Gorman v McKnight

Case [2020] NSWCA 20


Court of Appeal


Supreme Court


New South Wales

  • Amendment notes
Medium Neutral Citation: Gorman v McKnight [2020] NSWCA 20
Hearing dates: 25 October 2019
Date of orders: 19 February 2020
Decision date: 19 February 2020
Before: Bell P at [1]; Payne JA at [91]; Emmett AJA at [97]
Decision:

1.   Grant leave to appeal.

 2.   Dismiss the appeal with costs.
Catchwords:

APPEAL – whether permanent stay of proceedings should be granted – civil claims arising from alleged sexual assaults up to 40 years ago – where alleged perpetrator dead but had been charged with regard to some of the underlying complaints prior to his death – where perpetrator had admitted some of the acts but asserted that they were consensual – where each of the plaintiffs was a minor at the time of the alleged assaults

 

CIVIL PROCEDURE – historic sexual assault – claim against Estate – where alleged perpetrator dead

  TORTS – sexual assault – alleged consent – where plaintiffs were minors at the time of alleged consent – whether consent by a minor is a defence to a civil claim for damages for sexual assault
Legislation Cited: Crimes (Amendment) Act 1984 (NSW)
Crimes Act 1900 (NSW) s 81
Crimes Amendment (Sexual Offences) Act 2003 (NSW)
Civil Procedure Act 2005 (NSW) s 67
Limitation Act 1969 (NSW) s 6A(6)
Cases Cited: Bain v Altoft [1967] Qd R 32
Council of Trinity Grammar School v Anderson [2019] NSWCA 292
Dean v Phung [2012] NSWCA 223
Freeman v Home Office (No 2) [1984] QB 524
House v R (1936) 55 CLR 499; [1936] HCA 40
Moon v Whitehead [2015] ACTCA 17
Moubarak by his tutor Coorey v Holt [2019] NSWCA 102
Murakami v Wiryadi (2010) 268 ALR 377; [2010] NSWCA 7
Norberg v Wynrib [1992] 2 SCR 226
R v Howard [1966] 1 WLR 13
Secretary, Department of Health and Community Services v JWB and SMB (1992) 175 CLR 218; [1992] HCA 15
Voth v Manildra Flour Mills Pty Ltd (1990) 171 CLR 538; [1990] HCA 55
Walton v Gardiner (1993) 177 CLR 378; [1993] HCA 77
Ward v The Trustees of the Roman Catholic Church for the Diocese of Lismore [2019] NSWSC 1776
White v Johnston (2015) 87 NSWLR 779; [2015] NSWCA 18
ZYX (pseudonym initials) v JD (pseudonym initials) [2019] WADC 164
Texts Cited: SKN Blay, “Onus of Proof of Consent in an Action for Trespass to the Person” (1987) 61 ALJ 25
J Goudkamp, Tort Law Defences (Hart Publishing, 2016)
W Page Keeton et al (eds), Prosser and Keeton on Torts (5th ed, West Publishing Co, 1984)
Category:Principal judgment
Parties: Trevor Athol Gorman (First Appellant)
Ian Alexander Duncan (Second Appellant)
Christopher John McKnight (First Respondent)
Craig Andrew Channell (Second Respondent)
Aaron Gammage (Third Respondent)
Representation:

Counsel:
M Neil QC with M Kalyk (Appellants)
N Newton with J Horowitz (First Respondent)
Submitting appearance (Second Respondent)
D Weinberger (Third Respondent)

  Solicitors:
Murphy’s Lawyers Inc (Appellants)
Conditsis Lawyers (First Respondent)
Brazel Moore Lawyers (Second…

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Details
AGLC
Gorman v McKnight [2020] NSWCA 20
Case
[2020] NSWCA 20
Decision Date

CaseChat Overview and Summary

The appeal concerned civil claims brought by several plaintiffs against the estate of the deceased, Mr McKnight, alleging sexual assaults that occurred up to 40 years prior. Mr McKnight had been charged in relation to some of the alleged incidents before his death, and had admitted to some of the acts but asserted they were consensual. Crucially, each of the plaintiffs was a minor at the time of the alleged assaults. The appeal was heard by Bell P, Payne JA, and Emmett AJA.

The central legal issues before the court were whether a permanent stay of proceedings should be granted in these circumstances, and whether consent by a minor could constitute a defence to a civil claim for damages for sexual assault.

The Court of Appeal determined that consent by a minor to sexual activity is not a defence to a civil claim for damages for sexual assault. The reasoning was that the law does not recognise a minor as having the capacity to consent to such acts, particularly given the inherent vulnerability of minors. The court found that the claims were not an abuse of process and that a permanent stay was not warranted.

Leave to appeal was granted, but the appeal itself was dismissed with costs.

Orders

Orders of the court

1. Grant leave to appeal.

2. Dismiss the appeal with costs.

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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