Earthquake Commission v Insurance Council of New Zealand Inc

Case

[2014] NZHC 3138

10 December 2014

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IN THE HIGH COURT OF NEW ZEALAND WELLINGTON REGISTRY

CIV 2014-485-5698 [2014] NZHC 3138

BETWEEN EARTHQUAKE COMMISSION Plaintiff

AND

INSURANCE COUNCIL OF NEW ZEALAND INCORPORATED

First Defendant

CHRISTCHURCH CITY COUNCIL Second Defendant

SOUTHERN RESPONSE EARTHQUAKE SERVICES LTD Third Defendant

Hearing: 28, 29, 30 and 31 October 2014 (at Christchurch)

Court:

Heath, Kós and Gilbert JJ

Counsel:

J E Hodder QC, B A Scott, T D Smith and G K Rippingale for
Plaintiff
D J Goddard QC, J D Every-Palmer and S K Swinerd for First
Defendant
D A Ward for Second Defendant
D J Friar and M Powell for Third Defendant
D A Webb and S Goodwin for Flockton Cluster Group
(Intervener)

G D R Shand and J A Glucina for Ms D Culf (Intervener) T C Weston QC and K L Clark QC, amici curiae

Judgment:

10 December 2014

JUDGMENT OF THE COURT

This judgment was delivered by me on 10 December 2014 at 9.30am pursuant to

Rule 11.5 of the High Court Rules

Registrar/Deputy Registrar

EARTHQUAKE COMMISSION v INSURANCE COUNCIL OF NEW ZEALAND INCORPORATED [2014] NZHC 3138 [10 December 2014]

CONTENTS

PART 1:  INTRODUCTION

The proceeding  [1]

The scheme of the Earthquake Commission Act 1993  [11]

Agreed facts

(a)      The Canterbury earthquakes  [22]

(b)      The relevant land  [27] (c)      Land classification in Christchurch since the earthquakes              [31] (d)      Flooding Vulnerability  [35] The Commission’s Increased Flooding Vulnerability Policy

(a)      Development of the Policy  [39]

(b)      The Policy in outline  [45] (c)      Assessment of Increased Flooding Vulnerability  [46] (d)      Settlement of Increased Flooding Vulnerability claims  [49] (e)      A proposed claims review process  [51] PART 2: THE PROPOSED DECLARATIONS  [53] PART 3:  INTERPRETATION

Is Increased Flooding Vulnerability natural disaster damage to residential land

(a)      Background  [58]

(b)      Analysis  [63] (c)      Declaration  [80] Is Increased Flooding Vulnerability natural disaster damage

to residential buildings?

(a) (b) (c) Background Analysis Declaration [81] [82] [88]
Is Increased Liquefaction Vulnerability natural disaster damage?
(a) Background [89]
(b) Analysis [91]
(c) Declaration [93]
Assessment of indemnity value
(a) Background [94]
(b) Issue [100]
(c) Analysis [105]
(d) Declarations [125]

PART 4: ANTICIPATORY RELIEF

Declaratory judgments:  jurisdiction and discretion

(a)
(b)
Is judicial review available?
The Declaratory Judgments Act 1908
[126]
[129]
The legitimacy of the Commission’s policy
(a) The Commission’s statutory obligations [140]
(b) Consultation on the terms of the Policy [142]
(c) Issue [144]
(d) Is the Policy legally valid? [147]
(e) Can declarations be made? [152]
(f) Declarations [160]

PART 5:  ENFORCEMENT

Enforcement of the Commission’s statutory obligations

(a) The issue [163]
(b) Analysis [169]

PART 6:  OUTCOME

Costs  [200]

Result  [202]

PART 1:  INTRODUCTION The proceeding

[1]      In  New Zealand, insurance for natural disaster damage is provided by a statutory regime.    It is administered by the Earthquake Commission (the Commission) under the terms of the Earthquake Commission Act 1993 (the Act).1

[2]      This proceeding concerns damage to residential land2  that was caused by a series of earthquakes that struck in the Canterbury region, in 2010 and 2011.3 In particular, it relates to (what has been called) Increased Flooding Vulnerability; a phenomenon when, as a result of a natural disaster (in this case an earthquake) there

have been changes to land levels, which have left the land more prone to flooding than it was beforehand.4     The Commission seeks declarations to give effect to a policy it has developed (the Policy), by which it contends such claims should be resolved. A number of declarations are sought.  Some are anticipatory in nature.

[3]      The questions raised include:

(a)       Is the Commission liable for damage to residential land that results in

Increased Flooding Vulnerability?

(b)      If so, how may the Commission settle claims?

1      Earthquake Commission Act 1993, s 4.

2      The term “residential land” is defined by s 2(1) of the Earthquake Commission Act 1993, and is

set out at para [17] below.

3      See paras [22]–[26] below.

4      See paras [27] and [28] below.

(c)      Can a claimant challenge the Commission’s determination through court proceedings as an ordinary action or an application for judicial review?

(d)Can the Commission use standardised methodologies to calculate the appropriate settlement, provided the methodologies comply with the Act and public law principles?

[4]      Assuming the above questions are resolved in the Commission’s favour, it seeks an advance sanction of its Policy to declare its lawfulness, so as to avoid public law challenges to its implementation.   Further, it seeks a declaration that claims that it has already settled pursuant to it are lawful.

[5]      The Commission joined the Insurance Council, Christchurch City Council (the City Council) and Southern Response Earthquake Services Ltd (Southern Response) as defendants to the proceeding.  The Insurance Council represents the interests of private insurance companies in New Zealand.  The City Council is a territorial authority with responsibility for much of the area affected by the earthquakes.    Southern  Response  is  a  Crown-owned  company  which  formerly carried on business as a private insurer, under the name of AMI Insurance Ltd. Many affected properties were insured under private insurance policies with that company.

[6]      Two   parties   were   given   leave   to   intervene.      Both   Ms   Byrne   and Ms McMeeking  represent  what  is  known  as  the  Flockton  Cluster  Group.     It comprises many homeowners in the Flockton Basin who contend that they have an Increased  Flooding  Vulnerability  as  a  result  of  the  earthquakes.    The  other  is

Ms D M Culf.  She continues to live in an affected property in the Red Zone.5   Those

properties are subject to Increased Flooding Vulnerability.   In addition, they are prone to Increased Liquefaction Vulnerability, a topic with which we deal separately

at the request of the Insurance Council.6

5      See paras [32] and [33] below.

6      See para [9] below.

[7]      Kós J was responsible for pre-trial case management.   He appointed two amici curiae:

(a)      Mr Weston QC was appointed to represent homeowners affected by the earthquakes, to ensure that issues relevant to them were ventilated before the Court.  While some of those people had chosen to remain living within the Red Zone, Mr Weston advised us that “the vast majority  of  [Red  Zone]  properties  …  have  been  acquired  by  the

Crown reserving rights against private insurers”.7

(b)Ms Clark QC was appointed as a contradictor, in relation to questions about whether this Court could properly invoke its declaratory jurisdiction in the circumstances of this case and whether Increased Flooding Vulnerability and Increased Liquefaction Vulnerability constitutes “natural disaster damage”, as that term is defined in s 2(1)

of the Act.8

[8]      Initially,   the   City   Council   also   counterclaimed,   seeking   independent declarations.  While shortly before the hearing, the City Council discontinued, it was represented at the hearing by counsel, on a “watching brief”.  That caused one problem in relation to a declaration it had sought that Increased Flooding Vulnerability was  a  form  of “natural  disaster  damage” that  applied  not  only to

residential land,9  but also residential buildings.10    As a result of debate during the

hearing, the Commission subsequently elected to seek a declaration that Increased Flooding Vulnerability was not natural disaster damage in respect of residential buildings.

[9]      The Insurance Council filed a counterclaim to seek declarations in respect of a separate (but related) phenomenon; namely, Increased Liquefaction Vulnerability.11

7      See para [32] and [33] below.

8      The definition of “natural disaster damage” is set out at para [15] below.

9      Residential land is defined in s 2(1) of the Earthquake Commission Act 1993 and set out at para

[17] below.

10     Ibid.

11     See para [29] below.

In  the  same  way  that  movements  in  the  land  create  a  greater  vulnerability  to flooding, so it is said that vulnerability to liquefaction damage is also increased.

[10]     Although the proceeding was filed in the Wellington Registry of this Court, the hearing took place in Christchurch.  That change in venue enabled local residents who will be affected by the outcome of the proceeding to attend.  Many did.  We acknowledge their presence at the hearing.

The scheme of the Earthquake Commission Act 1993

[11]     The Earthquake and War Damage Act 1944 was the first statute to provide a statutory insurance regime to respond to earthquake damage.  At that time, private contracts  of  fire  insurance  were  coupled  with  compulsory  public  cover  for earthquake and war damage.12     The 1944 Act applied to both residential and commercial properties.13   The statutory insurance scheme was funded by a fire levy imposed under the predecessor of the Fire Service Act 1975.14

[12]     In 1951, amendments were made to the 1944 Act to recognise the distinction between indemnity insurance and replacement cover.   The need for replacement cover arose out of changes within the private insurance market.  In Farmers Mutual Insurance Co Ltd v Bay Milk Products Ltd, Richardson J, delivering the judgment of the Court of Appeal said:15

The 1944 Act was the first statutory provision with respect to the insurance of property against earthquake damage. Only those property owners with fire insurance policies are covered. A premium calculated on indemnity value is paid by the holder of a fire Policy and the insurer is responsible for passing the statutory premium on to the Commission. Initially the statutory cover reflected the practice of the insurance industry to cover a property for indemnity value only. The development of replacement risk insurance led to amending legislation in 1951 allowing for the provision by private insurers of a replacement cover in excess of the Commission’s statutory liability.

12     Earthquake and War Damage Act 1944, s 14.

13     The s 2(1) definition of property was “any real or personal property in New Zealand”.

14     For a description of this funding mechanism, see New Zealand Fire Service Commission v

Insurance Brokers Association of NZ Inc [2014] NZCA 179, [2014] 3 NZLR 541.

15     Farmers Mutual Insurance Co Ltd v Bay Milk Products Ltd [1989] 3 NZLR 647 (CA) at 652–

653.

[13]     In 1993, the Act repealed and replaced the 1944 Act.  Cover for commercial properties was terminated.  A “humanitarian” approach was adopted.16   The focus of the  Act  was  on  three  types  of  “natural  disaster  damage”  that  could  occur  to residential properties:

(a)      residential buildings;17 (b)      residential land;18 and (c)      personal property.19

[14]     The Commission is a Crown entity, to which the Crown Entities Act 2004 applies.20    The Commission is charged with administering the insurance against natural disaster damage provided by the Act, to collect premiums payable for that insurance, to administer the Natural Disaster Fund,21 to protect the value of the Fund and to obtain reinsurance in respect of the whole or part of the insurance offered.22

[15]     The term “natural disaster damage” is defined by s 2(1) of the Act:

2   Interpretation

(1)       In this Act, unless the context otherwise requires,—

natural disaster damage means, in relation to property,—

(a)       any physical loss or damage to the property occurring as the direct result of a natural disaster; or

(b)       any  physical  loss  or  damage  to  the  property  occurring (whether accidentally or not) as a direct result of measures taken under proper authority to avoid the spreading of, or otherwise to mitigate the consequences of, any natural disaster, but does not include any physical loss or damage to

16     See para [75] below. See also Morley v Earthquake Commission [2013] NZHC 230 at paras

[27]–[32].

