FEDERAL COURT OF AUSTRALIA
Beling v Sixty International S.A. [2015] FCA 250
Citation: Beling v Sixty International S.A. [2015] FCA 250 Parties: JOEL BELING v SIXTY INTERNATIONAL S.A. File number: VID 626 of 2014 Judge: MORTIMER J Date of judgment: 20 March 2015 Catchwords: COSTS – Appeal from Registrar of Trademarks’ decision as to costs – litigant in person – solicitor litigant exception to principle that successful self-represented litigants not entitled to costs – applicability of exception to awards of costs under Trade Marks Act 1995 (Cth) Legislation: Federal Court of Australia Act 1976 (Cth) s 43
Trade Marks Act 1995 (Cth) ss 54, 56, 201, 202, 203, 206, 221, 222Trade Mark Regulations 1995 (Cth) Pt 5, regs 21.12, 21.13(1), 21.15, Sch 8
Cases cited: A & D Douglas Pty Ltd v Lawyers Private Mortgages Pty Ltd [2006] FCA 690
Cachia v Hanes (1994) 179 CLR 403
Cashman and Partners v Secretary, Department of Human Services and Health (1995) 61 FCR 301
Dobree v Hoffman (1996) 18 WAR 36
George v Fletcher (Trustee) (No 2) [2010] FCAFC 71
Guss v Veenhuizen (No 2) (1976) 136 CLR 47
Re New Tel Ltd (in liq) (No 4) [2008] FCA 1085
Registrar of Trade Marks v Woolworths Ltd (1999) 93 FCR 365; [1999] FCA 1020
Secretary, Department of Foreign Affairs and Trade v Boswell (No 2) (1992) 39 FCR 288
Tyne v UBS AG (No 2) [2014] FCA 1228R v Hardie [2003] NZIPOTM 39
Date of hearing: 5 February 2015 Date of last submissions: 5 February 2015 Place: Melbourne Division: GENERAL DIVISION Category: Catchwords Number of paragraphs: 91 Counsel for the Applicant: The Applicant appeared in person Counsel for the Respondent: Dr L Duncan Solicitor for the Respondent: M+K Lawyers
IN THE FEDERAL COURT OF AUSTRALIA
VICTORIA DISTRICT REGISTRY
GENERAL DIVISION
VID 626 of 2014
BETWEEN: JOEL BELING
ApplicantAND: SIXTY INTERNATIONAL S.A.
Respondent
JUDGE:
MORTIMER J
DATE OF ORDER:
20 MARCH 2015
WHERE MADE:
MELBOURNE
THE COURT ORDERS THAT:
1.Appeal allowed.
2.The decision of the delegate of the Registrar of Trade Marks as to Trade Mark Application Number 1441489 made on 16 October 2014 is set aside only insofar as the delegate declined, in paragraph [37] of the decision, to make an award of costs to the applicant.
3.The Registrar is directed, whether through a delegate of the Registrar or otherwise, to reconsider the applicant’s application for costs in accordance with the reasons of the Court on this appeal.
4.The respondent is to pay the applicant’s professional costs of and incidental to the appeal on and from 12 January 2015 and disbursements incurred in the appeal, such costs and disbursements to be fixed by the Court in accordance with directions given.
Note: Entry of orders is dealt with in Rule 39.32 of the Federal Court Rules 2011.
IN THE FEDERAL COURT OF AUSTRALIA
VICTORIA DISTRICT REGISTRY
GENERAL DIVISION
VID 626 of 2014
BETWEEN: JOEL BELING
ApplicantAND: SIXTY INTERNATIONAL S.A.
Respondent
JUDGE:
MORTIMER J
DATE:
20 MARCH 2015
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- Case
- [2015] FCA 250
- Decision Date
CaseChat Overview and Summary
The legal issues in the case centered around the applicability of the solicitor litigant exception to awards of costs under the Trade Marks Act. This exception, which precludes self-represented litigants from claiming costs incurred, is well-established in Australian law. However, the court had to determine whether this exception should apply to awards of costs under s 221 of the Act, which grants the Registrar the power to award costs against a party to proceedings brought before her. The court also considered whether the respondent's delay in filing evidence and the lack of meaningful material in opposition justified an award of costs above scale.
