FAMILY COURT OF AUSTRALIA
Bensaid & Fasih [2021] FamCA 512
File number(s): PAC 2686 of 2009 Judgment of: FOSTER J Date of judgment: 16 July 2021 Catchwords: FAMILY LAW – PROPERTY – property adjustment – where only asset remaining for division is the husband’s half interest in a property as tenants-in-common – where discussion of applicable principles – where contributions assessed as equal – where adjustment in favour of wife by reason of s 75(2) considerations. Legislation: Family Law Act 1975 (Cth) ss 75(2), 79, 102NA Cases cited: Bevan & Bevan [2014] FamCAFC 19
Chapman & Chapman [2014] FamCAFC 91
Figgins & Figgins [2002] FamCA 688
Horrigan & Horrigan [2020] FamCAFC 25
Russell & Russell (1999) FLC 92-877
Scott & Danton [2014] FamCAFC 203
Stanford v Stanford [2012] HCA 52
Teal & Teal [2010] FamCAFC 120
Number of paragraphs: 90 Date of last submission/s: 5 May 2021 Date of hearing: 3 and 4 February 2021 and 29 and 30 March 2021 Place: Parramatta Counsel for the Applicant: Mr Pickering Solicitor for the Applicant: H K Husseini & co Counsel for the Respondent: Mr Cairns Solicitor for the Respondent: Crimcorp Defence Lawyers Pty Ltd Intervener – unrepresented litigant: The intervener attended in person ORDERS
PAC 2686 of 2009 BETWEEN: MS FASIH
Applicant
AND: MR BENSAID
Respondent
MR WARDI
Intervener
ORDER MADE BY:
FOSTER J
DATE OF ORDER:
16 JULY 2021
THE COURT ORDERS THAT:
1.Within six weeks from this date the second respondent pay to the wife the sum of $121,000 and to the husband $99,000 less any Westpac Bank mortgage balance in excess of $380,000.
2.In consideration of such payments the husband do all things necessary to transfer his interest in the property at B Street, Suburb D to the second respondent; and
3.Concurrently with such transfer the second respondent procure a discharge or refinance of the present mortgage encumbrance in favour of the Westpac Bank.
4.In default of the payments as provided for in Order 1, the husband and second respondent forthwith do all things necessary to sell the property at B Street, Suburb D for the best price reasonably obtainable and upon sale the proceeds be paid as follows:
(a)in payment of selling costs including agent’s commission and legal expenses;
(b)in payment of one half of the balance then remaining to the second respondent;
(c)in discharge of the mortgage in favour of Westpac Bank provided always that the husband shall from his share of the proceeds of sale pay any mortgage balance in excess of $380,000;
(d)in payment of 55 per cent of the balance then remaining to the wife;
(e)in payment of the balance then remaining to the husband less any sum to be paid by the husband in relation to any mortgage balance over $380,000.
5.Liberty to apply as to implementation or enforcement of these orders.
6.The matter be removed from the active pending cases list.
7.All subpoenaed documents produced and all exhibits tendered in these proceedings, be returned at the expiration of one calendar month…
Continue reading Bensaid & Fasih
Sign in free to access the full text
- AGLC
- Bensaid & Fasih [2021] FamCA 512
- Case
- [2021] FamCA 512
- Decision Date
CaseChat Overview and Summary
The court was required to determine the appropriate property adjustment between the parties. This involved assessing their respective contributions to the marriage and considering various factors under section 75(2) of the relevant Act, which include the age and health of the parties, their financial resources and earning capacities, and the responsibilities each party has to support themselves and any other persons. The court also had to consider the impact of the husband's conduct on the wife's financial position and well-being.
Foster J assessed the parties' contributions as equal. However, after considering the factors under section 75(2), particularly the wife's circumstances and the husband's conduct, the court determined an adjustment in favour of the wife was warranted. The court ordered that within six weeks, the second respondent (Mr. Wardi) was to pay $121,000 to the wife and $99,000 to the husband, less any Westpac Bank mortgage balance exceeding $380,000. In consideration of these payments, the husband was to transfer his interest in the property to the second respondent, and concurrently, the second respondent was to procure a discharge or refinance of the existing mortgage. In the event of default in payment, the property was to be sold, with proceeds distributed according to a specified order of priority, including payment to selling costs, the second respondent, the Westpac Bank mortgage, and then a division of the remaining balance between the wife (55%) and the husband (45%), with adjustments for any excess mortgage balance.
