FEDERAL CIRCUIT AND FAMILY COURT OF AUSTRALIA
(DIVISION 1)
Garwood & Shipton (No 8) [2024] FedCFamC1F 208
File number: ADC 4460 of 2023 Judgment of: TREE J Date of judgment: 28 March 2024 Catchwords: FAMILY LAW – PRACTICE AND PROCEDURE – Where the wife seeks the husband’s counsel be restrained from continuing to act for him – Application of the test in Porter v Dyer (2022) 402 ALR 659 – Assertion of abuse of process – Where there is no evidence to suggest counsel was aware of the non-disclosure of the husband – Legal professional privilege – Where there was no waiver – Conflict of interest – Where the asserted conflict is with solicitors that are no longer instructing counsel – Where neither independently nor cumulatively none of the contentions of the wife are elevated beyond the theoretical – Application dismissed. Legislation: Federal Circuit and Family Court of Australia (Family Law) Rules (2021) (Cth) rr 6.03, 6.09, 6.17 Cases cited: Abigroup Ltd v Atkins (1997) 42 NSWLR 623
Apple Inc v Samsung Electronics Co Limited (No2) [2012] FCA 1358
Attorney-General (NT) v Maurice (1986) 161 CLR 475
Charisteas & Charisteas (2022) FLC 94-109
DSE Holdings Pty Ltd v Intertan Inc (2003) 127 FCR 499
Harris v Caladine (1991) 172 CLR 84
Jones v Dunkel (1959) 101 CLR 298
Nine films and Television Pty Ltd V Ninox Television Ltd (2005) 65 IPR 442
Division: Division 1 First Instance Number of paragraphs: 81 Date of last submissions: 14 February 2024 Date of hearing: 6 and 7 February 2024 Place: Heard in Adelaide, delivered in Cairns Counsel for the Applicant: Mr Rice KC and Mr Manatta Solicitor for the Applicant: Angela Ferdinandy Counsel for the Respondent: Mr Cox KC and Ms Hume Solicitor for the Respondent: Mills Oakley ORDERS
ADC 4460 of 2023 FEDERAL CIRCUIT AND FAMILY COURT OF AUSTRALIA (DIVISION 1)
BETWEEN: MS SHIPTON
Applicant
AND: MR GARWOOD
Respondent
ORDER MADE BY:
TREE J
DATE OF ORDER:
28 MARCH 2024
THE COURT ORDERS THAT:
1.Paragraph 4 of the Applicant’s Further Amended Application in a Proceeding filed 13 August 2023 is dismissed.
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.
IT IS NOTED that publication of this judgment by this Court under the pseudonym Garwood & Shipton has been approved pursuant to s 121(9)(g) of the Family Law Act 1975 (Cth).
REASONS FOR JUDGMENT
TREE J:
INTRODUCTION
Keep reading for free
Create a free CaseChat account to read Garwood & Shipton (No 8) and more:
- Read every judgment in full
- Ask AI and get answers linked to paragraphs
- See how each paragraph was cited in later cases
- Download judgments as PDF or Word
One click creates your free account or signs you in.
By continuing you agree to the Terms and Privacy Policy.
- Case
- [2024] FedCFamC1F 208
- Decision Date
CaseChat Overview and Summary
The court examined the mother's allegations to ascertain if they met the stringent criteria set out in Porter v Dyer. The mother contended that Ms AP SC had acted in a way that might suggest an abuse of process, given her alleged failure to disclose certain information. However, the court found no evidence to suggest Ms AP SC was aware of the non-disclosure. Furthermore, the court considered issues of legal professional privilege and conflict of interest. Despite the mother's assertions, none of the alleged conflicts were substantiated, particularly as they involved solicitors no longer instructing Ms AP SC. The court concluded that the mother's claims, whether viewed individually or cumulatively, did not elevate beyond theoretical concerns.
The court held that the application to restrain Ms AP SC did not meet the threshold established by Porter v Dyer. The court noted that even if the allegations had been substantiated, the factors weighing against restraint, such as the significant delay in bringing the application and the substantial cost and disruption of replacing Ms AP SC mid-trial, were compelling. The court also observed that the mother's application appeared tactical, aimed at causing financial hardship to Mr Garwood and seeking to start anew with different legal representatives. Ultimately, the application was dismissed.
The court ordered that paragraph 4 of Ms Shipton's Further Amended Application in a Proceeding filed on 13 August 2023 be dismissed. This decision underscores the high threshold required to restrain a barrister from acting in family law proceedings, emphasizing the importance of substantial evidence and the potential consequences of such an action.
Orders
Orders of the court
ADC 4460 of 2023
FEDERAL CIRCUIT AND FAMILY COURT OF AUSTRALIA (DIVISION 1)
BETWEEN:
MS SHIPTON
Applicant
AND:
MR GARWOOD
Respondent
ORDER MADE BY:
TREE J
DATE OF ORDER:
28 MARCH 2024
THE COURT ORDERS THAT:
1. Paragraph 4 of the Applicant’s Further Amended Application in a Proceeding filed 13 August 2023 is dismissed.
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
Full text does not contain this section.
Decision
Reasons for decision
Ratio Decidendi
Legal Principle Established
It is trite to observe that this allegation can be raised, at least in theory, against every barrister appearing in a case, and sadly, on occasion demonstrably correctly. However, there is nothing on the evidence to suspect that, in the case of Ms AP SC in these proceedings, that is even slightly elevated beyond the theoretical. The test is plainly not satisfied.Cumulative consideration Here the facts are the facts, and the allegations are the allegations. The various threads to the mother’s arguments are really, when viewed from a distance, the same issues differently expressed. The cumulative consideration of them does little in the way of aggregation – the facts remain the facts. I am not satisfied that a consideration of all the matters she relies upon reaches a point where the test is satisfied. Moreover, even if the test was satisfied by the concerns which may nonetheless hover around Ms AP SC’s continued involvement in the proceedings, such that the discretion to restrain Ms AP SC arises, those concerns are vastly outweighed by:(a)The fact that the trial has now run for nine days, and the cost of alternate senior counsel coming up to speed likely to be vast, a matter which goes directly to the due administration of justice;(b)The fact that from the time her then lawyers became aware of the material on which the claim is now grounded, it took the mother nearly a year to bring her application to restrain Ms AP SC. Worse, most of that material has been in the mother’s possession at all material times since its creation, and had not been disclosed. It is, as Porter acknowledges, an exceptional thing to restrain a legal practitioner from appearing, here all the more so where the client, separately represented by eminent lawyers, nonetheless wants to have his barrister of choice continue to appear for him. This is not one of those exceptional cases, and whether the allegations are viewed individually or collectively, not only is the test not satisfied, but there are weighty matters which would strongly tell against any restraint of Ms AP SC in any event. Finally, I should advert to the claim made by the father that the mother’s application was tactical in two respects. Firstly, it was said to be an attempt to create an outcome where the father would be obliged to find a new barrister to act for him in the part-heard trial, thus occasioning him great expense. In common parlance it was said to be trying to “run him out of petrol.” Secondly, it was said that the mother, over her nine days in the witness box, gave such a poor performance that she wanted a new legal team for herself (and has that) a new solicitor acting for the father (and has that) and now wants a new barrister acting for the father (hence this application), and a new judge (she has on foot applications for Kari J to recuse herself). In other words she is using all means at her disposal to expunge any memory of her bad performance as a witness, and wants to start over with a clean slate.