Knox & Knox
[2024] FedCFamC1F 708
•21 October 2024
FEDERAL CIRCUIT AND FAMILY COURT OF AUSTRALIA
(DIVISION 1)
Knox & Knox [2024] FedCFamC1F 708
File number: SYC 3239 of 2024 Judgment of: CAMPTON J Date of judgment: 21 October 2024 Catchwords: FAMILY LAW – APPLICATION FOR REVIEW – Where the wife seeks to review orders of a senior judicial registrar as to disclosure and the appointment of single valuation experts – Where the wife has access to documents in her capacity as a director of a corporation and does not have the right to possession or control of the documents sought to be disclosed in her personal capacity – Where the wife has an obligation pursuant to the Federal Circuit and Family Court of Australia (Family Law) Rules 2021 (Cth) (“the Rules”) to provide disclosure of information achieved in her personal capacity relevant to the proceedings – Where orders are made in accordance with the purpose of litigation as contained in s 67 of the Federal Circuit and Family Court of Australia Act 2021 (Cth) and to progress the litigation including as to the filing of an affidavit pursuant to r 6. 06(6) of the Rules and the issue of subpoena for the production of documents directed to the trustee of a trust – Application for Review otherwise dismissed. Legislation: Corporations Act2001 (Cth) ss 198F and 290
Family Law Act 1975 (Cth) s 79
Federal Circuit and Family Court of Australia Act 2021 (Cth) s 67
Federal Circuit and Family Court of Australia (Family Law) Rules 2021 (Cth) chapter 6 and chapter 7, rr 6.01, 6.06 and 14.01
Cases cited: Barro & Barro (No. 2) (1983) FLC 91-317; [1983] FamCA 14
Hickey and Hickey and the A-G for the Commonwealth of Australia (Intervener) (2003) FLC 93-143; [2003] FamCA 395
Kennon & Spry (2008) 238 CLR 366; [2008] HCA 56
Masoud & Masoud (2016) FLC 93-689; [2016] FamCAFC 24
Schweitzer& Schweitzer (2012) FamCA 445
Stanford v Stanford (2012) 247 CLR 108; [2012] HCA 52
Zunino& Zunino [2019] FamCA 845
Division: Division 1 First Instance Number of paragraphs: 43 Date of hearing: 21 October 2024 Counsel for the Applicant: Mr Sansom SC Solicitor for the Applicant: Hopgood Ganim Lawyers Counsel for the Respondent: Ms McMahon Solicitor for the Respondent: Nolan Lawyers ORDERS
SYC 3239 of 2024 FEDERAL CIRCUIT AND FAMILY COURT OF AUSTRALIA (DIVISION 1)
BETWEEN: MS KNOX
Applicant
AND: MR KNOX
Respondent
ORDER MADE BY:
CAMPTON J
DATE OF ORDER:
21 OCTOBER 2024
THE COURT ORDERS THAT:
1.The proceeding is placed in the Major Complex Financial Proceedings list and placed in my docket.
2.The listing before a senior judicial registrar on 28 October 2024 at 9.30 am be vacated.
3.The matter be listed before me by Microsoft Teams at 9.30 am on 13 December 2024.
4.On or before 25 October 2024 the wife file and serve an affidavit in compliance with r 6.06(6) of the Federal Circuit and Family Court of Australia (Family Law) Rules 2021 (Cth) (“the Rules”) identifying all information personal to her as to her understanding as to:
(a)The nature and character of the B Investment Trust;
(b)The document establishing that the B Investment Trust, including its date and the parties to it,
(c)The published financial statements of the B Investment Trust for the year ended 30 June 2020;
(d)Any income or capital distribution statement of the B Investment Trust as directed to the wife or the D Trust for the year ended 30 June 2018 to date; and
(e)The assets and liabilities of the B Investment Trust, including but not limited to any debit or credit loan account payable by or to that trust by the wife, the D Trust, or the E Trust.
5.On or before 31 October 2024 each of the husband and the wife shall file and serve a financial questionnaire.
6.On or before 8 November 2024 the wife shall serve upon the husband a joint draft balance sheet to include all assets, liabilities, superannuation interest and financial resources as she understands to be suggested to be relevant and to include values as she understands are alleged by each party.
