FEDERAL COURT OF AUSTRALIA
Geneva Laboratories Limited v Nguyen [2014] FCA 1270
Citation: Geneva Laboratories Limited v Nguyen [2014] FCA 1270 Parties: GENEVA LABORATORIES LIMITED v STEVEN NGUYEN TRADING AS HEALTH LINE PHARMACY SYDNEY, TANIA HOANG TRADING AS HEALTH LINE PHARMACY SYDNEY, INSPIRED HEALTH (AUST) PTY LTD (ACN 161 693 625), JOHN NGUYEN, VINOD NEGI TRADING AS CINCOTTA DISCOUNT CHEMIST CARLINGFORD and SAMER MEGALLI TRADING AS SHOPSMART WHOLESALE PHARMACY NEWTOWN File number: NSD 710 of 2014 Parties: GENEVA LABORATORIES LIMITED v OZE-PHARMACY PTY LTD (ACN 092 541 510), RAYMOND SHAHIDI, WARREN TURNER, CASTLE HILL PHARMACY PTY LTD (ACN 166 252 839), ZELIMIR ANTHONY SEMAN, OZE-PHARMACY GROUP PTY LTD (ACN 129 906 912), OZE-PHARMACY NORTHERN BEACHES PTY LTD (ACN 111 485 502), OZE-PHARMACY TUGGERAH SERVICES PTY LTD (ACN 154 500 508) and HIGH STREET PENRITH PHARMACY PTY LTD (ACN 166 252 900) File number: NSD 711 of 2014 Judge: GLEESON J Date of judgment: 25 November 2014 Catchwords: PRACTICE AND PROCEDURE – application for discharge of ex parte search and seizure orders and delivery up orders – where orders for seizure and delivery up of allegedly counterfeit skincare product – where respondents are registered pharmacists – where orders executed – whether applicant breached duty of candour – whether any risk that evidence might be destroyed or caused to become unavailable – whether orders should be discharged because no real possibility evidence would be destroyed or caused to become unavailable – application dismissed
PRACTICE AND PROCEDURE – application for summary dismissal – whether proceedings frivolous, vexatious or an abuse of process – whether no reasonable prospect of success – application dismissed
Legislation: Civil Dispute Resolution Act2011 (Cth) ss 6(2), 11
Competition and Consumer Act 2010 (Cth) Sch 2 s 18,
Copyright Act 1968 (Cth) ss 37, 38
Federal Court Act 1976 (Cth) s 31A(2)
Federal Court Rules 2011 (Cth) rr 7.42, 7.43, 8.02, 23.12, 23.13, 26.01, 39.05
Trade Marks Act 1995 (Cth) ss 6, 17, 120, 123, 132, 133Cases cited: Booker McConnell Plc v Plascow [1985] RPC 425
Brags Electrics Pty Ltd v Gregory [2010] NSWSC 1205
Campaign Master (UK) Ltd v Forty Two International Pty Ltd (No 4) (2010) 269 ALR 76
Campomar Sociedad Limitada v Nike International Ltd (2000) 202 CLR 45
Dart Industries v Bryar (1997) 38 IPR 389
Dasreef Pty Ltd v Hawchar (2011) 243 CLR 588
Dormeuil Frères SA v Nicolian International (Textiles) Ltd [1988] 3 All ER 197
EFG Australia Ltd v Kennedy [1995] NSWSC 58
Flower & Hart v White Industries (Qld) Pty Ltd (1999) 87 FCR 134
Garrard (t/as Arthur Anderson & Co) v Email Furniture Pty Ltd (1993) 32 NSWLR 662
Ghanem v Australian Research Council [2014] FCAFC 132
Hayden v Teplitzky (1997) 74 FCR 7
JC Techforce v Pearce (1996) 138 ALR 522
Jones v Sutton (No 2) [2005] NSWCA 203
Liberty Financial Pty Ltd v Scott [2002] FCA 345
Macquarie Bank Limited v Commissioner of Taxation [2013] FCAFC 119
Norman v Matthews (1916) 85 LJKB 857
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- Case
- [2014] FCA 1270
- Decision Date
CaseChat Overview and Summary
The court considered whether there had been a breach of the applicants' duty of candour or material non-disclosure, and whether the orders should be discharged due to the lack of established grounds. The court found that there was no breach of duty of candour and no material non-disclosure. The court also found that the orders should not be discharged even if there was no lack of disclosure, as there was no real possibility that evidence would be destroyed or become unavailable after the orders had been executed. The court further found that the proceedings were neither frivolous, vexatious, nor an abuse of process.
