Averkin v Insurance Australia Ltd

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Court of Appeal


Supreme Court


New South Wales

  • Amendment notes
Medium Neutral Citation: Averkin v Insurance Australia Ltd [2016] NSWCA 122
Hearing dates: 6 May 2016
Decision date: 23 May 2016
Before: McColl JA at [1];
Basten JA at [2];
Leeming JA at [30]
Decision:

1. Appeal allowed.

 

2. Set aside orders 1 and 2 made by the District Court on 24 April 2015, and in lieu thereof enter judgment for the plaintiff.

 3. Direct the parties to file and serve, within 14 days, submissions not exceeding 5 pages indicating the orders they propose as to (a) the amount of the judgment to be entered, if such an order is required, and (b) costs at first instance and on appeal, if any orders as to costs are sought.
Catchwords:

EVIDENCE – hearsay – business records – where representations made in connection with investigation relating to or leading to a criminal proceeding – burden of proof – representations contained in records made by police officer responding to report of burning vehicle – Evidence Act 1995 (NSW), s 69(2) and (3)

  INSURANCE – policy insuring vehicle against destruction by fire – insurer denied indemnity and alleged insured was complicit in vehicle's destruction –whether primary judge reversed onus of proof – whether primary judge erred in admitting expert evidence as to engine immobiliser – whether primary judge erred in admitting records made by police relating to the incident – whether primary judge erred in concluding that insurer had established the exclusion applied – appeal allowed and judgment entered in favour of insured
Legislation Cited: Companion Animals Regulation 2008 (NSW), cl 5
Evidence Act 1995 (Cth), s 143
Evidence Act 1995 (NSW), ss 59, 69, 140, 190; Pt 3.2
Motor Vehicle Standards Act 1989 (Cth)
Supreme Court Act 1970 (NSW), s 101
Uniform Civil Procedure Rules 2005 (NSW), rr 36.16, 42.35, 51.29
Vehicle Standard (Australian Design Rule 82/00 – Engine Immobilisers) 2006
Cases Cited: Australian Competition and Consumer Commission v Advanced Medical Institute Pty Ltd (No 2) (2005) 147 FCR 235
Averkin v Insurance Australia Ltd (30 March 2015, unrep)
Averkin v Insurance Australia Ltd t/a NRMA Insurance (24 April 2015, unrep)
Cassell v The Queen [2000] HCA 8; 201 CLR 189
Commercial Union Assurance of Australia Ltd v Ferrcom Pty Ltd (1991) 22 NSWLR 389
Lewincamp v ACP Magazines Ltd [2008] ACTSC 69
Thomas v State of New South Wales [2008] NSWCA 316; 74 NSWLR 34
Vitali v Stachnik [2001] NSWSC 303
Walsh v Walgett Shire Council [2014] NSWSC 812
Texts Cited: Uniform Evidence Law (December 2005, ALRC Report 102, NSWLRC Report 112, VLRC Final Report)
Category:Principal judgment
Parties: Mr Michael Averkin (Appellant)
Insurance Australia Ltd (Respondent)
Representation:

Counsel:
D R J Toomey SC, T B Jones (Appellant)
G Carolan (Respondent)

  Solicitors:
Toby Tancred Solicitor (Appellant)
MCK Lawyers (Respondent)
File Number(s): 2015/147224
 Decision under appeal 
Court or tribunal:
District Court of New South Wales
Jurisdiction:
Civil
Date of Decision:
30 March 2015
Before:
Norton DCJ
File Number(s):
2014/22660

Judgment

  1. McCOLL…

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Details
Case
[2016] NSWCA 122
Decision Date

CaseChat Overview and Summary

The appeal in *Averkin v Insurance Australia Ltd* concerned a dispute over an insurance policy for a vehicle destroyed by fire. The insurer denied indemnity, alleging the insured, Mr Averkin, was complicit in the vehicle's destruction. The matter came before the Court of Appeal of New South Wales following a decision in the District Court.

The Court of Appeal was required to determine several legal issues. These included whether the primary judge had reversed the onus of proof in finding that the exclusion clause in the policy applied, whether the primary judge had erred in admitting expert evidence concerning the vehicle's engine immobiliser, and whether the primary judge had erred in admitting records made by a police officer in relation to the incident. The central question was whether the insurer had established that the exclusion clause, which related to the insured's complicity in the destruction of the vehicle, was enlivened.

The Court of Appeal found that the primary judge had erred in admitting certain police records under section 69 of the *Evidence Act 1995* (NSW), as these records were made in connection with an investigation that related to or led to a criminal proceeding, and the insurer had not discharged the burden of proof required by section 69(2) and (3) of the Act. This error, along with other findings regarding the onus of proof and the admission of expert evidence, led the Court to conclude that the insurer had not established that the exclusion clause applied.

Consequently, the Court of Appeal allowed the appeal, set aside the orders of the District Court, and entered judgment in favour of the plaintiff. The parties were directed to file submissions regarding the amount of judgment and costs.

Orders

Orders of the court

1. Appeal allowed.

2. Set aside orders 1 and 2 made by the District Court on 24 April 2015, and in lieu thereof enter judgment for the plaintiff.

3. Direct the parties to file and serve, within 14 days, submissions not exceeding 5 pages indicating the orders they propose as to (a) the amount of the judgment to be entered, if such an order is required, and (b) costs at first instance and on appeal, if any orders as to costs are sought.

Background

Background to the litigation

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Evidence

Evidence Before The Court

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Decision

Reasons for decision

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Ratio Decidendi

Legal Principle Established

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