New South Wales
Court of Appeal
CITATION: MBAKWE v SARKIS [2009] NSWCA 330 HEARING DATE(S): 10/08/2009
JUDGMENT DATE:
15 October 2009JUDGMENT OF: Allsop P at 1; Ipp JA at 2; Handley AJA at 3 DECISION: Appeal dismissed with costs. CATCHWORDS: TORTS - negligence - duty of care in utterance - defendant plaintiff's financial adviser - advice volunteered -duty of care existed. - MISREPRESENTATION - need not the sole cause of plaintiff's change of position - liability not excluded by other contributing causes. - MISREPRESENTATION – when representation continues. CASES CITED: Abalos v Australian Postal Commission (1990) 171 CLR 167 at 179 ;96 ALR 354 at 363
Shaddock & Associates Pty Ltd v Parramatta City Council [No. 1] [1981] HCA 59, 150 CLR 225, 251, 255-6
San Sebastian Pty Ltd v The Minister [1986] HCA 68, 162 CLR 340, 355-6, 371-2
Esanda Finance Corporation Ltd v Peat Marwick Hungerfords [1997] HCA 8, 188 CLR 240, 249-50, 255, 261
Tepko Pty Ltd v Water Board [2001] HCA 19, 206 CLR 1, 16-7, 23
JEB Fasteners Ltd v Marks Bloom & Co [1983] 1 All ER 583 CA, 589
Gould v Vaggelas [1985] HCA 85, 157 CLR 215, 219, 236
Mutual Life and Citizens Assurance Co Ltd v Evatt [1968] HCA 74, 122 CLR 556, 571PARTIES: Samuel Mbakwe - Appellant
Sam George Sarkis - RespondentFILE NUMBER(S): CA 40007/2009 COUNSEL: Appellant: N Obrart
Respondent: M K RollinsonSOLICITORS: Appellant: Keith Hurst & Associates
Respondent: Benjamin Khoury SolicitorsLOWER COURT JURISDICTION: District Court LOWER COURT FILE NUMBER(S): DC 159/2007 LOWER COURT JUDICIAL OFFICER: Rolfe DCJ LOWER COURT DATE OF DECISION: 11/09/2008
CA 40007/09
15 October 2009ALLSOP P
IPP JA
HANDLEY AJA
Samuel MBAKWE v Sam George SARKIS
CATCHWORDS
NEGLIGENCE - duty of care in utterance - defendant plaintiff's financial adviser - advice volunteered -duty of care existed.
MISREPRESENTATION – when representation continues.MISREPRESENTATION - need not the sole cause of plaintiff's change of position - liability not excluded by other contributing causes.
HEADNOTE
The plaintiff had a small but profitable business servicing x-ray film processing and similar equipment in hospitals. However he knew that he needed assistance from someone with financial skills and in late 1999 or early 2000 he appointed the defendant as his financial adviser on a monthly retainer. The plaintiff consulted the defendant about his business on a regular basis and sought his advice on particular matters. However the defendant also offered unsolicited advice which the plaintiff had accepted. In March 2002 the defendant drew to the plaintiff's attention an opportunity to make an unsecured loan to a property developer at what appeared to be a very attractive rate of interest and recommended the investment to him. The plaintiff acted on this advice on three occasions during that year and lent a total of $245,000 to the developer. In fact the borrower and his companies were hopelessly insolvent and the moneys invested were lost. The…
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Details
- AGLC
- Mbakwe v Sarkis [2009] NSWCA 330
- Case
- [2009] NSWCA 330
- Decision Date
CaseChat Overview and Summary
The appeal concerned a claim in negligence brought by the plaintiff, Mr Sarkis, against the defendant, Mr Mbakwe, who had provided financial advice to the plaintiff. The central dispute revolved around whether Mr Mbakwe owed a duty of care to Mr Sarkis in relation to the financial advice he provided. The matter was heard in the Court of Appeal of New South Wales.
The primary legal issue before the court was whether a duty of care could arise in circumstances where financial advice was volunteered by the defendant to the plaintiff, rather than being sought by the plaintiff. This required the court to consider the principles governing the establishment of a duty of care in negligence, particularly in the context of unsolicited advice and the relationship between the parties.
The Court of Appeal affirmed the existence of a duty of care. Applying established principles of negligence, the court found that Mr Mbakwe had voluntarily assumed responsibility for the advice he gave to Mr Sarkis. The court reasoned that when a person voluntarily assumes responsibility for the accuracy of advice given to another, and that other person relies on that advice to their detriment, a duty of care can arise, irrespective of whether the advice was formally sought. The court considered the circumstances in which such a duty is imposed, focusing on the reliance placed by the plaintiff on the defendant's expertise and the foreseeability of harm.
The appeal was dismissed, and Mr Mbakwe was ordered to pay the costs of the appeal.
The primary legal issue before the court was whether a duty of care could arise in circumstances where financial advice was volunteered by the defendant to the plaintiff, rather than being sought by the plaintiff. This required the court to consider the principles governing the establishment of a duty of care in negligence, particularly in the context of unsolicited advice and the relationship between the parties.
The Court of Appeal affirmed the existence of a duty of care. Applying established principles of negligence, the court found that Mr Mbakwe had voluntarily assumed responsibility for the advice he gave to Mr Sarkis. The court reasoned that when a person voluntarily assumes responsibility for the accuracy of advice given to another, and that other person relies on that advice to their detriment, a duty of care can arise, irrespective of whether the advice was formally sought. The court considered the circumstances in which such a duty is imposed, focusing on the reliance placed by the plaintiff on the defendant's expertise and the foreseeability of harm.
The appeal was dismissed, and Mr Mbakwe was ordered to pay the costs of the appeal.
Orders
Orders of the court
Appeal dismissed with costs.
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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