Emanuele v Australian Securities Commission

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HIGH COURT OF AUSTRALIA

BRENNAN CJ, DAWSON, TOOHEY, GAUDRON AND KIRBY JJ

EMANUELE & ANOR v AUSTRALIAN SECURITIES COMMISSION & ORS; FC 97/018, A23/1996
Companies

(1997) 188 CLR 114

5 June 1997
Companies

Companies—Winding up in insolvency—Failure to obtain leave to apply to wind up a company in insolvency—Whether order can be made granting leave nunc pro tunc—Whether requirement of leave in s 459P(2) of Corporations Law is procedural or substantive in nature. ss 459A, 459P Corporations Law s 42(3) Corporations (South Australia) Act 1990 (SA) n

Orders



Order:
1. Appeal and cross-appeal dismissed.

2. The appellants pay the respondents' costs of the appeal.

3. No order as to costs of the cross-appeal.

Decision



BRENNAN CJ:

1.The appellants were directors of a number of companies that were members of the Emanuel Group. Among that group were companies that, for the purposes of proceedings in the Full Court of the Federal Court, were identified as the "Group A Companies". They were insolvent at all relevant times. The Australian Taxation Office ("the ATO") was owed a considerable amount by some of these companies and made an application for their winding up. After that application was made, a deed of company arrangement was entered into, binding the ATO. Accordingly, by force of s 444E(2)(b) of the Corporations Law ("the Law"), the ATO was unable to "proceed with such an application made before the deed became binding on [it]". The Australian Securities Commission ("the ASC") had become a party to those proceedings by intervening therein in exercise of the power to do so conferred by s 1330 of the Law. It gave notice of an intention to apply for an order for the winding up of the companies in insolvency pursuant to s 459A of the Law which reads:
"On an application under section 459P, the Court may order that an insolvent company be wound up in insolvency."

2. The ASC was neither a creditor nor a contributory of any of the companies but, subject to the provisions of s 459P, it was competent to apply to the Court for a company to be wound up in insolvency. Section 459P reads as follows:

" (1) Any one or more of the following may apply to the Court for a company to be wound up in insolvency:

(a) the company;

(b) a creditor (even if the creditor is a secured creditor or is only a contingent or prospective creditor);

(c) a contributory;

(d) a director;

(e) a liquidator or provisional liquidator of the company;

(f) the Commission;

(g) a prescribed agency.

(2) An application by any of the following, or by persons including any of the following, may only be made with the leave of the Court:

(a) a person who is a creditor only because of a contingent or prospective debt;

(b) a contributory;

(c) a director;

(d) the Commission.

(3) The Court may give leave if satisfied that there is a prima facie case that the company is insolvent, but not otherwise.

(4)…
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Details
Case
[1997] HCA 20
Decision Date

CaseChat Overview and Summary

The High Court of Australia considered an appeal and cross-appeal concerning an application to wind up a company in insolvency. The dispute arose from the failure of the applicant to obtain the requisite leave under section 459P(2) of the Corporations Law before commencing proceedings to wind up the company. The primary question before the Court was whether it was permissible for a court to grant leave *nunc pro tunc* (retrospectively) after the application for winding up had already been made.

The central legal issues before the High Court were twofold. Firstly, whether the requirement for leave to apply for the winding up of a company under section 459P(2) of the Corporations Law was a procedural or a substantive requirement. Secondly, if it was procedural, whether a court possessed the power to grant such leave retrospectively, effectively validating an application that was initially defective for want of leave.

The High Court, in dismissing the appeal and cross-appeal, reasoned that the requirement for leave under section 459P(2) was a substantive condition precedent to the commencement of winding up proceedings. Brennan CJ, with whom Dawson, Toohey, Gaudron and Kirby JJ agreed, held that the provision was not merely procedural but went to the jurisdiction of the court to entertain the application. Consequently, an application made without the necessary leave was fundamentally flawed and could not be cured by a retrospective grant of leave. The Court affirmed that the legislative intent behind section 459P(2) was to prevent vexatious or unsubstantiated winding up applications, and allowing retrospective leave would undermine this purpose.

The appeal and cross-appeal were dismissed. The appellants were ordered to pay the respondents' costs of the appeal, with no order as to the costs of the cross-appeal.

Orders

Orders of the court

1. Appeal and cross-appeal dismissed.

2. The appellants pay the respondents' costs of the appeal.

3. No order as to costs of the cross-appeal.

Background

Background to the litigation

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Evidence

Evidence Before The Court

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Decision

Reasons for decision

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Ratio Decidendi

Legal Principle Established

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