SUPREME COURT OF SOUTH AUSTRALIA
(Civil)
ALBAYRAK v TRUTH (SA) PTY LTD
[2020] SASC 87
Judgment of Judge Bochner a Master of the Supreme Court
20 May 2020
CORPORATIONS
Remuneration of liquidator - s 482 - costs of voluntary administration and DoCA.
Corporations Act 2001 (Cth); Supreme Court Act 1935 (SA); Liquor Licencing Act 1997 , referred to.
Venetian Nominees Pty Ltd v Conlan (1998) WAR 96; Deputy Commissioner of Taxation v Starpicket Pty Ltd (No 2) [2013] FCA 699; Sanderson as Liquidator of Sakr Nominees Pty Ltd (in liquidation) v Sakr [2017] NSWCA 38; Park & Muller (liquidators of LM Investment Management Ltd) v Whyte No 2 [2017] QSC 229; Lock, in the matter of Cedenco JV Australia Pty Ltd (in liq) (No 2) [2019] FCA 93; Leveraged Capital Pty Ltd (in liq) v Modena Imports Pty Ltd (in liq) [2010] NSWSC 739; Morgan v Poulter (in his capacity as former liquidator of Twenty-Seventh Android Pty Ltd) [2019] VSC 563, considered.
ALBAYRAK v TRUTH (SA) PTY LTD
[2020] SASC 87
By way of interlocutory application filed on 27 September 2019, Mr Strazdins, the former liquidator of Truth (SA) Pty Ltd (“the company”), seeks to have his remuneration determined for the work that he carried out while the company was in liquidation. His application has been strongly resisted by the company’s sole director and shareholder, Mr Seref Albayrak.
For the purpose of the application, the following material was tendered:
L1 Letter dated 21 October 2019
L2 Letter dated 25 October 2019
A3 Report of Mr John Melluish
L4 Affidavit of Mr Strazdins filed on 13 August 2019
L5 Affidavit of Mr Strazdins filed on 28 August 2019
L6 Affidavit of Mr Strazdins filed on 13 February 2020
L7 Timesheet analysis for period 24 August 2019 to February 2020
L8Second Affidavit of Mr McCusker filed on 17 February 2020 subject to the striking out of paragraphs 9-11 and the related exhibit
A9 Affidavit of Mr Albayrak filed on 9/8/19
A10 Affidavit of Mr Albayrak filed on 13/8/19
A11 Affidavit of Nilufer Kavouklis filed on 9/8/19
A12 Affidavit of Mr Albayrak filed on 12/8/19
A13 Affidavit of Nikitas Kavouklis filed on 11/9/19
A14 Affidavit of Nilufer Kavouklis filed on 11/9/19
A15 Affidavit of Mr Albayrak filed on 11/9/19
A16 Affidavit of Mr Vaezi filed on 11/9/19
I note that this matter was commenced by Mr Albayrak, as plaintiff, in his capacity as director and shareholder of the company in liquidation. The company was the defendant. At the hearing of the remuneration argument, there was some confusion between the parties as to the way that the parties should be named, given that the interlocutory applicant was Mr Strazdins as intervenor and the interlocutory respondent was, effectively, the company, as it is the company that will be liable for Mr Strazdins’ fees. To avoid confusion, I will refer to Mr Strazdins and Mr Albayrak by their names rather than as applicant and respondent. When I am dealing…
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CaseChat Overview and Summary
The central legal issue before the court was whether the remuneration sought by Mr Strazdins was reasonable and necessary for the work performed as liquidator of the company. The court had to consider the Insolvency Practice Schedule (Corporations) which outlines the matters that the court must have regard to when making a remuneration determination. Specifically, the court needed to determine if the work was necessary and properly performed, the complexity of the work, and whether the remuneration was in line with market rates.
The court considered the evidence provided by both parties and the expert opinion of Mr Melluish, an experienced liquidator. Mr Melluish provided two methods of assessing the reasonable remuneration, the checklist method and the adjustment method, resulting in amounts of $28,076.50 and $38,033 respectively. After reviewing all the evidence and expert opinion, the court determined that Mr Strazdins was entitled to remuneration in the amount of $91,651.40, inclusive of GST. The court also found that the disbursements claimed by Mr Strazdins were reasonable and awarded him $25,164.20 in disbursements.
