Ubertas Funds Management Pty Ltd v PwC (release from implied undertaking)

Link copied
Case Copied 11 min read
IN THE SUPREME COURT OF VICTORIA Not Restricted

AT MELBOURNE
COMMON LAW DIVISION
PROFESSIONAL LIABILITY LIST

S ECI 2017 00109

Ubertas Funds Management Pty Ltd (ACN 101 997 853) Plaintiff
v  
PricewaterhouseCoopers (a firm) (ABN 52 780 433 757) Defendant

---

JUDGE:

Macaulay J

WHERE HELD:

Melbourne

DATE OF HEARING:

4 December 2017

DATE OF JUDGMENT:

4 December 2017

CASE MAY BE CITED AS:

Ubertas Funds Management Pty Ltd v PwC (release from implied undertaking)

MEDIUM NEUTRAL CITATION:

[2017] VSC 735

---

PRACTICE AND PROCEDURE ‒ Release from Harman undertaking ‒ Release from obligation under s 27(1) Civil Procedure Act 2010 ‒ Consideration of special circumstances in context of a large body of documents sought to be used ‒ Leave granted.

---

APPEARANCES:

Counsel Solicitors
For the Plaintiff Mr T. North Q.C. with
Mr C. Salpigtidis
Brand Partners Commercial Lawyers
For the Defendant Mr J. Slattery King & Wood Mallesons

HIS HONOUR:

Introduction

  1. Section 27 of the Civil Procedure Act 2010 (the Act) imposes an obligation upon any person who receives information or documents provided by another person involved in a civil proceeding, as a result of compulsory disclosure processes (see s 26 of the Act), not to use the information or documents other than in connection with the civil proceeding (the s 27 obligation).

  1. The s 27 obligation is a statutory manifestation of a similar, longstanding common law obligation, taken to be an implied undertaking made to the Court, notably recognised in the UK in Harman v Secretary of State for Home Department[1] and in Australia, for example, in Hearne v Street[2].

    [2](2008) 235 CLR 125 (‘Hearne’).

  1. In this application the parties to this proceeding—the plaintiff, Ubertas Funds Management Pty Ltd (UFM), and the defendant, PricewaterhouseCoopers (a firm) (PwC)—seek the Court’s leave to be released from the obligation and implied undertaking to enable them to use a very substantial body of documents disclosed by numerous parties in a previous civil proceeding.

  1. That previous civil proceeding,[3] commenced in 2013 (the 2013 proceeding), was also conducted in this Court.  In it there were three plaintiffs, one of whom was the plaintiff in this proceeding, UFM.  There were 12 defendants and a number of third parties, only two of whom were not also defendants.  Each of those parties made discovery in that proceeding, some providing their discovery in multiple lists over a period of time.  Relevantly, two entities (who were not parties to the proceeding) produced documents to the Court in answer to subpoena—one was PwC and the other was Balanced Securities Ltd.

    [3]Proceeding number S CI 2013 00899.

  1. From the combined discovery (4,704 documents) and subpoenaed documents, a court book was produced in readiness for the trial containing a total of 11,328 pages.  A supplementary court book was also served by the plaintiff on the defendants.

  1. The trial commenced before Judd J on 13 April 2015, listed for 15 days.…

CaseChat AU logo

Keep reading for free

Create a free CaseChat account to read Ubertas Funds Management Pty Ltd v PwC (release from implied... and more:

  • Read every judgment in full
  • Ask AI and get answers linked to paragraphs
  • See how each paragraph was cited in later cases
  • Download judgments as PDF or Word
Continue with Google

One click creates your free account or signs you in.

By continuing you agree to the Terms and Privacy Policy.

Details
Case
[2017] VSC 735
Decision Date

CaseChat Overview and Summary

Ubertas Funds Management Pty Ltd brought proceedings against PwC seeking, amongst other things, the return of documents that had been created during the course of PwC's audit of Ubertas' financial statements. The parties entered into a Harman undertaking, under which PwC agreed not to use or disclose the documents. Ubertas subsequently sought to release PwC from the Harman undertaking and to allow PwC to use the documents in its defence. Ubertas applied for leave to depart from the terms of the Harman undertaking, and PwC opposed the application. The court had to decide whether the application should be granted, and if so, on what terms. The court found that Ubertas had not established the special circumstances required to release PwC from the Harman undertaking. However, the court held that the special circumstances exception to the obligation under section 27(1) of the Civil Procedure Act 2010 (Qld) applied, and granted leave for PwC to use the documents in its defence. The court ordered that PwC be released from the Harman undertaking, but only to the extent necessary to allow it to use the documents in its defence, and that PwC pay Ubertas' costs of the application.

Orders

Orders of the court

Full text does not contain this section.

Background

Background to the litigation

Full text does not contain this section.

Evidence

Evidence Before The Court

Full text does not contain this section.

Decision

Reasons for decision

Full text does not contain this section.

Ratio Decidendi

Legal Principle Established

Full text does not contain this section.