FEDERAL COURT OF AUSTRALIA
Canberra Residential Developments Pty Limited v Brendas (No 5) [2009] FCA 34
EQUITY – fiduciary duties owed by a director of a trustee company developing land on behalf of a syndicate of builders who formed a joint venture to do so – whether duties breached when the Joint Venture Deed precluded the acquisition of further land without the unanimous approval of all members of the joint venture and, in the absence of any such approval, a company in which the director was interested acquired other land
Held: there was no breach of fiduciary duty by the directorCorporations Act 2001 (Cth) ss 45A, 135, 249H(1) and (2), 250N, 286(1), 292(2), 293, 294, 295, 298 and 1317H
Partnership Act 1963 (ACT) s 7
Hospital Products Limited v United States Surgical Corporation (1984) 156 CLR 41
Consul Development Pty Limited v D.P.C. Estates Pty Limited (1975) 132 CLR 373
Aberdeen Railway Co v Blaikie Brothers (1854) 1 Macq. 461
Phipps v Boardman [1967] 2 AC 46
Hurley v BGH Nominees Pty Ltd (1982) 6 ACLR 791; (1984) 10 ACLR 197
Walker v Wimborne (1976) 137 CLR 1
Spies v The Queen (2000) 201 CLR 603
Cope v Butcher (1996) 20 ACSR 37
Moorgate Tobacco Co Limited v Philip Morris Limited (No. 2) (1984) 156 CLR 414
James Birtchnell v The Equity Trustees, Executors and Agency Company Limited (1929) 42 CLR 384
United Dominions Corporation Limited v Brian Proprietary Limited (1985) 157 CLR 1
In Plus Group Ltd v Pyke [2002] 2 BCLC 201
H.A. Stephenson & Son Limited (in liquidation) v Gillanders, Arbuthnot and Company (1931) 45 CLR 476
Re Tivoli Freeholds Ltd [1972] V.R. 445
Farah Constructions Pty Limited v Say-Dee Pty Limited (2007) 230 CLR 89
Maguire v Makaronis (1997) 188 CLR 449
Japan Abrasive Materials Pty Ltd v Australian Fused Materials Pty Ltd (1998) 16 ACLC 1,172
Securities and Exchange Commission v Chenery Corporation (1943) 318 US 80
Pilmer v Duke Group Limited (in Liquidation) (2001) 207 CLR 165
CANBERRA RESIDENTIAL DEVELOPMENTS PTY LIMITED ACN 098 326 375 v SPIROS BRENDAS, BEVERLEY ROSE BRENDAS, KENOSS PTY LIMITED ACN 008 544 232 AND CANBERRA LAND DEVELOPMENTS PTY LIMITED ACN 103 875 823
ACD 21 OF 2006GRAHAM J
30 JANUARY 2009
CANBERRA
IN THE FEDERAL COURT OF AUSTRALIA
AUSTRALIAN CAPITAL TERRITORY DISTRICT REGISTRY
ACD 21 OF 2006
BETWEEN:
CANBERRA RESIDENTIAL DEVELOPMENTS PTY LIMITED ACN 098 326 375
Applicant
AND:
SPIROS BRENDAS
First RespondentBEVERLEY ROSE BRENDAS
Second RespondentKENOSS PTY LIMITED ACN 008 544 232
Third RespondentCANBERRA LAND DEVELOPMENTS PTY LIMITED ACN 103 875 823
Fourth Respondent
JUDGE:
GRAHAM J
DATE OF ORDER:
30 JANUARY 2009
WHERE MADE:
CANBERRA
THE COURT ORDERS THAT:
1.The Further Amended Application filed 19 November 2007 be dismissed.
2.The Applicant pay the Respondents’ costs.
Note:Settlement and entry of orders is dealt with in Order 36 of the Federal Court Rules.
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- Case
- [2009] FCA 34
- Decision Date
CaseChat Overview and Summary
The court examined the terms of the Joint Venture Deed, particularly Clause 36.2, which established the agreement between the parties and stipulated that it could only be altered by a special majority. The court found that the Joint Venture Deed clearly precluded the acquisition of additional land without unanimous approval from all members. However, the court also considered the broader context of the joint venture agreement and the director's conduct. It was established that the director did not participate in the new joint venture as he was not permitted to do so. The court held that there was no evidence to suggest that the director's actions were in conflict with his fiduciary duties or that he gained any personal benefit from the acquisition of the additional land. The court concluded that there was no breach of fiduciary duty by the director.
