SUPREME COURT OF SOUTH AUSTRALIA
(Testamentary Causes Jurisdiction: Application)
In the Estate of MUSOLINO (DECEASED)
[2008] SASC 334
Judgment of The Honourable Justice Gray
2 December 2008
SUCCESSION - WILLS, PROBATE AND ADMINISTRATION - PROBATE AND LETTERS OF ADMINISTRATION - ALTERATION AND REVOCATION OF GRANTS - IN WHAT CIRCUMSTANCES - OTHER CASES
SUCCESSION - WILLS, PROBATE AND ADMINISTRATION - PROBATE AND LETTERS OF ADMINISTRATION - GRANTS OF PROBATE AND LETTERS OF ADMINISTRATION - LIMITED, SPECIAL, AND CONDITIONAL GRANTS OF PROBATE AND ADMINISTRATION - OTHER CASES
Application by Public Trustee for revocation of grant of letters of administration of deceased’s estate, and for grant of probate of unsigned photostat copy of will of deceased – copy will bore a stamp indicating that original was executed on 21 January 1982 and lodged in office of Public Trustee – following deceased’s death, Public Trustee advised administrator that original will could not be found – Public Trustee initially reluctant to admit copy will to proof – the deceased’s children agreed that the youngest son would apply for letters of administration, and other children would transfer their entitlements to administrator – Deed of Family Arrangement to effect the transfer prepared – due to subsequent falling out between deceased’s two eldest sons and rest of family deed was not executed – Public Trustee then instructed administrator to initiate proceedings to admit copy will to proof – consents sought from “all persons who may be prejudiced by the grant” pursuant to Rule 68 The Probate Rules 2004 (SA) – administrator, deceased’s daughter and deceased’s second youngest son agreed to application – deceased’s two eldest sons were served with proceedings but did not appear – application referred to a Judge.
Held, allowing the application: Deceased made a valid will – copy will was a true and correct copy of original will which cannot be found – original will was not revoked before deceased’s death – in the circumstances, it is just and expedient to dispense with the requirement for consent from all persons who may be prejudiced by the grant – letter of administration – grant of probate of copy will to Public Trustee.
The Probate Rules 2004 (SA) s 68, s 77; Administration and Probate Act 1919 (SA) s 5; Supreme Court Act 1935 (SA) s 18, referred to.
Butler v Meriga [1904] St R Qd 248; Caldar v Public Trustee [2003] NSWCA 187; Curley v Duff (1985) 2 NSWLR 715; Greenland v Baldwin and Neale [2007] 1 Qd R 117, applied.
In the Estate of Gerard, deceased (2007) 251 LSJS 176; In the Estate of Gwynne, deceased (1988) 48 SASR 209; In the Estate of Marden, deceased [2008] SASC 312; In the Estate of Roediger Deceased [1967] SASR 118, distinguished.
In the Estate of Vauk (1986) 41 SASR 242; In the Estate of Yeo (1978) 17 SASR 545; In the Will of Christian (1975) 25 FLR 89, discussed.
Karwala v Skrzypczak; In the Estate of Ratajczak [2006] NSWSC 203
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- AGLC
- MUSOLINO (DECEASED) [2008] SASC 334
- Case
- [2008] SASC 334
- Decision Date
CaseChat Overview and Summary
The legal issues before the court included whether the copy will was a true and correct copy of the original will, whether the original will had been revoked before the deceased's death, and whether it was just and expedient to dispense with the requirement for consent from all potentially prejudiced parties. The court needed to determine if the circumstances justified revoking the letters of administration and granting probate over the copy will. The court held that the copy will was a true and correct copy of the original will, which was not revoked before the deceased's death. It was satisfied that a proper and reasonable attempt had been made to obtain consent from all potentially prejudiced parties. The court found that it was just and expedient to dispense with the requirement for consent from the two eldest sons, who had not responded to the proceedings. Consequently, the court revoked the grant of letters of administration to the youngest son and granted probate over the copy will to the Public Trustee, limited until the original will or a more authentic copy is produced.
The court’s decision led to specific orders being made. The grant of letters of administration issued to Vincenzo Musolino on 1 November 2006 was revoked and declared null and void. Probate of the last will and testament executed on 21 January 1982, as contained in the copy will, was granted to the Public Trustee, limited until the original will or a more authentic copy is brought into and left in the Probate Registry of the Court. This decision ensures that the deceased's estate is administered according to the terms of the will, rather than under the rules of intestacy.
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