7.On or before 15 November 2024 the husband shall make any additions to the joint collaborative draft balance sheet as required to reflect his contra allegations and any values that are agreed (if applicable).
8.Wheresoever controversy exists as to the inclusion of an item or the value of an item a footnote shall be appended to explain the controversy.
9.On or before 22 November 2024 the wife shall cause a copy of the draft working collaborative joint balance sheet to be filed and served.
10.On or before 5 November 2024 the wife shall do all such things as are necessary to provide to the husband by way of disclosure as to the E Trust:
(a)Copies of minutes of meetings of the trustee from the time the trust was established to date;
(b)Any document amending the terms of the trust from that contained in the last will of the wife’s late father as recorded in the grant of probate;
(c)Any capital or income distribution statement issued by the trust from the date the trust was established to the current time; and
(d)Any balance sheet or profit and loss statement of the trust from the date the trust was established to the current time.
11.In the event the wife is unable to comply with the prior order, in circumstances where she contends the relevant document is not in her possession or control, leave is granted for the wife to issue a subpoena directed to herself and the other co-trustee of that trust to require the production of the documents identified in Order 10, such subpoena to be made returnable on or before 29 November 2024.
12.The husband be granted leave to issue such subpoena for the production of documents as he considers relevant directed to the trustee of the B Investment Trust, such leave not to be exercised prior to 8 November 2024 and in the event the subpoena is issued, it is to be returnable no later than 29 November 2024.
13.Save and except as provided for by these orders, Orders 2(a), 2(d), 2(e), 2(f), 7(e), 7(f), 7(g), 7(h), and 7(i) as made by the senior judicial registrar on 23 August 2024 are discharged.
14.Orders 10 and 11 as made by the senior judicial registrar on 23 August 2024 are suspended until 5 December 2024.
15.The Application for Review of the wife filed 13 September 2024 be otherwise dismissed.
THE COURT NOTES THAT:
A.Each of the parties are on notice that in the event of a failure to comply with the obligations of disclosure as codified in ch 6 of the Rules, active consideration will be given to the striking out of the substantive relief of the party in default and leave being granted for the other party to proceed on an undefended basis.
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).
Part XIVB of the Family Law Act 1975 (Cth) makes it an offence, except in very limited circumstances, to publish an account of 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 Knox & Knox has been approved pursuant to subsection 114Q(2) of the Family Law Act 1975 (Cth).
EX TEMPORE REASONS FOR JUDGMENT
CAMPTON J:
These reasons determine an Application for Review filed on 13 September 2024 by Ms Knox (“the wife”) of selected orders made by a senior judicial registrar on 23 August 2024 as to disclosure, the appointment of single valuation experts pursuant to ch 7 of the Federal Circuit and Family Court of Australia (Family Law) Rules 2021 (Cth) (“the Rules”), and as to the facilitation of that expert evidence.
The substantive proceeding was commenced by Mr Knox (“the husband”) filing an application in the Federal Circuit Court and Family Court of Australia (Division 2) on 30 April 2024 seeking orders pursuant to s 79 of the Family Law Act 1975 (Cth) (“the Act”) adjusting property between he and the wife. By way of a Response to an Initiating Application filed on 24 June 2024, the wife seeks different orders adjusting that property.
Limited orders for disclosure were made by a judicial registrar on 24 June 2024. Those orders record the husband's contention that the value of the property of the parties is in the range of $50 million, and the wife's contention as to the value of that property being in the range of $10 million.
The husband filed an Application in a Proceeding on 30 April 2024 seeking orders as to specified disclosure and the appointment of single valuation experts. The wife opposed that relief. That contest was determined by the orders made by the senior judicial registrar on 23 August 2024 currently the subject of review.
BACKGROUND
The wife was born in 1966 and is currently 57 years of age. She identifies that she has retired from employment. The husband was born in 1971 and is 53 years of age. He identifies he is employed as a consultant.
The parties commenced cohabitation in 1996 and were married in 1997. They separated on a final basis on 12 February 2022. An order for divorce was made in mid-2023. There are two children of the marriage, both of whom are now adults.