17     Earthquake Commission Act 1993, s 18.

18     Ibid, s 19.

19     Ibid, s 20.

20     Ibid, s 4A.

21     The nature of the Natural Disaster Fund is described in s 13 of the Act.

22     Earthquake Commission Act 1993, s 5(1)(d).

the property for which compensation is payable under any other enactment

[16]     A  “natural  disaster”  includes  an  earthquake  and,  in  the  case  only  of

residential land, a flood.23

[17]     The terms “residential building” and “residential land” capture only those parts of the land on which the dwelling is situated, and an area of land appurtenant to it:24

residential building means—

(a)       any building, or part of a building, or other structure (whether or not fixed  to  land  or  to  another  building,  part,  or  structure)  in  New Zealand which comprises or includes one or more dwellings, if the area of the dwelling or dwellings constitutes 50 % or more of the total area of the building, part, or structure:

(b)       any building or part of a building (whether or not fixed to land, or to another building, part, or structure) in New Zealand which provides long-term accommodation for the elderly, if the area of the building which provides long-term accommodation for the elderly constitutes

50 % or more of the total area of the building, part, or structure:

(c)       every building or structure appurtenant to a dwelling referred to in paragraph (a), or a building or part of a building referred to in paragraph (b), of this definition and that is used for the purposes of the household of the occupier of the dwelling or for the purposes of the residents of the building or part:

(d)       all water supply, drainage, sewerage, gas, electrical, and telephone services, and structures appurtenant thereto—

(i)       serving a dwelling referred to in paragraph (a), or a building or part of a building referred to in paragraph (b), of this definition or surrounding land; and

(ii)      situated  within  60  metres,  in  a  horizontal  line,  of  the dwelling or building or part; and

(iii)      owned by the owner of the dwelling or building or part, or by the owner of the land on which the dwelling or building or part is situated:

residential land means, in relation to any residential building, the following property situated within the land holding on which the residential building is lawfully situated:

23     Ibid, s 2(1) definition of “natural disaster”.

24     Ibid, s 2(1) definitions of “residential building” and “residential land”.

(a)      the land on which the building is situated; and

(b)      all land within 8 metres in a horizontal line of the building;

and

(c)      that part of the land holding which—

(i)       is  within  60  metres,  in  a  horizontal  line,  of  the building; and

(ii)      constitutes the main access way or part of the main access way to the building from the boundary of the land holding or is land supporting such access way or part; and

(d)       all bridges and culverts situated within any area specified in paragraphs (a) to (c) of this definition; and

(e)       all  retaining  walls  and  their  support  systems  within  60 metres, in a horizontal line, of the building which are necessary for the support or protection of the building or of any property referred to in any of paragraphs (a) to (c) of this definition.

[18]     Section 19 of the Act deals with claims in relation to “residential land”.  It

states:

19   Residential land

Subject to any regulations made under this Act and to Schedule 3 to this Act, where a residential building is deemed to be insured under this Act against natural  disaster  damage,  the  residential  land  on  which  that  building  is situated shall, while that insurance of the residential building is in force, be deemed to be insured under this Act against natural disaster damage to the amount (exclusive of goods and services tax) which is the sum of, in the case of any particular damage,—

(a)      The value, at the site of the damage, of—

(i)       If there is a district plan operative in respect of the residential  land,  an  area  of  land  equal  to  the minimum area allowable under the district plan for land used for the same purpose that the residential land was being used at the time of the damage; or

(ii)      An area of land of 4000 square metres; or

(iii)     The area of land that is actually lost or damaged—

whichever is the smallest; and

(b)       The   indemnity   value   of   any   property   referred   to   in paragraphs  (d)  and  (e)  of  the  definition  of  the  term

“residential land” in section 2(1) of this Act that is lost or

damaged.

[19]     Schedule 3 to the Act (to which s 19 refers) sets out various conditions of the statutory insurance provided by the Act.   Clause 3 of that Schedule specifies the circumstances in which the Commission may decline to accept (in whole or in part) “a claim made under any insurance of property under [the] Act”.

[20]     Section 29 of the Act deals with the settlement of claims.  It states:

29   Settlement of claims

(1)   Subject to any regulations made under this Act—

(a)       a claim may be made in respect of any insurance under this Act only by a person who has an insurable interest in the property concerned; and

(b)       without limiting section 31 of this Act, where more than one person has such an insurable interest, the Commission shall in settling any claim have due regard to the respective insurable interests.

(2)    Subject to any regulations made under this Act and, where a contract has been entered into under section 22 of this Act, to the provisions of that contract, if, during the period for which any property is insured under this Act,  the  property suffers natural  disaster  damage,  the  Commission  shall settle any claim (by payment, replacement, or reinstatement, at the option of the Commission) to the extent to which it is liable under this Act.

(3)   Where any property is insured under this Act for its replacement value and the Commission is satisfied that goods and services tax has been paid or will be payable by an insured in the course of replacing or reinstating the property, the amount of any payment under subsection (2) of this section shall be increased by the amount of goods and services tax paid or payable by the insured.

(4)   Subject to any regulations made under this Act and without limiting the liability of the Commission under this Act, any payments or expenditure for which the Commission may be liable under this section shall be made as soon as reasonably practicable, and in any event not later than 1 year after the amount of the damage has been duly determined (which determination shall be made as soon as reasonably practicable).

(5)   The Commission may make ex gratia payments in respect of natural disaster damage to property that is not insured under this Act where a premium has been paid under this Act in respect of that property in the belief that the property was insured under this Act.

[21]     The cover provided by the Act is akin to that offered by private insurers.  The conditions set out in Schedule 3 are the equivalent of the terms of a private insurance policy.  A claim only arises where there has been “natural disaster damage” caused by a “natural disaster” from which damage or loss has resulted in respect of a “residential building”, “residential land” or “personal property”.   To avoid any problems arising out of “double insurance”, an ability to insure privately, in addition

to the statutory cover, is conferred by s 30 of the Act.25

Agreed facts

(a)      The Canterbury earthquakes

[22]     On  4  September  2010,  a  major  earthquake,  with  a  magnitude  of  7.1,26 occurred   near   Darfield,   a   community   based   some   40   kilometres   west   of Christchurch.  The earthquake struck at a depth of 10 kilometres.  Considerable damage was caused to land and buildings, both on the Canterbury Plains and in the city.

[23]     On 22 February 2011, a more devastating earthquake struck, causing the tragic loss of 185 lives, as well as significant damage in the central business district and land and buildings situated on both the Canterbury Plains and the Port Hills. While of a lesser magnitude than the September 2010 event, its impact was much more severe.  The epicentre of this earthquake was near the port of Lyttelton, 10 kilometres south east of Christchurch.  It had a depth of five kilometres and a magnitude of 6.2.

[24]     On 13 June 2011, two earthquakes occurred in quick succession.  They were centred about 10 kilometres south east of Christchurch City, to the east of where the February 2011 earthquake had struck.  Their magnitudes were 5.6 and 6 respectively. The ground motions were larger than those of September 2010.  More damage was caused to land on the Plains and on the Port Hills, though generally less than what

had occurred in February 2011.

25     Section 30 was discussed recently by the Supreme Court in Firm P 1 Ltd v Zurich Australian

Insurance Ltd [2014] NZSC 147.

26     All measurements of this type are referable to the Richter scale.

[25]     On 23 December 2011, there were two further earthquakes.  They occurred within a period of 90 minutes.  They were of magnitude 5.8 and 5.9 respectively. The epicentre was approximately 8 kilometres off the coast of New Brighton, to the east of  Christchurch City.

[26]    We have described the most significant of the land damaging events that occurred in the period between 4 September 2010 and 23 December 2011.  Including significant   aftershocks   that   occurred   after   23   December   2011,   the   greater Christchurch area has experienced over 10,000 earthquakes since 4 September 2010. Of those, about 4,000 were of magnitude 3 or greater; over 60 were greater than magnitude 5.

(b)      The relevant land

[27]     The land in issue was, before the first major earthquake, at risk of some flooding from the three principal rivers that flow through Christchurch; the Styx, to the north; the Avon, through the middle; and the Heathcote, to the south.  As a result of one (or more) of the earthquakes some land has subsided.  That land is now more prone to flooding than it was beforehand.

[28]     Christchurch and its surrounding areas have a history of flood events, of various severity.  These floods have tended to occur in areas adjacent to the rivers, their tributaries, and the coast.  The City Council has dealt with that natural hazard risk through Flood Management Areas, ponding areas and basins, for which allowance has been made in various planning documents.  Those measures were designed to mitigate the effects of flooding through the imposition of controls on development within those areas.  They were in place before the September 2010 earthquake.

[29]     Much of the land affected by the earthquakes has suffered damage through the effects of liquefaction.  That is the process by which liquefied soil is ejected from the ground  and  spreads  outwards.   This  is  caused  by ground movement  of the tectonic plates.  Although, before the earthquake sequence, the risk of liquefaction was recorded on land information memoranda maintained by the City Council, there

was minimal public awareness of the nature and extent of the problems that might arise.

[30]   Widespread land damage was caused by the earthquakes.   There are approximately 169,000 separately insured residential properties in Canterbury.  As a result of one or more of the earthquakes, the Commission has received 468,881 claims.  Some have been settled.  Many await resolution.   In respect of those that have been resolved, building repairs and property reinstatement is continuing.

(c)      Land classification in Christchurch since the earthquakes

[31]     Following the February 2011 earthquake, Parliament enacted the Canterbury Earthquake Recovery Act 2011, by which the Canterbury Earthquake Recovery Authority (CERA) was established.  Its primary role is to lead planning for the recovery of the Canterbury region.  CERA has undertaken assessments of the areas most affected by the earthquakes and made recommendations to government about the suitability of the land for residential occupation, in the short to medium term.  In general terms, the use of land for residential purposes is now subject to two classifications, known as the Red Zone and the Green Zone.

[32]     Land within the Red Zone was so badly damaged by the earthquakes that it is unlikely any rebuilding can be undertaken in the foreseeable future.   The Crown made an offer to owners of Red Zone residential properties to purchase them at 2007 rating valuations.  There were two different purchase options, both of which had the effect of subrogating the Crown to the rights of the previous owners under statutory or private insurance.  That being so, the largest claimant on the statutory insurance regime for Red Zone properties will be the Crown, on whose behalf CERA is acting.

[33]     Owners of Red Zone properties were not compelled to accept the Crown’s offers to purchase.  While, from a legal (as opposed to practical) point of view, there is no impediment to the repair or rebuilding of residential dwellings in the Red Zone, the increased engineering requirements for foundations, and the associated costs of repair and rebuilding, act as a disincentive.  For homeowners who continue to live in Red Zone properties (such as Ms Culf), construction of new services is unlikely in

the foreseeable future, and the maintenance of existing services is likely to decrease as the number of people living in an area dwindles.

[34]   Although Green Zone properties are regarded as suitable for residential occupation, some parts require further geotechnical investigation.  In a number of cases, particular types of foundations will be required to minimise the risk of future liquefaction damage.  Investigations were undertaken by the Department of Building and  Housing,27   to  provide  guidance  on  the  types  of  foundations  that  would  be

required for particular types of land within the Green Zone.28   On 28 October 2011,

three technical categories were established:

(a)      TC 1 applies when liquefaction damage is unlikely in future large earthquakes.    Standard residential foundation assessments and construction remains appropriate.

(b)TC 2 applies when liquefaction damage is possible in future large earthquakes but standard enhanced foundation repair and rebuild options are suitable to mitigate against that possibility.

(c)      TC 3 applies when liquefaction damage is possible in future large earthquakes,  but  the  land  is  such  as  to  require  an  individual engineering  assessment  to  select  the  most  appropriate  foundation repair or rebuild option.

(d)      Flooding Vulnerability

[35]     Three mechanisms that cause flooding have been identified as having been affected by changes to land as a result of the earthquakes.

[36]     The first involves the paths through which water can flow over land.  Pluvial flooding is caused by run-off that is in excess of the capacity of the stormwater

systems and causes excess water to flow over land.   This can be exacerbated in

27     Now part of the Ministry of Business, Innovation and Employment.

28     Ministry of Business, Innovation and Employment Guidance on repairing and rebuilding houses affected by the Canterbury earthquake sequence available at where subsidence of land settlement has occurred, as that can change overland flow paths or reduce hydraulic gradients to both rivers and streams.

