Lodin v Lodin

Case [2017] NSWCA 327


Court of Appeal


Supreme Court


New South Wales

  • Summary available
  • Amendment notes
Medium Neutral Citation: Lodin v Lodin [2017] NSWCA 327
Hearing dates:6 October 2017
Decision date: 15 December 2017
Before: Basten JA at [1];
White JA at [4];
Sackville AJA at [16]
Decision:

1.   Appeal allowed.
2.   Set aside order 1 made by the primary Judge on 25 January 2017.
3.   In lieu thereof order that the summons filed on 9 June 2015 be dismissed.
4.   Set aside order 2 made by the primary Judge on 25 January 2017.
5.   In lieu thereof order that:
(a)   the plaintiff pay the defendant’s costs of the proceedings on the ordinary basis;
(b)   the defendant’s costs, on the indemnity basis, insofar as not paid by the plaintiff, be paid or retained out of the Deceased’s estate.
6.   The moneys held in the controlled moneys account referred to in the undertakings noted on 4 May 2017 be released to or at the direction of the appellant.   
7.   The respondent pay the appellant’s costs of the appeal on the ordinary basis.
8. The respondent have a certificate under the Suitors’ Fund Act 1951 (NSW).

Catchwords: SUCCESSION – family provision – application for family provision order under s 57(1)(d) of the Succession Act 2006 (NSW) by former spouse of deceased – primary judge awarded $750,000 legacy out of estate valued at about $5 million – whether factors warranted the respondent making the application within s 59(1)(b) of the Succession Act 2006 (NSW) – whether respondent a natural object of testamentary recognition in circumstances where marriage had ended 25 years previously and financial affairs resolved by final orders of Family Court
Legislation Cited:

Family Law Act 1975 (Cth), s 75

 

Evidence Act 1995 (NSW), s 60
Family Provision Act 1982 (NSW), ss 6, 9, 33
Infants Act 1916 (NSW), s 3
Interpretation Act 1987 (NSW), s 21C
Succession Act 2006 (NSW), ss 57, 59, 60, 127
Succession Amendment (Family Provision) Act 2008 (NSW), s 3, Sched 1
Suitors’ Fund Act 1951 (NSW)

  Family Provision Bill 1982
Succession Amendment (Family Provision) Bill 2008
Cases Cited: Brown v Faggoter [1998] NSWCA 44
Chapple v Wilcox [2014] NSWCA 392
Churton v Christian (1988) 13 NSWLR 241; [1988] NSWCA 23
Dijkhuijs (formerly Coney) v Barclay (1988) 13 NSWLR 639
Diver v Neal [2009] NSWCA 54
Doshen v Pedisich [2013] NSWSC 1507
Evans v Levy [2011] NSWCA 125
Re Fulop Deceased; Fulop v Public Trustee (1987) 8 NSWLR 679
Golosky v Golosky (Court of Appeal (NSW), 5 October 1993, unrep)
House v The King (1936) 55 CLR 499; [1936] HCA 40
Lodin v Lodin [2017] NSWSC 10
Norbis v Norbis (1986) 161 CLR 513; [1986] HCA 17
O’Shaughnessy v Mantle (1986) 7 NSWLR 142
Page v Page [2017] NSWCA 141
Penfold v Perpetual Trustee [2002] NSWSC 648
Sassoon v Rose [2013] NSWCA 220
Singer v Berghouse (1994) 181 CLR 201; [1994] HCA 40
Smoje v Forrester [2017] NSWCA 308
Tobin v Ezekiel (2012) 83 NSWLR…

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AGLC
Lodin v Lodin [2017] NSWCA 327
Case
[2017] NSWCA 327
Decision Date

CaseChat Overview and Summary

The appeal concerned an application for a family provision order under section 57(1)(d) of the *Succession Act 2006* (NSW) brought by the former spouse of the deceased. The primary judge had awarded the former spouse a legacy of $750,000 from an estate valued at approximately $5 million. The appellant, the executor of the estate, challenged this decision.

The central legal issues before the Court of Appeal were whether the respondent, as a former spouse whose marriage had ended 25 years prior and whose financial affairs had been resolved by final Family Court orders, was a "natural object of testamentary recognition" for the purposes of section 59(1)(b) of the *Succession Act 2006* (NSW). The court was required to consider whether the circumstances warranted the respondent making such an application.

The Court of Appeal allowed the appeal, setting aside the primary judge's order for the legacy. The court reasoned that the long period since the dissolution of the marriage and the final resolution of financial matters in the Family Court meant the respondent was not a natural object of testamentary recognition. The court found that the primary judge had erred in making the provision. Consequently, the summons for family provision was dismissed. The court also made orders regarding costs, with the respondent to pay the appellant's costs of the appeal on the ordinary basis and the appellant's costs of the proceedings to be paid by the respondent, with a portion to be retained out of the deceased's estate on an indemnity basis.

Orders

Orders of the court

1. Appeal allowed.

2. Set aside order 1 made by the primary Judge on 25 January 2017.

3. In lieu thereof order that the summons filed on 9 June 2015 be dismissed.

4. Set aside order 2 made by the primary Judge on 25 January 2017.

5. In lieu thereof order that:

(a) the plaintiff pay the defendant’s costs of the proceedings on the ordinary basis;

(b) the defendant’s costs, on the indemnity basis, insofar as not paid by the plaintiff, be paid or retained out of the Deceased’s estate.

6. The moneys held in the controlled moneys account referred to in the undertakings noted on 4 May 2017 be released to or at the direction of the appellant.

7. The respondent pay the appellant’s costs of the appeal on the ordinary basis.

8. The respondent have a certificate under the Suitors’ Fund Act 1951 (NSW).

Background

Background to the litigation

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Evidence

Evidence Before The Court

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Decision

Reasons for decision

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Ratio Decidendi

Legal Principle Established

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