Federal Circuit and Family Court of Australia
(DIVISION 1) APPELLATE JURISDICTION
Fierro & Fierro (No 7) [2023] FedCFamC1A 24
Appeal from: Fierro & Fierro (No 5) [2022] FedCFamC1F 948 Appeal number: NAA 263 of 2022 File number: SYC 7639 of 2021 Judgment of: AUSTIN, WILLIAMS & HOWARD JJ Date of judgment: 14 March 2023 Catchwords: FAMILY LAW – APPEAL – Contempt – Where the primary judge dismissed all contempt counts alleged against the respondents – Error of law – Where the primary judge conflated two different legal tests when dismissing the contempt counts – Where allegations of contempt are not amenable to application of the summary dismissal principles which apply in conventional civil proceedings – Where the primary judge erred at law – Where there was no miscarriage of justice as the dismissal orders are plainly correct for other reasons and should not be disturbed – Appeal dismissed.
FAMILY LAW – APPLICATION IN AN APPEAL – Further evidence – Where the proposed evidence does not make it clear how or why the primary judge erred by dismissing the contempt counts against the respondents – Application dismissed.
Legislation: Crimes Act 1914 (Cth) ss 35, 36
Evidence Act 1995 (Cth) Ch 3
Family Law Act 1975 (Cth) Pt VII, ss 69ZM, 69ZT, 112AP
Federal Circuit and Family Court of Australia Act 2021 (Cth) ss 45, 46
Federal Circuit and Family Court of Australia (Family Law) Rules 2021 (Cth) rr 10.09, 11.70, 11.71
Criminal Procedure Act 1986 (NSW) ss 17, 18
Cases cited: Australian Securities and Investments Commission v Healey (2011) 196 FCR 291; [2011] FCA 717
CDJ v VAJ (1998) 197 CLR 172; [1998] HCA 67
Construction, Forestry, Mining and Energy Union v Boral Resources (Vic) Pty Ltd (2015) 256 CLR 375; [2015] HCA 21
Conway v The Queen (2002) 209 CLR 203; [2002] HCA 2
Coward v Stapleton (1953) 90 CLR 573; [1953] HCA 48
Driclad Pty Ltd v Commissioner of Taxation (1968) 121 CLR 45; [1968] HCA 91
European Asian Bank AG v Wentworth (1986) 5 NSWLR 445
Fierro & Fierro (No 4) [2022] FedCFamC1A 208
Fierro & Fierro (No 4) [2022] FedCFamC1F 687
Fraser v The Queen [1984] 3 NSWLR 212
House v The King (1936) 55 CLR 499; [1936] HCA 40
James v Australia and New Zealand Banking Group Ltd (1986) 64 ALR 347; [1986] FCA 41
Keeley v Brooking (1979) 143 CLR 162; [1979] HCA 28
Kowalski v MMAL Staff Superannuation Fund Pty Ltd (2009) 178 FCR 401; [2009] FCAFC 117
May v O’Sullivan (1955) 92 CLR 654; [1955] HCA 38
Mead v Mead (2007) FLC 93-327; [2007] HCA 25
Re Colina; Ex parte Torney (1999) 200 CLR 386; [1999] HCA 57
Registrar of the Court of Appeal v Collins [1982] 1 NSWLR 682
Spencer v The Commonwealth (2010) 241 CLR 118; [2010] HCA 28
New South Wales v Beck [2013] NSWCA 437
Tate v Johnson (1953) 70 WN (NSW) 302
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- AGLC
- Fierro & Fierro (No 7) [2023] FedCFamC1A 24
- Case
- [2023] FedCFamC1A 24
- Decision Date
CaseChat Overview and Summary
The legal issues the court needed to decide included whether the primary judge had correctly applied the legal principles in dismissing the contempt applications and whether the proposed further evidence adduced by the appellant would assist in determining the appeal. The court had to consider whether the primary judge had correctly exercised his discretion in dismissing the contempt applications and whether the proposed further evidence was relevant and necessary to the appeal.
The court held that while the primary judge had fallen into error by incorrectly applying legal principles, the dismissal orders were correct for other reasons and should not be disturbed. The proposed further evidence did not make it clear how or why the primary judge had erred in dismissing the contempt counts against the respondents, and it did no more than underscore the antipathy which continued to prevail between the parties. The appeal was dismissed.
The court dismissed the appellant's application to adduce further evidence in the appeal and dismissed the appeal itself. The primary judge's dismissal of the contempt applications was affirmed.
Orders
Orders of the court
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Background
Background to the litigation
Evidence
Evidence Before The Court
Decision
Reasons for decision
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Ratio Decidendi
Legal Principle Established
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