[37]     The second is river flooding.   Fluvial flooding is caused by a flowing of water in rivers and streams that exceeds the capacity of a particular channel and floods adjacent land.  Lateral spreading, caused by the earthquakes, has reduced the capacity of some such waterways by reducing widths and increasing riverbed levels. Ground subsidence, particularly along stream banks, can increase the overflow from such waterways onto surrounding land.

[38]     The third involves tidal flooding.   Tidal flooding is caused by extreme sea levels in coastal areas and lower rivers that flood adjacent land.  When land settles to a level below extreme tide levels that is not protected, it can become more prone to tidal flooding.

The Commission’s Increased Flooding Vulnerability Policy

(a)      Development of the Policy

[39]    When developing its Policy, the Commission gained information from two primary sources to determine what changes in the land had resulted from the earthquakes.  While Mr Hodder QC, for the Commission, accepts that the base data from which the Policy was developed is imperfect, what has been used by the Commission is all that is presently available.

[40]     One source of information is aerial LiDAR surveys.  One was undertaken in

2003; the others were after each of the four major earthquake events.  There are problems in comparing the 2003 pre-earthquakes data with results from survey conducted  after  they  had  occurred.  The  2003  survey  was  conducted  with  less accurate  equipment  and  significantly  fewer  returns.  The  post  September  2010 surveys did not cover all of the river catchments and the post December 2011 survey did not cover all of Christchurch.

[41]     Data from LiDAR surveys were used to create (what are known as) bare earth

Digital Elevation Models of Christchurch both before and after the September 2010

earthquake; and, after each of the 2011 events to which we have referred.29   That information forms the basis on which land elevation changes are considered for the purpose of managing the risk of flooding.

[42]    The Commission also obtained information, after each of the four major earthquakes, from some 400 engineers about land damage across Christchurch.  An index of land damage severity was created from that information.  That has enabled relevant observations to be captured on maps.

[43]     As well as those primary sources of information, the Commission sought expert advice from groups of engineers and valuers:

(a)      Engineers were asked to develop a methodology to assess, for each individual property, whether there had been a physical change to the residential land caused by an earthquake that had increased the vulnerability of the land to flooding; and, the extent of any increase. The outcome of their deliberations was reviewed by an expert panel of three engineers from outside New Zealand.   This methodology is designed to determine whether “natural disaster damage”, as defined in the Act, has occurred.

(b)Valuers were instructed to develop a methodology to assess, for each individual property, whether any increase in vulnerability of the land to flooding adversely affected the use and amenities that could otherwise be associated with the land, and its effect on the value of the insured property.  The valuers crafted a methodology by which a relevant diminution in value could be calculated.  This work has been peer reviewed by four other valuers who were nominated for that purpose by professional valuation institutes within New Zealand.

[44]     The work undertaken by the engineers and valuers has formed the basis of the

Policy.   An amended version of the Policy (dated September 2014) was finalised after input from experts engaged by other parties to this proceeding.

29     See paras [22]–[26] above.

(b)      The Policy in outline

[45]     The  Commission’s  Policy  contains  a  number  of  component  parts.     In

summary: 30

(a)      It recognises “Increased Flooding Vulnerability” as a form of “natural disaster damage” to which the statutory insurance will respond.

(b)From  an  engineering  perspective,  three  threshold  tests  have  been developed to determine whether land has suffered an increase in flooding vulnerability and, if so, to what extent.31

(c)      From a valuation perspective, a model has been developed to enable an assessment to be made of whether any change in flooding vulnerability to the land has adversely impacted on the uses and amenities of the land.

(d)The  Commission  has  proposed  a  “claim  review  process”  that  is designed  to  provide  a  private  dispute  resolution  mechanism  into which owners of affected properties may opt to participate.

(c)      Assessment of Increased Flooding Vulnerability

[46]     The Commission’s Policy identifies four thresholds that must be crossed in order for a claim to be recognised under the Increased Flooding Vulnerability category of natural disaster damage:

15       In order for residential land to qualify as having Increased Flooding

Vulnerability, the residential land must satisfy the following:

Threshold 1:     The exacerbated flood depth on the residential land has increased by 0.2 m or more as a result of the Canterbury earthquake sequence.32

30     For a discussion of the status of the Commission’s Policy, in the context of the anticipatory judicial review and declaratory judgment claims, see paras [140]–[159] below.

31     See para [46] below.

32     The term is defined in the Policy as the series of earthquakes experienced by the Canterbury region between 4 September 2010 and 23 December 2011.

Threshold 2:     The exacerbated flood depth on the residential land has increased by 0.1 m or more as a result of a single earthquake event.

Threshold 3:     The  residential  land  has  suffered  observable  land damage as a result of the Canterbury earthquake sequence.

Threshold 4:     The   change   in   flooding   vulnerability   to   the residential land has caused the value of the property to decrease.

[47]     The Commission’s view is that these thresholds will permit robust assessment of “the significant majority of properties in the Canterbury region”.  Nevertheless, it has identified “a limited number of instances … for which an exception should be made”:

16.1Event exception: properties with 0.2 m or greater exacerbated flood depth  over  the  Canterbury  earthquake  sequence  and  that  have suffered observable land damage, but which have not suffered 0.1 m or greater exacerbated flood depth in any one event; and

16.2Uplift exception: properties in specified areas of tectonic uplift for which there is evidence that differential subsidence has increased their flood vulnerability;

16.3Land   damage   exception:   properties   with   0.2   m   or   greater exacerbated flood depth over the Canterbury earthquake sequence, and 0.1 m or greater exacerbated flood depth in any one event, but which have not suffered recorded observable land damage.

[48]     Assessments in relation to all thresholds and exceptions are to be made by Tonkin & Taylor, the Commission’s engineers, “on the basis of automated processing of flood modelling data and manual engineering review with site-specific inspections to determine whether the property has suffered potential Increased Flooding Vulnerability”. After that initial assessment, a review is to be undertaken by a senior engineer  to  determine  whether  any  application  of  that  criteria  may  have  been

wrong.33

33     The technical application of those steps is described in a report by Tonkin & Taylor Ltd, Canterbury Earthquake Sequence – Increased Flooding Vulnerability Assessment Methodology (April 2014).

(d)      Settlement of Increased Flooding Vulnerability claims

[49]    The Policy envisages settlement of claims based on Increased Flooding Vulnerability by payment of a fixed sum, rather than reinstatement.  That payment is to be computed by reference either to the cost of repair (or reinstatement) of the land, or the diminution in market value caused by the natural disaster damage.  The Commission has identified four relevant factors, in determining whether to make a payment in lieu of a repair (or reinstatement) cost, or to pay an amount assessed as the diminution in market value:

24.1If the residential building requires to be removed in order to enable repairs to the land to address the Increased Flooding Vulnerability, [the Commission] will settle based on the Diminution of Value;

24.2     If resource consent is required under the Resource Management Act

1991 in order to enable repairs to the land to address the Increased
Flooding Vulnerability, [the Commission] will settle based on the

Diminution of Value unless the claimant demonstrates that he or she can obtain resource consent and will effect the repairs;

24.3If  the  residential  land  has  been  sold  by  the  claimant  after  the earthquake event recognised as causing Increased Flooding Vulnerability, [the Commission] will settle based on the Diminution of Value;

24.4In all other cases, [the Commission] will pay the repair cost unless that  cost  is  disproportionate  to  the  Diminution  of Value,  having regard to the circumstances of the claimant (including his or her stated intentions in relation to repair of the land).

[50]     A separate part of the Policy deals with the assessment of diminution in value.  This is to be done by independent valuers, on the basis that the diminution will:34

27.1be the discount from the price that would have been paid for a property (the residential land and residential buildings combined) on the day prior to the earthquake that would be agreed between a willing buyer and a willing seller because of the specified physical change to the land, with full knowledge about that change and its impact on the vulnerability of the land to flooding, the cost of repair options, and advice from competent and reasonable advisors.

34     Further detail on the assessment of diminution in value is set out in a paper entitled Diminution of Value Methodology for Increased Flooding Vulnerability (April 2014) which has been endorsed by an Expert Valuation Panel nominated by the New Zealand Institute of Valuers and the Property Institute of New Zealand to undertake an independent peer review of work carried out by valuers instructed by the Commission.

27.2     not take into account:

(a)       any change in value to the property resulting from external changes   or   effects,   whether   from   the   earthquakes   or otherwise (including regulatory changes);

(b)      any general stigma arising from the earthquakes;

(c)      any changes in value to non-insured residential land and buildings.

(e)      A proposed claims review process

[51]     The claims  review process is designed  to establish a means  by which a claimant can challenge any decision made by the Commission to refuse cover.  It:

(a)       entitles    a    claimant    to   provide    additional   information    to   the

Commission,

(b)      assures claimants of a dispassionate internal review of the claim; and

(c)       offers a mediation process as a last resort before a claimant might issue proceedings in a Court of competent jurisdiction.

[52]     As it is not open to the Commission to compel a claimant to go through that process, the claims review procedure will be something into which a claimant may opt to participate, should he or she consider that process appropriate.

PART 2: THE PROPOSED DECLARATIONS

[53]     Before, during and after the hearing, counsel helpfully conferred with a view to refining the nature of the declarations sought.  On 5 November 2014, following directions given at the conclusion of the hearing, Mr Hodder filed a memorandum reflecting the terms of the directions sought, both by the Commission and the Insurance Council, on the latter’s counterclaim.  The memorandum incorporated comments from other counsel on the terms of the directions sought.

[54]     The Commission seeks declarations in the following terms:35

35     For ease of reference when we deal with the declarations sought, we have provided our own

(a) A1:

In  relation  to  “residential  land”,  “natural  disaster  damage”

under the Act may include circumstances where one or more

earthquakes have caused physical changes to any such land

and  such  changes  have  adversely  affected  the  uses  and

amenities that could otherwise be associated with the land by

increasing the vulnerability of that land to flooding events

(Increased Flooding Vulnerability).

(b)

A2:

The settlement of claims compliant with the Act for natural

disaster   damage   to   residential   land   involving   Increased

Flooding Vulnerability may be approached on the basis of the

Commission  indemnifying  the  claimant  against  his  or  her

financial  loss  by  an  appropriate  payment,  including  by

payment of the costs of relevant and  appropriate repair or

reinstatement activities or, in appropriate circumstances, by

payment  of  the  loss  of  market  value  of  the  insured  land

together with any associated residential buildings (or, at the

option  of  the  Commission,  by  undertaking  relevant  and appropriate repair or reinstatement activities).

(c)

A3:

In calculating payments to settle claims for natural disaster damage  to  residential  land  involving  Increased  Flooding

Vulnerability, the Commission is entitled to prepare and apply

standardised policies and methodologies, including materiality

thresholds, exclusions and discounts, provided that (i) such

policies  and  methodologies  are  relevant  and  rational  and

consistent with the Act, (ii) any claimant is entitled to provide

further information (or an alternative interpretation of existing

information) and ask the Commission to reconsider whether

the  payment  calculated  in  accordance  with  such  policies

provides an appropriate and full settlement consistent with the

alpha-numeric listing of the declarations sought by both the Commission and the Insurance Council. We have also amended the terms of the declarations sought to reflect the way in which we have described the various participants and statutes.

Act, and (iii) any claimant is entitled to pursue appropriate court challenge.

(d)

A4:

On the evidence before  the Court,  the Policy,  amended  in

September  2014,  adopted  by  the  Commission  incorporates

policies and methodologies which are appropriate and rational

and consistent with the contemporaneous Declarations A1, A2

and A3 of this Court in this proceeding.

