FEDERAL COURT OF AUSTRALIA
Bechara v Bates (No 3) [2023] FCA 1559
Appeal from: Bates v Bechara (No 2) [2021] FCCA 1809, Bates v Bechara (No 3) [2021] FedCFamC2G 155 and Bates v Bechara (No 4) [2021] FedCFamC2G 304 File number: NSD 38 of 2022 Judgment of: MARKOVIC J Date of judgment: 11 December 2023 Catchwords: BANKRUPTCY – appeal from orders made by the Federal Circuit and Family Court of Australia (then the Federal Circuit Court of Australia) following review of a decision made by a registrar to make a sequestration order against the estate of the appellant – where review is a hearing de novo – whether primary judge erred in finding that the Federal Circuit Court’s jurisdiction was invoked under s 43 of the BankruptcyAct 1966 (Cth) – the proper construction of s 43(1)(b) of the Bankruptcy Act – whether subss 43(1)(b)(i) to (iii) of the Bankruptcy Act are to be read cumulatively and not alternatively – whether Re Mendonca; Ex parte Commissioner of Taxation (1969) 15 FLR 256 is plainly wrong – whether Re Vassis; Ex parte Leung (1986) 9 FCR 518 is plainly wrong – whether primary judge erred in analysis of evidence against rr 4.04, 4.05 and 4.06 of the Federal Circuit Court (Bankruptcy) Rules 2016 (Cth) – whether primary judge erred in finding that non-compliance with the Bankruptcy Rules was not of such a nature as to cause substantial injustice within the meaning of s 306(1) of the Bankruptcy Act – whether primary judge erred in finding that appellant was required to comply with r 2.04 and r 2.06 of the Bankruptcy Rules on a review application – appeal dismissed Legislation: Bankruptcy Act 1966 (Cth) ss 41 subs (3)(c)(i), 43 subs (1)(a) and subs (1)(b), 47, 52 subs (1) and subs (2), 306 subs (1)
Federal Circuit and Family Court of Australia (Division 2) (Bankruptcy) Rules 2021 (Cth) r 1.04
Federal Circuit and Family Court of Australia Act 2021 (Cth) s 189(2)
Federal Circuit Court (Bankruptcy) Rules 2016 (Cth) rr 1.03, 1.04, 2.04, 2.06, 4.04, 4.05 and 4.06
Federal Circuit Court of Australia Act 1999 (Cth) s 57(2) and s 104(2)
Federal Circuit Court Rules 2001 (Cth)
Cases cited: Adams v Lambert (2006) 228 CLR 409
Bechara v Bates (2021) 286 FCR 166
Bechara v Bates (No 2) [2020] FCA 659
Bhagat v Global Custodians Ltd [2002] FCA 926
Carver v de Robillard [2006] FCA 1041
Compton v Ramsay Healthcare Australia Pty Ltd (2017) 256 FCR 345
de Robillard v Carver (2007) 159 FCR 38
Fuller JR, in the matter of Alford v Alford (2017) 252 FCR 168
Kleinwort Benson Australia Ltd v Crowl (1988) 165 CLR 71
Owners of the Ship Shin Kobe Maru v Empire Shipping Co Inc (1994) 181 CLR 404
Re Mendonca; Ex parte Commissioner of Taxation (1969) 15 FLR 256
Re Vassis; Ex parte Leung (1986) 9 FCR 518
Robson v Body Corporate for Sanderling at Kings Beach CTS 2942 (2021) 286 FCR 494
Continue reading Bechara v Bates (No 3)
Sign in free to access the full text
- AGLC
- Bechara v Bates (No 3) [2023] FCA 1559
- Case
- [2023] FCA 1559
- Decision Date
CaseChat Overview and Summary
The court considered Ms Bechara's arguments and found that the primary judge had not erred in his interpretation of the relevant sections of the Bankruptcy Act. The court held that the language of the Act and the use of the word "or" in subsections 43(1)(b)(i) to (iii) indicated that the subsections should be read alternatively. The court also found that Mr Bates had satisfied the requirements of the relevant subsections, thereby establishing the court's jurisdiction to entertain the creditor's petition. Additionally, the court held that the primary judge did not err in his analysis of evidence against rules 4.04, 4.05, and 4.06 of the Federal Circuit Court (Bankruptcy) Rules 2016 (Cth) and in finding that non-compliance with the Bankruptcy Rules was not of such a nature as to cause substantial injustice within the meaning of section 306(1) of the Bankruptcy Act.
