Khalif & Khalif (No 2)

Case [2021] FedCFamC1F 308


FEDERAL CIRCUIT AND FAMILY COURT OF AUSTRALIA

(DIVISION 1)

Khalif & Khalif (No 2) [2021] FedCFamC1F 308

File number(s): SYC 6144 of 2016
Judgment of: WATTS J
Date of judgment: 16 December 2021
Catchwords:

FAMILY LAW – STAY APPLICATION – Whether the husband’s brother has established that there are exceptional or special circumstances to grant a stay pending the conclusion of the proceedings he has commenced in the High Court of Australia – Where no exceptional or special circumstances exist – Whether there are other discretionary factors that would have led to an exercise of discretion had the husband’s brother met the threshold test – Where other discretionary factors would not have led to an order granting the stay.

FAMILY LAW – ENFORCEMENT – Whether an order should be made enforcing the husband’s brother’s compliance with the order that has not been stayed – Where there are currently apparent difficulties with the form of order sought by the wife by way of enforcement – Where the wife is given liberty, upon giving 7 days’ notice, to seek further orders in respect to enforcement.

FAMLY LAW – COSTS – Where the wife seeks a reiteration of the costs order made by the Full Court on 23 July 2021 – Where the husband’s brother seeks a condition be placed upon that costs order – Where both applications are dismissed.

FAMILY LAW – CAVEAT – Where the wife seeks an order that she be entitled to lodge a caveat on the title of a property which is vested bankruptcy property – Where no order has yet been in the wife’s favour made pursuant to s 79 of the Act – Where the wife has not otherwise asserted any equitable interest in that property – Application dismissed.

Legislation:

Family Law Act 1975 (Cth) ss 33, 34, 78, 79, 80, 90AE, 123

Federal Circuit and Family Court of Australia Act 2021 (Cth) s 44

Real Property Amendment (Certificates of Title) Act 2021(NSW)

Federal Circuit and Family Court of Australia (Family Law) Rules 2021 (Cth) rr 1.06, 13.12

Cases cited:

Clemett and Clemett (1981) FLC 91-013

Commissioner of Taxation (Cth) of Australia v The Myer Emporium Ltd [No. 1] (1986) 160 CLR 220

Fencott v Muller (1983) 152 CLR 570

Jackson & Balen [2009] FamCAFC 131

Jennings Constructions Ltd v Burgundy Royale Investments Pty Ltd (1986) 161 CLR 681

Khalif & Khalif and Anor [2020] FamCA 39

Philip Morris Inc v Adam P Brown Male Fashions Pty Ltd (1981) 148 CLR 457

Re Wakim: Ex parte McNally (1999) 198 CLR 511

Rizeq v Western Australia (2017) 262 CLR 1

Stack v Coast Securities (No. 9) Pty Ltd (1983) 154 CLR 261

Stanford v Stanford (2012) 247 CLR 108

Stephens & Stephens (Stay Application) (2010) FLC 93-429

Valceski v Valceski (2007)  70 NSWLR 36

Division: Division 1 First Instance
Number of paragraphs: 73
Date of hearing: 29November 2021
Place: Sydney (via video-link)
Counsel for the Applicant: Mr Lange with Ms Bartley
Solicitor for the Applicant: Aquila…

Continue reading Khalif & Khalif (No 2)

Sign in free to access the full text

Details
AGLC
Khalif & Khalif (No 2) [2021] FedCFamC1F 308
Case
[2021] FedCFamC1F 308
Decision Date

CaseChat Overview and Summary

In the case of Khalif & Khalif (No 2), the wife sought an order enforcing a previous ruling that the husband's brother should deliver a transfer of his interest in certain property to her. The husband's brother, in turn, sought a stay of the wife's application pending the outcome of his application for special leave to appeal and any subsequent appeal to the High Court. The matter was heard in the Supreme Court of New South Wales.

The legal issues before the court included whether the husband's brother had established exceptional or special circumstances that warranted a stay of the wife's application and whether the husband's brother's recent changes to conveyancing practices in New South Wales could be considered a legitimate "practical difficulty" that required further time to comply with the order. The court had to balance the interests of both parties and determine the appropriate course of action.

The court found that the husband's brother had not demonstrated exceptional or special circumstances that would warrant a stay of the wife's application. The court also found that the husband's brother's argument regarding recent changes to conveyancing practices in New South Wales was not substantiated by any evidence and was, therefore, insufficient to warrant a stay. The court concluded that the husband's brother should comply with the previous order as soon as practicable and transfer his interest in the property electronically in accordance with the new regulations.

The court dismissed the husband's brother's application for a stay and ordered him to comply with the previous order within seven days. The wife's application for the delivery of a duly executed transfer was granted, with the understanding that the transfer would be completed electronically in accordance with the new conveyancing regulations.

Orders

Orders of the court

Full text does not contain this section.

Background

Background to the litigation

Full text does not contain this section.

Evidence

Evidence Before The Court

Full text does not contain this section.

Decision

Reasons for decision

In relation to where the balance of convenience lies, the husband’s brother repeats arguments as to how the Trustee may seek to deal with the property and how Rees J may take the property into account in the pool of assets in a future property settlement hearing and determination which takes place prior to the High Court proceedings. I have already found those arguments to be without substance.Conclusion in respect to the stay Ultimately, the central question is whether or not the husband’s brother has established exceptional or special circumstances because the failure to grant a stay would render his application for special leave and his appeal to the High Court nugatory. I find it will not. In any event, the discretionary factors would not move me to grant the stay. Accordingly, I shall dismiss the husband’s brother’s application for a stay. Consequently, the husband’s brother should comply with Order 2 as soon as is practicable.THE WIFE’S APPLICATION FOR THE DELIVERY OF A DULY EXECUTED TRANSFER By way of enforcement of Order 2 made 31 January 2020, the wife seeks an order that the husband’s brother cause to be delivered to the solicitor for the wife, a duly executed transfer of such interest in registerable form in partial compliance with Order 2 within seven days. In the event that that order was not made without more, in the alternative, the wife offers an undertaking by the wife’s solicitor that he shall hold the transfer pending disposal of the High Court proceedings and in the event that the husband’s brother is successful, shall within seven days return the transfer to the husband’s brother’s solicitors but in the event that the appeal is unsuccessful, he would register the transfer within seven days of the dismissal of the special leave application or any High Court appeal. It is reasonable to assume that the wife’s application refers to a paper transfer. On the morning of the hearing, the husband’s brother raised as a “practical difficulty” as to the form of the enforcement order sought by the wife because of very recent changes to conveyancing practices in New South Wales which has abolished the use of paper Certificates of Title. The written submissions in reply refer to the Real Property Amendment (Certificates of Title) Act 2021(NSW) and the Registrar’s Declaration that, from 11 October 2021, all dealings must be effected electronically. During submissions I pointed out that no document had been provided to support that submission. An undertaking was given to provide documents. After the hearing, the solicitor for the husband’s brother provided a copy of the legislation but no other document. Assessing the publicly available link to the website of the Office of the Registrar-General (Absolution of Certificates of Title | Registrar-General (nsw.gov.au)) it seems to indicate that from 11 October 2021 all dealings must be effected electronically. The wife’s solicitor has not had any proper opportunity to comment upon the very recent changes in conveyancing practices but it seems that what now needs to happen is for the husband’s brother to complete various tasks and give the necessary authorities to his lawyers to ensure that legal title is transferred to his brother electronically in accordance with Order 2.

Ratio Decidendi

Legal Principle Established

Full text does not contain this section.