(e)

A5:

On the evidence before the Court, any payments to insured

persons by the Commission in relation to claims for natural

disaster   damage   to   residential   land   involving   Increased

Flooding Vulnerability that the Commission has admitted in

accordance with its Policy (as amended in September 2014, or

in an essentially similar form) and with the Act, are lawful

payments in respect of insurance under section 19 of the Act

and, together with all  expenditure in connection with  such

claims,   constitute  lawful   expenditure  from   the  National

Disaster Fund.

(f)

A6:

In  determining  claims  made  in  respect  of  insurance  under

sections 18, 19 or 20 of the Act, the Commission is exercising

statutory powers of decision necessary to administer both the

insurance provided under the Act and the National Disaster

Fund, and such determinations may involve judgements on

issues  of  evaluation  or  discretion  and  are  subject  to  legal

challenge only by way of an application for judicial review or

under the Declaratory Judgments Act 1908.

(g)

A7:

In   relation    to    “residential    buildings”,    “natural    disaster

damage”  insurance  under  section  18  of  the  Act  does  not

include,   of   itself,      circumstances   where   one   or   more

earthquakes have caused physical changes to land and such

changes have (i) caused the residential building to reduce in

height relative to a remote datum and (ii) adversely affected

the uses and amenities that could otherwise be associated with

the residential building by increasing the vulnerability of that building to flooding events.

[55]

direct

By ions:

way  of

counterclaim,  the  Insurance  Council  seeks  the  following

(a)

B1:

In  relation  to  “residential  land”,  “natural  disaster  damage”

under the Act may include circumstances where one or more

earthquakes have caused physical changes to any such land

and  such  changes  have  adversely  affected  the  uses  and

amenities that could otherwise be associated with the land by

increasing  the  vulnerability  of  that  land  to  liquefaction

damage in future earthquake events (Increased Liquefaction

Vulnerability).

(b)

B2:

The settlement of claims compliant with the Act for natural disaster   damage   to   residential   land   involving   Increased

Liquefaction Vulnerability may be approached on the basis of

the  Commission  indemnifying  the  claimant  by  undertaking

appropriate  repairs  or  reinstatement,  or  by  an  appropriate

payment including, in appropriate circumstances, by payment

of the loss of market value of the insured land together with any associated residential buildings.

(c)

B3:

In calculating payments to settle claims for natural disaster damage to residential land involving Increased Liquefaction

Vulnerability, the Commission is entitled to prepare and apply

standardised policies and methodologies, including materiality

thresholds, exclusions and discounts, provided that (i) such

policies  and  methodologies  are  relevant  and  rational  and

consistent with the Act, (ii) any claimant is entitled to provide

further information (or an alternative interpretation of existing

information) and ask the Commission to reconsider eligibility

and/or  entitlement  consistently  with  the Act,  and  (iii)  any

claimant is entitled to pursue appropriate court challenge.

(d)

B4:

The  Commission  should  finalise  its  proposed  Liquefaction

Policy as soon as reasonably practicable.

(e)

B5:

Leave is reserved to the Commission or to any other party to

this proceeding to apply, once the Commission has finalised

its proposed Liquefaction Policy, for a declaration in relation

to the consistency of that Policy with the Act.

[56]     The declarations can be grouped into three distinct issues:

(a)      The first raises questions of statutory interpretation.  Declarations A1 and B1 consider whether “natural disaster damage” includes Increased Flooding Vulnerability and Increased Liquefaction Vulnerability. Declaration A7 considers when that damage extends to residential buildings.  Declarations A2 and B2 consider how the Commission can settle claims.

(b)The second involves a consideration of the circumstances in which this Court may grant anticipatory relief, either by way of judicial review or under the Declaratory Judgments Act 1908.  Declaration A4 seeks to validate the Policy, while Declaration A5 seeks to validate payments made pursuant to it.   Declarations A3 and B3 address the question whether the Commission is entitled to develop standardised methodologies  for  calculating  the  payment  of  settlements. Declarations B4 and B5 relate to the expediency with which a policy for Increased Liquefaction Vulnerability should be developed and whether it can also be challenged in Court.

(c)      The  third  concerns  the  question  of  enforcement.    Declaration A6 requires  the  Court  to  determine  what  kinds  of  proceedings  are

available to a claimant who seeks to sue the Commission for an erroneous determination.

[57]     We deal with the issues raised in that sequence:

(a)       First, in Part 3, we deal with questions of statutory interpretation.

These  involve  whether  Increased  Flooding  Vulnerability  and Increased Liquefaction Vulnerability constitute “natural disaster damage” to residential land and (in the case of Increased Flooding Vulnerability) residential buildings.36    We also consider the way in which indemnity value should be assessed under the Act.37

(b)Second, in Part 4, we consider the scope of the Court’s powers to provide anticipatory relief, and the circumstances in which it is appropriate to grant a remedy of that type.38     Part 4 addresses Declarations A4 and A5 which seek confirmation of the legitimacy of the Policy, and payments made under it.39

(c)      Third, in Part 5, we discuss the way in which individual claimants may, as a matter of law, enforce the Commission’s statutory obligation to meet lawful claims.  In particular, we consider whether a claimant is permitted to bring ordinary proceedings in a Court of civil jurisdiction to enforce that obligation.40

PART 3:  INTERPRETATION

Is Increased Flooding Vulnerability natural disaster damage to residential land?

(a)      Background

[58]     Many areas of residential land in the Canterbury region are at a lower level than before the earthquakes and have an increased vulnerability to flooding as a

36     See paras [58]–[93] below.

37     See paras [94]–[125] below.

38     See paras [126]–[139] below.

39     See paras [140]–[162] below.

40     See paras [163]–[199] below.

result.  Before analysing whether this constitutes natural disaster damage to the land for the purpose of the Act, it is helpful to give a brief explanation of the geological processes that caused this change. These processes included:

(a)       tectonic ground movement associated with fault displacement; and

(b)liquefaction  causing  the  ejection  of  silt,  sand  and  water,41    soil densification and lateral spreading.42

[59]     During the main earthquakes, the bedrock on one side of the fault moved relative to the other, causing parts to slip several metres in some locations.  This slip in the bedrock caused folding of the overlying soil deposits resulting in both subsidence and uplift of the ground surface near the fault trace, as well as horizontal movement.   Tectonic ground surface movements resulted in subsidence of approximately 150 mm to the east of the central business district and an uplift of approximately 450 mm  at  the Avon-Heathcote  estuary.    Horizontal  displacement ranged up to approximately 500 mm.  The ground displacement from tectonic effects is relatively uniform over large areas with smooth and gradual transitions between areas of greater and lesser change in elevation.

[60]     Soil liquefaction is caused by the ground shaking during an earthquake and typically occurs in loose, saturated, fine-grained soils, such as silts and sands often found adjacent to rivers and streams.  Liquefaction also occurs in poorly compacted man-made fills.  During the liquefaction process, the soil behaves more like a liquid than a soil.  The soil particles are rearranged and compacted, resulting in decreased volume.    Ground  surface  displacement  from  liquefaction  can  vary  significantly across short distances due to the geological variability of the near-surface soils and depending on the proximity to rivers which can affect lateral spreading.

[61]     The damage caused by liquefaction was severe in a number of Christchurch suburbs.   It took the form of ground deformation, principally subsidence resulting

41     Some 500,000 tonnes of silt and sand was ejected during the earthquakes and subsequently removed from land in the Canterbury region.

42     Lateral spreading is the sideways movement of land, typically towards watercourses. Blocks of the earth’s crust move sideways over liquefied soils towards a lower area. Surface damage can include minor or major cracks in the land and tilting of ground crust blocks.

from the ejection of liquefied soil, but also from differential settlement and lateral spreading.  In the September 2010 earthquake, liquefaction was mainly concentrated along the Avon River and local streams, but it was much more widespread in the February 2011 earthquake.

[62]   The Commission undertook an extensive programme of geotechnical observation, measurement and assessment to evaluate damage to residential land insured under the Act.  Land damage was also assessed by inspections carried out at some 65,000 properties.  The Commission obtained data from ground elevation surveys undertaken before and after the earthquakes.  It used this information in conjunction with data obtained from the geotechnical assessment programme and aerial photographs to assess how physical changes to the land have affected its vulnerability to flooding.   Preliminary results of flood modelling work show that there are up to 13,500 low lying residential properties in the Christchurch area that may now be materially more susceptible to flooding as a result of the reduced land levels.

(b)      Analysis

[63]     In  2012,  the  Commission  announced  that  it  would  recognise  Increased Flooding Vulnerability as natural disaster damage for the purposes of the Act.  The Commission has defined Increased Flooding Vulnerability as a physical change to residential land as a result of an earthquake which adversely affects the uses and amenities that could otherwise be associated with the land by increasing the vulnerability of that land to flooding events.  The physical change to the land is the reduction in the height or level of the land relative to sea level or, in some cases, relative to nearby land, directly resulting from one or more of the earthquakes.

[64]     One of the principal issues the Court has been asked to determine is whether Increased Flooding Vulnerability comes within the meaning of “natural disaster damage” in terms of the Act.

[65]     “Natural disaster” is defined to mean: 43

43     “Natural disaster damage” is defined in s 2(1) of the Act, and is set out at para [15] above.

(a)       An  earthquake,  natural  landslip,  volcanic  eruption,  hydrothermal activity, or tsunami; or

(b)      Natural disaster fire; or

(c)       In the case only of residential land, a storm or flood.

[66]     There is no dispute that physical changes to residential land have been caused by  a  natural  disaster;  namely,  one  or  more  of  the  earthquakes.  These  physical changes have resulted in the reduction in height of many areas of residential land. The critical question is whether these physical changes are properly characterised as physical loss or damage to the property for the purposes of the Act.

[67]    The definition states that “physical loss or damage, in relation to property, includes any physical loss or damage to the property that (in the opinion of the Commission) is imminent as the direct result of a natural disaster which has occurred”.44   The meaning of “physical loss or damage” is not otherwise defined in the Act but it is a commonly used expression in the context of material damage insurance.

[68]     The meaning of these words in a house insurance policy was considered recently in O’Loughlin v Tower Insurance.45   Asher J held that the word “physical” means “of or concerning the body”.46    He observed that in English law, “damage” usually refers to a “changed physical state”.47   Therefore, in the context of house insurance,  “physical  damage”  would  require  some  type  of  disturbance  of  the

physical integrity of the materials and structures that constitute the body of the house.48     Asher J referred to the authorities showing that the word “loss” in the

context of building insurance generally means physical loss, not economic loss.49

44     Physical loss or damage is defined in s 2(1) of the Act.

45     O’Loughlin v Tower Insurance [2013] NZHC 670, [2013] 3 NZLR 275.

46 Ibid, at para [43].

47 Ibid, at para [46].

48     Ibid, at paras [43] and [44].

49 Ibid, at para [52].

[69]     The meaning of “natural disaster damage” under the Act was also considered in Kraal v Earthquake Commission.50   Mallon J applied the reasoning in O’Loughlin and concluded that “loss” in the context of the Act means loss to the physical materials or structure of the building and does not include purely economic loss.51

[70]     With the need for clarification of one aspect of Kraal, we adopt the analysis in these cases.  It is supported by the authorities to which they refer.  Natural disaster damage to residential land for the purposes of the Act requires a physical change or loss to the body of the land that has occurred, or is imminent, as the direct result of the earthquakes, and which affects the use or amenity of the land.

[71]     The need for clarification arises out of Mallon J’s observation in Kraal that:

[39]      The requirement for a “physical loss” means that economic loss is not covered.  [The Commission] submits that the loss of the right to inhabit a house is an economic loss.  All other things being equal, it is certainly likely that there will be a loss in the market value of a property which can no longer be occupied.  I agree that if the plaintiffs were seeking cover for the loss in market value of the property that would be an economic loss and therefore not covered.

[72]     Mallon J was dealing with the concept of “physical loss”, in the context of para (a) of the definition of “natural disaster damage”.52   She was not suggesting that economic losses caused by physical damage to residential land could not be claimed. In Kraal the land was physically unchanged.  The likely reduction in the property’s value was due to a non-imminent off-site danger from rock fall.53   That meant it was unsuitable for residential purposes.

