Reported Decision:
340
District Court
CITATION: Photi v Target Australia Pty Ltd (No. 3) [2008] NSWDC 14 HEARING DATE(S): 15/02/2008
JUDGMENT DATE:
22 February 2008JURISDICTION: Civil JUDGMENT OF: Gibson DCJ DECISION: (1) The defendant is to pay the plaintiff’s costs for the hearing on 25-27 June and subsequent directions dates 9 August, 24 August, 18 September, 4 October, 9 November, 23 November, 11 December 2007 and 15 February 2008 on an indemnity basis; (2) Exhibits retained for 28 days. CATCHWORDS: Tort - costs - application for indemnity costs when trial adjourned due to late amendment - s.48A Defamation Act 1974 (NSW) LEGISLATION CITED: Civil Procedure Act 2005 (NSW), ss.60 and 98
Defamation Act 1974 (NSW), ss.7A, 13 and 48A
Defamation Act 2005(NSW)
Supreme Court Rules 1970 (NSW), Part 52A r.33CASES CITED: Beoco Ltd v Alfa Laval Co Ltd [1995] QB 137
Brisbane South Regional Health Authority v Taylor (1996) 139 ALR 1
Jones v Sutton (No. 2) [2005] NSWCA 203
National Auto Glass Supplies (Australia)Pty Ltd (No 9) [2007] FCA 1826
Photi v Target Australia Pty Ltd [2007] NSWDC 265
Photi v Target Australia Pty Ltd (No. 2) [2007] NSWDC 302
Sims v Wran [1984] 1 NSWLR 317
West & Anor v Nationwide News Pty Ltd [2003] NSWSC 767PARTIES: Plaintiff: Julia Photi
Defendant: Target Australia Pty LtdFILE NUMBER(S): 3364 of 2006 COUNSEL: Plaintiff: L Evans
Defendant: M BarkoSOLICITORS: Plaintiff: Stephen Spinak Solicitor
Defendant: McCabe Terrill
Introduction
1. The plaintiff in these proceedings was awarded a total of $85,000 in damages in actions for assault, wrongful arrest, false imprisonment and defamation: Photi v Target Australia Pty Ltd [2007] NSWDC 265 (11 December 2007). Interest on damages has been agreed at $5,016.
2. The plaintiff now seeks an order for indemnity costs of the trial pursuant to s.48A Defamation Act 1974 (NSW) and s.98 Civil Procedure Act 2005 (NSW). The basis for the application is the defendant’s conduct of the trial, and in particular the late application (made in the course of addresses) to amend the defence to plead a defence of qualified privilege at common law. The history of the delay to the proceedings caused by this late amendment is set out in my judgment of 11 December 2007 at [7] – [18]. Effectively, the handing down of judgment was delayed from 27 June (the last day of the trial) to 23 November (when the parties completed their submissions, following which I handed down my judgment of 11 December 2007).
3. The defendant concedes that the late amendment was made in circumstances warranting an order for indemnity costs, but submits that this should be restricted to the costs thrown away by reason of the late amendment, namely from 27 June to 23 November 2007. The defendant also relies upon s.48A to demonstrate the “reasonableness” of the defendant’s conduct in accordance with that section, and submits that the conduct referred to in s.48A as constituting grounds for indemnity costs has not been made out.
Section 48A
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- Case
- [2008] NSWDC 14
- Decision Date
CaseChat Overview and Summary
The primary legal issue before the court was whether the defendant's late amendment to its pleadings was sufficiently egregious to warrant an award of indemnity costs under section 48A. The court considered the circumstances surrounding the late amendment, including the reasons provided by the defendant for the delay, and the impact of the amendment on the trial process.
The court found that the defendant's late amendment was unjustified and caused significant disruption to the trial process. The court held that the defendant's conduct warranted an award of indemnity costs under section 48A. The court also noted that the defendant had failed to provide a satisfactory explanation for the delay, and that the amendment had a significant impact on the trial process, including causing the adjournment of the trial. Accordingly, the court ordered that the defendant was to pay the plaintiff's costs for the hearing and subsequent directions dates on an indemnity basis.
In addition to the costs order, the court also ordered that any exhibits retained by the parties were to be kept for a period of 28 days. This order was made to ensure that the parties had sufficient time to review any relevant evidence before the trial resumed. Overall, the court's decision highlights the importance of timely and appropriate amendments to pleadings in defamation cases, and the potential consequences of failing to do so.
Orders
Orders of the court
(1) The defendant is to pay the plaintiff's costs for the hearing on 25-27 June and subsequent directions dates 9 August, 24 August, 18 September, 4 October, 9 November, 23 November, 11 December 2007 and 15 February 2008 on an indemnity basis; (2) Exhibits retained for 28 days.
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
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