FEDERAL COURT OF AUSTRALIA
Bagshaw v Scott [2005] FCA 104
COSTS – indemnity costs – where any extant causes of action vested in applicant’s trustee in bankruptcy – whether proceedings commenced or continued in circumstances where the applicant should have known he had no chance of success
LEGAL PRACTITIONERS – duty to court not to initiate or continue an action unreasonably where it has no chance of success – where limited instructions and evidence to support actions – whether dereliction of duty by solicitor for applicant – whether proceedings initiated or continued unreasonably – whether solicitor for the applicant should be jointly liable for costs – solicitor liable with respect to one of the claims
COURTS AND JUDICIAL SYSTEM – substitution of judge in heard proceeding –where parties did not object to substitution of judge
Bankruptcy Act 1966 (Cth) ss 58(1), 116(1)(a)
Federal Court of Australia Act 1976 (Cth) s 43Federal Court Rules O 11 r 1B, O 62 r 9
Law Society of New South Wales’ Solicitors’ Rules, Rule A35A159 of 2002 v Minister for Immigration & Multicultural & Indigenous Affairs [2003] FCA 1087 referred to
Australian Transport Insurance Pty Ltd v Graeme Phillips Road Transport Insurance (1986) 10 FCR 177 followed
Bagshaw v Jefferson (Trustee) [2002] FCA 955 referred to
Brennan v Brennan (1953) 89 CLR 129 referred to
Buckingham Gate International Pty Ltd v Australia New Zealand Banking Group Ltd (2000) 35 ACSR 411 referred to
Chua Chee Chor v Chua Kim Young [1963] 1 All ER 102 referred to
Coleshill v Manchester Corporation [1928] 1 KB 776 referred to
Cook v Pasminco Ltd (No 2) (2000) 107 FCR 44 followed
Cotogno v Lamb (No 2) (1986) 3 NSWLR 221 referred to
Daemar v Industrial Commission of New South Wales (No 2) (1990) 22 NSWLR 178 cited
De Sousa v Minister for Immigration, Local Government & Ethnic Affairs (1993) 41 FCR 544 followed
Deputy Commissioner of Taxation v Levick (1999) 168 ALR 383 referred to
Fountain Selected Meats (Sales) Pty Ltd v International Produce Merchants Pty Ltd (1988) 81 ALR 397 followed
Gersten v Minister for Immigration & Multicultural Affairs [2000] FCA 922 referred to
Hamod v State of New South Wales [2002] FCAFC 97 referred to
Kumar v Minister for Immigration & Multicultural & Indigenous Affairs (No 2) (2004) 133 FCR 582 followed
Levick v Deputy Commissioner of Taxation (2000) 102 FCR 155 followed
McMahon v Livingstone [2001] NSWSC 55 referred to
Orr v Holmes (1948) 76 CLR 632 referred to
Pegler v Dale [1975] 1 NSWLR 265 cited
Re Bendeich (No 2) (1994) 53 FCR 422 referred to
Re British Reinforced Concrete Engineering Co Ltd’s Application (1929) 45 TLR 186 referred to
Ridehalgh v Horsefield [1994] Ch 205 referred to
Rondel v Worsley [1969] 1 AC 191 referred to
Scott v Bagshaw [2002] FCA 276 referred to
Stone v ACE-IRM Insurance Broking Pty Ltd [2003] QCA 218 referred to
Ugly Tribe Co Pty Ltd v Sikola [2001] VSC 189 followed
Vasram v AMP…
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- AGLC
- Bagshaw v Scott [2005] FCA 104
- Case
- [2005] FCA 104
- Decision Date
CaseChat Overview and Summary
The primary legal issues revolved around the vesting of Mr Bagshaw's causes of action in his trustee in bankruptcy upon his bankruptcy, and whether these causes of action remained vested despite his discharge from bankruptcy. Furthermore, the court had to assess whether Mr Graham acted reasonably and within the scope of his professional duties when he initiated the proceedings on behalf of Mr Bagshaw, and whether Mr Graham's failure to conduct proper independent inquiries warranted personal liability for costs.
The court examined Mr Graham's actions and found that while he had instructions and formed a view that there was a basis for the proceedings, he failed to conduct adequate independent inquiries to substantiate the serious allegations made against the respondents. Despite this, the court determined that Mr Graham did not act with deliberate unreasonableness or abuse of process, and thus, Mr Graham was not personally liable for costs in relation to Mr Scott and Ms Hermanson. However, the court found that Mr Graham's failure to conduct proper inquiries regarding the allegations against the third, fourth, and sixth respondents warranted personal liability for costs. Consequently, the court varied the costs orders to reflect these findings.
In summary, the court concluded that while Mr Bagshaw's causes of action were vested in his trustee in bankruptcy, certain proceedings could still be brought after his discharge. However, Mr Graham's conduct in initiating the proceedings was scrutinised, leading to varied costs orders against Mr Bagshaw and Mr Graham.
Orders
Orders of the court
The costs orders of Beaumont J of 17 May and 20 August 2004 are varied as follows:
1. The applicant pay the first respondent’s costs of the proceedings, such costs to be assessed on an indemnity basis.
2. The applicant pay the fifth respondent’s costs of the proceedings, such costs to be assessed on an indemnity basis.
3. The applicant pay the third, fourth and sixth respondents’ costs of the proceedings, such costs to be assessed on a party and party basis.
4.
Background
Background to the litigation
Evidence
Evidence Before The Court
Decision
Reasons for decision
Ratio Decidendi
Legal Principle Established
Established by: BENNETT J
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