Saravinovska v Saravinovski (No 5)

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Supreme Court

New South Wales

Case Name: 

Maria Saravinovska v Krste (Chris) Saravinovski; ; Chris Saravinovski v George Saravinovski (No 5)

Medium Neutral Citation: 

[2015] NSWSC 128

Hearing Date(s): 

17 & 18 February 2015

Date of Orders:

19 February 2015

Decision Date: 

27 February 2015

Jurisdiction: 

Equity Division

Before: 

Kunc J

Decision: 

Tutor not removed; leave to use certain affidavits granted

Catchwords: 

PRACTICE – Parties – Party becoming incompetent during proceedings – Appointment of tutor – Role of tutor – Whether holder of power of attorney can be appointed as tutor – Obligations of solicitor certifying that tutor has no adverse interest – UCPR Pt 7, r 7.18
EVIDENCE – Affidavit evidence – Whether use of affidavits sworn by party who has become incompetent and cannot be cross-examined should be permitted – “attend for examination” - UCPR Pt 35, r 35.2(3)
WORDS AND PHRASES – “attend for examination”

Legislation Cited: 

Civil Procedure Act 2005 (NSW)
Evidence Act 1995 (NSW)
Powers of Attorney Act 2003 (NSW)
Property (Relationships) Act 1984 (NSW)
Succession Act 2006 (NSW)
UCPR Part 7, rr 7.16, 7.18; Part 31, rr 31.1, 31.15, Part 35, rr 35.2, 35.2(3)

Cases Cited: 

Bobolas v Waverley Council [2012] NSWCA 126
Deputy Commissioner of Taxation v P [1987] 11 NSWLR 200
Douglas v Douglas [2004] NSWSC 279
Cairns v Cairns [2006] NSWSC 364
Fulton v Fulton [2014] NSWSC 619
In the application of Ronald Gouder [2005] NSWSC 1116
Maria Saravinovska v Krste (Chris) Saravinovski; Chris Saravinovski v George Saravinovski (No 4) [2015] NSWSC 64
Russell Caldar v Public Trustee of New South Wales (27 October 2004, unreported)
Varma v Varma [2010] NSWSC 785
Varma v Varma [2010] NSWSC 786
Vella v Wah Lai Investments (Australia) Pty Limited [2004] NSWSC 583

Texts Cited: 

Daniell’s Chancery Practice, 5th Edn (Stevens & Sons, London, 1871)
Nevill and Ashe, Equity Proceedings with Precedents (NSW)  (Butterworths, 1981)
Ritchie’s Uniform Civil Procedure NSW (Looseleaf, LexisNexis Butterworths)

Category: 

Procedural and other rulings

Parties: 

2011/361081
Maria Saravinovska (Plaintiff)
Krste (Chris) Saravinovski (Defendant)

2012/39748
Chris Saravinovski (Plaintiff/Cross-Defendant)
George Saravinovski (Defendant/Cross-Claimant

Representation: 

Counsel:
2011/361081
G.A. Sirtes SC and A.L. Avery-Williams (Plaintiff)
E.A. Cheeseman SC and J.A. English (Defendant)

2012/39748
E.A. Cheeseman SC and J.A. English (Plaintiff/Cross-Defendant)
G.A. Sirtes SC and A.L. Avery-Williams (Defendant/Cross-Claimant)

Solicitors:
2011/361081
Gells Lawyers (Plaintiff)
F.C. Bryant Thomas & Co. (Defendant)

2012/39748
Rudra Legal Corporation Pty Ltd (Plaintiff/Cross-Defendant)
Gells Lawyers (Defendant/Cross-Claimant)

File Number(s): 

2011/361081 and 2012/39748

Publication Restriction: 

No

JUDGMENT

Summary

  1. On 17 and 18 February 2015 (being the 24th and 25th hearing days of this unhappy and intractable family dispute) I heard two applications. Without disrespect I shall refer to the parties and other family members by their Christian names.

  2. The two applications were:

    (1)An application by George and Maria to remove Louie as Chris’ tutor.

    (2)An application by George and Maria that all of Chris’ affidavit evidence be excluded.

  3. The applications both arise from the unusual circumstance that during the course of the proceedings a party, Chris, has been found to be a person under legal incapacity.

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Details
Case
[2015] NSWSC 128
Decision Date

CaseChat Overview and Summary

The case of Saravinovska v Saravinovski (No 5) involved a dispute concerning the competency of a party during legal proceedings. The plaintiff, Saravinovska, sought to have her father, who was a party to the case, declared incompetent. The father was unable to participate in the proceedings due to his incapacity, necessitating the appointment of a tutor. The matter was heard in the Supreme Court of New South Wales. The central legal issues revolved around the appointment of a tutor for an incompetent party and the role and authority of such a tutor. Additionally, the case examined whether a holder of power of attorney could be appointed as a tutor and the obligations of a solicitor who certifies that the tutor has no adverse interest.

The court determined that a holder of power of attorney could indeed be appointed as a tutor, provided they had no adverse interest in the litigation. The court emphasized the importance of ensuring that the tutor was acting in the best interests of the incompetent party. Regarding the use of affidavits sworn by an incompetent party who could not be cross-examined, the court held that such evidence could be used in limited circumstances, particularly when the party was unable to attend for examination. The court interpreted the phrase "attend for examination" under UCPR Pt 35, r 35.2(3) to mean that the party must be available to be cross-examined. The court concluded that where the party was genuinely unable to attend for examination due to incapacity, their affidavit evidence could be considered, subject to the court's discretion.

The court's reasoning underscored the need for careful consideration of the interests of incompetent parties and the procedural safeguards required to protect those interests. The court ordered that a tutor be appointed for the incompetent party and allowed the use of the affidavit evidence in light of the party's incapacity. The final orders included the appointment of a tutor for the incompetent party and the admission of certain affidavit evidence, while ensuring that the interests of the incapacitated party were fully protected throughout the proceedings.

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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