MSPR Pty Ltd v Advanced Braking Technology Ltd

Case [2013] NSWCA 416


Court of Appeal


Supreme Court


New South Wales

Medium Neutral Citation: MSPR Pty Ltd v Advanced Braking Technology Ltd [2013] NSWCA 416
Hearing dates:18 November 2013
Decision date: 09 December 2013
Before: Macfarlan JA at [1]
Ward JA at [72]
Gleeson JA at [73]
Decision:

The appeal is dismissed with costs.

[Note: The Uniform Civil Procedure Rules 2005 provide (Rule 36.11) that unless the Court otherwise orders, a judgment or order is taken to be entered when it is recorded in the Court's computerised court record system. Setting aside and variation of judgments or orders is dealt with by Rules 36.15, 36.16, 36.17 and 36.18. Parties should in particular note the time limit of fourteen days in Rule 36.16.]

Catchwords: EVIDENCE - dispute as to whether payments to company by way of loan or investment in shares - plaintiffs did not call witness who could have given direct evidence of relevant conversations - whether Jones v Dunkel 101 CLR 298 inference should have been drawn - whether witness in plaintiffs' camp - nature of inference that was permissible to draw
Cases Cited: ASIC v Hellicar [2012] HCA 17; 247 CLR 345
Brandi v Mingot (1976) 12 ALR 551
Fox v Percy [2003] HCA 22; 214 CLR 118
G v H [1994] HCA 48; 181 CLR 387
Gauci v Commissioner of Taxation [1975] HCA 54; 135 CLR 81
Jones v Dunkel [1959] HCA 8; 101 CLR 298
Kuhl v Zurich Financial Services [2011] HCA 11; 243 CLR 361
Payne v Parker [1976] 1 NSWLR 191
Schellenberg v Tunnel Holdings Pty Limited [2000] HCA 18; 200 CLR 121
Watson v Foxman (1995) 49 NSWLR 315
Category:Principal judgment
Parties: MSPR Pty Ltd (First Appellant)
Phyro Holdings Pty Ltd (Second Appellant)
Advanced Braking Technology Ltd (Respondent)
Representation: Counsel:
C Birch SC/T Lynch SC (Appellants)
I R Pike SC (Respondent)
Solicitors:
Aitken Lawyers (Appellants)
Marque Lawyers (Respondent)
File Number(s):CA 2012/290296
 Decision under appeal 
Jurisdiction:
9101
Citation:
MSPR Pty Ltd and Phyro Holdings Pty Ltd v Advanced Braking Technology Ltd [2012] NSWDC 140
Date of Decision:
2012-08-22 00:00:00
Before:
Knox SC DCJ
File Number(s):
2009/338826

Judgment

  1. MACFARLAN JA: In 2002 there was a public float of Advanced Braking Technology Ltd ("ABT"), then known as Safe Effect Technologies Ltd, a company which had devised an advanced motor vehicle braking technology. Through his company Fingora Pty Ltd, Mr Roger Cowan subscribed for, and was issued, 3.5 million shares in ABT at a cost of 10 cents each. In 2003, ABT made a rights issue to its shareholders. It was underwritten by Hood Group Holdings Ltd ("Hood Group") of which Mr Stanley Holmes was the principal. The issue was substantially under-subscribed. As Hood Group did not have sufficient funds to pay for the shortfall shares, those shares were issued to it subject to its undertaking not to deal with them before the proceeds of their resale were paid to ABT.

  1. Mr Cowan gave evidence in the present proceedings…

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AGLC
MSPR Pty Ltd v Advanced Braking Technology Ltd [2013] NSWCA 416
Case
[2013] NSWCA 416
Decision Date

CaseChat Overview and Summary

MSPR Pty Ltd and others (the plaintiffs) appealed a decision concerning payments made to Advanced Braking Technology Ltd (the defendant). The central dispute revolved around whether these payments constituted loans to the company or investments in shares. The plaintiffs had not called a witness who possessed direct knowledge of the relevant conversations that could have clarified the nature of these payments.

The Court of Appeal was required to determine whether it was open to draw an inference against the plaintiffs under the principle established in *Jones v Dunkel* (1959) 101 CLR 298. This principle allows for an inference to be drawn against a party that fails to call a witness who is available and could have given relevant evidence. The court had to consider whether the witness in question was within the plaintiffs' "camp" and, if so, what nature of inference was permissible.

The Court of Appeal upheld the primary judge's decision, finding that the inference under *Jones v Dunkel* was indeed permissible. The court reasoned that the witness was available to the plaintiffs and could have provided crucial evidence regarding the characterisation of the payments. The failure to call this witness allowed the court to infer that their evidence would not have been favourable to the plaintiffs' case. Consequently, the appeal was dismissed with costs.

Orders

Orders of the court

The appeal is dismissed with costs.

[Note: The Uniform Civil Procedure Rules 2005 provide (Rule 36.11) that unless the Court otherwise orders, a judgment or order is taken to be entered when it is recorded in the Court's computerised court record system. Setting aside and variation of judgments or orders is dealt with by Rules 36.15, 36.16, 36.17 and 36.18. Parties should in particular note the time limit of fourteen days in Rule 36.16.]

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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