FEDERAL COURT OF AUSTRALIA
Chacmol Holdings Pty Limited v Handberg (in his capacity as Administrator of Australian Risk Analysis Pty Limited) [2005] FCAFC 40
PRACTICE AND PROCEDURE - Appeal - Leave to - From interlocutory judgment - Answers given to questions set down for a preliminary hearing - Relevant considerations - Well-settled principles - Caution to be exercised in hearing questions as preliminary matters - Leave granted.
CONTRACT - Meaning and operation of an all moneys clause in a Deed of Charge - Three instruments executed to effect sale of business - Contract of Sale - Deed of Acknowledgement of Debt - Deed of Charge - Not contemporaneously executed - Unusually long delay until execution of Deed of Charge - Fixed charge - Floating charge - Basic and significant distinction between fixed and floating charge - All moneys clause - Usual terms of all moneys clauses - Principles of construction of contract - Objective approach - Conflict between recital and operative clause - Operative clause unambiguous - Operative clause prevails - Appeal allowed.
Federal Court Rules O 29 r 2(a)
Décor Corp Pty Limited v Dart Industries Ltd (1991) 33 FCR applied
Neimann v Electronic Industries Ltd [1978] VR 431 applied
Grant v John Grant & Sons Pty Limited (1954) 91 CLR 112 discussed
Glynn v Margetson [1893] AC 351 referred to
Fountain v Bank of America National Trust & Savings Association (1992) 5 BPR 11 referred to
Buchler v Talbot [2004] 2 AC 298 approved
Fire Nymph Products Pty Ltd v Heating Centre Pty Ltd (in liq) (1992) 7 ACSR 365 approved
Re Bankrupt Estate of Donnelly v Commonwealth Bank of Australia Ltd (1996) 140 ALR 46 referred to
Leggott v Barrett (1880) 15 Ch D 306 at 309 applied
MacKenzie v Duke of Devonshire (1896) AC 400 at 406 approved
Inland Revenue Commissioners v Raphael (1935) AC 96 approved
O’Loughlin v Mount (1998) 71 SASR 206 discussed
Equuscorp Pty Limited v Glengallan Investments Pty Limited [2004] HCA 55 applied
State of Queensland v J L Holdings Pty Ltd (1997) 189 CLR 146 applied
McVeigh, In the Matter of Piccolo v National Australia Bank Ltd [2000] FCA 187 distinguished
Manks v Whiteley (1912) 1 Ch 735 distinguished
Codelfa Constructions Pty Ltd v State Rail Authority of New South Wales (1981-1982) 149 CLR 337 discussed
Bank of Credit and Commerce International SA v Ali [2002] 1 AC 251 distinguished
Re Clark’s Refrigerated Transport Pty Ltd (In Liquidation) [1982] VR 989 referred toChitty on Contracts, 27th edn, Sweet & Maxwell, London, 1994
K. Lewison The interpretation of contracts, Sweet and Maxwell, London 1989
J. O’Donovan and J.C. Phillips, The modern contract of guarantee Law Book Co, Sydney, 1992
Sir Frederick Pollock Principles of contract, 3rd ed, Stevens & Sons, London, 1929
Norton on Deeds 2nd edn (1928), Sweet and Maxwell, London
Halsbury’s Laws of Australia, vol 10CHACMOL HOLDINGS PTY LIMITED (ACN 008 605 892) AND MATTHEW LEE JOHNSTON v GEOFFREY NIELS HANDBERG (IN HIS CAPACITY AS…
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- Case
- [2005] FCAFC 40
- Decision Date
CaseChat Overview and Summary
The court found that the primary Judge had erred in excluding evidence that was relevant to the case. The evidence in question was intended to demonstrate that the parties had contemplated further advances by Chacmol to ARA at the time of executing the contract, acknowledgment, and deed. The court concluded that this evidence was relevant to rebut the assertion that the three documents constituted a single transaction, and that the "all moneys" clause in the deed should only include ARA's obligations under clause 5 of the acknowledgment. The court also found that the primary Judge had misapplied the principle that several instruments made to effect one object may be construed as one instrument and read together.
As a result of the errors made by the primary Judge, the appeal was allowed, and the orders of the primary Judge were set aside. The matter was remitted to be heard in accordance with the court's reasons. The respondents were ordered to pay the appellants' costs of the appeal.
Orders
Orders of the court
1. Leave be granted to the Appellants to appeal from the interlocutory judgment of primary Judge.
2. Appeal allowed.
3. Orders of primary Judge set aside.
4. Matter remitted for hearing in accordance with these reasons.
5. The Respondents pay the Appellants’ costs of this appeal.
Background
Background to the litigation
Evidence
Evidence Before The Court
Decision
Reasons for decision
Ratio Decidendi
Legal Principle Established
Established by: TAMBERLIN, NORTH AND DOWSETT JJ
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