[73]     In this case we are dealing with instances where there has been physical damage to residential land that has been caused by a natural disaster; an earthquake. Thus, the qualifying criterion of “physical … damage” is met and a loss in market

value consequent on that damage is covered.

50     Kraal v Earthquake Commission [2014] NZHC 919, [2014] 3 NZLR 42.

51     Ibid, at paras [39] and [68].  O’Loughlin is discussed at paras [51]–[57] above.

52     See para [15] above.

53     See the definition of “physical loss or damage” in s 2(1) of the Earthquake Commission Act.

[74]     The limitations on losses that might be claimed are set out in cl 2 of Schedule

3 to the Act.  That clause refers to “consequential losses”, not “economic losses”. The consequential losses that cannot be claimed include loss of profits or business interruption.  That is consistent with the primary object of the legislation being to protect homeowners.  The calculation of loss caused by physical damage to the land by reference to its diminution in value is not of the same character as the consequential losses to which cl 2 refers.

[75]     Ms Clark tested the argument that Increased Flooding Vulnerability amounts to natural disaster damage.  Ms Clark submits that the meaning of these words must be considered in the light of the underlying philosophy and purpose of the Act.  She drew attention to a statement made by the Associate Minister of Finance when introducing the Earthquake Commission  Bill  at  the time of  its  third reading in

1992:54

[T]he Government’s prime concern in the aftermath of a major disaster is a humanitarian concern.  Thus the priority should be the provision of basic, adequate housing and other amenities, and the re-establishment of a basic infrastructure ...

[76]    Ms Clark submits that the underlying humanitarian focus of the legislation suggests  that  Parliament  intended  a  narrow  construction  of  the  words  “natural disaster damage”.  While she acknowledges that the land has undergone physical changes as a direct result of the earthquakes, she contends that these changes do not constitute present physical loss or damage.  Rather, they increase the vulnerability of the land to sustain such loss or damage in a future natural disaster, namely a flood. Ms Clark argues that this vulnerability, which may cause physical loss or damage covered by the Act in a future flooding event, does not qualify as present physical loss or damage occurring as the direct result of the earthquakes.

[77]     Ms Clark submits that her interpretation is supported by the requirement that the physical loss or damage to the property must be the direct result of the natural disaster.  Prospective loss or damage is only brought within the definition of physical

loss or damage if it is imminent.55   She argues that physical loss or damage that may

54     (15 December 1992) 532 NZPD 13188.

55 See the definition in s 2(1) and above at para [67].

be caused in a future flooding event is not imminent and is therefore not included. Although Ms Clark advanced an argument that the Act does not respond to economic loss, we disagree with that proposition for the reasons previously given.56

[78]     We accept Ms Clark’s submission that it is necessary to differentiate between the physical loss or damage to the insured land that has occurred as a direct result of the earthquakes and the physical loss or damage that may occur in the future as a result of a flood.  Only the former can amount to natural disaster damage caused by the earthquakes.  While a later flood may cause natural disaster damage to residential land,57 the physical damage that it may cause is attributable to that subsequent event.

[79]     As a direct result of the earthquakes, there has been a disturbance to the physical integrity of the land, reducing it in volume and leaving the body of the land in a changed physical state. This changed physical state has resulted in the land being more vulnerable to flooding, thereby adversely affecting its use and amenity. The primary use of residential land is as a platform for building.   Land that is materially more prone to flooding is plainly less suitable for this purpose and is less habitable.  The criteria for physical loss or damage are satisfied.  We conclude that Increased Flooding Vulnerability constitutes natural disaster damage to insured residential land for the purposes of the Act.

(c)      Declaration

[80]     Having regard to these conclusions, we make a declaration in the form of

Declaration A1,58 namely:

In relation to “residential land”, “natural disaster damage” under the Act may include circumstances where one or more earthquakes have caused physical changes to any such land and such changes have adversely affected the uses and amenities that could otherwise be associated with the land by increasing the vulnerability of that land to flooding events (Increased Flooding Vulnerability).

56     See para [72] above.

57     Earthquake Commission Act 1993, s 2(1) definition of “natural disaster”; see para [16] above.

58     See para [54](a) above.

Is Increased Flooding Vulnerability natural disaster damage to residential buildings?

(a)      Background

[81]     We have been asked to determine whether a residential building, which is more vulnerable to damage from a future flooding event because of a reduction in its height relative to sea level (or other relevant datum) as a result of the earthquakes, has  sustained  natural  disaster  damage  even  if  there  has  been  no  change  or disturbance to the physical integrity of its materials and structure.   The example given is that of a house that has simply “ridden down” with the land as a result of the earthquakes, but has sustained no other physical damage.

(b)      Analysis

[82]     The Commission, the Insurance Council and Southern Response submit that the residential building has not suffered natural disaster damage in these circumstances  because  there  has  been  no  physical  change  to  the  materials  or structure of the building and no damage to its physical integrity.   Mr Webb and Mr Shand disagree.  Mr Webb submits that the residential building has nonetheless sustained  natural  disaster  damage  because  it  has  an  increased  vulnerability  to flooding as a direct result of the earthquakes.  Mr Weston supports this submission.

[83]     Mr Webb submits that a building that has moved down relative to its surroundings has undergone a physical change.  This physical change, being the change  in  its  location,  has  resulted  in  the  building  being  more  susceptible  to flooding.

[84]     Mr Webb referred to Hughes v Potomac Insurance Company,59 in support of his submission.  That case concerned an insured’s entitlement to recover under a policy insuring against physical loss of and damage to a “dwelling” in circumstances where the land forming the backyard of the house slipped into a creek leaving the house  perched  on  the  edge  of  a  newly  created  30  foot  cliff,  but  otherwise

undamaged.  The insurer declined the claim on the basis that the house had suffered

59     Hughes v Potomac Insurance Company 199 Cal App 2d 239 (Cal Dist Ct App 1962).

no direct physical loss.  The Court interpreted the word “dwelling” in the policy, which was defined to include lawns but not trees, shrubs or plants, as including the underlying land and curtilage.   It was therefore not necessary for the Court to determine whether the relevant damage was to the land or to the building; both came within the definition of “dwelling” under the policy.  For this reason, the case does not assist in determining the present issue, which is whether the damage should be regarded as damage to the residential building or the residential land, or both.

[85]     Mr Webb also referred to Snapp v State Farm Fire & Casualty Company.60

That case concerned a policy insuring against all risks of physical loss to the insured premises.  Because the insured’s house had been built on unstable fill, it moved laterally following a period of unusually heavy rainfall, causing damage to the structure of the house and its foundations.  There was no dispute that the dwelling was damaged; the only issue was the extent of the insurer’s obligation to repair.  The Court found that the insurer’s liability included the costs of repairing the house with adequate  foundations  to  prevent  further  damage.    The  Court  did  not  need  to determine whether the policy covered the underlying land or whether the damage was to the land or to the building.  For these reasons, this case does not assist us.

[86]     The Act deals separately with the insurance against natural disaster damage of residential buildings, residential land and personal property.  There are separate insuring provisions for each, set out in ss 18, 19 and 20 respectively.  The terms of insurance differ for each category of insured property.  Different excesses apply and there are different limits of indemnity.61   There is cover for flood and storm damage

to residential land, but not for residential buildings.62  All of this emphasises the need

to  differentiate  between  physical  loss  or  damage  to  a  residential  building  and physical loss or damage to the residential land on which it is erected.

[87]     Where there has been physical damage to land resulting in subsidence, but there  has  been  no  change  to  the  physical  state  or  integrity  of  the  structure  or

60     Snapp v State Farm Fire & Casualty Company 206 Cal App 2d 827 (Cal Dist Ct App 1962).

61     Excesses and premiums are calculated under the Earthquake Commission Regulations 1993, regs 3 and 4.

62     Natural disaster is defined in s 2(1) of the Act to include a storm or flood, but only in the case of residential land.

materials that comprise the body of the house erected on the land including its foundations, we consider that this should be regarded as damage to the residential land, not to the residential building.  We consider that this fits with the scheme of the Act which is unusual, if not unique, in providing separate cover for residential land and for residential buildings.63

(c)      Declaration

[88]     For those reasons, we make a declaration in similar terms to Declaration

A7,64 namely:

In relation to “residential buildings”, “natural disaster damage” under the Act does not include circumstances where one or more earthquakes have caused physical changes to the land only and such changes have:

(i)       caused  the  residential  building  to  reduce  in  height  relative  to  a remote datum; and

(ii)      adversely affected the uses and amenities that could otherwise be associated  with  the  residential  building  by  increasing  the vulnerability of that building to flooding events.

Is Increased Liquefaction Vulnerability natural disaster damage?

(a)      Background

[89]     Following the earthquakes, some areas of residential land have become more vulnerable to liquefaction damage from future earthquakes.  This is broadly because the affected land now has a thinner “crust”, being the non-liquefiable layer of earth between the ground surface and the water table.  This reduction in the thickness and quality of the crust renders the land more prone to liquefaction damage and less able to support a house in the event of a future earthquake.

[90]     Because of the large number of residential properties affected by Increased Liquefaction Vulnerability as a result of the earthquakes, the Commission proposes to  formulate  a  policy  to  enable  such  claims  to  be  assessed  and  dealt  with

appropriately and consistently.  As the Increased Liquefaction Vulnerability policy is

63     The Commission understands that the statutory insurance of land, as distinct from buildings, is unique.

64     See para [54](g) above.

not yet fully developed, the Commission does not seek any declarations in relation to Increased Liquefaction Vulnerability at this stage.  However, the Insurance Council seeks declarations in relation to Increased Liquefaction Vulnerability, including a declaration  that  Increased  Liquefaction  Vulnerability  is  natural  disaster  damage under the Act.

(b)      Analysis

[91]     Our analysis of whether Increased Flooding Vulnerability constitutes natural disaster damage under the Act is equally applicable in relation to Increased Liquefaction Vulnerability.    All counsel agree that if Increased Flooding Vulnerability qualifies as natural disaster damage, as we are satisfied it does, it must follow that so too must Increased Liquefaction Vulnerability.

[92]     We conclude that residential land that is materially more prone to liquefaction damage in a future earthquake because of changes to its physical state as the direct result of one or more of the earthquakes in the Canterbury earthquake sequence, has sustained natural disaster damage in terms of the Act.  These physical changes have reduced the use and amenity of the land such that it is now less suitable for use as a building platform and for the other purposes usually associated with residential land.

(c)      Declaration

[93]     As a result, in terms of Declaration B1,65 we declare that:

In relation to “residential land”, “natural disaster damage” under the Act may include circumstances where one or more earthquakes have caused physical changes to any such land and such changes have adversely affected the uses and amenities that could otherwise be associated with the land by increasing the vulnerability of that land to liquefaction damage in future earthquake events.

Assessment of indemnity value

(a)      Background

[94]     Residential land is insured on an indemnity basis.66     The issue raised by

Declarations A267 and B268 is how that value should be assessed.

[95]     The  most  obvious  way  of  remediating  land  that  has  sustained  Increased Flooding Vulnerability is to raise it to its pre-earthquake level by overlaying it with compacted soil.  However, this will often not be feasible.  In many cases it would require removing the house, any other structures, and trees and gardens.  Further, placing significant quantities of fill on land can create geotechnical problems affecting its stability, including by increasing its vulnerability to lateral spreading and settlement in the event of a further earthquake causing liquefaction of the underlying soil.  This is obviously a serious issue with land that is already prone to liquefaction, as is the case with many of the affected properties.