An order made by the senior judicial registrar on 23 August 2024, not being the subject of review, transferred the proceeding to the Federal Circuit and Family Court of Australia (Division 1) and referred it to the National Assessment Team for inclusion in the Major Complex Financial Proceedings list.
The evidence of the parties implicitly records that they had engaged in extensive exchanges by way of pre-action procedures as prescribed by the Rules prior to the commencement of the proceedings in Division 2. Notwithstanding that apparent compliance, substantial issue exists in identifying their property interests and their financial resources. The parties have not prepared a collaborative draft working balance sheet, nor have they filed Financial Questionnaires. I am told that the wife filed an Undertaking as to Disclosure in compliance with ch 6 of the Rules on 9 August 2024, and the husband filed an Undertaking as to Disclosure in compliance with the Rules on 30 August 2024.
The wife's affidavit evidence identifies contributions made on her behalf by way of her parents, and specifically her father, over the period of cohabitation. Should that evidence be accurate, the parties have achieved significant funds by way of the largesse of the wife's family.
It is uncontroversial for the purposes of the s 79 litigation that the D Trust is the property of the wife amenable to adjustment. The wife has the power of appointment and removal of trustees. The wife is the sole shareholder and director of the current trustee, D Pty Ltd. The trustee has an absolute discretion as to the distribution of the capital and income of the trust. The D Trust by way of its trustee owns all of the issued shares in C Pty Ltd. The wife is the sole director of C Pty Ltd.
During the period of cohabitation, the wife was the sole member of a self-managed superannuation fund, Superannuation Fund 1. The husband and the wife were directors of the corporate trustee of the self-managed superannuation fund. At one time, the wife's member entitlement in the fund had a value in the range of $345,723. Sometime after 30 June 2021, the wife's member entitlement in the self-managed superannuation fund was rolled into an industry fund.
The wife's father passed away in 2022. An order has been made granting of probate of his will. The grant of probate is not in evidence before me. By way of the wife's late father's will, the E Trust was established. It is agreed for the purposes of the proceedings today that the wife holds the power to appoint and to remove trustees of the E Trust at her absolute discretion. The husband was a trustee of the E Trust with the wife until he was removed by way of the wife's exercise of that power of appointment. The wife's brother Mr F and the wife are currently the trustees of the trust.
An entity identified as the B Investment Trust has been the subject of exchange between the parties. B Pty Ltd is the trustee of the B Investments Trust. The wife and her three siblings each hold 25 per cent of the issued shares in the trustee. They are each one of the four directors of the trustee. The is an absence of evidence as to the nature and characteristics of that trust. It may be a discretionary trust. It may be a unit trust. It may be a hybrid trust. The evidence suggests that the B Investment Trust holds:
(a)All of the 12 issued shares in H Pty Ltd; and
(b)All of the 100 issued shares in G Pty Ltd.
The wife currently legally holds with her brother Mr F 7000 (being half) of the issued shares in J Pty Ltd. Her remaining two siblings each hold 3500 issued shares in J Pty Ltd. It is somewhat unclear at this stage, but J Pty Ltd may own all of the issued shares in K Pty Ltd. The wife is a director each of J Pty Ltd and K Pty Ltd. The wife identifies that the ASIC register records that she does not beneficially hold her shares in J Pty Ltd.
The husband identifies that the wife did hold the legal interest in 30 shares in L Pty Ltd as at the date of separation. He contends she has disposed of those shares. The wife contends that at no time did she beneficially hold those shares.
THE APPLICATION FOR REVIEW
Rule 14.07 of the Rules sets out the power of the Court on review from an order of a senior judicial registrar to be exercised by way of an original hearing. The orders subject to review as made by the senior judicial registrar on 23 August 2024 are as follows:
Financial Disclosure
2.That within 28 days from the date of these Orders, the Wife shall provide to the Husband’s solicitors the following documents by way of disclosure:
a. The documents outlined in Annexure “A” to these Orders.
