FEDERAL COURT OF AUSTRALIA
Wong v Wong [2022] FCA 78
File number(s): NSD 682 of 2021 Judgment of: HALLEY J Date of judgment: 8 February 2022 Catchwords: CONTRACTS – interlocutory application to declare a binding and enforceable agreement between applicant and second respondent (Agreement) – where offer provided that bankrupt estate was to receive an amount estimated to be $220,000 by reference to figures in a report to creditors – where acceptance provided that bankrupt estate was to receive $220,000 – whether Agreement binding and enforceable – whether acceptance corresponded with offer or constituted a counter offer – whether material variation –where divergence in expression did not entail a difference in substance – where no material variation – where offer was a purported Calderbank offer – where draft deed of settlement provided subsequent to offer – whether offer was subject to entry into deed of settlement – application granted
CONTRACTS – where third respondent opposed the making of a declaration on grounds that it would suffer prejudice and detriment – where third respondent not a party to the Agreement – whether third respondent has sufficient interest in the Agreement to oppose the declaration – where hypothetical prejudice to third respondent not sufficient to preclude making the declaration
PRACTICE AND PROCEDURE – whether solicitor for second respondent had authority to accept the offer – where solicitor has actual and ostensible authority where Agreement is actually and genuinely related to litigation
Legislation: Bankruptcy Act1966 (Cth) ss 58, 82 Cases cited: Ashmere Cove Pty Ltd v Beekink (No 2) (2007) 244 ALR 534; [2007] FCA 1421
Baulkham Hills Private Hospital Pty Ltd v G R Securities Pty Ltd (1986) 4 NSWLR 622
Boreland v Docker [2007] NSWCA 94
Brambles Holdings Ltd v Bathurst City Council (2001) 53 NSWLR 153; [2001] NSWCA 61
Brookfield Australia Investments Ltd v Lucas Stuart Pty Ltd [2012] NSWSC 1130
Calderbank v Calderbank [1975] 3 WLR 586
Clarence City Council v Commonwealth of Australia (2020) 280 FCR 265; [2020] FCAFC 134
Direct Factory Outlets Pty Ltd v Westfield Management Ltd (2003) 132 FCR 428; [2003] FCA 1095
Ex parte Fealey (1897) 18 LR (NSW) 282
Gall v Mitchell (1924) 35 CLR 222
G R Securities Pty Ltd v Baulkham Hills Private Hospital Pty Ltd (1986) 40 NSWLR 631
Jackson v Turquand (1869) LR 4 HL
Lark v Outhwaite [1991] 2 Lloyd’s Rep 132
Lewis v Combell Constructions Pty Ltd (1989) 18 NSWLR 528
Lucke v Cleary (2011) 111 SASR 134; [2011] SASCFC 118
Masters v Cameron (1954) 91 CLR 353
Mulcaire v Newsgroup Newspapers Ltd [2012] Ch 435; [2012] EWHC 3469
Mushroom Composters Pty Ltd vIS & DE Robertson Pty Ltd [2015] NSWCA 1
Olivaylle Pty Ltd v Flottweg GMBH & Co KGAA (No 4) (2009) 255 ALR 632; [2009] FCA 522
Outer Suburban Property Ltd v Clarke [1933] SASR 221
Palmer v Ayres (2017) 259 CLR 478
Pavlovic v Universal Music Australia Pty Ltd (2015) 90 NSWLR 605
Continue reading Wong v Wong
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- AGLC
- Wong v Wong [2022] FCA 78
- Case
- [2022] FCA 78
- Decision Date
CaseChat Overview and Summary
The court found that the Agreement was binding and enforceable, and that it was appropriate for the Court to make a declaration to that effect. The court found that the 29 July Offer represented, without qualification, that it was an “offer to agree to a settlement of the dispute between our client and the bankrupt estate”. The 2 August Response contained a purported acceptance of that offer, expressed in terms that provided for the payment of a fixed sum, rather than the acceptance of a formula that was stated would determine an amount equivalent to that fixed sum. The court found that the divergence in expression in the second term of the Agreement did not entail a difference in substance, and that a reasonable person would not view the 2 August Response as introducing a new term into the bargain or constituting only a qualified acceptance of the offer.
The court also found that the loan agreements between Bankwest and Ms Wong were valid and enforceable, and that Mr Wong was not entitled to a discharge of the Bankwest mortgage. The court found that the Bankwest mortgage secured all indebtedness of Mr Wong, Mrs Wong and Ms Wong to Bankwest, and that the amounts outstanding under the First Bankwest Home Loan and the Second Bankwest Home Loan were secured by the Bankwest mortgage.
The court made a declaration that the Agreement was binding and enforceable, and that the loan agreements between Bankwest and Ms Wong were valid and enforceable. The court also found that Mr Wong was not entitled to a discharge of the Bankwest mortgage.
Orders
Orders of the court
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Background
Background to the litigation
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Evidence
Evidence Before The Court
Decision
Reasons for decision
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Ratio Decidendi
Legal Principle Established
Sixth, Mr Wong’s allegations that the Trustee had acted improperly were irrelevant to the issues to be determined and can safely be ignored, even if relevant could not be determined on an interlocutory application, and are “manifestly without basis”.Consideration I am satisfied that the Agreement was a binding and enforceable agreement that was made between Mr Wong and the Trustee by the provision of the offer contained in the 29 July Offer and the acceptance of that offer in the 2 August Response. I have reached that conclusion for the following reasons. First, the 29 July Offer represents, without qualification, that it was an “offer to agree to a settlement of the dispute between our client and the bankrupt estate”. I note the 2 August Response incorrectly referred to a letter dated “29 August 2021” but in context this was clearly a reference to the 29 July Offer. The 29 July Offer contained an offer to settle on the following basis:a)the property is sold as soon as possible under the instruction of our client;b)out of the net proceeds of sale of the property, the bankrupt estate is to receive an amount sufficient to cover the unsecured debts and estimated costs of the estate set out in your report to creditors of 15 April 2020 (after realisation of the other assets disclosed), being approximately $220,000; andc)the balance of the net proceeds of sale of the property are paid to our client. The 2 August Response contained a purported acceptance of that offer, expressed in these terms:1.the Maroubra property is to be sold as soon as possible under your client’s instruction;2.the amount of $220,000 be paid to the Bankrupt Estate of Mei Ru Leung from the net proceeds of sale; and 3.the balance of the net proceeds of sale are to be retained by your client. There can be no question that the first and third terms in the 29 July Offer were accepted without any qualification. The acceptance of the second term was in terms that provided for the payment of a fixed sum, rather than the acceptance of a formula that was stated would determine an amount equivalent to that fixed sum. I accept that it is possible by a process of addition and subtraction by reference to the figures contained in the Report to Creditors to arrive at a figure of $219,102.38. The divergence in expression in the second term of the Agreement did not entail a difference in substance: see Ex parte Fealey at 292 (Cohen J); Boreland at [76]-[78]. Nor did it give rise to a material amendment to the 29 July Offer or the imposition of a new term that might constitute an offer to enter into an additional contract on that term: Olivaylle at [23]; see also Mulcaire at [27]; Outer Suburban Property at 225-6. I do not consider that a reasonable person would view the 2 August Response as introducing a new term into the bargain or constituting only a qualified acceptance of the offer: Brambles Holdings Ltd v Bathurst City Council (2001) 53 NSWLR 153; [2001] NSWCA 61 at [81] (Heydon JA).