NEW SOUTH WALES COURT OF APPEAL
CITATION: Natcomp Technology Australia Pty Limited v Graiche [2001] NSWCA 120
FILE NUMBER(S):
40063/00
HEARING DATE(S): 30 March 2001
JUDGMENT DATE: 30/04/2001
PARTIES:
Natcomp Technology Australia Pty Limited (Appellant)
Joseph Graiche (Respondent)
JUDGMENT OF: Spigelman CJ Stein JA Heydon JA
LOWER COURT JURISDICTION: District Court
LOWER COURT FILE NUMBER(S): DC 3626/97
LOWER COURT JUDICIAL OFFICER: Hogan ADCJ
COUNSEL:
B A J Coles QC/T D Blackburn (Appellant)
R B S MacFarlan QC/M Wigney (Respondent)
SOLICITORS:
Gray & Perkins (Appellant)
P A Somerset & Co (Respondent)
CATCHWORDS:
COMMERCIAL LAW - director's duties - s 60(1) The Corporations Law - whether a de facto director or a shadow director - extent of involvement in business necessary to be deemed a director - ND
LEGISLATION CITED:
The Corporations Law (NSW)
Fair Trading Act 1987 (NSW)
DECISION:
Appeal dismissed with costs
JUDGMENT:
IN THE SUPREME COURT
OF NEW SOUTH WALES
COURT OF APPEALCA 40063/00
DC 3626/97
SPIGELMAN CJ
STEIN JAHEYDON JA
Monday, 30 April 2001
NATCOMP TECHNOLOGY AUSTRALIA PTY LIMITED v Joseph GRAICHE
Facts:
The appellant company supplied computer equipment to Amtech Industries Pty Ltd (Amtech), a company that went into liquidation in late 1996. At first instance, the appellant obtained default judgment against the appointed directors of Amtech, Messrs Le Gentil and Serra. The respondent, who was not an appointed director of Amtech, had made a series of statements, and permitted statements to be made in his presence, which suggested a close connection between himself and Amtech. The appellant appeals the decision of Hogan ADCJ that the respondent was neither a ‘de facto’ or a ‘shadow’ director under s60(1) of the Corporations Law.
Held:
Per Spigelman CJ, Stein JA and Heydon JA:
That the evidence placed before the trial judge was inadequate to establish that the respondent was either a de facto or a shadow director of Amtech. Accordingly, his Honour was correct to dismiss the proceedings against the respondent.
Orders:
Appeal dismissed with costs.
oOo
IN THE SUPREME COURT
OF NEW SOUTH WALES
COURT OF APPEAL
CA 40063/00
DC 3626/97
SPIGELMAN CJ
STEIN JAHEYDON JA
Monday, 30 April 2001
NATCOMP TECHNOLOGY AUSTRALIA PTY LIMITED v Joseph GRAICHE
JUDGMENT
SPIGELMAN CJ: I agree with Stein JA.
STEIN JA: This is an appeal from a decision of Hogan ADCJ. At first instance it was alleged that the respondent, Dr Joseph Graiche, was a ‘de facto’ or ‘shadow’ director of Amtech Industries Pty Ltd (Amtech) under s 60(1) of the Corporations Law. The evidence failed to satisfy his Honour on either basis. The appellant (Natcomp Technology Australia Pty Ltd) seeks to recover the price of goods sold and delivered by it in 1996 to Amtech, from the respondent personally. Amtech went into liquidation in late 1996. In the subject proceedings, the appellant obtained default judgment against the appointed directors of Amtech, Mr Patrick Le Gentil and Mr Jose Bernardino Lopes Serra. The appellant unsuccessfully sought relief against the respondent under the Fair Trading Act 1987
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- AGLC
- Natcomp Technology Australia Pty Ltd v Graiche [2001] NSWCA 120
- Case
- [2001] NSWCA 120
- Decision Date
CaseChat Overview and Summary
The primary legal issue before the Full Federal Court was to determine whether Mr Graiche's conduct and level of influence over Natcomp's affairs constituted him as a director, either de facto or shadow, for the purposes of section 60(1) of the *Corporations Law*. This required the court to consider the nature and degree of control or direction Mr Graiche exercised over the company's management and operations.
The Court affirmed the principles governing the identification of de facto and shadow directors. It held that to be a de facto director, a person must act as a director in substance, even if not formally appointed. For a shadow director, the person must be someone in accordance with whose directions or instructions the directors of the company are accustomed to act. The Court found that the evidence supported the conclusion that Mr Graiche's involvement was such that he was accustomed to directing the directors of Natcomp, thereby fulfilling the criteria for being a shadow director.
The appeal was dismissed, and Natcomp was ordered to pay Mr Graiche's costs.
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
Established by: SPIGELMAN CJ
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