 99 ALR 295, 303 and Pearce and Geddes, Statutory Interpretation in Australia, 5 th ed. (2001) at [3.30]-[3.31]. [18] The lack of a single reason for the decision also makes it an unreliable basis on which to give the judgment sought here. This application is not one for interlocutory relief of the type before McDougall J. It is however an interlocutory application seeking, in effect, summary judgment. The applicant seeks to rely upon Hanel to enforce a money claim against the first respondents as directors. That provides another reason why I should not follow Hanel in this context. [19] Nor was the evidence, at this stage at least, satisfactory in respect of the inferences as to the assets available to LJAW. The fact that it has been put into liquidation where there is no evidence from the directors about the company s ability to pay the claimed debt was relied upon by the applicant to argue that I should draw the inference on the current evidence that the trust fund had no assets, thus permitting the use of s. 197. At this stage of the proceeding I would not have converted that conjecture into inference, to use the language of Kitto J in Jones v Dunkel (1959) 101 CLR 298, 305. Nor was the first respondent a director of LJAW when the liability was incurred, although he was when judgment was entered, another reason for refusing the relief against him at least. [20] Principally, however, I would refuse the application because it can only succeed if Hanel is right, and I am of the view that the decision is plainly wrong and should

6 not be followed. Accordingly the application is dismissed. I shall hear the parties further as to costs.