Black Head Bowling Club Ltd v Harrower

Link copied
Case Copied 76 min read

Court of Appeal


Supreme Court


New South Wales

Medium Neutral Citation: Black Head Bowling Club Ltd v Harrower [2023] NSWCA 267
Hearing dates: 10–11 October 2023
Decision date: 09 November 2023
Before: Payne JA and Simpson AJA at [1]; Adamson JA at [60]
Decision:

In respect of the appeal by the Club:

(1)   Allow the appeal by the Club on ground 6 only.

(2)   Otherwise dismiss the appeal.

(3)   Order that Mr Edstein pay the Club’s costs of ground 6 of the appeal.

(4)   Order that the Club pay the costs of the first to seventh respondents to the appeal (the plaintiffs below), other than the costs of grounds 4 and 6.

(5)   Each party bear their own costs of ground 4 of the appeal.

In respect of the cross-appeal by the first to seventh respondents (the plaintiffs below):

(6)   Allow the cross-appeal by the first to seventh respondents (the plaintiffs below).

(7)   Dismiss the “Notice of Contention – Cross Appeal” filed by Mr Edstein on 21 March 2023.

(8)   Order that Mr Edstein pay the first to seventh respondents’ (the plaintiffs below) costs of the cross-appeal.

In both cases:

(9)   Set aside orders 2 and 3 made by the primary judge on 27 October 2022 and order 2 made by the primary judge on 3 February 2023 of and in lieu thereof make the following orders:

(a)   Judgment be entered in favour of the plaintiffs against the second defendant, Mr Edstein.

(b)   Mr Edstein to pay the plaintiffs damages in the agreed amount.

(c) Pursuant to s 5 of the Law Reform (Miscellaneous Provisions) Act 1946 (NSW) order that Black Head Bowling Club Ltd contribute 50% and Mr John Thomas Edstein contribute 50% to the agreed sum of damages payable to the plaintiffs.

Catchwords:

APPEALS — TORTS — Negligence — child killed by memorial headstone falling on her at bowling club — monument poorly constructed — whether club liable in negligence — whether club owed duty to undertake reasonable enquiries to ensure fixation of monument was sound — whether club failed to test stability of structure by pushing against it — whether scope of liability should extend to stonemason who constructed monument

APPEAL — PRACTICE AND PROCEDURE — allegations admitted in defences by eighth respondent/cross-defendant — allegations purportedly withdrawn in further defences — application for leave to withdraw the admissions —whether primary judge erred in refusing to allow admissions to be withdrawn or to admit transcript of the motion

Legislation Cited:

Civil Liability Act 2002 (NSW), ss 5B, 5D

Environmental Planning and Assessment Act 1979 (NSW), s 102

Evidence Act 1995 (NSW), ss 42, 69, 79, 128, 183

Law Reform (Miscellaneous Provisions) Act 1946 (NSW), s 5

Law Reform (Miscellaneous Provisions) Act 1965 (NSW), s 9

Local Government (Approvals) Regulation 1993 (NSW), cll 12, 31

Uniform Civil Procedure Rules 2005 (NSW), r 42.1

Cases Cited:

Australian Safeway Stores Pty Ltd v Zaluzna (1987) 162 CLR 479; [1987] HCA 7

Bitumen and Oil Refineries (Australia) Ltd…

CaseChat AU logo

Keep reading for free

Create a free CaseChat account to read Black Head Bowling Club Ltd v Harrower and more:

  • Read every judgment in full
  • Ask AI and get answers linked to paragraphs
  • See how each paragraph was cited in later cases
  • Download judgments as PDF or Word
Continue with Google

One click creates your free account or signs you in.

By continuing you agree to the Terms and Privacy Policy.

Details
Case
[2023] NSWCA 267
Decision Date

CaseChat Overview and Summary

The appeal concerned a tragic incident where a child was killed by a memorial headstone that fell on her at the Black Head Bowling Club. The Black Head Bowling Club Ltd appealed a decision that found it liable in negligence. The court was required to determine whether the Club owed a duty of care to ensure the monument's fixation was sound, whether it breached that duty by failing to test its stability, and whether its liability should extend to the stonemason who constructed the monument. Additionally, the court considered whether the primary judge erred in refusing to allow admissions made in defences to be withdrawn.

The court allowed the Club's appeal on one specific ground, but otherwise dismissed the appeal. In a cross-appeal by the plaintiffs, the court allowed it. The court set aside previous orders and entered judgment in favour of the plaintiffs against Mr Edstein, the stonemason, for agreed damages. Crucially, the court ordered that both the Black Head Bowling Club Ltd and Mr Edstein were to contribute 50% each to the agreed sum of damages payable to the plaintiffs, pursuant to section 5 of the Law Reform (Miscellaneous Provisions) Act 1946 (NSW).

Orders

Orders of the court

In respect of the appeal by the Club:

(1) Allow the appeal by the Club on ground 6 only.

(2) Otherwise dismiss the appeal.

(3) Order that Mr Edstein pay the Club’s costs of ground 6 of the appeal.

(4) Order that the Club pay the costs of the first to seventh respondents to the appeal (the plaintiffs below), other than the costs of grounds 4 and 6.

(5) Each party bear their own costs of ground 4 of the appeal.

In respect of the cross-appeal by the first to seventh respondents (the plaintiffs below):

(6) Allow the cross-appeal by the first to seventh respondents (the plaintiffs below).

(7) Dismiss the “Notice of Contention – Cross Appeal” filed by Mr Edstein on 21 March 2023.

(8) Order that Mr Edstein pay the first to seventh respondents’ (the plaintiffs below) costs of the cross-appeal.

In both cases:

(9) Set aside orders 2 and 3 made by the primary judge on 27 October 2022 and order 2 made by the primary judge on 3 February 2023 of and in lieu thereof make the following orders:

(a) Judgment be entered in favour of the plaintiffs against the second defendant, Mr Edstein.

(b) Mr Edstein to pay the plaintiffs damages in the agreed amount.

(c) Pursuant to s 5 of the Law Reform (Miscellaneous Provisions) Act 1946 (NSW) order that Black Head Bowling Club Ltd contribute 50% and Mr John Thomas Edstein contribute 50% to the agreed sum of damages payable to the plaintiffs.

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

Full text does not contain this section.

Ratio Decidendi

Legal Principle Established

Full text does not contain this section.