…
d.With respect to all corporations in which the Wife is recorded as a shareholder:
i.all financial statements for the last 3 financial years, including balance sheets, profit and loss accounts, depreciation schedules and taxation returns;
ii. annual returns for the last 3 financial years; and
iii.the memoranda and articles of association, constitution or founding documents.
e.With respect to any trust in which the Wife is either an appointor, trustee, or in the case of a corporate trustee, an office holder or shareholder, or of which she is a beneficiary or potential beneficiary of any kind:
i.all financial statements for the last 3 financial years, including balance sheets, profit and loss accounts, depreciation schedules and taxation returns;
ii. the trust deed (including any amendments); and
iii. all market appraisals for any asset held by the trust.
f..In relation to any partnership in which the Wife has a legal and beneficial interest:
i.all financial statements for the last 3 years, including balance sheets, profit and loss accounts, depreciation schedules and taxation returns;
ii. the partnership agreement; and
iii. all business activity statements for the last 12 months.
…
Corporate and Trust Valuations
7.That within 35 days of the date of these Orders, the Husband’s solicitor write to the Wife’s solicitor with a draft joint letter of instruction and nominating three (3) valuers, to be appointed as Single Expert pursuant to Division 7.1 of the Federal Circuit and Family Court of Australia (Family Law) Rules 2021 to value the Wife’s interest in the following entities:
a. [E Trust];
…
e. [B Investment Trust];
f. [B Pty Ltd];
g. [B Property Trust];
h. [K Pty Ltd];
i. [J Pty Ltd];
(“the entities valuations”)
10.To the extent that any of the entities referred to above at Order 9 hold any of the real property referred to at Order 3A of the Husband’s interlocutory Application contained in his Amended Application filed 9 August 2024, then within 14 days of the date of these orders, the Husband’s solicitor shall write to the Wife’s solicitor with a draft joint letter of instruction nominating 3 registered valuers to be appointed a Single Expert pursuant to Division 7.1 of the Federal Circuit and Family Court of Australia (Family Law) Rules 2021 to value the relevant properties.
11.Within a further 14 days, the Wife shall nominate a valuer from the list of valuers, and if the Wife fails to nominate a valuer, then the Husband shall nominate the valuer.
(As per the original)
The obligations pursuant to ch 6 of the Rules
The wife's position as to disclosure is encapsulated in paragraph 49 of her affidavit filed on 24 June 2024, being as follows:
I cannot provide disclosure or agreed evaluations of entities I do not own or control.
The husband contends that the Court has the capacity to compel the wife to produce documents consistent with that provided for in ch 6 of the Rules by way of disclosure of entities in which she has an interest by way of a minority shareholding and/or by way of she being a director of a corporation, including a corporation of a corporate trustee of a trust, by way of she making application pursuant to either s 198F(1) of the Corporations Act2001 (Cth) (“the Corporations Act”) or s 290D of the Corporations Act. Those sections permit directors to inspect company records for the purposes of a proceeding to which the director is a party. The husband identifies the definition of financial records as contained within the Corporations Act. He submits that, by way of that legislation, the wife has a right to take copies of documents to which the obligations of disclosure as codified in ch 6.06 of the Rules apply. He submits that a similar right exists by way the wife being a discretionary beneficiary of a trust to inspect and take copies of the records of the trust. It is his case that the wife in these proceedings has undertaken a course to frustrate her access to documents, whether by way of the Corporations Act, or by general law.
The wife identifies that, while she may have rights to access and copy documents in her capacity as a director of a corporation, she does not have that right to possession or control of such documents in a personal capacity for the purposes of ch 6 of the Rules. Putting it another way, she says there is only a right to access those documents strictly for the purposes of the relevant corporation and not for these proceedings.
There are some decisions that have held that s 198F of the Corporations Act gives a director the right to access and copy documents that are material to family law proceedings, notwithstanding those proceedings are of a private nature. That was first identified by the Full Court in Barro & Barro (No. 2) (1983) FLC 91-317 (“Barro”) and more recently at first instance in Zunino& Zunino [2019] FamCA 845.
As identified by senior counsel for the wife, at first instance in Schweitzer& Schweitzer (2012) FamCA 445 (“Schweitzer”), the Court determined that the fiduciary obligations of a company director means they do not have a right to possession or control of corporate documents in any personal capacity, and there is only a right of access to documents strictly for the purposes of the corporation and not for Family Court proceedings. The approach in Schweitzer was approved by the Full Court in Masoud & Masoud (2016) FLC 93-689.
The current Rules no longer provide for a duty of disclosure for a party as to "custody of documents" as was the case in Barro.
