FEDERAL CIRCUIT AND FAMILY COURT OF AUSTRALIA
(DIVISION 1)
O’Cleary & Vukasin (No 4) [2024] FedCFamC1F 872
File number: SYC 4005 of 2020 Judgment of: CAMPTON J Date of judgment: 18 December 2024 Catchwords: FAMILY LAW – COSTS – Where the husband seeks costs payable by the wife pursuant to s 117 of the Family Law Act 1975 (Cth) of substantive s 79 proceedings – Where consideration is given to the conduct of the wife in the proceedings, including opposing a determination as to a portion of the husband’s interests in a corporation being held on trust for a third party to the marriage, the wife prosecuting relief outside the reasonable ambit of the s 79 discretion, the wife’s offer of settlement being unreasonable, proposing a compromise well outside the reasonable ambit of discretion – Where the husband made a competitive offer of settlement that had some deficiency in the interpretation of its terms – Where both parties, but the wife to a greater extent, failed in compliance with their obligations pursuant to the legislation and the Federal Circuit and Family Court of Australia (Family Law) Rules 2021 (Cth) – Costs ordered for both the substantive proceedings and the costs application in a fixed sum. Legislation: Family Law Act 1975 (Cth) ss 75, 79, 95, 117
Federal Circuit and Family Court of Australia Act 2021 (Cth) s 67
Federal Circuit and Family Court of Australia (Family Law) Rules 2021 (Cth) Sch 3, r 1.04 and r 12.07
Cases cited: Browne v Green (2002) FLC 93-115; [2002] FamCA 791
D & D (Costs) (No 2) (2010) FLC 93-435; [2010] FamCAFC 64
Graham & Squibb (2019) FLC 93-892; [2019] FamCAFC 33
Idoport Pty Ltd v the National Australia Bank Ltd [2007] NSWSC 23
Kohan & Kohan (1993) FLC 92-340; [1992] FamCA 116
Limousin v Limousin (Costs) (2007) 38 Fam LR 478; [2007] FamCA 1178
O’Cleary & Vukasin (No 2) [2024] FedCFamC1F 660
O’Cleary & Vukasin (No 3) [2024] FedCFamC1F 814
Sfakianakis& Sfakianakis (2019) 59 Fam LR 419; [2019] FamCAFC 54
Warbrick and Warbrick (No. 2) (2021) FLC 94-030; [2021] FamCAFC 101
Division: Division 1 First Instance Number of paragraphs: 50 Date of hearing: 6 December 2024 Place: Sydney Counsel for the Applicant: Mr Puckey KC Solicitor for the Applicant: Jeffrey Choy Legal Counsel for the Respondent: Mr Smith Solicitor for the Respondent: JC Legal Practice ORDERS
SYC 4005 of 2020 FEDERAL CIRCUIT AND FAMILY COURT OF AUSTRALIA (DIVISION 1)
BETWEEN: MR VUKASIN
Applicant
AND: MS O’CLEARY
Respondent
ORDER MADE BY:
CAMPTON J
DATE OF ORDER:
18 DECEMBER 2024
THE COURT ORDERS THAT:
1.On or before 31 March 2025, or within such further time as agreed in writing between the husband and the wife, the wife pay the husband’s costs fixed in the sum of $177,500.
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…
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- AGLC
- O’Cleary & Vukasin (No 4) [2024] FedCFamC1F 872
- Case
- [2024] FedCFamC1F 872
- Decision Date
CaseChat Overview and Summary
The court found that the wife's conduct was a significant factor in the husband's application for costs. It was noted that the wife had opposed the recognition of Mr Passerini's entitlements in Vukasin Pty Ltd, which the court considered a core issue in the proceedings. The wife's evidence was found to be either reckless or deliberately inaccurate, aimed at securing a greater division of property in her favour. Despite the wife's contention that her prior solicitors were responsible for her deficiencies, the court gave little weight to this argument. The husband's submission that the wife's conduct led to an unmeritorious claim was also accepted by the court. The court further considered the financial circumstances of both parties and found that the wife's financial situation weighed in her favour. Nevertheless, the court ordered the wife to pay the husband's costs of the substantive proceedings and the costs application in a fixed sum.
In its judgment, the court ordered Ms O'Cleary to pay Mr Vukasin's costs of the substantive proceedings fixed in the sum of $165,000, and the costs of the costs application in the sum of $12,500, making a total of $177,500. The payment was to be made on or before 31 March 2025. The form of the order is subject to entry in the Court’s records, and any minor typographical or grammatical errors may be reviewed or rectified in accordance with the Federal Circuit and Family Court of Australia (Family Law) Rules 2021 (Cth).
