SUPREME COURT OF SOUTH AUSTRALIA
(Civil)
KOSTOPOULOS v DELLIS & ANOR
[2023] SASC 78
Judgment of Auxiliary Judge Costello a Master of the Supreme Court
SUCCESSION - FAMILY PROVISION - CRITERIA FOR DETERMINING APPLICATION - GENERALLY - PRINCIPLES OF EXERCISE OF DISCRETION
Application for provision - applicant and second respondent are children of the deceased - applicant received legacy of $20,000 with the residue being left to the second respondent - net value of estate approximately $400,000 - in her will the deceased recorded her disapproval of the applicant's former lifestyle as an escort worker - applicant 62 years old, impecunious and over her life a victim of physical, sexual and financial abuse - consideration of whether applicant's conduct disentitling - second respondent was the main carer for the deceased and her husband in their latter years - second respondent a 60 year old pensioner with limited means - in his capacity as executor, the second respondent breached an undertaking given under oath not to use monies set aside for the applicant, used estate monies for unauthorised purposes and intermingled trust and estate monies - exact value of the estate thereby rendered uncertain - consideration of the respective entitlements of the parties.
Held:
1. The applicant is to receive 40% of the estate.
2. The second respondent is to receive 60% of the estate.
Inheritance (Family Provision) Act 1972 (SA); Aged and Infirm Persons' Property Act 1940 (SA), referred to.
Illman v Sterrey & Ors [2023] SASC 50; Scott & Anor v Scott & Anor [2021] SASC 96; Bramwell v Bramwell & Ors [2022] SASC 12; Hughes v National Trustees, Executors & Agency Co of Australasia Ltd (1979) 143 CLR 134, considered.
KOSTOPOULOS v DELLIS & ANOR
[2023] SASC 78CIVIL
This is an application pursuant to the Inheritance (Family Provision) Act 1972 (“the Act”). Mary Kostopoulos (“the applicant”) seeks provision to be made out of the estate of her mother, Efstathia Dellis (“the deceased”), for her maintenance and advancement in life.
Vasilios Dellis (“the second respondent”), the applicant’s brother, is the executor of the will and a beneficiary in the estate. In his capacity as a beneficiary he opposes the application.
Background
The deceased left a will dated 28 September 2015 (“the will”). She died on 26 August 2021. Probate of the will was granted on 19 October 2021. By her will the deceased made a specific bequest of $20,000 to the applicant and left the residue to the second respondent.
In Clause 8 of the will the deceased set out the reasons as to why she left only $20,000 to the applicant and the residue to the second respondent. Clause 8 reads:
8.I wish it noted that I make the dispositions above noting the difficulties I have experienced in my relations with my daughter and her family for well over twenty years. In that time she and her family have been careless of any responsibility to me and my spouse and she has undertaken…
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- AGLC
- Kostopoulos v Dellis [2023] SASC 78
- Case
- [2023] SASC 78
- Decision Date
CaseChat Overview and Summary
The legal issues the court had to resolve include determining the net value of the estate, the disposition of certain funds held in a Westpac account, whether the applicant was left without adequate provision for her maintenance, the impact of Clause 8 on the applicant's claim, and the appropriate amount to be awarded to the applicant. The court also had to consider the balance between the statutory scheme allowing the court to award further provision and the deceased's freedom of testation.
The court found that the applicant, despite her difficult past, had been left without adequate provision for her maintenance. It was noted that the applicant's circumstances, including her age, disability, lack of savings, and reliance on the pension, warranted a significant award from the estate. The court also recognised the second respondent's role as a source of love, care, and support to the deceased, meriting a substantial portion of the estate. The court decided to distribute the estate in a 40/60 split, awarding 40% to the applicant and 60% to the second respondent, while acknowledging the potential necessity of selling the properties to achieve this distribution. The court emphasised the importance of avoiding any tendency to reform the will and ensuring that the provision made is adequate and appropriate in all the circumstances.
Orders
Orders of the court
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Background
Background to the litigation
Evidence
Evidence Before The Court
Decision
Reasons for decision
Ratio Decidendi
Legal Principle Established
I also adopt the observations of Judge Dart (in Scott & Anor v Scott & Anor[18]) in relation to aspects of the assessment task where his Honour said:[18] [2021] SASC 96 at [13]-[14].… it is also necessary to have regard to the conflict between the statutory scheme allowing the Court to award further provision by way of an amendment to the will of the deceased and the entitlement of a person to freely make a testamentary distribution as they see fit. There is an obvious and unavoidable tension. In Andrew v Andrew Hallen AsJ said: In addition to the above matters, there are some general principles that are relevant to the facts of this case. Whilst most of these principles were given in the context of the former Act, they are equally apt in a claim such as this one.Bryson J noted in Gorton v Parks (1989) 17 NSWLR 1, at 6, in relation to the former Act, that it is not appropriate, to endeavour to achieve a “fair” disposition of the deceased's estate. It is not part of the court's role to achieve some kind of equity between the various claimants. The court's role is not to reward an applicant, or to distribute the deceased's estate according to notions of fairness or equity. Rather, the court's role is of a specific type and goes no further than the making of “adequate” provision in all the circumstances for the “proper” maintenance, education and advancement in life of an applicant.In Cooper v Dungan (1976) 50 ALJR 539, Stephen J, at 542, reminded the court to be vigilant in guarding “against a natural tendency to reform the testator's will according to what it regards as a proper total distribution of the estate rather than to restrict itself to its proper function of ensuring that adequate provision has been made for the proper maintenance and support of an applicant”.The court's discretion is not untrammelled, or to be exercised according to idiosyncratic notions of what is thought to be fair, or in such a way as to transgress, unnecessarily, upon the deceased's freedom of testation (Pontifical Society for the Propagation of the Faith v Scales [1962] HCA 19; (1961) 107 CLR 9, per Dixon CJ at 19); McKenzie v Topp [2004] VSC 90 at [63]. Freedom of testamentary disposition remains a prominent feature of the Australian legal system.The task before the Court is limited to the making of an adequate provision for claimant who satisfies the jurisdiction requirement. No interfering with the terms of the will beyond that is authorised by the Act.[footnotes omitted]Consideration Against this factual and statutory background, the following issues arise for consideration and determination:(i)The true value of the estate.(ii)The treatment and disposition of the monies originally deposited in Westpac Account 291970.(iii)Whether the applicant been left without adequate provision?(iv)Whether the applicant’s conduct been such as to disentitle her from being able to prosecute her claim?(v)The relevance and treatment of Clause 8 of the will.(vi)What amount (if anything) would represent an appropriate level of provision?The true value of the estate