FEDERAL CIRCUIT AND FAMILY COURT OF AUSTRALIA
(DIVISION 1)
Chen & Chen [2024] FedCFamC1F 48
File number MLC 5805 of 2016 Judgment of WILSON J Date of judgment 27 February 2024 Catchwords FAMILY LAW – MAJOR COMPLEX FINANCIAL PROCEEDINGS LIST – LIQUIDATORS AND RECEIVERS – COMPANY LAW – remuneration application by joint and several liquidators appointed to several respondents and joint and several receivers appointed to several trusts – large sums sought by way of remuneration – part of claim made for remuneration in respect of work not yet undertaken – whether claimable – whether remuneration maintainable according to the provisions of the Insolvency Practice Schedule (Corporations) of Schedule 2 to the Corporations Act, of rule 11.49 of the rules of court and of what the insolvency practitioners asserted was “the inherent jurisdiction of this Honourable Court” – remuneration ordered. Legislation Corporations Act 2001 ss 60, 473, 477, 556
Evidence Act 2008 s 138
Family Law Act 1975 ss 79, 117
Federal Circuit and Family Court of Australia Act 2021 s 272
Federal Court of Australia Act 1976
Federal Circuit and Family Court of Australia (Family Law) Rules 2021
Federal Circuit and Family Court of Australia (General Federal Law) Rules 2021
Federal Court (Corporations) Rules 2000
Companies Act (UK) (25 & 26 Vict c 89) s 81
Cases cited Alcan (NT) Alumina Pty Ltd v Commissioner of Territory Revenue (2009) 239 CLR 27
Arkin & Blasberg [2019] FamCA 476
Batten v Wedgwood Coal and Iron Co (1884) 28 Ch D 317
Burns Philp Investments Pty Ltd v Dickens (No 2) (1993) 31 NSWLR 280
Carr v Western Australia (2007) 232 CLR 138
Carter Holt Harvey Wood Products Australia Pty Ltd vCommonwealth of Australia (2010) 268 CLR 524
Chen v Chen (No 3) (2020) 63 Fam LR 448
Computer Machinery Co Ltd v Drescher [1983] WLR 1379
Deputy Commissioner of Taxation v Shi (2021) 273 CLR 235
Director of Public Prosecutions for Victoria v Le (2007) 232 CLR 562
Downes v Cottam [1893] 1 Ch 547
Fitzgerald v Fish and Anor (2005) 33 Fam LR 123
Hillam & Barret [2019] FamCA 193
Holder & Holder [2022] FamCA 347
In the Matter of Barokes Pty Ltd (in liq); Koutsoukos v Daiwa Can Company [2020] VSC 555
In the Matter of Houben Marine Pty Ltd (in liq) [2018] NSWSC 745
In the Matter of Idylic Solutions Pty Ltd [2016] NSWSC 1292
Jess & Jess (No 7) [2023] FedCFamC1F 291
Karjala & Gallard [2020] FamCA 110
Lin v Yew (2021) 62 Fam LR 244
Northern Territory v Collins (2008) 235 CLR 619
Paul’s Retail Pty Ltd v Morgan (2009) 76 ASCR 26
Project Blue Sky Inc v Australian Broadcasting Authority (1998) 194 CLR 355
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- AGLC
- Chen & Chen [2024] FedCFamC1F 48
- Case
- [2024] FedCFamC1F 48
- Decision Date
CaseChat Overview and Summary
The court found that the primary consideration for approving the remuneration was the reasonableness of the sums claimed. While creditors' approval was relevant, it was not determinative. The court referenced the decision in Re MJM (WA) Enterprises Pty Ltd (in liq) to support the notion that the reasonableness of the claim was the key factor. Additionally, the court noted that when dealing with remuneration from trust assets, it exercised its inherent jurisdiction rather than a statutory one, as per the decision in In the Matter of Houben Marine Pty Ltd (in liq). After considering the evidence and submissions, the court approved the remuneration sought by the joint and several liquidators and receivers.