Orders
Orders of the court
SYC 4005 of 2020
FEDERAL CIRCUIT AND FAMILY COURT OF AUSTRALIA (DIVISION 1)
BETWEEN:
MR VUKASIN
Applicant
AND:
MS O’CLEARY
Respondent
ORDER MADE BY:
CAMPTON J
DATE OF ORDER:
18 DECEMBER 2024
THE COURT ORDERS THAT:
1. On or before 31 March 2025, or within such further time as agreed in writing between the husband and the wife, the wife pay the husband’s costs fixed in the sum of $177,500.
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 10.14(b) Federal Circuit and Family Court of Australia (Family Law) Rules 2021 (Cth)), or to record a variation to the order pursuant to r 10.13 Federal Circuit and Family Court of Australia (Family Law) Rules 2021 (Cth).
Part XIVB of the Family Law Act 1975 (Cth) makes it an offence, except in very limited circumstances, to publish an account of proceedings that identify persons, associated persons, or witnesses involved in family law proceedings.
Background
Background to the litigation
Evidence
Evidence Before The Court
Decision
Reasons for decision
Full text does not contain this section.
Ratio Decidendi
Legal Principle Established
The Full Court has made clear that it is unnecessary to spell out detailed reasons for decisions in costs matters. I shall refer to such s 117(2A) matters as are relevant and engaged here.CONSIDERATION After the s 79 determination, each party has the benefit of significant property as identified earlier. The wife’s income and income earning capacity is less than that of the husband but is nevertheless not insubstantial (at [241]). To raise funds to retain the G Street property the wife entered a loan agreement to borrow $3.11 million, attracting interest of one per cent each month. The parties’ financial circumstances are a consideration that weighs in favour of the wife. The husband submitted the wife’s conduct in the proceeding was the primary factor grounding his application for costs, including consideration of:(a)The wife’s opposition to the determination of Mr Passerini’s entitlements in Vukasin Pty Ltd. He said this “struck at the core” of the s 79 process in the identification of the existing legal and equitable interests of the husband, and that the dispute as to Mr Passerini’s entitlements, being an issue in the s 79 proceeding since it was initiated, “should never have existed”.(b)The wife’s adducing of inaccurate and at times deliberately false evidence designed to secure a greater division of property in her favour. The husband submitted, and I accept, that the wife was absolute in her position on the first subject matter throughout the litigation, alleging fraud on the part of both he and Mr Passerini as to entering documents in 2006 and 2013 recording the terms of their agreement as to the husband holding 30 percent of his interest in Vukasin Pty Ltd for Mr Passerini. The wife “at the eleventh hour” (on the eve of the trial) conceded that she had been made aware of Mr Passerini’s entitlements by the husband at the time of the commencement of her relationship with him in early 2013. She nevertheless maintained in cross-examination that the written agreement between the husband and Mr Passerini was fabricated, although she could not point to any fact of circumstance or evidence to support that assertion (Exhibit 1, Transcript 10 September 2024, p.157 lines 14–45). The submission of the husband then flowed to the position taken by the wife being an “unmeritorious claim pursued from start to finish”, and that the husband was “dragged to judgment” before a settlement as to the issue of Mr Passerini’s interest was achieved. The wife had little to say in response to this submission. The submission attracts significant weight. The husband’s criticisms as to the evidence adduced by the wife at trial echo the findings made in the primary reasons, especially as identified in bold:36I accept the submission of the husband that an underlying theme constructing the presentation of the wife’s case was to adduce evidence in which she had been either reckless as to its content, or which she knew was inaccurate, with the objective of achieving a perceived advantage in securing findings to generate a greater value of the adjustment of property in her favour. …136At no time during the four years of the proceeding did the wife identify or disclose her knowledge of an agreement or understanding between the husband and [Mr Passerini] for [Mr Passerini] to be “entitled” to 30 per cent of the proceeds of any sale of [Vukasin Pty Ltd]. She did not adduce evidence to explain her secretion of her knowledge of that information or why she provided evidence of her knowledge of this understanding on the business day prior to the trial. She had steadfastly put directly into issue the contention that [Mr Passerini] has any interest arising from any agreement or understanding at any time in [Vukasin Pty Ltd].137It is a reasonable indicator that the wife implicitly knew this information was relevant and material, else it would not have been included in her late affidavit. Her evidence as to her knowledge of an understanding or agreement between the husband and [Mr Passerini] does not stand on all fours with the case that she had pleaded. The circumstances and content of this evidence adversely impacts on her reliability and credibility on the subject matter of [Vukasin Pty Ltd] and the husband’s interests therein. I treat her evidence on this subject matter with caution. 138In cross-examination the wife said she did not know whether the 2006 and 2013 agreements were fabricated. She said she could not point to any fact grounding the assertion that the documents had been fabricated. She nevertheless maintained her contention that the 2006 agreement and the 2013 agreement were not authentic. (Emphasis added)