[96]    There is the added complication that raising the land may adversely affect surface drainage patterns and increase the risk of inundation on neighbouring properties.   For this reason, there are limitations on the amount of fill that can be imported, particularly in designated flood management areas where many of the affected properties are located.  The earthworks required to repair most affected properties in these flood management areas will exceed the permitted maximum of

0.3 m in height and 10 m³ in volume.  Resource consent would also be required for all properties outside the flood management areas if there is a need to raise the land by more than 0.3 m, as is the case with approximately half of the affected properties in these areas.   These difficulties are compounded by the fact that the insured residential land comprises only the footprint of the house and the surrounding eight

metres of land.69

[97]     For all of these reasons, Tonkin & Taylor considers that in most cases it will not be possible to obtain resource consent to remediate the land, even if it were

technically feasible to do so.

66     See para [105] below.

67     See para [54]above.

68     See para [55] above.

69     The full description of “residential land” is set out in s 2(1) of the Act. See para [17] above.

[98]   The Commission’s Policy contemplates that many Increased Flooding Vulnerability claims will need to be settled by way of a payment.  This is expressly authorised by s 29(2) of the Act which provides that the Commission “shall settle any claim (by payment, replacement, or reinstatement, at the option of the Commission) to the extent to which it is liable under this Act”.70

[99]     The  Commission’s  option  to  settle  claims  by  paying  the  amount  of  the damage is also confirmed in Schedule 3 to the Act which sets out the conditions applying to the insurance.   Clause 9(1) of Schedule 3 relevantly states: “The Commission may at its option replace or reinstate any property that suffers natural disaster damage, or any part thereof, instead of paying the amount of the damage”.

(b)      Issue

[100]   The Commission’s proposed Increased Flooding Vulnerability Policy is to pay the repair cost where repairs are technically feasible, can lawfully be undertaken, are not disproportionately expensive, and are likely to be carried out by the claimant. In all other cases, the Policy provides for payment of the loss of market value of the insured property as the result of the natural disaster damage.  The Commission seeks a declaration that it may settle such claims on the basis of this diminution of value in appropriate cases in accordance with its Policy.

[101]   The  Commission’s  proposed  approach  is  based  on  its  contention  that residential land is insured under the Act on an indemnity basis and that the amount payable is to be determined by assessing the amount of money required to restore the claimant  to  the  position  he  or  she  would  have  been  in  if  the  damage  had  not occurred.  In the case of indemnity insurance, the emphasis is on the actual loss suffered by the claimant as a result of the insured fortuity.  The Commission’s Policy is designed to achieve this objective.

[102]   The   Insurance  Council   concurs  with   the   Commission’s   position   that

residential land is insured under the Act on an indemnity basis.  Mr Weston agrees

and considers that the Commission’s proposed Policy appropriately gives primacy to

repair options.  However, he submits that any declaration should reflect this.

[103]   Mr Webb, supported by Mr Shand, submits that land is insured under the Act on a reinstatement basis, not merely for any loss of value. The Act’s equivalent of an insuring clause for residential land is set out in s 19 which provides that residential land is insured against natural disaster damage to the amount which is the sum of the value of the area of land calculated in accordance with s 19(a) and the indemnity value of any bridges, culverts and retaining walls that come within the definition of “residential land” in s 2.  Mr Webb submits that the plain and ordinary meaning of s

19 is that the residential land is insured up to the value of the land lost or damaged whereas he contends that the Commission’s interpretation would require the section to be read as only providing compensation for the loss of value of the land at the site of the damage.

[104]   Mr Webb submits that the modes of settlement of claims set out in s 29(2), being “payment, replacement or reinstatement”, are “expressed as equivalences”.  He argues that the Commission is therefore required to pay the cost of reinstating the land up to the limit of indemnity, being the value of the land.  He submits that the Commission is not justified in paying the diminution in value of the land as a result of the natural disaster damage which he describes as falling “woefully short” of the insured’s reinstatement entitlement.

(c)      Analysis

[105]   Section 19 sets a limit of indemnity based on the value of the residential land, calculated in the prescribed manner, plus the indemnity value of any associated retaining walls, bridges and culverts. 71   The words “to the amount” make clear that this is the limit of the Commission’s liability for such damage.  Whereas residential land is insured for its indemnity value, residential buildings and personal property are  separately  insured  against  natural  disaster  damage,  under  ss 18  and  20

respectively, for replacement value.

[106]   “Replacement value” is defined in s 2 of the Act with reference to residential buildings and personal property but there is no comparable provision for residential land, including retaining walls, bridges and culverts.  These provisions show that Parliament drew a distinction between the indemnity available under the Act in respect of residential land and that provided for residential buildings and personal property.

[107]  The legislative history tends to confirm this.   As originally drafted, the Earthquake Commission Bill provided for “residential property”, which included both the residential building and the associated land, to be insured against natural disaster damage “to the amount which is the lesser of the replacement value of the property or the maximum amount [$100,000], plus the value of any land covered

under this section suffering natural disaster damage”.72  In its submissions to the

Select Committee, the Commission pointed out that the effect of these provisions would be to provide replacement cover for land as well as buildings, whereas this was not intended and was not previously provided:73

It is not intended that cover for land be on a replacement basis.  Instead, the aim is to continue the existing level of land cover.  In a number of respects the Bill fails to do this.

Perhaps most fundamentally, the consequence of including land associated with a building in the definition of “residential property” is that clauses 18 and 21 confer replacement cover for land as well as for buildings.

[108]  For that reason, the Commission submitted to the Select Committee that “residential building” and “residential land” should be defined separately and that there should be separate insuring provisions for each.  This submission appears to have been accepted.  The Act separately defines residential buildings and residential land and these are insured under separate provisions.  Further, the replacement cover expressly provided in the case of residential buildings and personal property is not referred to in the insuring provision for residential land.  Nor does the definition of

“replacement value” extend to residential land.74     This supports the submissions

72     Earthquake Commission Bill 1992 (210–1), cl 18.

73     Earthquake  Commission  “Submission  of  the  Earthquake  Commission  on  the  Earthquake

[166]   In contrast, the Insurance Council submits that an ordinary action lies to enforce money payable under a statute, as much as it does a contractual right.   It relies on decisions of this Court in Earthquake Commission v Disputes Tribunal and Maryville Courts Trust Board v Earthquake Commission.117    It relies also on the decision of the House of Lords in Roy v Kensington and Chelsea and Westminster Family Practitioner Committee and in Steed v Home Secretary and of the Court of

Appeal in Trustees of Dennis Rye Pension Fund v Sheffield City Council.118

112   See Declaration A6, set out at para [54] above.

113   Relying on R v Lord Leigh [1897] 1 QB 132 (CA) at 145 per A L Smith LJ, R v Corby District

Court ex parte McLean [1975] 1 WLR 735 (QB) and Commissioner of State Revenue (Victoria)

v Royal Insurance of Australia Ltd [1994] HCA 61, (1994) 182 CLR 51.

114   Earthquake Commission v Disputes Tribunal [1997] NZAR 115 (HC) at 116–117.

115   X (Minors) v Bedfordshire County Council [1995] 2 AC 633 (HL) at 728 and Wool Board Disestablishment Co Ltd v Saxmere Co Ltd [2010] NZCA 513, [2011] 2 NZLR 442 at paras [188]–[193].

116   Shepherd v Hills (1855) 11 Exch 55, 156 ER 743 (Exch); Richardson v Willis (1873) LR 8 Exch

69 (Exch); Lloyd v Burrup (1868) LR 4 Exch 63 (Exch).

117   Earthquake Commission v Disputes Tribunal [1997] NZAR 115 (HC) and Maryville Courts

Trust Board v Earthquake Commission [2013] NZHC 1575.

118   Roy v Kensington and Chelsea and Westminster Family Practitioner Committee [1992] 1 AC

624 (HL); Steed v Home Secretary [2000] 1 WLR 1169 (HL); Trustees of Dennis Rye Pension

[167]   According to Mr Goddard, the entitlement of insured persons under the Act is neither contractual nor tortious.  It is an ordinary action for a sum payable under statute.  In a contractual insurance context, the claim would be for a sum payable under the contract.  In neither case is it a claim for damages for some wrong on the part of the insurer.  Mr Goddard submits that judicial review is neither compulsory nor sufficient to vindicate potential claimants’ rights under the Act.   The standard will not always be appropriate to resolve differences (importing soft edged considerations  such  as  rationality),  the  summary  procedure  adopted  in  judicial review cases is inappropriate, and the nature of relief (including the fact that it is discretionary) is inappropriate.

[168]  These submissions were supported by Mr Weston and by counsel for both interveners.

(b)      Analysis

[169]   We begin by making three general observations.

[170]   First, statutory obligations to pay sums of money are ubiquitous.   In some circumstances, the obligation is cast on a public body to pay a private person.   In others, on a private person to pay a public body.  Alternatively, of course, the obligation may lie as between persons or bodies of like classification.  In many instances, such as in the revenue and accident compensation legislation, the Act establishes a mechanism for dispute resolution and enforcement.  In fact the present legislation, from 1941 to 1993, contained a compulsory obligation to arbitrate. Between 1941 and 1951, and again from 1984 to 1993, the obligation to arbitrate was confined to quantum.   Between 1951 and 1984 cl 18 in the Schedule to the

Earthquake and War Damage Regulations 1944 provided:119

If any difference arises out of the insurance between the Commission and the insured person, the difference shall be referred to one arbitrator if the parties can agree upon one, and otherwise to two arbitrators, one to be appointed by the Commission and one by the insured person, under the Arbitration Act

Fund v Sheffield City Council [1998] 1 WLR 840 (CA).

119   The 1944 Regulations were repealed by the Earthquake and War Damage Regulations 1956.

The same provision was incorporated in cl 19 of the Schedule to the 1956 Regulations. See Low v Earthquake and War Damage Commission [1959] NZLR 1198 (HC) at 1204.

1908, and the obtaining of an award shall be a condition precedent to any right of action against the Commission.

[171]   Second, it is clear to us that the Act creates rights, or entitlements, pursuant to a “scheme of statutory insurance”.  That was how the scheme was described by the Privy Council in Earthquake and War Damage Commission v Waitaki International Limited.120   The Commission’s statutory obligation to make good or make payment under s 29(2) in particular creates entitlements on the part of the counterparties. That is reinforced in this case by the fact consideration has been paid by the insured

person – albeit the relationship between them is not contractual.  It is, nonetheless, an arrangement of insurance.   In AMP Fire and General Insurance Co (NZ) Ltd v Earthquake and War Damage Commission the Court of Appeal made clear that ordinary principles of insurance law and practice apply to the Commission’s scheme, except so far as clearly indicated otherwise by the Act and regulations made under

it.121     The Commission’s obligations under s 29(2) are definite, not discretionary

(other than as to which of the three options given is to be effected).  The same may be said of the insuring provisions: ss 18, 19 and 20.

[172]  Thirdly, the Act is silent as to how such entitlements (or rights) may be enforced.  Parliament must be taken to have intended them to be enforceable.  It follows that the common law has both remedial responsibility, and flexibility: where there is a right there is a remedy.122  As Lord Tenterden CJ said in Doe v Bridges:123

[W]here an Act creates an obligation, and enforces the performance in a specified manner, we take it to be a general rule that performance cannot be enforced in any other manner.  If an obligation is created, but no mode of enforcing its performance is ordained, the common law may, in general, find a mode suited to the particular nature of the case.

[173]   The   New   Zealand   authorities   on   the   means   of   enforcement   of   the

Commission’s statutory obligation to make good or pay are not entirely satisfactory.

In Earthquake Commission v Disputes Tribunal insured persons had been unable to

120   Earthquake and War Damage Commission v Waitaki International Limited [1992] 1 NZLR 513 (PC) at 514.

121   AMP Fire and General Insurance Co (NZ) Ltd v Earthquake and War Damage Commission

(1983) 2 ANZ Insurance Cases 78,016 (CA).

