FEDERAL COURT OF AUSTRALIA
Monarch Advisory Group Pty Ltd v Puxty (No 2) [2021] FCA 801
File number: NSD 951 of 2020 Judgment of: MARKOVIC J Date of judgment: 16 July 2021 Catchwords: PRACTICE AND PROCEDURE – application to restrain solicitors from acting for the applicant – whether there is a real and sensible possibility of the misuse of confidential information – whether the proper administration of justice requires the solicitors to be restrained from acting – where no evidence that solicitors acted for respondents – where unclear whether information was provided to solicitors – where information lacks necessary character of confidence even if provided to solicitors – application dismissed Legislation: Competition and Consumer Act 2010 (Cth) Sch 2 (Australian Consumer Law) ss 18 31
Corporations Act 2001 (Cth) ss 182, 183
Cases cited: Dyer v Chrysanthou (No 2) (Injunction) [2021] FCA 641
Jing Li v Jin Lian Group Pty Ltd [2018] NSWSC 479
Monarch Advisory Group Pty Ltd v Puxty [2021] FCA 341
Mumbin v Northern Territory of Australia (No 1) [2020] FCA 475
Division: General Division Registry: New South Wales National Practice Area: Commercial and Corporations Sub-area: Commercial Contracts, Banking, Finance and Insurance Number of paragraphs: 72 Date of hearing: 25 February 2021, 29 March 2021 Counsel for the Applicant: Mr D Mahendra Solicitor for the Applicant: Madison Marcus Law Firm Counsel for the Respondents: Mr M Luitingh Solicitor for the Respondents: Edge Legal Group ORDERS
NSD 951 of 2020 BETWEEN: MONARCH ADVISORY GROUP PTY LTD
Applicant
AND: MR BRETT JAMES PUXTY
First Respondent
MR FRANCIS COGGAN
Second Respondent
ODYSSEY ADVISORY SERVICES ACN 155 549 705
Third Respondent
ORDER MADE BY:
MARKOVIC J
DATE OF ORDER:
16 JULY 2021
THE COURT ORDERS THAT:
1.The respondents’ interlocutory application filed on 8 December 2020 (Interlocutory Application) is dismissed.
2.The applicant is to file its submissions on the question of the costs of the Interlocutory Application, not exceeding three pages in length, by 30 July 2021.
3.The respondents are to file their submissions on the question of the costs of the Interlocutory Application, not exceeding three pages in length, by 13 August 2021.
4.Unless either party requests an oral hearing, the question of costs of the Interlocutory Application will be dealt with on the papers.
Note: Entry of orders is dealt with in Rule 39.32 of the Federal Court Rules 2011.
REASONS FOR JUDGMENT
MARKOVIC J:
This is an application made by Brett James Puxty, Francis Coggan and Odyssey Advisory Services Pty Ltd, the respondents in this proceeding, against the applicant, Monarch Advisory Group Pty Ltd, for an order “removing and or barring” Monarch’s lawyers, Madison Marcus Law Firm Pty Ltd, from acting for it in this proceeding.
The grounds for the application appear to be first, the risk of misuse of confidential information said to be provided by Mr Puxty to Madison Marcus when that firm was retained…
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- Case
- [2021] FCA 801
- Decision Date
CaseChat Overview and Summary
The court examined the nature of the relationship between Madison Marcus and the respondents, the information allegedly provided to Madison Marcus, and the potential for misuse of this information. It was noted that there was no evidence that Madison Marcus had acted for the respondents or that the information provided was of a confidential nature. Even if the information had been provided to Madison Marcus, it lacked the necessary character of confidence to warrant restraint. The court concluded that a fair-minded reasonably informed member of the public would not find that the administration of justice required the court to exercise its inherent jurisdiction to restrain Madison Marcus from acting for the applicant.
The interlocutory application was dismissed, and the court ordered the parties to file submissions on the costs of the application. Unless an oral hearing was requested, the court would determine the issue of costs on the papers. This decision underscores the importance of demonstrating a real and sensible possibility of misuse of confidential information and the necessity for the proper administration of justice to justify restraining legal representatives from acting.
