FEDERAL COURT OF AUSTRALIA
Chang v Comcare Australia [1999] FCA 1677
PRACTICE AND PROCEDURE – security for costs – application to set aside consent orders of Administrative Appeals Tribunal made pursuant to heads of agreement on grounds of duress or lack of mental capacity – whether applicant is impecunious – whether applicant likely to be able to establish duress – whether applicant likely to be able to establish lack of mental capacity – present indebtedness of applicant – quantum of security
PAUL MENG CHANG v COMCARE AUSTRALIA and COMMONWEALTH OF AUSTRALIA
AG 125 of 1998
NG 1287 of 1998
MOORE J
1 DECEMBER 1999
SYDNEY
IN THE FEDERAL COURT OF AUSTRALIA
NEW SOUTH WALES DISTRICT REGISTRY
AG 125 of 1998
NG 1287 of 1998
BETWEEN:
PAUL MENG CHANG
ApplicantAND:
COMCARE AUSTRALIA
First RespondentCOMMONWEALTH OF AUSTRALIA
Second RespondentJUDGE:
MOORE J
DATE OF ORDER:
1 DECEMBER 1999
WHERE MADE:
SYDNEY
THE COURT ORDERS THAT:
1.In proceedings AG 125 of 1998, the applicant provide security for the Commonwealth’s costs in the sum of $10,000 and Comcare Australia’s costs in the sum of $35,000.
2.If the applicant fails to comply with the order to provide security in accordance with order 1 within 28 days the proceedings be dismissed.
3. The applicant pay the costs of the application for security.
Note: Settlement and entry of orders is dealt with in Order 36 of the Federal Court Rules.
IN THE FEDERAL COURT OF AUSTRALIA
NEW SOUTH WALES DISTRICT REGISTRY
AG 125 of 1998
NG 1287 of 1998
BETWEEN:
PAUL MENG CHANG
ApplicantAND:
COMCARE AUSTRALIA
First RespondentCOMMONWEALTH OF AUSTRALIA
Second Respondent
JUDGE:
MOORE J
DATE:
1 DECEMBER 1999
PLACE:
SYDNEY
REASONS FOR JUDGMENT
Introduction
The applicant, Mr Chang, has two applications before the Court. The first application (NG 1287 of 1998) (“the judicial review proceedings”) was filed on 25 November 1998 under the Administrative Decisions (Judicial Review) Act 1977 (Cth) for judicial review of a decision of the Administrative Appeals Tribunal (“the AAT”). The first respondent was the Productivity Commission (“the Commission”) and the second respondent was Comcare Australia (“Comcare”). The second application (AG 125 of 1998) (“the appeal proceedings”) was filed on 16 December 1998 under s 44 of the Administrative Appeals Tribunal Act 1975 (Cth) (“the AAT Act”) and was an appeal from the same decision on a question of law. The first respondent was Comcare and, in due course, the second respondent was the Commonwealth. On 18 February 1999 I stood the judicial review proceedings over generally pending the outcome of the appeal proceedings.
Nature of present application
The Commonwealth has applied for orders that Mr Chang provide security for costs in the sum of $15,000.00. Comcare has sought security in the sum of $51,000.00. At the commencement of the hearing of the applications for security on 7 October 1999, it was proposed by counsel for Comcare that I decide whether security should be ordered in the appeal proceedings on the basis that the decision would effectively resolve…
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- Chang v Comcare Australia [1999] FCA 1677
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- [1999] FCA 1677
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CaseChat Overview and Summary
The court held that special circumstances existed warranting an order for security. Mr Chang’s prospects of success were deemed limited, and the respondents would be unable to recover costs if they were successful in the current proceedings due to his bankruptcy. Mr Chang had also not satisfied an earlier liability to pay costs from previous proceedings. The court ordered Mr Chang to provide security for the Commonwealth’s costs in the sum of $10,000 and for Comcare’s costs in the sum of $35,000. If Mr Chang failed to comply with the order within 28 days, the proceedings would be dismissed. The court also ordered Mr Chang to pay the costs of the application for security.
Orders
Orders of the court
1. In proceedings AG 125 of 1998, the applicant provide security for the Commonwealth’s costs in the sum of $10,000 and Comcare Australia’s costs in the sum of $35,000.
2. If the applicant fails to comply with the order to provide security in accordance with order 1 within 28 days the proceedings be dismissed.
3. The applicant pay the costs of the application for security.
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: MOORE J
In oral argument, counsel for Comcare in these proceedings submitted that the fact of the $54,740.60 payment and the implausibility of the applicant’s explanation for its dissipation provided strong grounds for doubting that Mr Chang is impecunious. However, in supplementary submissions counsel for Comcare accepted that if any of the $54,740.60 remained in Mr Chang’s hands as at 20 May 1999, such monies would have vested in the Official Trustee and would be divisible among Mr Chang’s creditors: Bankruptcy Act ss 58, 115(2), 116(2). Likewise, if any of the $54,740.60 was disposed of by Mr Chang in order to defeat creditors or “as a preference”, such monies may still be available to the Official Trustee: ss 121, 122. However, while Comcare may prove in Mr Chang’s bankruptcy for the costs it is owed in respect of the earlier proceedings before Finn J (Bankruptcy Act s 82; Re British Gold Fields of West Africa [1899] 2 Ch 7), any liability incurred by Mr Chang in respect of costs in these proceedings would not be provable in his bankruptcy. Thus, irrespective whether Mr Chang has spent, as he contends, the $54,740.60 he was earlier paid, the respondents will be unable to recover any costs incurred in these proceedings even if they are successful and a costs order made in their favour.Principal considerations as to whether security should be ordered The power of the Court to order security is contained in s 56 of the Federal Court of Australia Act 1976 (Cth) and O 53 r 8 of the Federal Court Rules. Section 56 provides:“56 (1) The Court or a Judge may order an applicant in a proceeding in the Court or an appellant in an appeal to the Court to give security for the payment of costs that may be awarded against him or her.(2) The security shall be of such amount, and given at such time and in such manner and form, as the Court or Judge directs.(3) The Court or a Judge may reduce or increase the amount of security ordered to be given and may vary the time at which, or manner or form in which, the security is to be given.(4) If security, or further security, is not given in accordance with an order under this section, the Court or a Judge may order that the proceeding or appeal be dismissed.(5) This section does not affect the operation of any provision made by or under any other Act or by the Rules of Court for or in relation to the furnishing of security.”Order 53 r 8, which concerns appeals from the AAT, provides:“8 (1) The Court may, in special circumstances, order that such security for costs of appeal to the Court be given as it thinks fit.(2) Subject to sub-rule (1), no security for costs of an appeal to the Court shall be required.”The submissions of counsel raised the following considerations:Mr Chang’s impecuniosity While impecuniosity is not, by itself, sufficient to warrant an order for security, it is generally a relevant consideration: Barton v Minister for Foreign Affairs (1984) 2 FCR 463 at 469 per Morling J; Equity Access Ltd v Westpac Banking Corporation (1989) ATPR 40-972 at 50,635 – 50,636 per Hill J. Mr Chang is impecunious at least in the sense that Mr Chang will not be able to satisfy any order for costs. Moreover, counsel for Comcare submitted that the applicant’s impecuniosity was not caused or contributed to by Comcare and does not arise out of the settlement of the compensation proceedings. Counsel for Mr Chang did not attempt to argue otherwise.The applicant’s prospects in the litigation