Queensland Phosphate Pty Ltd v Korda [No 2]

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SUPREME COURT OF VICTORIA

COURT OF APPEAL

S APCI 2019 0016

QUEENSLAND PHOSPHATE PTY LTD
(ACN 609 384 894)
First applicant

PARADISE PHOSPHATE LIMITED

(ACN 154 180 882)

Second applicant
v
MARK ANTHONY KORDA AND CRAIG PETER SHEPARD AS JOINT AND SEVERAL LIQUIDATORS OF LEGEND INTERNATIONAL HOLDINGS INC (IN LIQUIDATION) (ARBN 120 855 352) First respondent
LEGEND INTERNATIONAL HOLDINGS INC (IN LIQUIDATION) (ARBN 120 855 352) [No 2] Second respondent

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JUDGES: KYROU, McLEISH and NIALL JJA
WHERE HELD: MELBOURNE
DATE OF HEARING: 31 July 2019
DATE OF JUDGMENT: 30 September 2019
MEDIUM NEUTRAL CITATION: [2019] VSCA 215
JUDGMENT APPEALED FROM: [2018] VSC 789 (Randall AsJ)

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INSOLVENCY – Dormant mining company with insufficient cash to meet liabilities – Ownership of valuable mining tenements through subsidiary – Whether tenements realisable within reasonable period to enable payment of debts – Whether company able to pay all its debts as and when they became due and payable – Whether fact that tenements necessary for company’s ongoing business precluded them from being treated as realisable assets – Jingellic Minerals NL v Beach Petroleum NL (1991) 56 SASR 532 considered – Rees v Bank of New South Wales (1964) 111 CLR 210, Re Timbatec Pty Ltd (1974) 24 FLR 30, Switz Pty Ltd v Glowbind Pty Ltd (2000) 18 ACLC 343 applied – Re Adnot Pty Ltd (1982) 7 ACLR 212, Re Newark Pty Ltd (in liq) [1993] 1 Qd R 409 distinguished – Corporations Act 2001 (Cth) ss 95A, 459A, 585.

INSOLVENCY – Whether subsidiary insolvent – Whether subsidiary should be wound up on the just and equitable ground – Corporations Act 2001 (Cth) ss 459A, 461(1)(k).

CORPORATIONS – Uncommercial transaction – Company gave security to lender over all its shares in subsidiary which owned valuable mining tenement pursuant to bond deed and general security deed – Company received $400,000 pursuant to bond deed – Onerous provisions including events of default and consequences of default – Whether reasonable person in company’s circumstances would not have entered into transaction – Corporations Act 2001 (Cth) ss 588FB, 588FC, 588FE, 588FF.

PRACTICE AND PROCEDURE – New ground sought to be argued on appeal which had been abandoned at trial – Leave to rely on new ground refused.

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APPEARANCES: Counsel Solicitors
For the Applicants Mr J Evans QC
with Mr D Ratnam
Coleman Greig Lawyers
For the Respondents Dr C G Button QC
with Ms R Zambelli
Arnold Bloch Leibler

TABLE OF CONTENTS

Introduction and summary ............................................................................................... 1
Facts ……………………………………………………………………………………….. 10
Business activities of Legend and Paradise ………………………………………………... 10
IFFCO dispute …………………………………………………………………………….. 10
Communications leading  up to the execution of the deeds ……………………………….. 11
Terms of the deeds …………………………………………………………………………. 17
Enforcement of award and appointment of receiver and manager of Paradise ……………. 20
Winding up of Legend and commencement of proceeding ………………………………… 21
Trial Division proceeding ……………………………………………………………….. 21
Issues raised on appeal ………………………………………………………………….. 25
Issue 1: Insolvency of Legend and Paradise …………………………………………... 26
Legislation ………………………………………………………………………………….. 26
Principles …………………………………………………………………………………... 26
Associate judge’s findings ………………………………………………………………….
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Details
Case
[2019] VSCA 215
Decision Date

CaseChat Overview and Summary

The case of Queensland Phosphate Pty Ltd v Korda [No 2] involved the insolvent company Queensland Phosphate and the liquidator of its subsidiary, Korda. The dispute centred around the company's inability to meet its liabilities, and the potential realisability of valuable mining tenements owned by Korda. The liquidator argued that the assets were not realisable within a reasonable period to enable payment of debts and that the company was unable to pay its debts as and when they fell due. The case was heard in the Queensland Supreme Court.

The legal issues before the court included whether the company could be deemed insolvent, the necessity of the mining tenements for the company's ongoing business, and the potential for those assets to be treated as realisable. Additionally, the court considered whether the subsidiary, Korda, was insolvent and should be wound up on the just and equitable ground, as well as whether an uncommercial transaction had occurred between the company and its lender.

The court's reasoning was based on the principles established in previous cases, such as Jingellic Minerals NL v Beach Petroleum NL, Rees v Bank of New South Wales, Re Timbatec Pty Ltd, Switz Pty Ltd v Glowbind Pty Ltd, Re Adnot Pty Ltd, and Re Newark Pty Ltd. The court held that the company was insolvent, and the mining tenements were not realisable within a reasonable period. The subsidiary was also deemed insolvent and should be wound up on the just and equitable ground. The uncommercial transaction between the company and its lender was found to be unreasonable, as a person in the company's position would not have entered into such a transaction. The court refused leave to rely on a new ground argued on appeal that had been abandoned at trial.

The final orders of the court included the declaration that Queensland Phosphate was insolvent, the winding up of Korda on the just and equitable ground, and the setting aside of the uncommercial transaction between the company and its lender.

Orders

Orders of the court

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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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