The court ordered that the liquidator be paid the determined remuneration and disbursements, with $100,000 from the Suitors’ Fund to be paid in part satisfaction of these amounts. The balance of the remuneration and disbursements was to be paid jointly and severally by the company and Mr Albayrak. The court reserved the question of costs associated with the remuneration application for further consideration by the parties.
Orders
Orders of the court
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Background
Background to the litigation
Evidence
Evidence Before The Court
Decision
Reasons for decision
Ratio Decidendi
Legal Principle Established
He also reiterated his view that the business operated by the company was a small one, with limited engagement with creditors, and significant funds in the bank.[37] [37] T120.1-11.The legislation and the authorities dealing with a liquidator’s remuneration The Insolvency Practice Schedule (Corporations) (“the Schedule”), set out in the schedules to the Act, relevantly provides:60-10 Remuneration determinations Remuneration determinations (1)A determination, specifying remuneration that an external administrator of a company (other than an external administrator in a members' voluntary winding up) is entitled to receive for necessary work properly performed by the external administrator in relation to the external administration, may be made: (a) by resolution of the creditors; or (b) if there is a committee of inspection and a determination is not made under paragraph (a)--by the committee of inspection; or (c) if a determination is not made under paragraph (a) or (b)--by the Court. Note: For determinations made by the Court, see also section 60- 12 (matters to which the Court must have regard). (2)A determination, specifying remuneration that an external administrator of a company in a members' voluntary winding up is entitled to receive for necessary work properly performed by the external administrator in relation to the external administration, may be made: (a) by resolution of the company at a general meeting; or (b) if a determination is not made under paragraph (a)--by the Court. Note: For determinations made by the Court, see also section 60- 12 (matters to which the Court must have regard). (3)A determination under this section may specify remuneration that the external administrator is entitled to receive in either or both of the following ways: (a) by specifying an amount of remuneration; (b) by specifying a method for working out an amount of remuneration. Remuneration on a time-cost basis (4)If a determination under this section specifies that the external administrator is entitled to receive remuneration worked out wholly or partly on a time-cost basis, the determination must include a cap on the amount of remuneration worked out on a time-cost basis that the external administrator is entitled to receive. More than one remuneration determination may be made (5)To avoid doubt, more than one determination under this section may be made in relation to a particular external administrator of a company and a particular external administration of a company. …60-12 Matters to which the Court must have regard In making a remuneration determination under paragraph 60-10(1)(c) or (2)(b), or reviewing a remuneration determination under section 60- 11, the Court must have regard to whether the remuneration is reasonable, taking into account any or all of the following matters: (a) the extent to which the work by the external administrator was necessary and properly performed; (b) the extent to which the work likely to be performed by the external administrator is likely to be necessary and properly performed; (c) the period during which the work was, or is likely to be, performed by the external administrator; (d) the quality of the work performed, or likely to be performed, by the external administrator; (e) the complexity (or otherwise) of the work performed, or likely to be performed, by the external administrator; (f) the extent (if any) to which the external administrator was, or is likely to be, required to deal with extraordinary issues; (g) the extent (if any) to which the external administrator was, or is likely to be, required to accept a higher level of risk or responsibility than is usually the case; (h) the value and nature of any property dealt with, or likely to be dealt with, by the external administrator; (i) the number, attributes and conduct, or the likely number, attributes and conduct, of the creditors; (j) if the remuneration is worked out wholly or partly on a time-cost basis--the time properly taken, or likely to be properly taken, by the external administrator in performing the work; (k) whether the external administrator was, or is likely to be, required to deal with one or more controllers, or one or more managing controllers; (l) if: (i)a review has been carried out under Subdivision C of Division 90 (review by another registered liquidator) into a matter that relates to the external administration; and (ii) the matter is, or includes, remuneration of the external administrator; the contents of the report on the review that relate to that matter; (m) any other relevant matters.