The court ordered that the liquidators and receivers were entitled to their respective remuneration for the specified periods, as detailed in the reasons for judgment. The court also dispensed with compliance with certain procedural requirements and directed that the costs of the application be recovered from the companies in liquidation and the trusts in receivership. Any interested party was granted liberty to apply to modify the orders, provided they gave at least 72 hours' notice.
Orders
Orders of the court
MLC 5805 of 2016
FEDERAL CIRCUIT AND FAMILY COURT OF AUSTRALIA (DIVISION 1)
BETWEEN
MS CHEN
Applicant
AND
MR CHEN
First Respondent
MS QUEN
Second Respondent
ORDER MADE BY
WILSON J
DATE OF ORDER
27 FEBRUARY 2024
THE COURT ORDERS THAT –
1. Pursuant to section 60-10(1)(c) of the Insolvency Practice Schedule (Corporations) (IPS), being Schedule 2 of the Corporations Act 2001 (Cth), the liquidators are entitled to remuneration for necessary work properly performed as liquidators of Quen Pty Ltd (in liquidation) of –
(a) $29,454.00 (plus GST) for the period of 1 January 2023 to 14 July 2023; and
(b) $75,000.00 (plus GST) for the period of 15 July 2023 to 31 March 2024.
2. Pursuant to section 60-10(1)(c) of the IPS, the liquidators are entitled to remuneration for necessary work properly performed as liquidators of E Pty Ltd (in liquidation) (ACN …) of –
(a) $33,670.50 (plus GST) for the period of 1 January 2023 to 14 July 2023; and
(b) $75,000.00 (plus GST) for the period of 15 July 2023 to 31 March 2024.
3. Pursuant to section 60-10(1)(c) of the IPS, the liquidators are entitled to remuneration for necessary work properly performed as liquidators of F Pty Ltd (in liquidation) of –
(a) $30,227.50 (plus GST) for the period of 1 January 2023 to 14 July 2023; and
(b) $75,000.00 (plus GST) for the period of 15 July 2023 to 31 March 2024.
4. Pursuant to rule 11.49 of the Federal Circuit and Family Court of Australia Rules 2021, the receivers are entitled to remuneration for work performed as receivers of the Quen Family Discretionary Trust of –
(a) $106,509.00 (plus GST) and $116.43 (plus GST) for internal disbursements for the period of 25 August 2022 to 14 July 2023; and
(b) $75,000.00 (plus GST) and $500.00 (plus GST) for internal disbursements for the period of 15 July 2023 to 31 March 2024.
5. Pursuant to rule 11.49 of the Federal Circuit and Family Court of Australia Rules 2021, the receivers are entitled to remuneration for work performed as receivers of the E Family Trust of –
(a) $132,668.50 (plus GST) and $424.68 (plus GST) for internal disbursements for the period of 25 August 2022 to 14 July 2023; and
(b) $75,000.00 (plus GST) and $500.00 (plus GST) for internal disbursements for the period of 15 July 2023 to 31 March 2024.
6. Pursuant to rule 11.49 of the Federal Circuit and Family Court of Australia Rules 2021, the receivers are entitled to remuneration for work performed as receivers of the F Family Trust of –
(a) $115,098.50 (plus GST) and $339.50 (plus GST) for internal disbursements for the period of 25 August 2022 to 14 July 2023; and
(b) $75,000.00 (plus GST) and $500.00 (plus GST) for internal disbursements for the period of 15 July 2023 to 31 March 2024.
7. Compliance with the requirements of rule 9.2(2) of the Federal Court (Corporations) Rules 2000 is dispensed with.
8. The applicants’ costs of and incidental to this application are costs in the liquidation of the companies in liquidation and in the receiverships of the trusts.
9. Any person who can demonstrate sufficient interest to modify these orders has liberty to apply on not less than 72 hours notice.