The court dismissed the applications for discharge of the ex parte orders and for summary dismissal of the proceedings. The court awarded costs to the applicants against the respondents. The court ordered that the respondents' applications filed on 12 and 15 September 2014 be dismissed with costs. The entry of orders was dealt with in Rule 39.32 of the Federal Court Rules 2011.
Orders
Orders of the court
1. The first to fourth respondents’ application filed 15 September 2014 be dismissed with costs.
Note: Entry of orders is dealt with in Rule 39.32 of the Federal Court Rules 2011.
1. The respondents’ application filed 12 September 2014 be dismissed with costs.
Note: Entry of orders is dealt with in Rule 39.32 of the Federal Court Rules 2011.
Background
Background to the litigation
Evidence
Evidence Before The Court
Decision
Reasons for decision
Ratio Decidendi
Legal Principle Established
At [22], Gillard AJA continued:In my opinion, this jurisdiction is different to the situation when an order made ex parte is set aside because there was a material non-disclosure of a material matter by the party who obtained the order. The order is set aside because of some irregularity and not on the merits. When this jurisdiction is enlivened, the court’s function is to determine on the material that was placed before the judicial officer at first instance, whether a party has failed to discharge the obligation which rests upon any party seeking an order ex parte, namely, making a full and fair disclosure of all matters within its knowledge and which are material, to the court. The court is not concerned whether the order should have been made on the material before the court. Whether or not the court will set aside the order upon proof of the failure to discharge the obligation depends upon the particular circumstances.Discretionary considerations Despite Mahoney AP’s statement in Garrard, there is no absolute right to have an ex parte order set aside; there is a discretion in the court whether to do so or not: Dormeuil Frères SA v Nicolian International (Textiles) Ltd [1988] 3 All ER 197 at 199 (“Dormeuil”). In Dormeuil, Browne-Wilkinson VC expressed the view that the appropriate time for the court to hear and determine an application to discharge a search order on the ground that it was obtained as a result of material non-disclosure is at the trial because, the order usually having been executed, the only consequence of the non-disclosure will be to affect the plaintiff’s liability under his undertaking as to damages, and interlocutory proceedings are not the appropriate time for the court to hear evidence and determine allegations of what has happened in the past. In Dart Industries v Bryar (1997) 38 IPR 389 at 419, Goldberg J, agreeing with Browne-Wilkinson VC, said that “save in exceptional cases it is not the correct procedure to apply to discharge an ex parte injunction on the grounds of lack of full disclosure at the interlocutory stage of the proceedings”. Goldberg J also accepted “the tentative view expressed by Sir Nicholas Browne-Wilkinson VC in Tate Access Floors Inc v Boswell [[1991] Ch 512 at 532-3] that investigations of the circumstances in which an ex parte Anton Piller [or search] order was granted should be restricted to those cases where there has been a serious failure to make a material disclosure”. His Honour declined to discharge the search order in that case. See also Liberty Financial Pty Ltd v Scott [2002] FCA 345 at [71]. In WEA Records Ltd, Donaldson MR said at 727:In the instant case the Anton Piller order is spent in the sense that it has been executed. However, the defendants seek to go back to the beginning of the action saying that, regardless of whether the fruits of the order are such as to show that it was abundantly justified, the judge had insufficient material to justify his action at the ex parte stage. They therefore invite us to set the ex parte order aside and to order the return of the …seized material …I regard this as wholly absurd. The courts are concerned with the administration of justice, not with playing a game of snakes and ladders. If it were now clear that the defendants had suffered any injustice by the making of the order…the defendants would have their remedy in the counter-undertaking as to damages. But this is a matter to be investigated by the High Court judge who is seised of the matter…