FAMILY COURT OF AUSTRALIA
Newman & Tate (No. 2) [2021] FamCA 31
File number(s):
SYC 4869 of 2017
Judgment of:
MCCLELLAND DCJ
Date of judgment:
4 February 2021
Catchwords:
FAMILY LAW – COSTS – Where the mother seeks the father pay legal costs incurred by her incidental to interim parenting proceedings which included a Contravention Application and Application for a recovery order, heard and determined by a Senior Registrar, and an Application for a review of the Senior Registrars decision – Where the father opposes the orders sought by the mother – Whether the conduct of the parties justifies making of orders for costs – Where the circumstances justify an order for the totality of costs incurred on an indemnity basis – Order made for costs to be paid by father in respect to the Contravention and recovery order Applications in a fixed sum.
Legislation:
Family Law Act 1975 (Cth) s 70NFB, 117
Family Court Rules 2004 (Cth) r 19.18
Cases cited:
Byrnes v Brisconnections Management Co Ltd (No. 2) [2009] FCA 1432
Cross & Beaumont (2008) 39 Fam LR 389
Fitzgerald (as child representative for A (Legal Aid Commission of Tasmania)) v Fish (2005) 33 Fam LR 123
Hawkins & Roe (2012) 47 Fam LR 526
Hitch v Hitch (2012) 47 Fam LR 603
Idoport Pty Ltd v National Australia Bank Ltd [2007] NSWSC 23
Kohan and Kohan (1993) FLC 92-340 at 79,614
Medlon & Medlon (No 6) (Indemnity Costs) (2015) FLC 93-664
Penfold v Penfold (1980) 144 CLR 311 at 315.
Stoian & Fiening (Costs) [2014] FamCA 944
Number of paragraphs:
47
Date of last submission/s:
12 January 2021
Date of hearing:
In Chambers by written submissions
Place:
Sydney
Solicitor for the Applicant:
Eddy Neumann Lawyers
Solicitor for the Respondent:
Mills Oakley Lawyers
ORDERS
SYC 4869 of 2017 BETWEEN: MS NEWMAN
ApplicantAND: MR TATE
Respondent
ORDER MADE BY:
MCCLELLAND DCJ
DATE OF ORDER:
4 FEBRUARY 2021
THE COURT ORDERS THAT:
1.Mr Tate is to, within 28 days, pay Ms Newman the sum of $23,092.25 in respect to legal fees incurred by her in relation to her Application in a Case filed 9 October 2020 and Contravention Application filed 12 October 2020, heard and determined on 20 October 2020.
Note: The form of the order is subject to the entry in the Court’s records.
Note: This copy of the Court’s Reasons for judgment may be subject to review to remedy minor typographical or grammatical errors (r 17.02A(b) of the Family Law Rules 2004 (Cth)), or to record a variation to the order pursuant to 17.02 Family Law Rules 2004 (Cth).
IT IS NOTED that publication of this judgment by this Court under the pseudonym Newman & Tate has been approved by the Chief Justice pursuant to s 121(9)(g) of the Family Law Act 1975 (Cth).
REASONS FOR JUDGMENT
McClelland DCJ:
INTRODUCTION
This matter concerns an Application for costs of and incidental to interim parenting proceedings – an Application in a Case filed 9 October 2020 by Ms Newman…
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- Newman & Tate (No. 2) [2021] FamCA 31
- Case
- [2021] FamCA 31
- Decision Date
CaseChat Overview and Summary
The primary legal issue before the court was whether the conduct of the parties justified making orders for costs, and if so, on what basis. The court was required to consider the relevant provisions of the *Family Law Act 1975* (Cth), particularly section 117(2A), which outlines factors to be considered when making costs orders, including the conduct of the parties. The court also considered the financial circumstances of both parties.
McClelland DCJ applied the principles established in *Wrensted & Eades*, confirming that there is no distinction in legislative considerations for costs orders in parenting proceedings compared to property proceedings. While acknowledging that both parties faced financial hardship in meeting legal fees, the court held that financial incapacity does not preclude a costs order where conduct warrants it. The court found that the mother was only partially successful in her application for costs, and therefore, an order for the totality of costs on an indemnity basis was not justified. However, the court did find that the father's conduct in relation to the Contravention and recovery order applications warranted an order for costs.
