Registrar-General (SA) v Wright

The Supreme Court of South Australia considered an appeal by the Registrar-General against a decision of a Master of the Court. The dispute concerned the Registrar-General's refusal to produce certain documents relating to a land title, despite the issue of a summons by the Master. The Registrar-General contended that the Master lacked the jurisdiction to compel the production of these documents under the *Real Property Act 1886* (SA).

The central legal issue before the Full Court was whether the Master had the power to issue a summons requiring the Registrar-General to produce documents held by the Registrar-General in their capacity as the keeper of the Real Property Register, and whether the Registrar-General could lawfully refuse to comply with such a summons. This involved an interpretation of the *Real Property Act* and the inherent jurisdiction of the court.

The Full Court held that the Master did have the power to issue the summons. It reasoned that the Registrar-General, in holding the register, was acting in a statutory capacity that was subject to the supervisory jurisdiction of the Supreme Court. The Court found that the *Real Property Act* did not grant the Registrar-General immunity from such court orders, and that the Master, as an officer of the Supreme Court, possessed the necessary authority to direct the production of relevant documents for the proper administration of justice. The appeal was dismissed.