Orders
Orders of the court
PAC 2686 of 2009
BETWEEN:
MS FASIH
Applicant
AND:
MR BENSAID
Respondent
MR WARDI
Intervener
ORDER MADE BY:
FOSTER J
DATE OF ORDER:
16 JULY 2021
THE COURT ORDERS THAT:
1. Within six weeks from this date the second respondent pay to the wife the sum of $121,000 and to the husband $99,000 less any Westpac Bank mortgage balance in excess of $380,000.
2. In consideration of such payments the husband do all things necessary to transfer his interest in the property at B Street, Suburb D to the second respondent; and
3. Concurrently with such transfer the second respondent procure a discharge or refinance of the present mortgage encumbrance in favour of the Westpac Bank.
4. In default of the payments as provided for in Order 1, the husband and second respondent forthwith do all things necessary to sell the property at B Street, Suburb D for the best price reasonably obtainable and upon sale the proceeds be paid as follows:
(a) in payment of selling costs including agent’s commission and legal expenses;
(b) in payment of one half of the balance then remaining to the second respondent;
(c) in discharge of the mortgage in favour of Westpac Bank provided always that the husband shall from his share of the proceeds of sale pay any mortgage balance in excess of $380,000;
(d) in payment of 55 per cent of the balance then remaining to the wife;
(e) in payment of the balance then remaining to the husband less any sum to be paid by the husband in relation to any mortgage balance over $380,000.
5. Liberty to apply as to implementation or enforcement of these orders.
6. The matter be removed from the active pending cases list.
7. All subpoenaed documents produced and all exhibits tendered in these proceedings, be returned at the expiration of one calendar month unless an appeal is lodged.
Note: The form of the order is subject to the entry in the Court’s records.
Note: This copy of the Court’s Reasons for judgment may be subject to review to remedy minor typographical or grammatical errors (r 17.02A(b) of the Family Law Rules 2004 (Cth)), or to record a variation to the order pursuant to 17.02 Family Law Rules 2004 (Cth).
Background
Background to the litigation
Evidence
Evidence Before The Court
Full text does not contain this section.
Decision
Reasons for decision
Full text does not contain this section.
Ratio Decidendi
Legal Principle Established
Overall, it is proper to assess the parties’ contributions as equal. The wife would be entitled to $110,000.Section 75(2) considerations The Court is required to consider the various relevant factors as set out in s 75(2) of the Act:(a) the age and state of health of each of the parties; and(b)the income, property and financial resources of each of the parties and the physical and mental capacity of each of them for appropriate gainful employment; and(c)whether either party has the care or control of a child of the marriage who has not attained the age of 18 years; and(d)commitments of each of the parties that are necessary to enable the party to support:(i) himself or herself; and(ii) a child or another person that the party has a duty to maintain; and(e) the responsibilities of either party to support any other person; and(f)subject to subsection (3), the eligibility of either party for a pension, allowance or benefit under:(i)any law of the Commonwealth, of a State or Territory or of another country; or(ii)any superannuation fund or scheme, whether the fund or scheme was established, or operates, within or outside Australia;and the rate of any such pension, allowance or benefit being paid to either party; and(g)where the parties have separated or divorced, a standard of living that in all the circumstances is reasonable; and(h)the extent to which the payment of maintenance to the party whose maintenance is under consideration would increase the earning capacity of that party by enabling that party to undertake a course of education or training or to establish himself or herself in a business or otherwise to obtain an adequate income; and(ha)the effect of any proposed order on the ability of a creditor of a party to recover the creditor's debt, so far as that effect is relevant; and(j)the extent to which the party whose maintenance is under consideration has contributed to the income, earning capacity, property and financial resources of the other party; and(k)the duration of the marriage and the extent to which it has affected the earning capacity of the party whose maintenance is under consideration; and(l)the need to protect a party who wishes to continue that party's role as a parent; and(m)if either party is cohabiting with another person--the financial circumstances relating to the cohabitation; and(n)the terms of any order made or proposed to be made under section 79 in relation to:(i) the property of the parties; or(ii) vested bankruptcy property in relation to a bankrupt party; and(naa)the terms of any order or declaration made, or proposed to be made, under Part VIIIAB in relation to:(i) a party to the marriage; or(ii)a person who is a party to a de facto relationship with a party to the marriage; or(iii)the property of a person covered by subparagraph (i) and of a person covered by subparagraph (ii), or of either of them; or(iv)vested bankruptcy property in relation to a person covered by subparagraph (i) or (ii); and(na)any child support under the Child Support (Assessment) Act 1989 that a party to the marriage has provided, is to provide, or might be liable to provide in the future, for a child of the marriage; and(o)any fact or circumstance which, in the opinion of the court, the justice of the case requires to be taken into account; and(p)the terms of any financial agreement that is binding on the parties to the marriage; and(q)the terms of any Part VIIIAB financial agreement that is binding on a party to the marriage.