Dennis v Cameron

In *Dennis v Cameron*, the New South Wales Court of Appeal considered a claim by a barrister against a solicitor for unpaid fees. The dispute arose from memoranda of fees that had been altered at the solicitor's request, leading to questions about their validity and the barrister's entitlement to payment.

The central legal issues before the Court of Appeal were whether the barrister's memoranda of fees complied with the requirements of sections 192 and 194 of the *Legal Profession Act 1987* (NSW) and regulation 22A of the *Legal Profession Regulations 1994* (NSW). Specifically, the Court had to determine whether the memoranda were sufficiently "signed" for the purposes of the legislation and what the legal effect was of the solicitor's acceptance of unsigned memoranda.

The Court of Appeal held that the memoranda of fees, as presented and altered, did not satisfy the statutory requirements for a valid bill of costs. The alterations made at the solicitor's request meant that the memoranda were not "signed" in accordance with the relevant provisions of the Act and Regulations. Consequently, the barrister was not entitled to recover the fees claimed under those memoranda. The appeal was dismissed, and the appellant was ordered to pay the costs of the appeal.