SUPREME COURT OF VICTORIA
COURT OF APPEAL
S APCI 2009 3876
| MBF INVESTMENTS PTY LTD (ACN 005 731 957) | Appellant |
| v | |
| DAMIEN NOLAN | Respondent |
---
| JUDGES | NEAVE, REDLICH and WEINBERG JJA | |
| WHERE HELD | MELBOURNE | |
| DATE OF HEARING | 29 and 30 July 2010 | |
| DATE OF JUDGMENT | 20 April 2011 | |
| MEDIUM NEUTRAL CITATION | [2011] VSCA 114 | 1st Revision: 25 Nov 2011 [163] & [227] |
| JUDGMENT APPEALED FROM | Nolan v MBF Investments Pty Ltd [2009] VSC 244 and [2009] VSC 457 (Vickery J) | |
---
MORTGAGES – Statutory power of sale – Transfer of Land Act 1958, s 77(1) – Scope of mortgagee’s duty – Pendlebury v The Colonial Mutual Life Assurance Society Ltd (1912) 13 CLR 676; Hawkesbury Valley Developments Pty Ltd v Custom Credit Corporation Ltd [1995] NSW Conv R 55-731, considered – Property sub-divided after default – House situated on one lot – Whether mortgagor had ‘home occupation interest’ – Relevance of international instruments to interpretation of statutory duty – Fair market value obtained at auction – Order of sale of lots contrary to wishes of mortgagor – Sale not causative of any loss.
CONTRACT – Construction – Exclusion clause – Deed of settlement – Limitation of duty owed by mortgagee to have regard to particular interest when exercising statutory power of sale – Waiver of any liability arising from exercise of power.
DAMAGES – Breach of duty owed when exercising statutory power of sale – Transfer of Land Act 1958, s 77(4) – Nature of remedy – Measure of loss and damage – Increase in value of properties wrongfully sold.
---
| Appearances: | Counsel | Solicitors |
| For the Appellant | Mr R M Garratt QC with Mr L E Hawas | Rigby Cooke Lawyers |
| For the Respondent | Mr C W R Harrison SC with Mr T J Sowden | Nicholas O’Donohue & Co Lawyers |
NEAVE JA
REDLICH JA
WEINBERG JA:
Introduction
The appellant, MBF Investments Pty Ltd (‘MBF’), an investment company controlled by the Christian religious order known as the Good Shepherd Sisters, was the mortgagee of property situated at 16-18 Walmer Street, Kew (the ‘property’). The respondent, Mr Damien Nolan, was the mortgagor of that property, which he held as trustee of a family trust known as the Prudent Trust. By the time the property came to be sold, it had been subdivided into three lots (hereafter referred to as ‘Lot 1’, ‘Lot 2’ and ‘Lot 3’). There was a house on Lot 1, in which Mr Nolan had lived with his wife and children for many years. The other two lots were vacant.
Following the mortgagor’s failure to make the payments of interest required by the mortgage, and after giving the required notices,[1] MBF exercised its power of sale by auctioning the three lots on 18 August 2001. Mr Nolan then initiated Supreme Court proceedings claiming damages from MBF for an alleged breach of the duty to sell ‘in good faith and having regard to the interests of the mortgagor’ imposed on it by s 77(1) of the Transfer…
Keep reading for free
Create a free CaseChat account to read MBF Investments Pty Ltd v Nolan and more:
- Read every judgment in full
- Ask AI and get answers linked to paragraphs
- See how each paragraph was cited in later cases
- Download judgments as PDF or Word
One click creates your free account or signs you in.
By continuing you agree to the Terms and Privacy Policy.
- Case
- [2011] VSCA 114
- Decision Date
CaseChat Overview and Summary
The court had to determine the scope of the duty owed by a mortgagee when exercising their statutory power of sale, particularly in the context of a sub-divided property where the mortgagor had a home occupation interest in one of the lots. The court was also required to consider whether the mortgagor had a home occupation interest in the lot on which the house was situated, and if this interest impacted the mortgagee's duty. Additionally, the court had to examine whether international instruments could be relevant to the interpretation of the statutory duty and whether the sale was conducted in a manner that resulted in any loss to the mortgagor.
The court held that the mortgagee owed a duty to the mortgagor when exercising its statutory power of sale, which included ensuring that the sale was conducted in a manner that did not cause loss to the mortgagor. The court found that the mortgagor had a home occupation interest in the lot on which the house was situated, and this interest impacted the mortgagee's duty. However, the court also found that the sale was conducted in a manner that did not result in any loss to the mortgagor, and therefore, the mortgagee did not breach its duty. The court also held that international instruments could be relevant to the interpretation of the statutory duty, but in this case, they did not impact the outcome.
The court dismissed the mortgagee's claim and ordered the mortgagee to pay the mortgagor's costs of the proceeding.
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
Full text does not contain this section.
Ratio Decidendi
Legal Principle Established
Full text does not contain this section.