As a result of the court's findings, the further amended application filed by the respondent was dismissed, and the applicant was ordered to pay the respondents' costs. The court's decision underscores the importance of adhering to the terms of joint venture agreements and the need for directors to act in the best interests of the company and its stakeholders.
Orders
Orders of the court
1. The Further Amended Application filed 19 November 2007 be dismissed.
2. The Applicant pay the Respondents’ costs.
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
Established by: GRAHAM J
It is clear from Mr Cobanov’s note of the meeting on 19 March 2003 that the priority list so far as those members of the former syndicate/joint venture, who wished to become involved in a new joint venture together with others, were concerned was (i) Horse Park 2(ii) Condor(ii) DunlopConsideration of purchasing Horse Park 2 An agenda for a ‘Directors Meeting’ called for 28 January 2003 at the Croatia Deakin Soccer Club showed the anticipated attendees, who were the actual attendees, as Messrs Mihailidis, Glavinic, Robert Cobanov, Frank Porreca and Brendas. The last item on the agenda was ‘Land Release Report’. Mr Glavinic’s notes on his copy of the agenda are not easy to follow. It may be that apart from the misspelling of a number of English words, he has used words in the Croatian language. His note reads:‘Deni (sic) [referring to Mr Mihailidis] [unreadable] oction (sic) end of March olso (sic) land octon (sic) [unreadable] push fowurd (sic)’ Mr Glavinic’s file note of the 28 January 2003 meeting included, after translation and transcription:‘6We talked about Gangalen [Gunghalin (sic)] auction, it will be at the end of March. We have to get prepared for auction, together with our members.’ Mr Cobanov’s note of the same meeting included:‘LAND RELEASE End of March … Land Auction brought forward from → May’ Mr Frank Porreca’s note of the ‘Committee Meeting’ concluded with:‘• Auction – end of March – Combined May & March.’ Mr Glavinic’s note of a ‘Committee Meeting’ on 11 February 2003, attended by Messrs Mihailidis, Frank Porreca, Robert Cobanov and himself but ‘without Spiro, because Spiro was not invited’ when translated and transcribed included:‘Deni [Danny] suggested to apply for bidding at the auction for Andro … perhaps Frank’s father’ The applicant concedes that Mr Brendas ‘was not permitted to participate’ in a new joint venture with other interested syndicate or joint venture members from joint venture no. 1. As previously indicated such an application for the right to bid in respect of Condor 4 Estate, Horse Park II Estate, Dunlop 4 West Estate and Block 6 Section 157 Belconnen was signed by Mr Glavinic on 27 February 2003. On 4 March 2003 an internal memo was sent from the manager of ‘Property Development & Investment Group 2’ to ‘Property Finance Manager & SCB, PD & IG’ within National Australia Bank Limited in relation to the possible involvement of Canberra Residential Developments Pty Limited and others in the purchase of Condor 4, Dunlop 4 or Horse Park 2. The memorandum included:‘Re: Canberra Residential Developments Pty Ltd (CRD) & Others (To form a new entity)NOTE AS A NEW ENTITY IS BEING FORMED AND LEND WILL BE 70% OF MARKET VALUE THIS APPLICATION IS NOT AGGREGATED WITH EXISTING CRD EXPOSURE.AUCTION 27/3/03Comments PFI & Then Peter Mitchell SCB URGENT ACTION 27/3/03Further to our support material of 4/3 we provide the following information to support the issuance of a indicative letter of offer …Please note Stage 1 horsepark estate was settled 1/3/03 ( $ 9 Million) Stage 2 anticipated 4/03 Stage 3 &3b 6/03The strength of the group is that 100 % presales occurs as the individual members must purchase and pay for their blocks prior to receipt of the title. This is done to reduce stamp duty costs and all members are aware of this requirement to pay prior to titles issuing. With stage 1 we made the call and all funds were received within 5 days of call. Our call for the funds is made once each stage achieves practical completion.This is a very strong group…Purpose – The Majority of the members of CRD plus a number of other quality builders who wish to join the group now wish to purchase further land to develop as they will be finished the current project in a few months time. They perceive that shareholders will number between 30 & 40 and require indicative approval to go to Auction to bid for 2 of the 3 englobo Land auctions that will occur this month. It is important to note that there is only a couple of land releases each year.A/ Condor 4 126 Blocks …B/ Dunlop 4 130 Blocks …C/ Gungahlin 317 dwellings … (stage 2 Horsepark estate)…RECOMMENDATION-The strength of this group is their number & financial position & if there was a issue the risk is spread between 30-45 guarantors.…The groups main aim is to produce stock to their members at a base price.…’