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[2001] VSC 242
Supreme Court of Victoria
2001-07-25
McDonald J
Original judgment source is linked above.
[2001] VSC 242
TESTATORS family maintenance - no provision in will of deceased for the plaintiff an adult male son of the deceased - responsibility to make provision for adult male son - matters to be taken into account in determining issues in proceedings - gender of applicant not a matter to be taken into account. Administration and Probate Act 1958 (as amended) s. 91(1)(3)(4).
"I DECLARE that I have made no provision in this my will for my son, WILLIAM JAMES ALLAN, as I have made substantial provision for his (sic) during my lifetime and I further declare that I have made the above mentioned provision for my two mentioned grandchildren in lieu of provision being made for their father, RONALD LEO ALLAN because of his incapacity."
"(1) Despite anything in this Act to the contrary, the Court may order that provision be made out of the estate of the deceased person for the proper maintenance and support of a person for whom the deceased had responsibility to make provision." ... (3) The Court must not make an order under sub section (1) in favour of a person unless the Court is of the opinion that the distribution of the estate of the deceased person affected by -
(a) His or her will.....
(b) ......
(c) ......
does not make adequate provision for the proper maintenance and support of the person."
It is further provided by s. 91(4) of that Act -
(a) whether or not the deceased had responsibility to make provision for a person and
(b) whether or not the distribution of the estate of that person as affected by -
(i) the deceased's will; or
(ii) ...
(iii) ...
makes adequate provision for the proper maintenance and support of the person; and
(c) the amount of provision (if any) which the Court may order for that person; and
(d) any other matter related to an application for an order under sub-section. (1) -
must have regard to - "
There is then set out sub-paragraphs (e) to (p) the matters which the Court must have regard to.
"(c) accept any evidence of the deceased's persons reason for making the dispositions in his or her will (if any) and for not making proper provision for the applicant whether or not the evidence is in writing."
By s. 58 of the Miscellaneous Acts (Omnibus No. M1) Act 1998, it was provided that for s. 60 of the Wills Act 1997 that there be substituted Part IV A which contain therein as is relevant to these proceedings, s. 99 AA which provided that -
"Despite the amendment of this Act by Part 7 of the Wills Act 1997 Part IV of this Act, as in force immediately before the commencement of Part 7 of the Wills Act 1997 continues to apply to the estate of a person who died before that commencement."
Accordingly, the provisions of s. 91 of the Administration and Probate Act 1958 to which I have referred and also the amendment to s. 94 of the Act, again to which I have referred, are applicable to this application, as the deceased died on 7 May 1999.
"It was submitted by Counsel for the defendant, and I accept, that notwithstanding the fact that substantial amendments to the legislation were then made, the overall effect of the changes in the legislation were to codify that which had been well established as the relevant principles at Common Law but to expand the category of persons for whom applications for family provision might be made."
"It has often been pointed out that very important words in the Statute are 'adequate provision for the proper maintenance and support' and that each of these words must be given value. 'Adequate' and 'proper' in particular must be considered as words which must always be relative. The 'proper' maintenance and support of a son claiming a statutory provision must be relative to his age, sex, condition and mode of life and situation generally. What is 'adequate' must be relative not only to his needs but to his own capacity and resources for meeting them. There is then a relation to be considered between these matters on the one hand and on the other, the nature, extent and character of the estate and the other demands upon it, and also what the testator regarded as superior claims or preferable dispositions. The words 'proper maintenance and support' although they must be treated as elastic, can not be pressed beyond their meaning. The Court is given not only a discretion as to the nature and amount of the provision it directs but, what is even more important, a discretion as to making a provision at all. All authorities agree that it was never meant that the Court should rewrite the will of the testator. Nor was it ever intended that the freedom of testamentary disposition should be so encroached upon that a testator's decision expressed in his will have only a prima facie affect, the real despotise power being vested in the Court."
While the principles enunciated by Dixon C.J. have in general application to a proceeding such as the present, being an application under s. 91 of the Act as amended, and notwithstanding that the matter of the appeal was whether provision should be made for the son of the deceased, nevertheless it is to be seen that Dixon C.J. had regard to the sex of the applicant for whom no provision had been made by the will of the deceased. At p. 19-20 in his judgment Dixon C.J. further said:
"In the present case the application for a provision for maintenance and support is by an adult son. In In re Sinnott [1948] VicLawRp 48; (1948) VLR 279 in the course of what is perhaps the soundest and most illuminating of all the discussions of the statutory provisions, Fullagar J. remarked:
'No special principle is to be applied in the case of an adult son. But the approach of the court must be different. In the case of a widow or an infant child, the court is dealing with one who is prima facie dependent on the estate and prima facie has a claim to be maintained and supported. But an adult son is, I think, prima facie able to 'maintain and support' himself, and some special need or some special claim must, generally speaking, be shown to justify intervention by the Court under the Act'."