122   Reflected in the Latin maxim ubi jus ibi remedium.

123    Doe v Bridges (1831) 1 B & Ad 847 at 859, 109 ER 1001 (KB) at 1006.

reach agreement with the Commission as to the amount payable to them.124    They lodged a claim in the Disputes Tribunal.  The jurisdiction of the Disputes Tribunal is limited by its statute.  The only potentially applicable jurisdictional basis was a claim in contract.   Eichelbaum CJ held that the relationship between the insured persons and the Commission was not one of contract.  It was (as the Privy Council had held in  Waitaki  International)  “a  scheme  of  statutory  insurance”.    Its  enforcement therefore lay beyond the realm of the Disputes Tribunal.  Eichelbaum CJ said:125

It seems a pity that claims of the present kinds of magnitude should be excluded from the jurisdiction of the Disputes Tribunal; realistically, that is the  only  remedy  available,  and  people  like  the  Wiblins  should  not  be excluded from access to justice, but that is a matter for the Legislature.

The legislature was unmoved by Eichelbaum CJ’s observation.  But that observation should  not  be  seen  to  exclude  the  less  constrained  statutory jurisdiction  of  the District Court to hear such claims.126

[174]   The next New Zealand case is Doyle v Earthquake Commission.127    In that case Mr Doyle issued proceedings in the High Court incorporating both a claim for indemnity under the Act and for judicial review.   The latter was based on alleged consideration of irrelevant considerations.  The judicial review cause of action was dismissed.  A declaration of limited indemnity was made under the other cause of action. The issue of jurisdiction was not specifically adverted to.

[175]   The third New Zealand case is Maryville Courts Trust Board v Earthquake Commission.128    The claim there was based on the plaintiff’s allegation that the Commission’s   loss   adjustor   had   determined   the   quantum   payable   by   the Commission.  The matter came before an Associate Judge on an application for summary  judgment.    Following  the  decision  of  Eichelbaum  CJ  in  Earthquake

Commission v Disputes Tribunal, Associate Judge Osborne held that:129

124   Earthquake Commission v Disputes Tribunal [1997] NZAR 115 (HC).

125   At 117.

126   There are currently approximately 40 actions in the District Court Canterbury Earthquake List.

Many seek a monetary sum or orders that the Commission make a “proper assessment” of loss

as precursor to an eventual monetary remedy.

127   Doyle v Earthquake Commission [2009] NZRMA 546 (HC).

128   Maryville Courts Trust Board v Earthquake Commission [2013] NZHC 1575.

129   Ibid, at para [14] (footnotes omitted).

The liability of EQC in a given case is not generally contractual.  Nor is it tortious.   EQC’s settlement obligations derived from the statute, which provides a scheme of statutory insurance.

An insured person’s cause of action is therefore not in contract or tort, but is a “claim for breach of a duty to pay insurance pursuant to a statutory scheme”.130   In its own terms that appears to be a recognition of the right to bring an ordinary action for payment.  Although the application for summary judgment was unsuccessful, there was no suggestion that the claim was otherwise an abuse of process.  There was no application for strike-out for instance.131

[176]   None of the New Zealand cases clearly articulate the nature of this Court’s jurisdiction to entertain an ordinary action to enforce payment for a sum of money pursuant to a statutory obligation.

[177]   Until the liberating decision of the House of Lords in Roy v Kensington Chelsea  and  Westminster  Family  Practitioner  Committee  there  were  two conventional but constrained forms of action to enforce a statutory obligation to pay a sum of money.132

[178]   The first of these was the writ of mandamus. This writ had its modern origins in the 17th century, and is said to have reached its zenith in the 18th century.133

Although it is now seen to be an exclusively public law remedy, its reach ran originally, and until recently, right across the common law.  It could be engaged to compel the performance of any legal duty of a public or private nature.134    It was available, said Lord Mansfield “upon all occasions where the law has established no specific  remedy,  and  where  in  justice  and  good  government  there  ought  to  be

one”.135

130 Ibid, at para [15].

131   The  Maryville proceeding was due  to  go  to  trial on 15  June 2014, but  was  discontinued

(presumably as a result of settlement) being agreed on 7 May 2014.

132   Roy v Kensington Chelsea and Westminster Family Practitioner Committee [1992] 1 AC 624 (HL).

133   Wade and Forsyth Administrative Law (11th ed, Oxford University Press, Oxford, 2014) at 520; Henderson  Foundations  of  English  Administrative  Law:  Certiorari  &  Mandamus  in  the

Seventeenth Century (Harvard University Press, Cambridge, 1963) at 80.

134   Ibid.  Wade and Forsyth give, for instance, the examples of it being used in the 18th and 19th centuries to enforce duties under trust deeds, copyhold, and the non-statutory duties of a university visitor at 522–523.

135   R v Barker (1762) 3 Burr 1256 (KB) at 1267, 97 ER 823 at 824.

[179]  There are numerous examples of mandamus issuing to enforce a statutory obligation to pay; in favour of a retired chief constable whose statutory pension had not been paid (there being an argument about his alleged failure to submit to medical examination); 136 to the London County Council against the Poplar Borough Council for non-payment of county rates,137 and to the owner of a post war experimental aluminium bungalow who was entitled to a “home loss payment” when corrosion necessitated the demolition of his house by the local authority.138    Mandamus also had the advantage of lying outside the short limitation period generally permitted for claims for money payable under statute.139

[180]   The second procedural mechanism was an action for debt.  In his submissions Mr Hodder quoted the following passage from the 1954 third edition of Halsbury’s Laws of England:140

Where an Act of Parliament creates an obligation on any person to pay a sum of money to any other person, the amount due can be recovered as a debt by action where no other remedy is provided but where no provision to the contrary is contained in the Act.

[181]  An action for debt lay where the obligation to pay a liquidated sum was unconditional.  Such actions lay on records (such as judgments), specialities (such as bills, bonds, leases and mortgages), simple contracts and generally whenever the action of indebitatus assumpsit was appropriate.   The latter effectively made the

action  of  debt  obsolete,  although  it  was  not  formally  abolished  until  1852.141

However despite the abolition of the form of action for debt, a cause of action in debt may still be brought, as the judgment of Wylie J in Prendergrast v Chapman makes clear.142   But the essence of that claim remained an obligation “to pay a sum certain on a day certain”.143   It was unavailable where the extent of the payment obligation,

if any, was uncertain.

136   R v Leigh [1897] 1 QB 132 (CA).

137   R v Poplar Metropolitan Borough Council ex parte London County Council (No 1) [1922] 1 KB

72 (CA).

138   R v Corby District Council ex parte McLean [1975] 1 WLR 735 (DC).

139   Commissioner of State Revenue (Victoria) v Royal Insurance of Australia Ltd [1994] HCA 61, (1994) 182 CLR 51.

140   Halsbury’s Laws of England (3rd ed, 1954), vol 8 Contract at para [448].

141   Windeyer Lectures on Legal History (2nd ed, Law Book Co, Sydney, 1957) at 108.

142   Prendergrast v Chapman [1988] 2 NZLR 177 (HC) at 190-192.

143   Ibid, at 186.

[182]   The argument now advanced by Mr Hodder has something of an echo of the speech of Lord Diplock in O’Reilly v Mackman.144   A consequence of that decision was that, as Wade and Forsyth put it:145

Judicial review by declaration and injunction in an ordinary action, which the Courts had encouraged with great success for many years, was suddenly held to be an abuse of the process of the courts.

That case concerned the validity of punishments imposed by prison authorities.  It was commenced as an ordinary action because the plaintiffs anticipated significant disputes of fact, and wished to call oral evidence.  In the House of Lords it was held that no such action now lay, following the introduction of Order 53 of the Rules of the Supreme Court in 1977.   The only available procedure was an application for judicial review.   What, then, was the implication of that decision for claims for money sums payable by virtue of statute?

[183] In Roy v Kensington and Chelsea and Westminster Family Practitioner Committee, Dr Roy, a general practitioner, issued an ordinary proceeding in the Queens Bench Division against the defendant committee which had withheld part of his National Health Service basic practice allowance.146    It did so on the basis that Dr Roy had failed to devote a substantial amount of time to general practice, as required  by  regulations.147      The  claim,  which  Dr Roy  appears  to  have  drafted himself, sought “repayment” of the amounts withheld by the committee, together with a declaration that they were not entitled to abate his allowance.  The committee applied to strike out the proceeding. It said it was an abuse of process: the claim was founded on an alleged breach of the committee’s public duty, and should be mounted by way of judicial review.148   Dr Roy by now had retained counsel.  In the Queen’s

Bench Division, Judge White149  held that the relationship between doctor and the

committee had “contractual echoes”, but the “rights and duties of those within the

144   O’Reilly v Mackman [1983] 2 AC 237 (HL).

145   Wade and Forsyth Administrative Law (11th ed, Oxford University Press, Oxford, 2014) at 569.

146   Roy v Kensington and Chelsea and Westminster Family Practitioner Committee [1992] 1 AC

624 (HL).

147   Ibid, at 631.  Dr Roy appeared to have developed wanderlust: between 1979 and 1987 he had been absent from his practice between one third and one half of each year (his absences being

covered by a locum) albeit without patient complaint.

148   Roy v Kensington and Chelsea and Westminster Family Practitioner Committee [1989] 1 Med LR 10 (QB) at 12 as quoted in. Roy v Kensington and Chelsea and Westminster Family Practitioner Committee [1992] 1 AC 624 (HL) at 633.

149   Sitting as a Judge of the Queen’s Bench Division.

scheme stem from and were entirely dependent on statute and regulation”, and were

not contractual. The Judge went on:150

The rights and duties are no less real or effective for the individual practitioner.   Private law rights flow from the statutory provisions and are enforceable, as such, in the courts, but no contractual relations come into existence.

That decision was reversed in the Court of Appeal, but restored in the House of

Lords.

[184]   Bearing in  mind  Mr Hodder’s  submission  to  us  that  the  case should  be “readily viewed as essentially contractual”, it should be noted that that was not the view of the House of Lords.  They took the same view as the Judge at first instance. Lord Bridge said:151

I do not think the issue in the appeal turns on whether the doctor provides services pursuant to a contract with the [Committee].  I doubt if he does and am content to assume that there is no contract.

Lord Lowry, who gave the principal speech, said that he could not altogether accept the reasoning which led the Court of Appeal to conclude the existence of a contract, and that he was not satisfied that there was a contract for services.152   The decision therefore proceeds on the premise that the relationship was not a contractual one.

[185]   The important thing is that the House of Lords unanimously took the view that it did not matter. As Lord Bridge put it:153

… it seems to me that the statutory terms are just as effective as they would be if they were contractual to confer upon the doctor an enforceable right in private law to receive the remuneration to which the terms entitle him.   It must follow, in my view, that in any case of dispute the doctor is entitled to claim and recover in an action commenced by writ the amount of remuneration which he is able to prove as being due to him.  Whatever remuneration he is entitled to under the statement is remuneration he has duly earned by the services he has rendered.  The circumstance that the quantum of that remuneration, in the case of a particular dispute, is affected by a discretionary decision made by the committee cannot deny the doctor

150   Roy v Kensington and Chelsea and Westminster Family Practitioner Committee [1992] 1 AC

624 (HL), at 633.

151   Ibid, at 630.

152   Ibid, at 649.

153   Ibid, at 630.

his private law right of recovery or subject him to the constraints which the necessity to seek judicial review would impose upon that right.

[186]   Lord Lowry was of the same view:154

But the actual or possible absence of a contract is not decisive against Dr Roy.  He has in my opinion a bundle of rights which should be regarded as his individual private law rights against the committee, arising from the statute and regulations and including the very important private law right to be paid for the work that he has done.

Lord Lowry went on to say:155

If the committee’s argument prevails, the doctor must in all these cases go by judicial review, even when the facts are not clear.  I scarcely think that this can be the right answer.

[187]   At the conclusion of his speech, Lord Lowry set out a series of principles, some of which we repeat:156

(1)     Dr Roy has either a contractual or statutory private law right to his remuneration in accordance with his statutory terms of service.

