SUPREME COURT OF SOUTH AUSTRALIA
(Full Court)
HARRY GOUDIAS PTY LTD v AKAKIOS
[2007] SASC 81
Judgment of The Full Court
(The Honourable Chief Justice Doyle, The Honourable Justice Gray and The Honourable Justice David)
8 March 2007
CONTRACTS - GENERAL CONTRACTUAL PRINCIPLES - ILLEGAL AND VOID CONTRACTS
Appeal from a decision of a District Court Judge – Judge rejected claims solely on the basis that the plaintiff entered into an agreement with the defendant for an illegal purpose – whether the finding of illegality could be sustained – whether a finding of illegality necessarily precludes relief – Held: the defendant did not plead the defence of illegality with adequate particularity and specificity – the Judge did not apply an appropriate onus of proof when considering the defence of illegality – a finding of illegality is not, by itself, fatal to a claim for relief – the Judge did not undertake a proper investigation of the relationship between the parties alleged to have been involved in illegality – appeal allowed – matter remitted for retrial before a differently constituted Court.
Trade Practices Act 1975 (Cth) s 52; Fair Trading Act 1987 (SA) s 56; Income Tax Assessment Act 1936 (Cth) s 161; Commonwealth Criminal Code s 135.4; Marriage Act 1928 (Vic) , referred to.
Holdcroft & Anor v Market Garden Produce Pty Ltd & Ors [2001] 2 Qd R 381; Gioginis v Kastrati (1988) 49 SASR 371; Nelson v Nelson (1995) 184 CLR 538; Fitzgerald v FJ Leonhardt (1997) 189 CLR 215; Middleton v O’Neill (1943) 43 SR (NSW) 178; Permanent Trustee Australia Ltd v FAI General Insurance Co Ltd (in liquidation) (2003) 214 CLR 514; Knowles v Fuller (1947) 48 SR (NSW) 243; Briginshaw v Briginshaw (1938) 60 CLR 336; Neat Holdings Pty Ltd v Karajan Holdings Pty Ltd (1992) 67 ALJR 170, considered.
HARRY GOUDIAS PTY LTD v AKAKIOS
[2007] SASC 81Full Court: Doyle CJ, Gray and David JJ
DOYLE CJ: I would allow the appeal, set aside the judgment dismissing the plaintiff’s claims, and order that the plaintiff’s claims for payment pursuant to a guarantee, and for damages for negligence, breach of fiduciary duty and misrepresentation be remitted to the District Court for re-hearing by another judge.
There is no reason to interfere with the Judge’s decision dismissing the plaintiff’s claims under the Trade Practices Act and the Fair Trading Act.
I agree with the substance of the reasons of Gray J.
I agree with him that there are two broad reasons for the decision to allow the appeal.
The Judge’s finding that the contracts of loan were made for an illegal purpose should be set aside. The finding goes beyond the Defence as amended. There is a significant difference between the plea of illegality, and the finding made by the Judge. A finding that the defence as pleaded is made out might well have different consequences from the finding made by the Judge.
Apart from that, as best…
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- Case
- [2007] SASC 81
- Decision Date
CaseChat Overview and Summary
The primary legal issues before the Court were whether the finding of illegality could be sustained and whether a finding of illegality necessarily precluded relief for the plaintiff. The Court considered whether the defendant had adequately pleaded the defence of illegality and whether the District Court Judge had applied the appropriate onus of proof when considering this defence. Additionally, the Court examined whether the Judge had undertaken a proper investigation of the relationship between the parties and whether a finding of illegality was fatal to the plaintiff’s claims.
The Court found that the defendant had not pleaded the defence of illegality with adequate particularity and specificity. Moreover, the Court held that the District Court Judge did not apply the appropriate onus of proof when considering the defence of illegality. The Court held that a finding of illegality is not, by itself, fatal to a claim for relief. The Judge had failed to undertake a proper investigation of the relationship between the parties and the nature of the alleged illegality. Consequently, the Court set aside the judgment of the District Court and remitted the matter for retrial before a differently constituted Court.
The Court’s decision emphasised the importance of ensuring that the defence of illegality is adequately pleaded and that the onus of proof is correctly applied. Furthermore, the Court underscored that a finding of illegality does not necessarily preclude relief and that a proper investigation of the relationship between the parties is required before reaching a conclusion on the consequences of illegality. The Court’s ruling provides guidance on the application of the defence of illegality in contract law and the need for a comprehensive examination of the circumstances surrounding alleged illegality.
Orders
Orders of the court
Full text does not contain this section.
Background
Background to the litigation
Evidence
Evidence Before The Court
Decision
Reasons for decision
Ratio Decidendi
Legal Principle Established
Established by: DAVID J
In the above circumstances, the finding of illegality should be set aside and the issue retried.The Judge’s Consideration of the Law Relating to Illegality The trial Judge also erred in holding that the plaintiff’s claim must necessarily fail due to his finding that the loan agreement was entered into for an illegal purpose. The trial Judge observed:[17]In my opinion, the illegality identified by me was so pervasive that it must taint any contract that was entered into between the parties, including a contract of guarantee, if one was entered into as alleged by the plaintiff.…It follows … that even if the plaintiff were able to establish a factual basis for its claim under the alleged guarantee, the plaintiff cannot succeed in enforcing such a guarantee.... Just as illegality precludes the enforcement of a contract, if the alleged breaches of duty, whether common law or fiduciary, induced the plaintiff to enter into a contract which he knew was for an illegal purpose, he cannot recover damages.[17] Harry Goudias Pty Ltd v Akakios [2006] SADC 69 at [46] and [50]-[51]. At the outset of this discussion it is important to recall that the trial Judge concluded that the loans of moneys between the parties was not illegal and that the payment of interest in cash was not illegal. The suggested illegality lay in the possible use of these contractual arrangements. It is also important to note that the plaintiff sought relief both in contract, tort, and equity from a person who was not a direct party to the contracts of loans. An early statement of the general principle of the defence of illegality can be found in the following dictum by Lord Mansfield in Holman v Johnson:[18]The objection, that a contract is immoral or illegal as between plaintiff and defendant, sounds at all times very ill in the mouth of the defendant. It is not for his sake, however, that the objection is ever allowed; but it is founded in general principles of policy, which the defendant has the advantage of, contrary to the real justice, as between him and the plaintiff, by accident, if I may so say. The principle of public policy is this; ex dolo malo non oritur actio. No Court will lend its aid to a man who founds his cause of action upon an immoral or an illegal act. If, from the plaintiff’s own stating or otherwise, the cause of action appears to arise ex turpi causa, or the transgression of a positive law of this country, there the Court says he has no right to be assisted. It is upon that ground the Court goes; not for the sake of the defendant, but because they will not lend their aid to such a plaintiff. So if the plaintiff and defendant were to change sides, and the defendant was to bring his action against the plaintiff, the latter would then have the advantage of it; for where both are equally in fault, potior est conditio defedentis.Holman involved a contract for sale of tea in Dunkirk. The plaintiff knew that the defendant intended to illegally smuggle the tea into England. But the original contract for sale involved no illegality; it was only the defendant’s intended use which was illegal. On that ground Lord Mansfield, with whom the three other Judges concurred, held that the plaintiff was entitled to recover.[18] Holman v Johnson (1775) 1 Cowp 341 at 343 [98 ER 1120 at 1121].