"It is well settled that these general principles apply to the case of an adult son as well to other cases. The age of the applicant is however material and if a son is mature, able bodied and capable of supporting himself, he may in those circumstances be in no need of maintenance or support."
After referring to that said by Fullagar J. in In re Sinnott as cited by Dixon C.J. in Scales and making reference to a number of other authorities Gibbs J. continued -
"In some cases a special claim may be found to exist because the applicant has contributed to building up the testator's estate or has helped him in other ways. In other cases, a son who has done nothing for his parents may have a special need. This may be because he suffers from some physical or mental infirmity, but it is not necessary for an adult son to show that his earning powers have been impaired by some disability before he can establish a special need for maintenance or support. He may have suffered a financial disaster; he may be unable to obtain employment; he may have a number of dependants who rely on him for support which he cannot adequately provide from his own resources. There are no rigid rules; the question is whether adequate provision has been for the proper maintenance and support of the adult son must depend on all the circumstances - that is, on all the facts that existed at the date of the death of the deceased, whether the testator knew of them or not, and all the eventualities that might, at that, that reasonably have been foreseen by the testator who knew the facts."
"It might be said that the principles applicable to the exercise of the statutory jurisdiction should be the same whether the applicant is a widow or widower, son or daughter and whether child or adult. Doubtless principles are the same but, as has been said before, the approach of the Court will differ according to the relationship that he or she has with the testator:.... This is because what a testator should have perceived as proper and adequate for a person in one category in the prescribed class will differ from that for a person in another category. A testator's approach must differ in considering the potential claim of a wife (where she has little property of her own) and when considering the claim of a successful son whose children have all left home. The approach of the courts, endorsed in Hughes case (see esp. at 147-8 per Gibb CJ, in whose judgment Mason and Acorn J. concurred), is that in ordinary circumstances, a testator is not under an obligation to make provision for an able bodied and successful adult son because that son is, almost invariably, 'in no need of maintenance or support' of the requisite kind: see Gibbs J in Hughes case at 147. However, if, as is not uncommon these days a son has reached adulthood without establishing himself in life and without adequate or certain prospects of doing so, the position will be different, and, subject to competing claims he may well show that the testator was under a duty to make appropriate provision for him, as in fact I held in Andersons' [Anderson v Trebonas [1990] VicRp 47; [1990] V.R. 527] case. Again if a son has reached late to middle age or beyond, then, not withstanding that he has met with reasonable prosperity during the most of his working life, he may well be able to show, especially in recent years, that his prospects of gaining employment (or improving his financial position where he is earning but a bare sufficiency), are such that the testator fairly should have contemplated that he would be likely to be in needy circumstances for much of the rest of his life. In such a case, a moral obligation to make further provision will likewise have rested on the testator. Not only may an applicant in the latter circumstances be able to show that he has over the years contributed to building up other testator's estate or given other assistance worthy of recognition (a 'special claim'), but he may, alternatively or in addition, be able to establish a 'special need for maintenance and support' in that: 'he may have suffered a financial disaster; he may be unable to obtain employment...' etc: Hughes' case at 147."
"(e) any family or other relationship between the deceased person and the applicant, including the nature of the relationship and, when relevant, the length of the relationship."
However, the Court is not required beyond that to have regard to the sex of the applicant or to distinguish between a child of a deceased who is an applicant by reason of the gender of that child.
"(g) the size and nature of the estate of the deceased person and any charges and liabilities to which the estate is subject; (h) the financial resources (including earning, capacity and the financial needs of the applicant); (l) any benefits previously given by the deceased person to any applicant or to any beneficiary and; (o) the character and conduct of the applicant or any other person".
[3] [1979] HCA 2; (1979) 143 CLR 134 at 147.
[4] [1938] at A.C. 463, at pp 478 - 479.
[5] [1992] N.Z.L.R. 281 at pp 220 - 221.
Allan
Allan [2001] VSC 242
(1962) 107 CLR 9
(1979) 143 CLR 134