The court found that the delegate of the Registrar had failed to apply the correct legal principles in declining to order costs to Mr Beling. The court held that the solicitor litigant exception should not apply to awards of costs under the Trade Marks Act, and that the Registrar has the discretion to award costs to a self-represented litigant who is a lawyer. The court further found that the respondent's delay in filing evidence and the lack of meaningful material in opposition justified an award of costs above scale. The appeal was allowed, and the decision of the delegate of the Registrar as to the applicant's application for costs was set aside. The Registrar was directed to reconsider the applicant's application for costs in accordance with the reasons of the Court on this appeal. The respondent was ordered to pay the applicant's professional costs of and incidental to the appeal on and from 12 January 2015 and disbursements incurred in the appeal, such costs and disbursements to be fixed by the Court in accordance with directions given.
Orders
Orders of the court
1. Appeal allowed.
2. The decision of the delegate of the Registrar of Trade Marks as to Trade Mark Application Number 1441489 made on 16 October 2014 is set aside only insofar as the delegate declined, in paragraph [37] of the decision, to make an award of costs to the applicant.
3. The Registrar is directed, whether through a delegate of the Registrar or otherwise, to reconsider the applicant’s application for costs in accordance with the reasons of the Court on this appeal.
4. The respondent is to pay the applicant’s professional costs of and incidental to the appeal on and from 12 January 2015 and disbursements incurred in the appeal, such costs and disbursements to be fixed by the Court in accordance with directions given.
Note: Entry of orders is dealt with in Rule 39.32 of the Federal Court Rules 2011.
Background
Background to the litigation
Evidence
Evidence Before The Court
Full text does not contain this section.
Decision
Reasons for decision
Ratio Decidendi
Legal Principle Established
The exception was subjected to rational and persuasive criticism in Dobree v Hoffman (1996) 18 WAR 36, especially at 41-48. I note but one of the persuasive observations made by Parker J (with whom Rowland and Steytler JJ agreed) at 41:While each member of the court [in Chorley] was adamant they were not establishing a privilege for solicitors, it must be accepted that non-solicitors would have difficulty seeing the result in any other terms, a perception which reflects poorly on the court and the administration of justice. By way of example, were a chartered accountant and a solicitor to engage in litigation against each other and were each to conduct their own case, from the viewpoint of the accountant there can be neither fairness nor logic in a rule of practice under which, should the accountant win, there would be no recompense for the time and effort expended by the accountant or his or her clerk, in conducting the case, but should the accountant lose the solicitor would be recompensed for the time and effort put in by the solicitor and his or her clerk, calculated on a basis which also allows the solicitor the ordinary profit as though acting for a client. The reality is unfairness and a privileged position for the court's officers.CONSIDERATION Although recognised as anomalous, in circumstances where courts have power to award costs, it is well established that this power may be exercised in favour of a self-represented party where that party is a lawyer. I have no difficulty in adding to the many judicial voices who have said this exception is unjustified, especially in contemporary litigation where it ignores the other aspects of the relationship of lawyer and client and the contractual basis for a party being liable to her or his lawyer for the cost of work performed. Lawyers, like anyone else, are capable of retaining legal representation if they wish to, and should, like anyone else, incur liability for such representation. If a lawyer wishes to represent herself or himself, in my opinion she or he should be treated like any other self-represented party. That is not, however, the law. Despite the persuasiveness of Dobree, and the fact that no such exception applies in Western Australia, so far as decisions of this Court are concerned the solicitor litigant exception continues to be recognised. The issue is whether the exception should be taken to apply to s 221 of the Act. There is no reported decision which has considered this issue. It is, however, difficult to see a principled basis on which a distinction could be made between the power in s 221 of the Act and the other statutory powers to award costs to which the principles have been applied. As the cases to which I have referred above demonstrate, the statutory power to award costs in the Federal Court of Australia Act has been seen as affected by the principles in Cachia and Guss. By s 201 of the Act, the Registrar has the powers and functions given to her under the Act, the Regulations or any other relevant act or regulations. Section 202 gives the Registrar some express powers and functions:202 Registrar’s powersThe Registrar may, for the purposes of this Act:(a) summon witnesses; and(b) receive written or oral evidence on oath or affirmation; and(c) require the production of documents or articles; and(d) award costs against a party to proceedings brought before the Registrar; and(e) notify, as he or she considers fit, any person of any matter that, in his or her opinion, should be brought to the person’s notice.