FEDERAL CIRCUIT AND FAMILY COURT OF AUSTRALIA
(DIVISION 1)
Greyson & Maher (No 2) [2023] FedCFamC1F 34
File number(s): MLC 14284 of 2020 Judgment of: MCNAB J Date of judgment: 7 February 2023 Catchwords: FAMILY LAW – PROPERTY – Costs Application – Application for Indemnity Costs – Application for indemnity costs dismissed – Effect of Calderbank offers – Conduct of the applicant in denying the length of a de facto relationship until the day of trial – Failure to make timely disclosure of assets – Party-Party costs in a fixed sum ordered. Legislation: Family Law Act 1975 (Cth) s117
Federal Circuit and Family Court of Australia (Family Law) Rules 2021 (Cth) r 4.2.2, 12.08, 12.13, 12.17
Cases cited: Bashour v Australia and New Zealand Banking Group Limited [2017] FCA 163
Bele & Vaughan (Costs) [2012] FamCAFC 198
Browne & Green [2002] FamCA 791
Calderbank v Calderbank [1975] 3 All ER 333
Fleming v Fleming (Review of Costs) [2009] FamCA 552
Hazeldene's Chicken Farm Pty Ltd v Victorian WorkCover Authority (No 2) (2005) 13 VR 435
I, In the Marriage of (No 2) (1995) FLC 92-625
Kannis v Kannis [2002] FamCA 1150
Magna Alloys & Research Pty Ltd v Coffey (No 2) [1982] VR 97
Medlon & Medlon (No 6) (2015) 54 Fam LR 1
Prantage & Prantage [2013] FamCAFC 105
Redmond & Redmond (Costs) [2014] FamCAFC 55
Division: Division 1 First Instance Date of hearing: On the Papers Place: Melbourne Number of paragraphs: 38 Date of last submission/s: 23 December 2022 Counsel for the Applicant: Mr Puckey KC Solicitor for the Applicant: Taussig Cherrie Fildes Counsel for the Respondent: Dr Ingleby Solicitor for the Respondent: Sage family Lawyers ORDERS
MLC 14284 of 2020 FEDERAL CIRCUIT AND FAMILY COURT OF AUSTRALIA (DIVISION 1)
BETWEEN: MR GREYSON
Applicant
AND: MS MAHER
Respondent
order made by:
MCNAB J
DATE OF ORDER:
7 FEBRUARY 2023
THE COURT ORDERS THAT:
1.Within one hundred and eighty (180) days of the date of this order, the respondent pay the applicant a lump sum of costs fixed at SEVENTY-FIVE THOUSAND DOLLARS ($75,000).
2.That the applicant’s application that the respondent pay costs on an indemnity basis 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 Greyson & Maher has been approved pursuant to s 121(9)(g) of the
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- Greyson & Maher (No 2) [2023] FedCFamC1F 34
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- [2023] FedCFamC1F 34
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CaseChat Overview and Summary
The legal issues the court had to address included whether the court should award indemnity costs to the applicant based on the principles outlined in section 117(2) of the Family Law Act 1975 and Rule 12.17(1)(b) of the Federal Circuit and Family Court of Australia (Family Law) Rules 2021. The court had to consider the conduct of both parties, their financial circumstances, and the various offers of settlement made during the proceedings. Specifically, the court had to determine if the respondent's refusal to seriously consider the applicant's proposals for an equal division of the property, and the subsequent outcome of the trial, justified awarding indemnity costs to the applicant.
The court found that while the applicant's position from the outset was for an equal division of the B Street property and the orders made reflected the applicant's initiating application, the circumstances did not justify awarding indemnity costs to the applicant. The court noted that the applicant had not provided an itemised accounting of his costs or a copy of any cost agreement, which were necessary for the court to properly assess the costs. Furthermore, the court considered the financial circumstances of the respondent, who had limited income and faced the prospect of homelessness if required to pay indemnity costs. The court also took into account that the proceedings were relatively straightforward, with no significant interlocutory applications or disputes over the value of the property. Therefore, the court concluded that the circumstances did not warrant an award of indemnity costs.
In conclusion, the court refused to make an order that the respondent pay the applicant's costs on an indemnity basis, finding that the circumstances did not justify such an award. The court's decision was based on the lack of detailed cost information provided by the applicant, the financial hardship it would cause the respondent, and the relatively straightforward nature of the proceedings.
Orders
Orders of the court
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Background
Background to the litigation
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Evidence
Evidence Before The Court
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Decision
Reasons for decision
Ratio Decidendi
Legal Principle Established
The respondent submits that if the court grants such an order as sought by the applicant, she would be required to immediately sell her home, and would have limited prospects of acquiring a primary place of residence. Her 2021 taxable income was $62,243 and she submits being required to pay indemnity costs as sought would put her at risk of being homeless. CONSIDERATION Under rule 12.13(4) of the Rules:A party applying for an order for costs on an indemnity basis must inform the court if the party is bound by a costs agreement or costs agreements in relation to those costs and, if so, the terms of the costs agreement or costs agreements. The applicant has not provided a copy of any cost agreement, nor an itemised account. In these circumstances and for the reasons outlined below, I will not make an order that the respondent pay the applicant’s costs on an indemnity basis. The applicant has not provided any summarised breakdown as to how the costs of about $370,000 have been incurred in relation to a two-day trial where it appears that there was never any dispute about the value of the principal asset. Further, there has not been substantial time taken up with interlocutory applications. The court's power to award costs are subject to the operation of sections 117(1), (2) and (2A) of the Act. Those sections provide:(1)Subject to subsection (2), subsections 45A(6) and 70NFB(1) and sections 117AA and 117AC, each party to proceedings under this Act shall bear his or her own costs. (2)If, in proceedings under this Act, the court is of opinion that there are circumstances that justify it in doing so, the court may, subject to subsections (2A), (4), (4A), (5) and (6) and the applicable Rules of Court, make such order as to costs and security for costs, whether by way of interlocutory order or otherwise, as the court considers just.(2A)In considering what order (if any) should be made under subsection (2), the court shall have regard to (a) the financial circumstances of each of the parties to the proceedings;(b)whether any party to the proceedings is in receipt of assistance by way of legal aid and, if so, the terms of the grant of that assistance to that party;(c)the conduct of the parties to the proceedings in relation to the proceedings including, without limiting the generality of the foregoing, the conduct of the parties in relation to pleadings, particulars, discovery, inspection, directions to answer questions, admissions of facts, production of documents and similar matters; (d)whether the proceedings were necessitated by the failure of a party to the proceedings to comply with previous orders of the court;(e)whether any party to the proceedings has been wholly unsuccessful in the proceedings; (f)whether either party to the proceedings has made an offer in writing to the other party to the proceedings to settle the proceedings and the terms of any such offer; and(g)such other matters as the court considers relevant. The starting point provided by s 117 (1) of the Act is that each party shall bear their own costs. Section 117 (2) provides that the court may make an order for costs which it considers just when the circumstances justifying doing so.