(2)     Although he seeks to enforce performance of a public law duty under paragraph 12.1, his private law rights dominate the proceedings.

(3)     The type of claim and other claims for remuneration (although not this particular claim) may involve disputed issues of fact.

(4)     The order sought (for the payment of money due) could not be granted on judicial review.

(7)     The action should be allowed to proceed unless it is plainly an abuse of process.

[188]   Roy was followed by the Court of Appeal in Trustees of Dennis Rye Pension

Fund  v  Sheffield  City  Council.157     That  case  concerned  the  refusal  by  a  local authority to pay improvement grants after repairs were performed by a landlord

154   Ibid, at 649-650.

155   Ibid, at 650.

156   Ibid, at 654.

157   Trustees of Dennis Rye Pension Fund v Sheffield City Council [1998] 1 WLR 840 (CA).

given notice under the Housing Act to effect repairs to make premises fit for human habitation.  Lord Woolf MR observed (with some evident asperity):158

In  this  situation  I can  see  no  reason  why the  landlord  cannot  bring an ordinary action to recover the amount of the grant which is unpaid as an ordinary debt.    Notwithstanding the statutory code, it would be disproportionate to seek a remedy of, say, mandamus or a declaration by way of judicial review to enforce payment.  Any suggestion that there had been any abuse of process involved in bringing an ordinary action in the High Court or country court would be totally misconceived.  Judicial review was not intended to be used for debt collecting.

This was a case where there was a factual dispute as to whether the pre-conditions for payment had been met.  It was not, therefore, suitable for summary process judicial review in any event.

[189]   It is also worth quoting from the judgment of Pill LJ:159

In present circumstances, a refusal to approve an application for a grant gives rise to no right to damages.  Discretions are also involved, for example section 115 (discretionary approval) and section 118 (determining a specification).   However, once an application is approved a duty to pay it arises upon compliance by the applicant with the statutory requirements and the duty is in my view enforceable by an ordinary money claim.

We do not see that passage as suggesting that the existence of unresolved discretions would have compelled judicial review only.  The proper exercise of discretion is capable of being assessed in an ordinary proceeding, and frequently is.160    It is not the exclusive preserve of judicial review.

[190]  A third English case to the same effect is Hutchings v Islington London Borough Council.161   In that case a retired council caretaker was in dispute with his former employer over the measure of his pension.  He brought a claim in the County Court  for  sums  allegedly  owed  in  respect  of  past  pension  payments,  and  a declaration as to the amount of his future pension entitlements.  The case turned, primarily, on the limits of the County Court’s jurisdiction.  If the claim was based on

statute  rather  than  “founded  on  contract”,  the  County  Court  could  not  hear  it.

158   Ibid, at 845 to 846.

159   Ibid, at 851.

160   See for example BOS International (Australia) Ltd v Strategic Nominees Ltd (in rec) [2013] NZCA 643 at para [70].

161   Hutchings v Islington London Borough Council [1998] 1 WLR 1629 (CA).

Evans LJ  (with  whom  Ward  LJ  agreed)162   concluded  that  the  regulations  gave Mr Hutchings “a private law statutory right to receive a pension in accordance with the scheme”.  But for the purposes of the County Court’s jurisdiction, those rights could still be said to be “founded on” contract.  The existence of a contractual relationship of employment was necessary to trigger the statutory rights.163

[191]   A fourth English case of importance is Steed v Home Secretary.164    In that case legislation required the plaintiff to surrender high calibre handguns and ammunition.   It also created a right to compensation for guns surrendered in accordance with the legislation.   Mr Steed surrendered his guns in July 1997.   In October 1997 he issued a County Court summons for £3,298 because of alleged “inordinate delay” in settling his compensation claims.   The Home Secretary contended that there was no inordinate delay, no statutory duty to pay, and that only judicial review lay in which to contend otherwise.   The latter contention was unsuccessful in the County Court, the Court of Appeal and the House of Lords.

Delivering the sole speech in the Lords, Lord Slynn said:165

In the present case, if there had been, e.g., a general challenge to the vires of the scheme – a question as to whether it complies with the statutory intention

– it would no doubt be right to begin by an application for judicial review.

But here essentially this claimant says that money was due to him; it was not paid when it was due; he has accordingly suffered damage (valued in terms of interest) because of the delay.  I do not see that any of the questions which might arise here cannot be dealt with by a judge on the hearing of the summons or that answering such questions usurps the province of the administration where a discretionary decision is reserved to the administration.

[192]   Against this background, we reach the following conclusions.

[193]  First, we repeat our preliminary general observations.166    In summary, the Commission’s statutory obligations to make good or make payment, under s 29(2), create entitlements  and  rights  in  insured  persons.   Those rights,  along  with  the

insurance provided in ss 18, 19 and 20, create definite obligations. Those obligations

162   Ibid, at 1643.

163   Ibid, at 1639.

164   Steed v Home Secretary [2000] 1 WLR 1169 (HL).

165   Ibid, at 1175.

166   See, paras [170]–[172] above.

are enforceable by ordinary action, notwithstanding that they arise under statute, and that the Commission exercises statutory powers.

[194]   Second, modern civil procedure provides an ordinary right of action against a person or body obligated to pay a sum of money pursuant to a statute.  That right of action arises under statute, unless expressly or necessarily excluded by statute.  It is an ordinary (or “private law”) action, regardless of whether the defendant is a private or public body.  It is not necessarily confined to a claim in debt.  There would be little point either resurrecting that form of action or in limiting claims to debt in its conventional sense. An ordinary action for payment is (and should be) available where the factual basis for payment is in dispute.

[195]   Third, exclusion of an ordinary right of action to enforce payment would, in our view, require clear expression by Parliament.  In Hutchings v Islington London Borough Council both Evans and Ward LJJ took the view that an ordinary action could be brought as of right, unless the statute expressly provided otherwise.  We agree with the way Evans LJ put it:167

The question in the present case therefore is whether there is a “positive prescription of law, by statute or by statutory rules” which prohibits the plaintiff  from  enforcing  his  right  to  receive  pension  benefits  by  action against the council.

Some criticism was made of that approach by Mr Hodder, but we consider it correct. It is important here not to confuse what the Courts have said about a right to bring an action in the ordinary way, with cases concerning whether a tortious cause of action (breach of statutory duty) may be inferred at all.  The former exists as of right, unless necessarily excluded.  The latter exists only if Parliamentary intent that it should be available can be inferred.

[196]   Fourth, New Zealand has resisted the imposition of procedural exclusivity for judicial review, in the manner embraced in England in O’Reilly v Mackman.168 That

167   Hutchings v Islington London Borough Council [1998] 1 WLR 1629 (CA) at 1636 quoting Lord

Wilberforce in Davy v Spelthorne Borough Council [1984] AC 262 (HL) at 276.

168   O’Reilly v Mackman [1983] 2 AC 237 (HL). See Siemer v Solicitor-General [2013] NZSC 68, [2013] 3 NZLR 441 at para [74]; Attorney-General v P F Sugrue Ltd [2004] 1 NZLR 207 (CA), at para [49].

Judicial review via an ordinary action would avert those limits.  In New Zealand no such limits attend judicial review.  The procedure in the Judicature Amendment Act

1972 is non-exclusive, as ss 6 and 7 make clear.170    Challenge to the actions of a

statutory body for non-payment of moneys required to be paid by statute may be mounted by judicial review under the 1972 Act, judicial review apart from that Act, or by ordinary action.

[197]   Fifth, judicial review is not generally an appropriate mechanism to determine entitlement to payment under a statute where the obligation is of a definite nature. That is particularly so in this case:

(a)      The legislation creates a statutory scheme of insurance parallel to, and with many features common to private contractual insurance.  The discretion as to make good or make payment, provided for in s 29(2), is not unusual in private insurance.  The Commission has a discretion as between the choices expressed in s 29(2).

(b)Where distinct insurance rights are in issue, the remedies available should be direct and definite, and not discretionary.   Where entitlement exists, relief should not be qualified by discretion.

(c)      Nothing in the legislative scheme suggests that Parliament intended the Commission’s claims disputes to be resolved by judicial review. Judicial review is not expressly or necessarily to be inferred as the exclusive, or even primary, method of resolving claims disputes.171

(d)It is difficult to comprehend why Parliament would have intended that all such proceedings as a matter of course must be commenced in the

High Court (which will be a consequence of insisting upon judicial

169   See para [182] above.

170   See,  for  example,  Joseph  Constitutional  &  Administrative  Law  in  New  Zealand  (4th  ed, Brookers, Wellington, 2014) at 861 and 1207–1208.

171   Section 15(a) of the Act refers to “claims admitted or sustained against the Commission” – an odd description of judicial review.

the District Court.

(e)      Such claims and disputes will often involve factual issues, requiring oral evidence.173   Judicial review is ill-suited to factual disputes, as the plaintiffs in O’Reilly v Mackman recognised.   The same point was made by Lord Lowry, in Roy.174

(f)       In cases where there is no material factual dispute, summary judgment ought to be open to the insured plaintiff, whether in the District or High Court, as was attempted at least in Maryville.

[198]   Finally where, as Lord Lowry put it in Roy, the insured person’s “private law rights  dominate  the  proceedings”,  an  ordinary  action  is  entirely  appropriate.175

Where, however, they do not dominate the proceedings (because the primary thrust of the proceeding is to challenge the exercise of a discretion, for example on the basis that a policy or its implementation is unlawful on other conventional judicial review grounds), judicial review may be the more appropriate course of action. None of that of course prevents a combined proceeding involving ordinary and judicial review claims, as was done in Doyle.

[199]   For these reasons we consider that it is inappropriate to make Declaration

A6,176 as sought by the Commission.  Claims in respect of insurance under ss 18-20 and 29 of the Act are not confined to judicial review proceedings.

172   $113,850  per  event,  in  accordance  with  s  18(1)  of  the Act  and  reg  4  of  the  Earthquake

Commission Regulations 1993.

173   As, for instance, in Doyle v Earthquake Commission [2009] NZRMA 546 (HC).

174   See para [186] above.

175   See para [187] above.

176   See para [54](f) above.

PART 6:  OUTCOME Costs

[200] The parties and interveners requested that we reserve costs for further submissions.  Submissions in support of any claim for costs shall be filed and served on or before 16 January 2015.  Submissions in opposition shall be filed and served on or before 13 February 2015.  Unless any party requests an oral hearing, the Registrar shall refer the submissions to us on receipt and we will make decisions on the papers.  In the event that a request for an oral hearing is made, a telephone conference will be arranged to enable the Court to determine whether that is necessary.

[201]   We  order  that  the  reasonable  costs  and  disbursements  incurred  by  both Mr Weston  and  Ms  Clark,  as  amici  curiae,  each  be  paid  out  of  public  funds appropriated for the purpose.  Should any unforeseen difficulties arise as to quantum, the Registrar shall refer them to Kós J, as an Earthquake List Judge, for further directions.

Result

[202]   We make the declarations set out at paras [80], [88], [93], [125], [160] and [161] above, to give effect to the conclusions we have reached.  We are not prepared to make the remaining declarations sought.

[203]  So far as the reservation of leave is concerned in relation to a policy for Increased Liquefaction Vulnerability, we consider it is better for any issues arising out of that policy to be addressed specifically in another proceeding, if necessary. Much of what we have said will apply equally to that form of natural disaster damage.

[204]   Questions of costs shall be dealt with in accordance with the directions set out in paras [200] and [201] above.

[205]   We thank counsel for their considerable assistance.

Solicitors:

Chapman Tripp, Wellington

DLA Phillips Fox, Wellington

Bell Gully, Auckland

Simpson Grierson, Wellington Lane Neave, Christchurch Grant Shand, Auckland

Counsel:

J E Hodder QC, Wellington

D J Goddard QC, Wellington

T C Weston QC, Wellington
K L Clark QC, Wellington

P R Heath J For the Court

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