It is trite to observe that r 6.01 identifies that “each party to a proceeding has a duty to the court and to each other party to give full and frank disclosure of all information relevant to the proceeding in a timely manner” (emphasis added). Rule 6.06 identifies in financial proceedings, such as these, the obligation to make a full and frank disclosure of:
(3) Without limiting subrule (1), a party to a financial proceeding must make full and frank disclosure of the party’s financial circumstances, including the following:
(a) the party’s earnings, including income that is paid or assigned to another party, person or legal entity;
(b) any vested or contingent interest in property;
(c) any vested or contingent interest in property owned by a legal entity that is fully or partially owned or controlled by a party;
(d) any income earned by a legal entity fully or partially owned or controlled by a party, including income that is paid or assigned to any other party, person or legal entity;
(e) the party’s other financial resources;
(f) any trust:
(i) of which the party is the appointor or trustee; or
(ii) of which the party, the party’s child, spouse or de facto spouse is an eligible beneficiary as to capital or income; or
(iii) of which a corporation is an eligible beneficiary as to capital or income if the party, or the party’s child, spouse or de facto spouse is a shareholder or director of the corporation; or
(iv) over which the party has any direct or indirect power or control; or
(v) of which the party has the direct or indirect power to remove or appoint a trustee; or
(vi) of which the party has the power (whether subject to the concurrence of another person or not) to amend the terms; or
(vii) of which the party has the power to disapprove a proposed amendment of the terms or the appointment or removal of a trustee; or
(viii) over which a corporation has a power referred to in any of subparagraphs (iv) to (vii), if the party, the party’s child, spouse or de facto spouse is a director or shareholder of the corporation;
(g) any disposal of property (whether by sale, transfer, assignment or gift) made by the party, a legal entity referred to in paragraph (c), a corporation or a trust referred to in paragraph (f) that may affect, defeat or deplete a claim:
(i) in the 12 months immediately before the separation of the parties; or
(ii) since the final separation of the parties;
(h) liabilities and contingent liabilities.
(Emphasis added)
The B Investment Trust
It is the husband's case, not apparently in issue by the wife, that the D Trust has received distributions of income or capital from the B Investment Trust in the year ended 30 June 2020 of $275,000.
I do not accept that the wife's proprietary right to the due administration of a trust as identified in Kennon & Spry (2008) 238 CLR 366 gives her an automatic entitlement, absent more, to obtaining documents relating to the B Investment Trust.
The wife has given evidence as to the content of letters sent to her siblings and to accountants requesting the published financial statements of the B Investment Trust and the document establishing the B Investment Trust. Each of her siblings and accountants retained by the trust have flatly refused to provide those documents.
The wife implicitly, by way of those requests for information, concedes the relevance of the documents sought to the s 79 proceedings and her obligation to disclose them.
As was identified in the earlier authorities, a simple solution to obtain the relevant documentation from the trustee of the B Investment Trust is to issue a subpoena to the trustee to produce the documents. While a capacity exists for the trustee to object to the production of the documents, the apparent relevance of them cannot be reasonably disputed on the material available to date.
I do not accept the wife's contention that she cannot obtain documents by way of the instrument establishing the B Investment Trust, the financial statements of the trust, including its balance sheet and profit and loss statements, any income or capital distribution statements, or minutes of meeting of the trustee by way of an issue of a subpoena. The husband too is not prevented from adopting that course. A subpoena is nothing more than an ex parte order of the Court, issued at the request of a party, requiring the recipient to produce documents.
The wife filed her Financial Statement on 24 June 2024. She has adduced evidence by way of three affidavits for the purposes of this hearing by way of review. The affidavit material filed by the wife and her Financial Statement do not disclose information that the wife has available to her by way of her control of the D Trust, or available to her personally, as to the nature of that distribution made by the B Investment Trust, as to the characteristics and nature of the B Investment Trust, or as to the broad financial circumstances of that trust.
Rule 6.06(6) records as follows:
(6) If a party is aware that the completion of a Financial Statement will not fully discharge the duty to make full and frank disclosure, the party must also file an affidavit giving further particulars.
