FEDERAL COURT OF AUSTRALIA
Park (Trustee) v Tschannen (Bankrupt) [2016] FCA 137
File number: QUD 1053 of 2015 Judge: EDELMAN J Date of judgment: 10 March 2016 Catchwords: PRACTICE AND PROCEDURE – service outside the jurisdiction – substituted service – application for examination of bankrupt – need to attempt service in foreign jurisdiction before substituted service possible Legislation: Federal Court Rules 2011 (Cth) rr 10.24, 10.44, 10.49
Bankruptcy Act 1966 (Cth) s 81
Agreement on Judicial Assistance in Civil and Commercial Matters and Co-operation in Arbitration between Australia and the Kingdom of Thailand. Signed 2 October 1997. Australia–Thailand. [1998] ATS 18 (entered into force 29 July 1998)
Cases cited: Clifton (Liquidator), in the matter of Solar Shop Australia Pty Ltd (In Liquidation) [2014] FCA 891
Deputy Commissioner of Taxation v McManus [2015] FCA 959
Laurie v Carroll [1958] HCA 4; (1958) 98 CLR 310
Re Deposit Investment Co Ltd (1991) 30 FCR 463
Re Skase (1991) 32 FCR 212
Southwell v Maladina [2002] FCA 802; (2002) 194 ALR 51
Date of hearing: 10 March 2016 Registry: Queensland Division: General Division National Practice Area: Commercial and Corporations Sub-area: General and Personal Insolvency Category: Catchwords Number of paragraphs: 19 Counsel for the Applicant Ms S D Anderson Solicitor for the Applicant: JHK Legal Solicitor for the First Respondent: The First Respondent did not appear Solicitor for the Second Respondent: The Second Respondent did not appear ORDERS
QUD 1053 of 2015 BETWEEN: JOHN RICHARD PARK AS TRUSTEE OF THE BANKRUPT ESTATE OF WARREN ERIC TSCHANNEN
Applicant
AND:
AND:
WARREN ERIC TSCHANNEN
First Respondent
HELEN MARGARET RANDELL
Second Respondent
JUDGE:
EDELMAN J
DATE OF ORDER:
23 FEBRUARY 2016
THE COURT ORDERS THAT:
1.The applicant be granted leave pursuant to rule 10.44 of the Federal Court Rules 2011 (Cth) to serve upon the first respondent by registered mail, to the Hotel Indigo, Bangkok or other address in the Kingdom of Thailand, the Form 9 Summons for Examination pursuant to section 81 of the Bankruptcy Act 1966 (Cth) attached together with the Notice of Filing and Hearing dated 20 November 2015.
2.This application otherwise be adjourned.
3.The date for examination of the first respondent be amended to 7 April 2016 at 10.00am, to be conducted at the Federal Court, Level 6, Commonwealth Law Courts, 119 North Quay, Brisbane, in the State of Queensland.
4.The adjourned part of this application be provisionally listed for hearing at 10.45am on 15 April 2016.
5.Costs of and incidental to this application be reserved.
Note: Entry of orders is dealt with in Rule 39.32 of the Federal Court Rules 2011.
REASONS FOR JUDGMENT
EDELMAN J:
Introduction
The applicant, the Trustee, seeks the leave of the Court to serve documents, including a summons for examination, on the first respondent, Mr Tschannen, in the Kingdom of Thailand. The Trustee also seeks orders that the summons be served by substituted service. Orders for…
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- Case
- [2016] FCA 137
- Decision Date
CaseChat Overview and Summary
The court considered whether Tschannen could be served by registered mail in Thailand under the Hague Service Convention, which generally requires an attempt at service in the foreign jurisdiction before resorting to substituted service. The court concluded that, while an attempt at service in Thailand was warranted, Tschannen's presence in Thailand was not definitively established, and there was no clear evidence of his address. The court also examined the potential to exercise the power under rule 1.34 to dispense with compliance with the implied requirement in rule 10.49 that an attempt be made at service, but found that the circumstances did not justify such an exception. The urgency of the bankruptcy process did not override the need for an attempt at service in the foreign jurisdiction.
In light of the above, the court granted leave for service out of jurisdiction but denied the application for substituted service. The court reasoned that, without sufficient evidence of Tschannen's presence in Thailand, an attempt at service should be made before resorting to substituted service. The application for substituted service was provisionally adjourned for further consideration. The court also set a new date for the examination of Tschannen and reserved costs of and incidental to the application.
ORDERS:
1. The applicant be granted leave pursuant to rule 10.44 of the Federal Court Rules 2011 (Cth) to serve upon the first respondent by registered mail, to the Hotel Indigo, Bangkok or other address in the Kingdom of Thailand, the Form 9 Summons for Examination pursuant to section 81 of the Bankruptcy Act 1966 (Cth) attached together with the Notice of Filing and Hearing dated 20 November 2015.
2. This application otherwise be adjourned.
3. The date for examination of the first respondent be amended to 7 April 2016 at 10.00am, to be conducted at the Federal Court, Level 6, Commonwealth Law Courts, 119 North Quay, Brisbane, in the State of Queensland.
4. The adjourned part of this application be provisionally listed for hearing at 10.45am on 15 April 2016.
5. Costs of and incidental to this application be reserved.
Orders
Orders of the court
1. The applicant be granted leave pursuant to rule 10.44 of the Federal Court Rules 2011 (Cth) to serve upon the first respondent by registered mail, to the Hotel Indigo, Bangkok or other address in the Kingdom of Thailand, the Form 9 Summons for Examination pursuant to section 81 of the Bankruptcy Act 1966 (Cth) attached together with the Notice of Filing and Hearing dated 20 November 2015.
2. This application otherwise be adjourned.
3. The date for examination of the first respondent be amended to 7 April 2016 at 10.00am, to be conducted at the Federal Court, Level 6, Commonwealth Law Courts, 119 North Quay, Brisbane, in the State of Queensland.
4. The adjourned part of this application be provisionally listed for hearing at 10.45am on 15 April 2016.
5. Costs of and incidental to this application be reserved.
Background
Background to the litigation
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Evidence
Evidence Before The Court
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Decision
Reasons for decision
Ratio Decidendi
Legal Principle Established
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