10. The costs of the joint liquidators and receivers of and incidental to this remuneration application are to be assessed by a registrar of this court and when assessed recovered from the companies in liquidation and the trusts in receivership as the case may.
Note: The form of the order is subject to the entry in the Court’s records.
Note: This copy of the Court’s Reasons for judgment may be subject to review to remedy minor typographical or grammatical errors (r 10.14(b) Federal Circuit and Family Court of Australia (Family Law) Rules 2021 (Cth)), or to record a variation to the order pursuant to r 10.13 Federal Circuit and Family Court of Australia (Family Law) Rules 2021 (Cth).
Section 121 of the Family Law Act 1975 (Cth) makes it an offence, except in very limited circumstances, to publish proceedings that identify persons, associated persons, or witnesses involved in family law proceedings.
Background
Background to the litigation
Evidence
Evidence Before The Court
Decision
Reasons for decision
Full text does not contain this section.
Ratio Decidendi
Legal Principle Established
While I have not decided this issue it will readily be apparent that in respect of the entities in liquidation, the proper person to undertake all tasks involved in getting in assets relevant to the insolvent administrations is the liquidator and his staff, not the husband.SUBMISSIONS IN SUPPORT OF THE REMUNERATION APPLICATION By written submissions filed 15 November 2023, the solicitors for the joint liquidators and receivers addressed certain factual and legal bases in support of orders for the remuneration sought. In précis form, those solicitors wrote as follows – (a)approval of the liquidators’ remuneration relates to three companies; (b)approval of the receivers’ remuneration relates to three trusts; (c)the liquidators’ remuneration application relates to two separate periods, the first being 1 January 2023 to 14 July 2023 and the second being 15 July 2024 to 31 March 2024; (d)the receivers’ remuneration application relates to two separate periods, the first being 25 August 2022 to 14 July 2023 and the second being 15 July 2023 to 31 March 2024; (e)pursuant to rule 11.49(2) of the rules, the consent receivership orders made by me on 25 August 2022 provided for payment of the receivers’ costs in such manner that those costs were to be treated in the same way as if they were costs in the liquidation of the companies in liquidation to be paid in accordance with the priority set out in s 556(1) of the Corporations Act;(f)creditors of Quen Pty Ltd (in liq) have previously approved the remuneration of the liquidators for the period 20 May 2022 to 31 December 2022 at $148,948.15 of which the sum of $133,924.63 has been paid; (g)creditors of E Pty Ltd (in liq) have previously approved remuneration of the liquidators for the period of 23 May 2022 to 1 December 2022 at $135,287.77 of which the sum of $115,733.49 has been paid; and (h)creditors of F Pty Ltd (in liq) have previously approved the remuneration of the liquidators for the period 20 May 2022 to 31 December 2022 at $142,895.70 of which the sum of $110,998.59 has been paid. The liquidators’ and receivers’ solicitors submitted that on this remuneration application, no approval has yet been given for the amounts claimed in respect of which part of the period claimed relates to activities actually conducted and part relates to activities yet to be conducted up to and including 31 March 2024. They argued that the activities demonstrate that the primary consideration for the court invited to approve the remuneration is the reasonableness of the sum claimed and in that regard, creditors’ approval is relevant but not determinative, citing the decision of the Supreme Court of New South Wales in Re MJM (WA) Enterprises Pty Ltd (in liq).[11][11] [2018] NSWSC 944 (at [10]). In their written submissions the solicitors for the liquidators and the receivers contended that the court’s power to approve liquidators’ and receivers’ remuneration from trust assets, the court is not exercising a statutory jurisdiction but rather the court is exercising its inherent jurisdiction when dealing with remuneration from trust assets in connection with the administration of the trust fund. They relied on the decision of the Supreme Court of New South Wales in In the Matter of Houben Marine Pty Ltd (in liq).[12][12] [2018] NSWSC 745 (at [19]).