In my view, the wife had an obligation pursuant to the Rules to provide by way of an affidavit all information personally available as to those matters identified matters pertinent to the B Investment Trust. I do not accept that the wife cannot provide disclosure of these matters as to the B Investment Trust because she does not own or control it. I infer for the purposes of these reasons that the wife has elected not to comply with the filing of an affidavit pursuant to r 6.06(6) of the Rules to give full and frank disclosure of all the relevant information she has in her personal capacity going to these subject matters relevant to the B Investment Trust and the interests that she has in that trust, whether they be of a proprietary nature or whether they be by way of a financial resource.
The E Trust
Although all the evidence is yet to be considered, it is more likely than not that the wife's interests in the E Trust would be a property interest amenable to adjustment pursuant to s 79 of the Act.
The wife has the capacity to remove her brother, Mr F, as a trustee and to appoint another person of her choosing as a replacement trustee. It is artificial for the wife to contend that she is unable to provide disclosure as to the relevant matters identified in r 6.06(3) in relation to the E Trust because she cannot achieve the agreement of her brother as the current joint trustee.
The remaining orders as to disclosure subject to challenge on review
A number of the orders subject to challenge on review simply repeat that as prescribed by r 6.06. There is little purpose in repeating those obligations.
The challenged orders as to single expert valuation evidence
The challenge to Order 7 as made by the senior judicial registrar has some merit, in that it requires the Court to value “the wife's interest” in certain entities. The wife's “interest” in the E Trust and the D Trust, being entities she controls, may be very different to “her interest” in the B Investment Trust. There may be a requirement to refine the terms of Order 7 to identify evaluation of the trusts themselves and the wife’s interests in them, after disclosure has been completed. The completion of disclosure will ground the scope of dispute, if any, as to the nature of the wife's “interests” in the respective trusts. There is no utility in ascribing a value B Pty Ltd. It does not trade on its own account, acting as a corporate trustee.
Order 10 as made by the learned senior judicial registrar was an attempt to prevent further litigation on the issue of the appointment of single experts to progress the litigation in compliance with the rules and objectives identified in s 67 of the Federal Circuit and Family Court of Australia Act 2021 (Cth). Order 11 falls into a similar category. The orders are premature at this time in the litigation.
It is trite to observe that, as identified by the Full Court in Hickey and Hickey and the A-G for the Commonwealth of Australia (Intervener) (2003) FLC 93-143, the sequential approach to the determination of proceedings in s 79 of the Act involves interrelated steps, the first being to make findings as to the identity and value of the property, liabilities and financial resources of the parties. It is only after that occurs that consideration can be given to the satisfaction as to justice and equity being achieved (as identified by the High Court in Stanford v Stanford (2012) 247 CLR 108) in adjusting property.
The obligation of disclosure and its implementation in the circumstances of this case at this time in the litigation pathway
A party to financial proceedings is required to make a full and frank disclosure of all documents and information regarding their financial circumstances. That duty is absolute and continues throughout the litigation process. It is critical to the function of the jurisdiction and fundamental to achieving justice and equity. The obligation, and how it is codified in ch 6 of the Rules, is significant. It goes to all documents and information that is relevant and material to factual findings to be made in the case, and specifically the identity and value of the property of the parties.
There has been some progression as to the valuation of real property interests held personally by the parties pursuant to the implementation of the senior judicial registrar's orders. As indicated during the hearing today, I propose to cause this matter to be placed in the Major Complex Financial Proceedings list and placed in my docket. Orders will be made vacating the listing before a judicial registrar on 28 October 2024 at 9.30 am.
On the material available to me at this time, including by way of the submissions today, and for the reasons identified earlier, the wife has the keys to many pieces of information and has a capacity to obtain that information, whether it be by way of the issue of a subpoena or whether it be by way of her filing an affidavit in compliance with r 6.06(6), to progress the identification the property, liabilities and financial resources of the parties. After this process is completed, the completion of the processes of the valuation of that property can progress.
A regime of directions will be made to enable the progression of this litigation effectively and efficiently, so the parties can commence to engage in what I might describe as “the main game”.
For all of the above reasons, I make the following orders.
I certify that the preceding forty-three (43) numbered paragraphs are a true copy of the Ex Tempore Reasons for Judgment of the Honourable Justice Campton. Associate:
Dated: 23 October 2024
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