FEDERAL COURT OF AUSTRALIA
Hewlett-Packard Aust Pty Ltd v Exeed Pty Ltd [2004] FCA 135
CORPORATIONS – charge – extension of time within which notice of particulars of charge and instrument creating charge or verified copy thereof required to be registered with Australian Securities and Investments Commission – defective execution of deed on behalf of chargees (signature by one director only) – significance of defective execution by chargees where effective execution by company/chargor – subsequent ratification by chargees by deed duly executed – discretionary considerations relevant to whether extension of time should be granted – solvency of chargor – oversight due to corporate merger and associated workload – lapse of some 17 months between expiry of statutory period allowed for registration and provisional registration of charge – extension of time granted subject to condition.
DEED – deed of fixed and floating charge duly executed by chargor but not duly executed as a deed by chargee companies (signature of one director only) – significance of defective execution by chargees where effective execution by chargor.
AGENCY – ratification – deed of fixed and floating charge duly executed by chargor but not duly executed as a deed by chargee companies (signature of one director only) – significance of defective execution by chargees – subsequent ratification by chargees by deed duly executed.
Corporations Act 2001 (Cth) ss 127, 263, 265, 266
Cooker v Child 1673) 2 Lev 74 (83 ER 456) cited
Otway v Braithwaite (1678) Finch 405 cited
Butler v Powis (1845) 2 Coll 156 (63 ER 679) cited
Sunderland Marine Insurance Co v Kearney (1851) 16 QB 925 (117 ER 1136) cited
Hungerford v Becher (1855) 5 Ir Ch R 417 cited
Chelsea and Walham Green Building Society v Armstrong [1951] Ch 853 cited
Lincoln Contractors Pty Ltd v Searle [1982] Qd R 71 cited
Carter v Schmierer [2003] QSC 035 cited
Green v Horne (1795) 1 Salk 197 (91 ER 177) cited
Federal Commissioner of Taxation v Sara Lee Household & Body Care (Australia) Pty Limited (2000) 201 CLR 520 cited
Hamilton v Property Investments Ltd (1983) 7 ACLR 932 citedSanwa Australia Finance Ltd v Ground-Breakers Pty Ltd [1991] 2 Qd R 456 cited
Rynmarc Pty Ltd v Classic Ergonomic Chairs Pty Ltd (1994) 12 ACLC 1038 distinguished
National Australia Bank Ltd v T2 Trading Pty Ltd [2003] FCA 1477 cited
Re Lloyd Anthony Furniture Pty Ltd (Receiver and Manager appointed) (in liq); ex parte Walker (1996) 19 ACSR 478.
Re Application of Guardian Securities Ltd [1984] 1 NSWLR 95 citedNorton on Deeds (2nd ed, 1928) at 29
GE Dal Pont, Law of Agency (Butterworths 2001) at [6.38] (132-133)HEWLETT-PACKARD AUSTRALIA PTY LIMITED (ACN 004 394 763) &
HEWLETT-PACKARD AUSTRALIA FINANCE PTY LIMITED (ACN 006 291 863) v
EXEED PTY LIMITED (ACN 097 115 172)N 3077 of 2003
LINDGREN J
1 MARCH 2004
SYDNEY
IN THE FEDERAL COURT OF AUSTRALIA NEW SOUTH WALES DISTRICT REGISTRY
N 3077 OF 2003
BETWEEN:
HEWLETT-PACKARD AUSTRALIA PTY…
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- Case
- [2004] FCA 135
- Decision Date
CaseChat Overview and Summary
The central legal issue before the court was whether the plaintiffs were entitled to an extension of time to lodge the charge with ASIC, given the failure to do so within the statutory period. The court had to consider the significance of the defective execution of the deed by the chargees (signature by one director only) and whether this could be rectified by subsequent ratification. The court also needed to weigh discretionary considerations, such as the solvency of the chargor, the oversight due to a corporate merger and the associated workload, and the lapse of 17 months between the expiry of the statutory period and the provisional registration of the charge.
The court found that the failure to register the charge was due to inadvertence and granted the extension of time. The court held that the defective execution by the chargees was not fatal where the chargor had properly executed the deed. The subsequent ratification by the chargees via a duly executed deed was also significant. The court took into account the solvency of Exeed, the oversight due to the corporate merger and the associated workload, and the 17-month lapse in registering the charge. The court granted the extension of time subject to conditions that reserved the right for any liquidator, administrator, or creditor of Exeed to apply for an order discharging or varying the extension if certain events occurred.
The court further ordered that the extension would be until 9 January 2004, when the notice was lodged with ASIC. If the word 'provisional' in the entry in the Register is deleted, the charge will be taken to have been registered from 9 January 2004. The court also ordered that the plaintiffs forward a copy of the orders to ASIC and request ASIC to ensure a copy of the orders be attached to the registered copy of the deed of charge.
Orders
Orders of the court
1. The time within which a notice must be lodged pursuant to s 263(1) of the Corporations Act 2001 (Cth) in respect of the charge granted by the defendant, Exeed Pty Limited, to the plaintiffs, Hewlett-Packard Australia Pty Limited (then called Hewlett-Packard Australia Limited) and Hewlett-Packard Australia Finance Pty Limited (then called Hewlett-Packard Australia Finance Limited) by Deed of Fixed and Floating Charge bearing date 30 June 2002 (‘the Charge’) be extended to 9 January 2004.
2. Order 1 be without prejudice to the rights of persons who had dealings with any property the subject of the Charge between the time of its creation and the date on which the Charge is taken to have been registered under s 265 of the Corporations Act 2001 (Cth).
3. Liberty be reserved for any liquidator, administrator or creditor of the defendant, to apply for an order discharging or varying order 1 in the event that an order that the defendant be wound up is made, or an administrator of the defendant is appointed, within six months of the date on which the Charge is taken to have been registered under s 265 of the Corporations Act 2001 (Cth).
4. These orders be entered forthwith.
5. The plaintiffs forward to the Australian Securities and Investments Commission (‘the Commission’) a copy of these orders as entered, and request the Commission to ensure that such a copy be, and remain, attached to the copy of the Deed of Fixed and Floating Charge by which the Charge was created, as registered with the Commission.
THE COURT NOTES THAT:
1. By agreement between the parties, there is no order as to the costs of the proceeding.
Note:
Background
Background to the litigation
Evidence
Evidence Before The Court
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Decision
Reasons for decision
Ratio Decidendi
Legal Principle Established
Established by: LINDGREN J
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