In light of the above findings, the court dismissed Ms Bechara's appeal. The appellant was ordered to pay the respondent's costs of the appeal, with such costs to be paid out of the appellant's estate in accordance with the priority in section 109(1)(a) of the Bankruptcy Act 1966 (Cth). The respondent was given the opportunity to file an application for payment of his costs to be assessed as a lump sum, with specific requirements outlined in the court's orders. If the parties were unable to agree on the appropriate order as to costs, the court would decide the matter on the papers unless a party requested an oral hearing.
Orders
Orders of the court
1. The appeal is dismissed.
2. The appellant is to pay the respondent’s costs of the appeal, with such costs to be paid out of the appellant’s estate in accordance with the priority in s 109(1)(a) of the Bankruptcy Act 1966 (Cth).
3. On or before 8 January 2024 the respondent is to file any application for payment of his costs to be assessed as a lump sum together with an affidavit in support, in accordance with paragraphs 4.10 to 4.12 of the Costs Practice Note (GPN-Costs), and submissions, not exceeding three pages in length.
4. In the event that an application is filed by the respondent in accordance with Order 3 above:
(a) the parties are to confer and on or before 15 January 2024 provide the Associate to Markovic J proposed consent orders as to costs; or
(b) if the parties are unable to agree on the appropriate order as to costs, on or before 22 January 2024 the appellant is to file and serve any affidavit in response, in accordance with paragraphs 4.13 to 4.14 of the Costs Practice Note (GPN-Costs), and her submissions, not exceeding three pages in length.
5. In the event that the parties are unable to agree on the appropriate order as to costs, unless a party requests an oral hearing, the question of costs will be dealt with on the papers.
Note: Entry of orders is dealt with in Rule 39.32 of the Federal Court Rules 2011.
Background
Background to the litigation
Full text does not contain this section.
Evidence
Evidence Before The Court
Full text does not contain this section.
Decision
Reasons for decision
Ratio Decidendi
Legal Principle Established
Rule 4.06 of the Bankruptcy Rules is titled “Additional affidavits to be filed before hearing”. It relevantly provides:(1)Before the hearing of a creditor’s petition, the applicant creditor must comply with this rule.(2)The applicant creditor must file an affidavit that:(a)states that the documents required to be served under rule 4.05 have been served, and when and how they were served; and (b)has attached to it a copy of the documents that were served and proof of service in relation to the documents. CONSIDERATION I address each category of error alleged by Ms Bechara (summarised at [48] above) in turn below.Jurisdiction The first category of error alleged by Ms Bechara concerns the question of whether the Federal Circuit Court had jurisdiction to entertain the creditor’s petition presented by Mr Bates. Ms Bechara’s challenge to the primary judge’s reasons is two-fold: first, she contends that the primary judge erred in his construction of s 43(1)(b) of the Bankruptcy Act; and secondly, she contends that the primary judge erred in finding that Mr Bates had established each of the requirements of subss 43(1)(b)(i), (ii) and (iii) of the Bankruptcy Act.The construction of s 43(1)(b) of the Bankruptcy Act Ms Bechara submits that the primary judge fell into error because Mr Bates, as creditor, did not establish a prima facie entitlement to the making of a sequestration order on the bases relied upon in paragraph 3 of his creditor’s petition. This was because the Federal Circuit Court could not have been satisfied on the balance of probabilities that Ms Bechara: (1)was ordinarily resident in Australia; and (2)had a dwelling house in Australia; and (3)had a place of business in Australia; or (4)was carrying on business in Australia personally or by an agent or by an agent or manager, when the act of bankruptcy occurred on 5 April 2016. Ms Bechara contends that s 43(1)(b) of the Bankruptcy Act requires each aspect of paragraph 3 of the creditor’s petition to be proved and that the legislation makes it clear, by inserting the word “or” at various points, that paragraphs 3(a), (b) and (c) of the creditor’s petition are cumulative and not alternative. At the heart of this submission is Ms Bechara’s contention that the proper construction of s 43(1)(b) of the Bankruptcy Act requires subss 43(1)(b)(i) to (iii) to be read cumulatively and not alternatively. To that end, Ms Bechara submits that: the decision in Re Mendonca is not binding on this Court; this Court ought to reconsider the decision in Re Mendonca as it misreads the language in s 43(1)(b) of the Bankruptcy Act to arrive at an unnaturally narrow construction of what the legislation is intended to mean; and if the legislature had intended the requirements of s 43(1)(b) to be read alternatively then it would have used the word “or” at the end of each subsection. She submits that instead the legislature inserted the word “or” sparingly at the end of s 43(1)(b), between subs (iii) and subs (iv), “for a reason”, without further explanation.