FEDERAL COURT OF AUSTRALIA
Zhang v Yan [2021] FCA 905
Appeal from: Yan v Zhang [2019] FCCA 2990 File number(s): VID 1244 of 2019 Judgment of: O'BRYAN J Date of judgment: 5 August 2021 Catchwords: BANKRUPTCY AND INSOLVENCY – appeal against a decision of the Federal Circuit Court of Australia dismissing an application for review of a sequestration order made by a registrar of the Federal Circuit Court – where sequestration order based on a judgment debt obtained in the Supreme Court of Victoria – where primary judge determined that it was appropriate to “go behind” the judgment debt to assess whether the debt was owing – circumstances in which a bankruptcy court is permitted to “go behind” a judgment debt – respondents’ notice of contention allowed in part – appeal dismissed
CONTRACTS – whether deed of settlement on which judgment debt was based is unenforceable as contrary to public policy – where complaint of criminal conduct had been made and accepted in China – where Australian legal proceedings had been settled on terms that included a promise to withdraw the criminal complaint made in China – whether promise was contrary to public policy in Australia – where appellant failed to adduce evidence before the primary judge of Chinese law, including whether promise was illegal or unenforceable in China – whether question of enforceability should be determined in circumstances where relevant obligations under the deed had been performed and no application had been made to enforce those promises – whether unenforceable promises in the deed are severable – whether deed was entered into under duress
Legislation: Bankruptcy Act 1966 (Cth) s 52
Evidence Act 1995 (Cth) s 136
Federal Court of Australia Act 1976 (Cth) s 27
Cases cited: A v Hayden(No 2) (1984) 156 CLR 532
Addison v Brown [1954] All ER 213
A-G (UK) v Heinemann Publishers Australia Pty Ltd (1987) 10 NSWLR 86
A-G (UK) v Heinemann Publishers Australia Pty Ltd [No 2] (1988) 165 CLR 30
Birstar Pty Ltd v The Proprietors “Ocean Breeze” Building Units Plan No 4745 [1997] 1 Qd R 117
BP Exploration Co (Libya) Ltd v Hunt [1980] 1 NSWLR 496
Codelfa Construction Pty Ltd v State Rail Authority (NSW) (1982) 149 CLR 337
Crescendo Management Pty Ltd v Westpac Banking Corporation (1988) 19 NSWLR 40
Electric Acceptance Pty Ltd v Doug Thorley Caravans (Aust) Pty Ltd [1981] VR 799
Electric Acceptance Pty Ltd v Doug Thorley Caravans (Aust) Pty Ltd [1981] VR 799
Evanturel v Evanturel (1874) LR 6 PC 1
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- AGLC
- Zhang v Yan [2021] FCA 905
- Case
- [2021] FCA 905
- Decision Date
CaseChat Overview and Summary
Orders
Orders of the court
THE COURT ORDERS THAT:
1. The respondents’ notice of contention be allowed in part.
2. The appeal be dismissed.
3. Within 14 days, the parties are to file and serve written submissions in relation to the costs of the appeal, limited to 3 pages, to be determined on the papers.
Background
Background to the litigation
Evidence
Evidence Before The Court
Decision
Reasons for decision
Ratio Decidendi
Legal Principle Established
The appellant argued that the facts and circumstances in this case were analogous to those in Ramsay: both parties were represented by counsel in the 2018 SC proceeding; the issue sought to be raised by the appellant in the bankruptcy proceeding could have been agitated and determined in the 2018 SC proceeding, but it was not and no appeal was taken from that decision. Conversely, the facts in Doggett were not analogous: the debtors conceded in that case that they were seeking to agitate in the bankruptcy proceeding a duress claim that had been raised before the court that gave judgment against them on the same evidence (at [47] - [49]). Similarly, in Commonwealth Bank of Australia v Jeans [2005] FCA 978, Hely J concluded that the issue raised by the debtor was not raised in good faith because the matters on which the debtor sought to rely upon as enlivening the power of the Bankruptcy Court were the same matters upon which the debtor had unsuccessfully relied before the court that gave judgment in support of an application to withdraw admissions (at [19]).Consideration of the first issue In the 2018 SC proceeding, the appellant defended the summons for judgment upon breach of clause 1.8 on the basis that the respondents failed to comply with their obligation in clause 1.10. In so doing, the appellant relied upon clauses 1.10 to 1.12 of the Deed and the appellant’s defence was based upon the validity and enforceability of those clauses. Indeed, that position was expressly affirmed by counsel for the appellant at the hearing before Justice Kennedy. The appellant’s defence based on a breach of clause 1.10 by the respondents failed. In the subsequent bankruptcy proceeding before the primary judge, the appellant advanced a new defence, that clauses 1.10 to 1.12 were void or unenforceable as being contrary to public policy thereby rendering the Deed, or at least clause 1.8, unenforceable. That defence was inconsistent with the defence raised in the 2018 SC proceeding, which had been based on the enforceability of those clauses. Further, in the 2018 SC proceeding, the appellant made a positive election not to raise that defence after enquiry by Justice Kennedy. The question raised in this appeal is whether, in the circumstances so presented, the primary judge erred in the exercise of her discretion to allow the appellant to go behind the judgment resulting from the 2018 SC proceeding. The High Court majority (Kiefel CJ, Keane and Nettle JJ) in Ramsay affirmed the following principles:(a)First, by reason of s 52 of the Act, a Bankruptcy Court must be satisfied with the proof of “the fact that the debt … on which the petitioning creditor relies is … still owing”, if the court’s power to make a sequestration order is to be enlivened (at [39]).(b)Second, a Bankruptcy Court is not obligated to treat a judgment as satisfactory proof of the petitioning creditor’s debt. A Bankruptcy Court exercising jurisdiction under s 52 of the Act may, in some circumstances, “go behind” a judgment in order to be satisfied that the debt relied upon by the petitioning creditor is truly owing. The Bankruptcy Court may take this course in order to satisfy itself that there is an extant petitioning creditor’s debt as a necessary foundation for the making of a sequestration order (at [1]).(c)Third, the circumstances in which a Bankruptcy Court may go behind a judgment are not limited to cases involving default judgments or cases involving fraud, collusion or miscarriage of justice (at [39], [43]). A Bankruptcy Court may go behind a judgment, notwithstanding that the judgment was obtained after a contested hearing (at [44]).(d)Fourth, scrutiny by a Bankruptcy Court of the debt propounded by a judgment creditor seeking a sequestration order does not involve an attempt to impeach the judgment; nor is a Bankruptcy Court concerned to prevent the judgment creditor from invoking the ordinary processes of execution available under the general law. Rather, a Bankruptcy Court is concerned only with the question whether the debt on which the application for a sequestration order is based is truly a basis for the making of the order (at [54]).(e)Fifth, the scrutiny required by s 52 of the Act as to whether there is, in truth and reality, a debt owing to the petitioning creditor serves to protect the interests of third parties, particularly other creditors of the debtor; their interest in being paid their debts in full should not be prejudiced by the making of a sequestration order in reliance on a judgment debt which does not reflect the true indebtedness of the debtor to the petitioning creditor (at [55]).(f)Sixth, the principle that a party is bound by the conduct of their case at trial is not a sufficient reason for a Bankruptcy Court not to look behind a judgment. That is because a Bankruptcy Court is concerned, not to discipline litigants or to protect finality in the administration of justice as between parties to litigation, but to protect the interests of third parties who were not participants in the litigation which led to the judgment in question (at [67]).