The court ordered Mr Tate to pay Ms Newman the sum of $23,092.25 in respect to legal fees incurred by her in relation to her Application in a Case filed 9 October 2020 and Contravention Application filed 12 October 2020, heard and determined on 20 October 2020.
Orders
Orders of the court
THE COURT ORDERS THAT:
1. Mr Tate is to, within 28 days, pay Ms Newman the sum of $23,092.25 in respect to legal fees incurred by her in relation to her Application in a Case filed 9 October 2020 and Contravention Application filed 12 October 2020, heard and determined on 20 October 2020.
Note: The form of the order is subject to the entry in the Court’s records.
Note: This copy of the Court’s Reasons for judgment may be subject to review to remedy minor typographical or grammatical errors (r 17.02A(b) of the Family Law Rules 2004 (Cth)), or to record a variation to the order pursuant to 17.02 Family Law Rules 2004 (Cth).
IT IS NOTED that publication of this judgment by this Court under the pseudonym Newman & Tate has been approved by the Chief Justice pursuant to s 121(9)(g) of the Family Law Act 1975 (Cth).
Background
Background to the litigation
Evidence
Evidence Before The Court
Full text does not contain this section.
Decision
Reasons for decision
Ratio Decidendi
Legal Principle Established
I respectfully agree with the reasoning of the Full Court in Wrensted & Eades in finding that there is no distinction in the legislative considerations that the court is required to have regard to in respect to an Application for costs in parenting proceedings, as opposed to property proceedings.CONSIDERATIONThe financial circumstances of the parties The mother, in her Financial Statement filed 7 January 2021, states that she is a contractor in finance and, by way of summary, her financial circumstances are as follows: ·her average weekly income is $3650; ·her weekly expenditure is $3609; ·the total value of property owned by her is $6470; ·the total value of her superannuation is $162,871; ·the totality of her liabilities is $462,704; and ·she has no additional financial resources. Comparatively, in his Financial Statement filed 12 January 2021, the father states that he is a self-employed farmer and, by way of summary, his financial circumstances are as follows:·his average weekly income is $5000; ·his weekly expenditure is $5000;·he owns no property;·he has superannuation valued at $10,000;·he has liabilities of $3000; and ·he has financial resources of $15,000. The mother contends that the father has not, in his Financial Statement, accurately set out his financial situation. It is not possible, however, in these proceedings, for me to make a determination as to whether that is or is not correct. On the face of the Financial Statements filed by both parties, in which they both attest to the accuracy of the information which they have provided, I am satisfied that meeting legal fees incurred by the parties in respect to these proceedings presents a hardship for both of them. However, in Cross & Beaumont (2008) 39 Fam LR 389 at 402,[60], the Full Court held that financial incapacity to pay a costs order is not a barrier where the conduct of the party may warrant the making of such an order. Whether either of the parties are in receipt of legal aid Neither party has suggested that they are in receipt of legal aid and, accordingly, s117 (2A)(b) of the Act is not relevant.The conduct of the parties In addressing s 117(2A)(c) of the Act, the submissions of the mother focused upon the conduct of the father in withholding X and Y in his care following the September 2020 school holidays. Section 117(2A)(c) is, however, focused at the conduct of the parties as litigants, rather than as separated parents generally: see Hitch v Hitch (2012) 47 Fam LR 603. That is not to say, however, that the parties’ conduct prior to the commencement of the proceedings is an irrelevant consideration. Accordingly, I will discuss the conduct of the parties in the context of considering s 117(2A)(g) of the Act. Having regard to the summary of the proceedings which I have set out above, in the context of events which occurred on 22 October 2020 when X was admitted for psychiatric care, and until when the father filed his Application for review of the Senior Registrar’s decision of 23 November 2020, there is, in my view, no reasonable basis for the mother to assert that the father has acted improperly in respect to the conduct of the proceedings.