Orders
Orders of the court
1. The respondents’ interlocutory application filed on 8 December 2020 (Interlocutory Application) is dismissed.
2. The applicant is to file its submissions on the question of the costs of the Interlocutory Application, not exceeding three pages in length, by 30 July 2021.
3. The respondents are to file their submissions on the question of the costs of the Interlocutory Application, not exceeding three pages in length, by 13 August 2021.
4. Unless either party requests an oral hearing, the question of costs of the Interlocutory Application will be dealt with on the papers.
Note: Entry of orders is dealt with in Rule 39.32 of the Federal Court Rules 2011.
Background
Background to the litigation
Evidence
Evidence Before The Court
Decision
Reasons for decision
Ratio Decidendi
Legal Principle Established
The nature of Monarch’s claim against the respondents is set out at [12]-[13] of Monarch (No 1). In summary, Monarch alleges that Messrs Puxty and Coggan breached various terms of their respective employment agreements, including in relation to restraint of trade and confidentiality, and their fiduciary duties owed to Monarch and that they contravened s 182(1) and s 183(1) of the Corporations Act 2001 (Cth) (Corporations Act). Monarch alleges that Odyssey was involved in the alleged breaches by Messrs Puxty and Coggan of their fiduciary duties and of the Corporations Act. Monarch also claims that the respondents made representations to its clients in contravention of s 18 of the Australian Consumer Law being Sch 2 to the Competition and Consumer Act 2010 (Cth) (ACL) and that they engaged in conduct which amounted to passing off. In effect, the respondents each deny the allegations made against them. Mr Puxty alone has filed a cross-claim against Monarch. Among other things, he alleges that:(1)in December 2018 he and Monarch concluded a joint venture agreement (JVA) in relation to which Mr Kardum and Ms Coulter, as authorised representatives, represented Monarch and Mr Puxty represented himself;(2)Monarch failed to comply with its obligations under the JVA in that it failed to make payments of the recurring revenue as agreed in the JVA and the performance review and bonus document (PRB) and failed to maintain the trust payments as agreed under the PRB;(3)on or about 20 April 2019 the Puxty Employment Agreement was terminated by mutual written consent between Monarch and Mr Puxty or, alternatively, by the entry into of a new joint venture agreement (2019 JVA) that superseded and was incompatible with the Puxty Employment Agreement;(4)on or about 20 April 2019 Mr Puxty, representing himself, and Ms Coulter, representing Monarch, entered into the 2019 JVA which was partly in writing and partly oral;(5)on or about 31 January 2020 Mr Puxty and Ms Coulter agreed that the 2019 JVA and the Puxty Employment Agreement would be terminated (2020 Termination Agreement). The 2020 Termination Agreement was partly in writing and partly oral; (6)on or about 26 July 2020 Mr Puxty paid $30,000 to Monarch (Loan Amount) at Monarch’s special insistence and request;(7)the Loan Amount was repayable on demand or alternatively within a reasonable time;(8)notwithstanding demand and/or lapse of a reasonable time, Monarch has failed and/or neglected to repay the Loan Amount or any part thereof to Mr Puxty; (9)as a result of Monarch’s breaches of the 2020 Termination Agreement Mr Puxty has suffered loss and damage;(10)in the event that the Court finds that the Puxty Employment Agreement has not been terminated, Mr Puxty alleges that in negotiating the Puxty Employment Agreement Monarch, represented by Mr Kardum and Ms Coulter, made a number of representations to him. Those representations were made in trade or commerce, were not true and/or were deceptive and/or likely to mislead within the meaning of s 31 of the ACL and, as a result of Monarch’s misleading and deceptive conduct, Mr Puxty suffered damage; and(11)Monarch also made representations in trade or commerce to Mr Puxty about the JVA, the 2019 JVA and the 2020 Termination Agreement. In making the representations Monarch engaged in conduct that was misleading or deceptive or likely to mislead or deceive in contravention of s 18 of the ACL and Mr Puxty relied on the representations which were not true and as a result of relying on the representations, Mr Puxty has suffered loss.LEGAL PRINCIPLES