HIGH COURT OF AUSTRALIA
BRENNAN CJ,
GAUDRON, McHUGH, GUMMOW AND KIRBY JJ
DENISE MARY CANNANE & ANOR APPELLANTS
J CANNANE PTY LIMITED
(In Liquidation) & ANOR RESPONDENTS
Cannane v Cannane Pty Limited;
Cannane v Official Trustee in Bankruptcy as Trustee
of the Bankrupt Estate of Cannane
(S215-1996) [1998] HCA 26
7 April 1998
ORDER
Appeal allowed with costs.
Orders of the Full Court of the Federal Court set aside and in lieu thereof order that the appeals to that Court be allowed with costs, the Orders of Tamberlin J be set aside and in lieu thereof order that the present respondents' application for relief under s 565 of the Corporations Law be dismissed with costs.
On appeal from the Federal Court of Australia
Representation:
D M J Bennett QC with S J McMillan for the appellants (instructed by Ferrier & Associates)
P G Hely QC with J W J Stevenson for the respondents (instructed by Mallesons Stephen Jaques)
Notice: This copy of the Court’s Reasons for Judgment is subject to formal revision prior to publication in the Commonwealth Law Reports.
HIGH COURT OF AUSTRALIA
BRENNAN CJ,
GAUDRON, McHUGH, GUMMOW AND KIRBY JJ
ANDREW VINCENT CANNANE & ANOR APPELLANTS
OFFICIAL TRUSTEE IN BANKRUPTCY
AS TRUSTEE OF THE BANKRUPT ESTATE
OF JOHN VINCENT CANNANE RESPONDENT
7 April 1998
S216/1996
ORDER
Appeal allowed with costs.
Orders of the Full Court of the Federal Court set aside and in lieu thereof order that the appeals to that Court be allowed with costs, the Orders of Tamberlin J be set aside and in lieu thereof order that the present respondent's application for relief under ss 120 and 121 of the Bankruptcy Act 1966 (Cth) be dismissed with costs.
On appeal from the Federal Court of Australia
Representation:
D M J Bennett QC with S J McMillan for the appellants (instructed by Ferrier & Associates)
P G Hely QC with J W J Stevenson for the respondent (instructed by Mallesons Stephen Jaques)
Notice: This copy of the Court’s Reasons for Judgment is subject to formal revision prior to publication in the Commonwealth Law Reports.
CATCHWORDS
Cannane & Anor v J Cannane Pty Limited & Anor;
Cannane & Anor v Official Trustee in Bankruptcy as Trustee of the Bankrupt Estate of John Vincent Cannane
Bankruptcy - Disposition of Property - Intention of bankrupt to use corporate vehicle owned by bankrupt for purchase of business for the purpose of a "back door listing" - Transfer of share in corporate vehicle to family members for nominal but adequate consideration in expectation of increase in value - Subsequent purchase of business by corporate vehicle and commensurate increase in value of share - Whether disposition of property for undervalue - Whether creditors entitled to the increased value of share - Whether intent to defraud creditors.
Corporations - Winding up - Undue preference - Disposition of property - Intention to use subsidiary corporate vehicle for purchase of business for the purpose of a "back door listing" - Transfer and issue of shares…
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- Case
- [1998] HCA 26
- Decision Date
CaseChat Overview and Summary
The central legal issue was whether the transfers of shares in Wisbeck Pty Ltd by Mr Cannane and J Cannane Pty Ltd to his wife and son constituted a disposition of property with intent to defraud creditors, rendering the transfers voidable under s 121 of the *Bankruptcy Act*. This required the court to determine the meaning and application of the phrase "with intent to defraud creditors" in the context of the statutory provision and the specific facts, particularly whether the transfers were made for valuable consideration and in good faith.
The High Court allowed the appeals, setting aside the orders of the Full Court of the Federal Court. The Court reasoned that s 121 of the *Bankruptcy Act*, as it stood at the time, required an actual intent to defraud creditors on the part of the transferor. While it was accepted that the purpose of the transfers was to ensure that Mr Cannane's family, rather than his and the company's creditors, would benefit from the potential success of the CCI venture, the Court found that there was no evidence of an intent to defraud. The transfers were made for nominal but adequate consideration in the context of the shares' value at the time of transfer, and the transferees, particularly Andrew Cannane, did not have knowledge of any fraudulent intent. The Court applied the principle that a disposition is only voidable under s 121 if there is an actual intent to defraud, and that bona fide purchasers for valuable consideration without notice are protected.
Consequently, the High Court ordered that the applications for relief under s 565 of the *Corporations Law* (which had been the basis of the proceedings in the Federal Court) be dismissed with costs.
Orders
Orders of the court
1.
Appeal allowed with costs.
2.
Orders of the Full Court of the Federal Court set aside and in lieu thereof order that the appeals to that Court be allowed with costs, the Orders of Tamberlin J be set aside and in lieu thereof order that the present respondents' application for relief under s 565 of the Corporations Law be dismissed with costs.
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
Established by: BRENNAN CJ, HUGH J,
Full text does not contain this section.