FEDERAL CIRCUIT AND FAMILY COURT OF AUSTRALIA
(DIVISION 1) APPELLATE JURISDICTION
Xin & Qinlang [2024] FedCFamC1A 150
Appeal from: Xin & Qinlang (No 6) [2024] FedCFamC1F 8 Appeal number: NAA 37 of 2024 File number: CAC 1782 of 2018 Judgment of: ALSTERGREN CJ, TREE & RIETHMULLER JJ Date of judgment: 10 September 2024 Catchwords: FAMILY LAW – APPEAL – Property – Where the contributions of the spouses were equal – Where the net assets of the spouses be divided as to 60 per cent in the wife’s favour – Whether the primary judge erred in not considering the wife’s cohabitation with her partner – Where the husband was self-represented at trial – Where the husband is bound by his conduct at trial – Where there is no substantial injustice – Whether the primary judge failed to consider the effect of orders in monetary terms – Where adequate consideration was given – Appeal dismissed – Costs ordered Legislation: Family Law Act 1975 (Cth) ss 75, 102NA Cases cited: Barker & Barker [2007] FamCA 153
Bennett and Bennett (1991) FLC 92-191; [1990] FamCA 148
Candle & Falkner (2021) FLC 94-069; [2021] FedCFamC1A 102
Conway v The Queen (2002) 209 CLR 203; [2002] HCA 2
Lovine & Connor and Anor (2012) FLC 93-515; [2012] FamCAFC 168
Macedonian Orthodox Community Church St Petka Inc v His Eminence Petar The Diocesan Bishop of The Macedonian Orthodox Diocese of Australia and New Zealand (2008) 237 CLR 66; [2008] HCA 42
Metwally v University of Wollongong (1985) 60 ALR 68; [1985] HCA 28
Murray & Murray (2020) FLC 94-000; [2020] FamCAFC 293
Phipson & Phipson [2009] FamCAFC 28
Sun Alliance Insurance Ltd v Massoud [1989] VR 8
Number of paragraphs: 31 Date of hearing: 29 May 2024 Place: Heard in Sydney, delivered in Melbourne Counsel for the Appellant: Mr Jones SC Solicitor for the Appellant: Longton Legal Counsel for the First Respondent: Mr Richardson Solicitor for the First Respondent: Dobson Davey Clifford Simpson Solicitor for the Second Respondent: Lander & Rogers (did not appear) – Submitting Notice filed 16 May 2024 Solicitor for the Third Respondent: Lander & Rogers (did not appear) - Submitting Notice filed 16 May 2024 The Fourth Respondent: Did not participate ORDERS
NAA 37 of 2024
CAC 1782 of 2018
FEDERAL CIRCUIT AND FAMILY COURT OF AUSTRALIA
DIVISION 1 APPELLATE JURISDICTIONBETWEEN: MR XIN
Appellant
AND: MS QINLANG
First Respondent
MR B XIN
Second Respondent
MS WANG
Third RespondentMR P
Fourth Respondent
ORDER MADE BY:
ALSTERGREN CJ, TREE & RIETHMULLER JJ
DATE OF ORDER:
10 SEPTEMBER 2024
THE COURT ORDERS THAT:
1.The appeal be dismissed.
2.The appellant pay the first respondent’s costs in the sum of $18,703 within 28 days.
Note: The form of the order is subject to the entry in the Court’s records.
Note: This copy of the Court’s Reasons for judgment may be subject to review to remedy minor typographical or grammatical errors…
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- Xin & Qinlang [2024] FedCFamC1A 150
- Case
- [2024] FedCFamC1A 150
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CaseChat Overview and Summary
The appellant argued that the primary judge erred in not taking into account Ms Qinlang’s cohabitation with her new partner, Mr AK, under section 75(2)(m) of the Family Law Act 1975 (Cth), which mandates consideration of whether either party is cohabiting with another person and the financial circumstances of that cohabitation. The appellant contended that the primary judge failed to consider this factor, which should have led to a different property division. However, the court found that the appellant did not raise this issue before the primary judge and failed to demonstrate how this circumstance could be of significant weight. The omission of a specific reference to this factor in the judgment did not indicate that the primary judge overlooked it, as the court was satisfied that the primary judge had carefully considered the parties’ circumstances.
Additionally, the appellant argued that the primary judge failed to consider and analyse the effect of the adjustment in monetary terms. The court found that the primary judge had given adequate consideration to the effect of the orders in monetary terms and that the appellant’s argument lacked merit. Therefore, the court dismissed the appeal and ordered that the appellant pay the first respondent’s costs of the appeal, which totalled $18,703 on a party-party basis.
Orders
Orders of the court
NAA 37 of 2024
CAC 1782 of 2018
FEDERAL CIRCUIT AND FAMILY COURT OF AUSTRALIA
DIVISION 1 APPELLATE JURISDICTION
BETWEEN:
MR XIN
Appellant
AND:
MS QINLANG
First Respondent
MR B XIN
Second Respondent
MS WANG
Third Respondent
MR P
Fourth Respondent
ORDER MADE BY:
ALSTERGREN CJ, TREE & RIETHMULLER JJ
DATE OF ORDER:
10 SEPTEMBER 2024
THE COURT ORDERS THAT:
1. The appeal be dismissed.
2. The appellant pay the first respondent’s costs in the sum of $18,703 within 28 days.
Note: The form of the order is subject to the entry in the Court’s records.
Note: This copy of the Court’s Reasons for judgment may be subject to review to remedy minor typographical or grammatical errors (r 10.14(b) Federal Circuit and Family Court of Australia (Family Law) Rules 2021 (Cth)), or to record a variation to the order pursuant to r 10.13 Federal Circuit and Family Court of Australia (Family Law) Rules 2021 (Cth).
Part XIVB of the Family Law Act 1975 (Cth) makes it an offence, except in very limited circumstances, to publish an account of proceedings that identify persons, associated persons, or witnesses involved in family law proceedings.
Background
Background to the litigation
Evidence
Evidence Before The Court
Full text does not contain this section.
Decision
Reasons for decision
Ratio Decidendi
Legal Principle Established
The appellant relied on one ground of appeal stating that:The learned trial judge erred in making a section 75(2) adjustment of 10% in favour of the first respondent by: (a)failing to take into account a relevant consideration, namely the financial circumstances of the first respondent’s cohabitation with her new partner pursuant to section 75(2)(m); and (b)failing to consider and analyse the effect of the adjustment in monetary terms. Whether the primary judge failed to take into account a relevant consideration (Ground (a)) The appellant argued that the primary judge fell into error by failing to take into account the financial circumstances of the first respondent’s cohabitation with her new partner (“Mr AK”) in accordance with s 75(2)(m), which provides that the matters to be taken into account includes “if either party is cohabiting with another person” and “the financial circumstances relating to the cohabitation”. The cohabitation was not expressly referred to in the reasons. The first respondent set out in her Financial Statement filed 7 November 2023 that Mr AK contributes approximately $200 per week to “share of household expenses”. She has only been in a relationship with him since mid-2020 and there is no evidence from which to assess the relative stability of this relationship. Mr AK set out that he and the first respondent “share our bills. We don’t have strict rules for who is paying for what” (Affidavit of AK filed 6 November 2023, paragraph 8). Whilst the first respondent’s Financial Statement estimates that $200 per week is paid by Mr AK to household expenses, it is apparent from his affidavit that it is his contribution to the joint expenses. The evidence of the first respondent’s cohabitation with Mr AK is, at best, of only marginal financial benefit. Indeed, it may be of no net financial benefit to the first respondent once the additional costs to the household, as a result of Mr AK’s presence, are taken into account. The trial ran for seven days and resulted in a detailed judgment of 315 paragraphs. Whilst the appellant self-represented, he had access to the Commonwealth Family Violence Cross Examination Scheme funding for legal representation, as a result of a final Family Violence Intervention Order and a consequent order pursuant to s 102NA of the Act (at [8]). However, it is apparent that he did not take up the option of being legally represented at the trial pursuant to the scheme. Significantly, the appellant did not file an Outline of Case prior to trial, did not advance an argument before the primary judge to the effect that the first respondent’s cohabitation with Mr AK should be taken into account, nor articulate how any real weight could be placed upon this circumstance. The omission of a specific reference by the primary judge to this factor does not demonstrate that his Honour overlooked the issue. It is clear that the primary judge had careful regard to the parties’ circumstances. The post-separation circumstances of the parties were discussed at [290]–[295]. Then at [296] the primary judge identified that there are matters pursuant to s 75(2) that “point to a further adjustment in favour of the [first respondent]”. We do not read this part of the judgment as intending to cover all the minutiae of the first respondent’s circumstances, rather, it was to identify the significant factors justifying an adjustment pursuant to s 75(2). It is not necessary for a judge to set out every fact and circumstance that may be relevant to a decision. Had the appellant raised this issue before the primary judge it may have been necessary to address the matter specifically in the reasons, however the issue was never raised at the trial.